diff --git a/marker2/ds9/EFTA00087088/EFTA00087088.md b/marker2/ds9/EFTA00087088/EFTA00087088.md new file mode 100644 index 0000000000000000000000000000000000000000..44262755dca5e2895ba82fadea37113f6a7b599c --- /dev/null +++ b/marker2/ds9/EFTA00087088/EFTA00087088.md @@ -0,0 +1,25 @@ +## Prrileb atatez Pistritt a:Court SOUTHERN DISTRICT OF NEW YORK + +TO: AT&T Attn: Global Legal Demands Center 11760 U.S. Highway 1, Suite 300 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 United States District Court for the Southern District of New York, 40 Foley Square, in the Borough of Manhattan, City of New York, New York, in the Southern District of New York, at the following date, time and place: + +Appearance Date: November 29, 2021 Appearance Time: 9:00 a.m. Appearance Place: 40 Foley Square, Courtroom 318 to testify and give evidence in the following matter: + +## United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +and not to depart the Court without leave thereof, or of the United States Attorney, and that you bring with you and produce at the above time and place the following: + +- Any and all records relating to phone number including subscriber records, billing records, call detail records, and toll records from 1999-2004. + +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 November 11, 2021 + +DAMIAN WILLIAMS United States Attorney for the Southern District of New York + +New York New York 10007 + +![](_page_0_Picture_13.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00087088/EFTA00087088.metadata.json b/marker2/ds9/EFTA00087088/EFTA00087088.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..9fd04a28ed7a6075f46af3b0dcc20bf407d5bf1b --- /dev/null +++ b/marker2/ds9/EFTA00087088/EFTA00087088.metadata.json @@ -0,0 +1,146 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087088.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1428, + "elapsed_seconds": 0.77, + "image_assets": [ + "_page_0_Picture_13.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Prrileb atatez Pistritt a:Court \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 186.66, + 91.53 + ], + [ + 433.17388916015625, + 91.53 + ], + [ + 433.17388916015625, + 130.1214599609375 + ], + [ + 186.66, + 130.1214599609375 + ] + ] + }, + { + "title": "GREETINGS:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 56.916000000000004, + 223.56000000000003 + ], + [ + 132.25616455078125, + 223.56000000000003 + ], + [ + 132.25616455078125, + 239.4735107421875 + ], + [ + 56.916000000000004, + 239.4735107421875 + ] + ] + }, + { + "title": "United States v. 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After being advised of the identity of the interviewing agents and the purpose of the interview, he provided the following information: + +Case Title: + +Type: FD302 + +To: MIAMI + +worked for JEFFREY EPSTEIN as a house manag for approximately six months between 2004 and 2005. During his employment he obtained a copy of a black book and other rs at had the contact information for numerous individuals claimed that man 'duals in the book were underage (minor) females. stated that he forgot that he had th e items until the past couple of months. wanted to sell these items for \$50,000.00 to attorney BRADLEY EDVVARDS se he had been unable to work since losing his job with EPSTEIN. Dunn employment with EPSTEIN he (' saw ked minor females sunbathing at EPSTEIN's pool, he saw images of naked nor females on EPSTEIN's computer, and he knew that EPSTEIN was aving sexual contact with minor females at his house 'as occasionally tasked with cleaning sex toys after the minor females + +had departed the residence. lid not tell the FBI nor any other law enforcement agency about this information, even though he knew there was an investigation, because he was scared of EPSTEIN. IMMclaimed that he did give the Palm Beach Police Department some information related to the EPSTEIN investigation. + +# Indexing + +No Entities to display. + +# Intelligence + +Intelligence Value: No Intelligence Value + +Potential IlFt/SIR? No + +Sentinel Tags: No Sentinel Tags Selected + +Can you identify the No source of this information? + +# Routing + +Drafted By: + +V + +# Filing and Security V + +Primary Case: 72-MM-113327 + +Serial Number: 6 + +Serialized: 11/03/2009 + +Category: Full Investigation + +Initiated: 10/28/2009 + +#### Details + +Case Title: + +Serial N: 6 + +From: + +Document Title: PURSUANT TO SEARCH:PROVIDED BY + +Approval Date: 11/3/2009 + +Classification: SN + +Contents 11/04/2009 + +### Indexing + +Type: FD302 + +To: MIAMI + +Pursuant to consent to by date of birth Social Security Account Numbe ehicle, a tan Chevrolet Trailblazer, Florida to Vehicle Identification Number (VIN) s searched and one AT&T 'csson cellular telephone, Serial Numbe h car charger was seized IMIalso consented to the search of th cellular telephone seized from the vehicle as well as the cellular telephone he caned on his person, an I-Phone telephone, + +The original FD-26 Consent to Search Form signed by Rodriguez was placed in a 1A envelope of case file. + +No Entities to display. + +### Intelligence + +Intelligence Value: No Intelligence Value + +Potential IIR/SIR? No + +Sentinel Tags: No Sentinel Tags Selected + +Can you identify the No + +source of this + +information? + +# Routing + +Drafted By: + +# Filing and Security + +Primary Case: 72-MM-113327 + +Serial Number: 5 + +Serialized: 11103/2009 + +Category: Full Investigation + +Initiated: 10/28/2009 + +Case Title: + +#### Details + +V + +Serial it 5 + +From: + +Document Title: INTERVIEW RE JULIO CESAR SUAREZ + +Approval Date: 11/3/2009 + +Classification: SN + +Contents 11/04/2009 + +Type: FD302 + +To: MIAMI + +Julio Cesar Suarez, date of birth Soda Security Account Number U.S. Permanent Resident emplo as a kitchen cabinet salesperson, cellular telephone residence interviewed in the vicinity of the Hilton Hotel, Boca Raton, Florida. Suarez had a North Carolina Drivers License in his essi n which reflected aprevious address of harlotte. North Carolina. Suarez was advised of the identity of the interviewing agents and purpose of the interview. Suarez was read an FD-395 Advice of Rights form which he stated he understood and signed. Suarez provided the following information: K + +Suarez the Hilton Hotel with his friend, Suarez met lEthrough their wives. picked Suarez up near his residence in Kendall and th planned to have lunch together. told Suarez he needed stop in Boca Raton but did not give areason why. Suarez acknowledged that brought documents to the Hilton Hot but he denied having any knowled f at the documents were related to. Suarez advised tha ents the El Cristo + +restaurant located at Miami, Florida and had been previously employed at another restaurant + +At the con and at the request of hevrolet Trailblazer. Florida tag as released to Suarez. + +The original FD-395 was placed in a lA envelope of case file + +# Indexing + +No Entities to display. + +# Intelligence + +Intelligence Value: No Intelligence Value Potential IIR/SIR? No Sentinel Tags: No Sentinel Tags Selected + +Can you identify the No source of this information? + +# Routing + +Drafted By: + +V + +V + +# Filing and Security + +Primary Case: 72-MM-113327 + +Serial Number: 13 + +Serialized: 11/06/2009 + +Category: Full Investigation + +Initiated: 10/28/2009 + +#### Details + +Case Title: + +Serial #: 13 Type: FD302 + +From: To: MIAMI + +Document Title: INTERVIEW RE + +Approval Date: 11/6/2009 + +Classification: SN + +Contents 12/03/2009 + +Miami. Florida 33173, telephone date of birth, social security number was advised o he identity of the interviewin aents and Assistant United States Atlome then provided i the FD-395, advice of rights form, and advised of his rights pursuant to the form by agents at approximately 2:30 PM sig the written waiver of rights at approximately 2:31 PM. He then provided the following information. + +advised that he had been told by GHISLAINE MAXWELL not to discuss what had occurred at the home of his fo employer, JEFFERY EPSTEIN, approximately 3-4 months after he s fired from his position as house manager in March 2005. further advised that MAXWELL also told him not to contact anyone else about what had occurred at the home expia. that one of his last contacts with anyone in EPSTEIN's organization in 2005 when he contacted asecretary in New York, regarding a letter of reference. In addition explained that after receiving a subpoena in the civil litigation, he + +contacted EPSTEIN's secretary approximately ten (10) months ago, in early 2009. After receiving the subpoena and alerting EPSTEIN's organization, was then contacted by attorney JACK GOLDBERGER(phonetic) concerning legal representationadvised that he declined representation by GOLDBERGER. He did not alert the attorney to the existence of the black bound book or handwritten notes that agents seized on November 3, 2009. + +was asked about the nature. circumstances. and content of the black bound book and handwritten notes agents seized explained that his first contact with law enforcement regarding the EPSTEIN investigation was with the Palm Beach Police Department and Detective He explained that he had been subpoenaed by the State Attorneys Office and that he turned papers over to several years ago. explained that the black bound book that was seized by agents on November 3,2009 was not among the documents he turned over to the detective. advised that he realized or remembered that he had possession of the black book approximately 5-6 months ago and had first came into possession of it dunn the time he was employed with EPSTEIN between + +In describing the handwritten notes on legal pad paper that were also seized,...ladvised that the content or lists were compiled from other hand ;mitten notes that he once had but has since thrown away.....oted that some of the names or contacts on the lists were not contained within the black book. explained that the names of girls on the handy/linen lists came from his personal notes regarding payments he had made to girls during his employment with EPSTEIN. explained that EPSTEIN would instruct him to go to the bank and Withdraw a specified amount of fund or GHISLAINE MAXWELL would then instru as to whom to make payment and in what amount. + +further indicated that during the period of his employment, girls would be transported to and from the house in private cars, taxis, and on occasion, he would transport the girls himself. He described the taxis as actual marked commercial vehicles with the cab company having an office or base of operation located near Belvedere Road and U.S. Highway 1 in Palm Beach county. He could not recall the actual name of the taxi company. + +explained that there were photographs of naked underage girls arranged in collages in the hallway or stair case of EPSTEIN's home and In EPSTEIN's closet. He reported seeing naked girls he believed to be underage at the pool area of the home. In addition, IIMEDIescribed seeing pornographic images of girls on computers in the house. Regarding the computers in the house, explained that after hurricanes in 2004 or 2005, a computer technician or specialist based in Ohio or having some connection to Ohio came to the home and performed repair or maintenance on the computers. + +explained that there appeared to be two distinct groups of girls that would frequent the house. One group would stay overnight in the house, and the second group of girls served as masseuses. IMMlifescribed what he observed after the masse es and what actions he took He and the housekeeper, (ph would dean the area where the massages occurred. This included cleaning massage tables, sex to s, and handcuffs, and disposing of used condoms xplained that the massages often times occurred twice per day. He also noted that (Ph)l.a(ph) would contact girls whose names were listed in the black bound book on behalf of EPSTEIN. advised he receivec the black bound book sometime in 2004 when the books were shipped from New York. + +explained that JEAN LUC BRUNEL(ph)would also bring girls to the house and would sometimes arrange for girls to be flown in via commercial and private planes. He also relayed that he had discussed the sexual activity with young girls that he ob use man r of the Paris, France property, also believed JEROME PIERRE, the gardener ae alm Beach county property was aware of the sexual activity that occurred at the house with young girls. + +#### Indexing + +No Entities to disc ay + +### Intelligence + +Intelligence Value: No Intelligence Value Potential IIR/SIR? No Sentinel Tags: No Sentinel Tags Selected + +Can you identify the No source of this information? + +### Routing + +Drafted By: + +V + +# Filing and Security V + +Primary Case: 72-MM-113327 + +Serial Number 18 + +Serialized: 12/08/2009 + +Category: Full Investigation + +Initiated: 10/28/2009 + +#### Details + +Serial #: 18 + +From: + +Document Title: ARREST RE + +Approval Date: 12/8/2009 + +Classification: SN + +Contents 12/15/2009 + +# Indexing + +Case The: + +Type: FD302 + +To: MIAMI + +Pursuant to an arrest warrant issued by United States + +Magistrate Judge Linnea R. Johnson for Obstruction of Justice, 18 + +U.S. C 1512 mber 8 2 + +at st Palm + +Beach, Florida s p a under arrest without ind• ent. Agents then transpose -to the Palm Beach County il. + +No Entities to display. + +# Intelligence + +Intelligence Value: No Intelligence Value + +Potential lIR/SIR? No + +Sentinel Tags: No Sentinel Tags Selected + +Can you Identify the No source of this information? + +## Routing + +![](_page_10_Picture_11.jpeg) + +--- + +Drafted By: + +# Filing and Security + +Primary Case: 72-MM-113327 + +Serial Number 19 + +Serialized: 12/08/2009 + +Category: Full Investigation + +Initiated: 10/28/2009 + +Case Title: + +#### Details + +V + +Serial #: 19 Type: FD302 + +From: To: MIAMI + +Document Title: PLACED UNDER ARREST AND TRAN PORTED + +Approval Date: 12/8/2009 + +Classification: SN + +Contents 12/15/2009 + +Pursuant to an arrest warrant issued by United States + +Magistrate Judge Linnea R. Johnson for Obstruction of Justice, 18 + +U.S.C. • 1512 mber 8, 2009, rams made cont + +at st Palm Beach, Florida placed under arrest without in' ent. Agents then transporte. to the Palm Beach County + +# Indexing V + +No Entities to display. + +# Intelligence V + +Intelligence Value: No Intelligence Value + +Potential IIFUSIR? No + +Sentinel Tags: No Sentinel Tags Selected + +Can you identify the No source of this Information? + +## Routing + +![](_page_12_Picture_11.jpeg) + +--- + +Drafted By: \ No newline at end of file diff --git a/marker2/ds9/EFTA00087089/EFTA00087089.metadata.json b/marker2/ds9/EFTA00087089/EFTA00087089.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..e5e0aa6df96e1235aff7fcda1ccd2fab70689f66 --- /dev/null +++ b/marker2/ds9/EFTA00087089/EFTA00087089.metadata.json @@ -0,0 +1,1200 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087089.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 13, + "chars": 12205, + "elapsed_seconds": 4.07, + "image_assets": [ + "_page_10_Picture_11.jpeg", + "_page_12_Picture_11.jpeg" + 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sha256:3a33e178a21d2621f07ad00566786e89cb6d04468a010440f8f96538ccb97da8 +size 851 diff --git a/marker2/ds9/EFTA00087089/_page_12_Picture_11.jpeg b/marker2/ds9/EFTA00087089/_page_12_Picture_11.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..01db7b8c73fc659825b1e3d3ce8bf690b61faf9b --- /dev/null +++ b/marker2/ds9/EFTA00087089/_page_12_Picture_11.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:671a128813c46ae78460c153ae07b3b611e4b1a59bff95d3a4f88b53b9668736 +size 843 diff --git a/marker2/ds9/EFTA00087102/EFTA00087102.md b/marker2/ds9/EFTA00087102/EFTA00087102.md new file mode 100644 index 0000000000000000000000000000000000000000..218300ded168de27ffba9d5d7e764da580782024 --- /dev/null +++ b/marker2/ds9/EFTA00087102/EFTA00087102.md @@ -0,0 +1,91 @@ +To: ' + +Subject: RE: [EXTERNAL] Fwd: SKY NEWS INTERVIEW REQUEST FOR AUDREY STRAUSS + +Date: Thu, 18 Nov 2021 15:08:19 +0000 + +Sure thing, thanks. + +From: + +Sent: Thursday, November 18, 2021 10:07 AM + +To (USANYS) < > + +Subject: Fwd: [EXTERNAL] Fwd: SKY NEWS INTERVIEW REQUEST FOR AUDREY STRAUSS + +FYI below. Could you please decline on Audrey's behalf? + +Begin forwarded message: + +From: + +Date: November 18, 2021 at 10:06:29 AM EST + +To: Audrey Strauss .r: > + +Subject: Re: [EXTERNAL] Fwd: SKY NEWS INTERVIEW REQUEST FOR AUDREY STRAUSS + +Of course. Looking forward to seeing you too! + +On Nov 18, 2021, at 10:05 AM, Audrey Strauss cz! > wrote: + +ould you please pass this along to and ask if he would handle? + +omLo ing forward to seeing you tomorrow. + +Best, + +Audrey + +Begin forwarded message: + +From: Rusty Wing < + +Subject: Fwd: SKY NEWS INTERVIEW REQUEST FOR AUDREY STRAUSS + +Date: November IS, 2021 at 8:03:44 AM EST + +To: Audrey , [REDACTED] + +<[REDACTED]> + +**Cc:** [REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] Jeff Pagliuca <[REDACTED]>, "Laura + +Menninger" <[REDACTED]>, "[REDACTED]" + +<[REDACTED]>, Patrick Smith <[REDACTED]> + +**Subject:** Re: 20cr330, US v. Maxwell - Request for [REDACTED] to be added to ECF as "movant" + +**Date:** Fri, 19 Nov 2021 14:45:50 +0000 + +**Attachments:** 20cr330\_ME\_11.19.21.pdf + +Counsel: + +Attached please find a memo endorsement issued by Judge Nathan, which will be filed on the public docket. + +Sincerely, +Chambers of the Hon. Alison J. Nathan + +**From:** Brian Burns <[REDACTED]> + +**Sent:** Thursday, November 18, 2021 6:20 PM + +**To:** Nathan NYSD Chambers <[REDACTED]>; [REDACTED] + +<[REDACTED]> + +**Cc:** [REDACTED] + +[REDACTED] + +[REDACTED] >; Jeff Pagliuca <[REDACTED]>; Laura Menninger + +<[REDACTED]>; [REDACTED] <[REDACTED]>; Patrick Smith + +<[REDACTED]> + +**Subject:** RE: 20cr330, US v. Maxwell - Request for [REDACTED] to be added to ECF as "movant" + +**CAUTION - EXTERNAL:** + +Dear Judge Nathan – Attached please find a letter requesting that [REDACTED] be added to ECF as a "movant" in this case so she may file papers on the docket as directed by the Court. We are available should the Court have any questions. + +Respectfully submitted, + +**Brian T. Burns** + +Smith Villazor LLP + +[REDACTED] + +New York, New York 10019 + +**Office** [REDACTED] | **Direct** [REDACTED] | **Mobile** [REDACTED] + +To: Cc: Brian Burns >\*, Jeff Pagliuca >; Laura Menninger < ; Patrick Smith < Subject: [EXTERNAL EMAIL) Re: 20cr330, US v. Maxwell + +Counsel: + +Attached please find a corrected memo endorsement. Please disregard the prior email, and please confirm receipt. + +Sincerely, Chambers of the Hon. Alison J. Nathan + +From: BOBBI C STERNHEIM Sent: Monday, November 15, 2021 8:32 PM To: Nathan NYSD Chambers Cc: Jeff Pagliuca ; Patrick Smith Subject: Re: 20cr330, US v. Maxwell Laura Menninger + +## CAUTION - EXTERNAL: + +Received. Thank you. + +BOBBI C. STERNHEIM, ESQ. Law Offices of Bobbi C. Sternheim 225 Broadway, Suite 715 New York, NY 10007 + +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. + +Attached please find a temporarily sealed memo endorsement issued by Judge Nathan. + +Please confirm receipt. + +Sincerely, + +Chambers of the Hon. Alison J. Nathan + +From: Brian Burns <1 + +Sent: Monday, November 15, 2021 7:08 PM + +To: Nathan NYSD Chambers + +Cc: ; Patrick Smith + +Subject: United States v. Maxwell, 20 Cr. 330-AJN - Letter re Rule 17(c) Subpoena to + +## CAUTION - EXTERNAL: + +Dear Judge Nathan — We represent and respectfully submit the attached letter from Patrick J. Smith by e-mail, pursuant to my call to Chambers this afternoon. We have copied counsel for the government and defense counsel on this email. We are available should the Court have any questions. + +Respectfully submitted, + +Brian T. Burns + +Smith Villazor LLP + +New York. New York 10019 + +Office I Direct Mobile + +CAUTION - EXTERNAL EMAIL: This email originated outside the Judiciary. Exercise caution when opening attachments or clicking on links. + +<20cr330 ME 11.15.21.pdf> + +CAUTION - EXTERNAL EMAIL: This email originated outside the Judiciary. attachments or clicking on links. Exercise caution when opening + +CAUTION - EXTERNAL EMAIL: This email originated outside the Judiciary. attachments or clicking on links. 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Ghislaine Maxwell, 20 Cr. 330 (AJN) + +**Date:** Fri, 19 Nov 2021 16:50:35 +0000 + +--- + +Alison, + +Monday at 6pm works for us for our next meeting with Pat. To avoid Webex issues, it would be great if we could use Zoom. If that works for you, we can use the following Zoom meeting ID: + +Meeting ID: 3127323168 or ryankusmin + +I'll send an invite to hold the time, but please let me know if that doesn't work. + +Thanks, + +Allison + +--- + +**From:** [REDACTED] <[REDACTED]> + +**Sent:** Wednesday, November 17, 2021 8:17 AM + +**To:** Stoddart, Allison + +**Cc:** Sahni, Anjan ; [REDACTED] (USANYS) <[REDACTED]>; [REDACTED] + +[REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> + +**Subject:** RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +**EXTERNAL SENDER** + +Thanks, yes. Let's plan to meet at 7. I'm heading to court now and will circulate a webex invitation later today. Thanks very much. + +--- + +**From:** Stoddart, Allison <[Allison.Stoddart@wilmerhale.com](mailto:Allison.Stoddart@wilmerhale.com)> + +**Sent:** Wednesday, November 17, 2021 8:15 AM + +**To:** [REDACTED] <[REDACTED]> + +**Cc:** Sahni, Anjan <[Anjan.Sahni@wilmerhale.com](mailto:Anjan.Sahni@wilmerhale.com)>; [REDACTED] (USANYS) <[REDACTED]>; [REDACTED] + +[REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> + +**Subject:** RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +Alison – + +Does tonight still work for a call with Pat? I know you're tied up during the day, but he is available from 6-9pm tonight. + +Thanks, +Allison + +**To:** [REDACTED] <[REDACTED]> + +**Cc:** Sahni, Anjan <[Anjan.Sahni@wilmerhale.com](mailto:Anjan.Sahni@wilmerhale.com)>; [REDACTED] (USANYS) <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> + +**Subject:** RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +Thanks, Alison. Pat has been traveling, but returning tomorrow. I'll pass your schedule along, and I expect to get back to you tomorrow with some possible times. + +Thanks, + +Allison + +**From:** [REDACTED] <[REDACTED]> + +**Sent:** Monday, November 15, 2021 6:16 PM + +**To:** Stoddart, Allison <[Allison.Stoddart@wilmerhale.com](mailto:Allison.Stoddart@wilmerhale.com)> + +**Cc:** Sahni, Anjan <[Anjan.Sahni@wilmerhale.com](mailto:Anjan.Sahni@wilmerhale.com)>; [REDACTED] (USANYS) <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> + +**Subject:** RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +**EXTERNAL SENDER** + +Hi Allison, + +I wanted to follow up on scheduling, since this week is a bit tight and I know everyone is busy. I'm available from 7 p.m. onwards tomorrow evening, Wednesday, or Thursday. I'm also available this weekend, if that's easier. Apologies for proposing evening/weekend times, but jury selection this week makes scheduling a little difficult. I'm also free on Monday from 12-4 if it's not possible to meet sooner. + +Thanks, + +Alison + +**From:** Stoddart, Allison <[Allison.Stoddart@wilmerhale.com](mailto:Allison.Stoddart@wilmerhale.com)> + +**Sent:** Wednesday, November 10, 2021 8:35 PM + +**To:** [REDACTED] <[REDACTED]> + +**Cc:** Sahni, Anjan <[Anjan.Sahni@wilmerhale.com](mailto:Anjan.Sahni@wilmerhale.com)>; [REDACTED] (USANYS) <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> + +**Subject:** RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +Hi Alison, + +Apologies for not responding sooner. I am still trying to confirm timing, but looking at next week, not tomorrow. + +Thanks, + +Allison + +EXTERNAL SENDER + +Hi Allison, + +Just checking in on timing, in case we're meeting tomorrow. If not, no worries, next week is fine. + +Thanks, + +Alison + +From: Stoddart, Allison + +Sent: Tuesday, November 9, 2021 8:43 PM + +To: + +Cc: Sahni, Anjan . (USANYS) ) ) + +Subject: RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) + +Thanks, Alison. I'll check and get back to you. + +Allison + +From: + +Sent: Tuesday, November 9, 2021 8:07 PM + +To: Stoddart, Allison + +Cc: Sahni, Anjan • (USANYS) > + +Subject: Re: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) + +EXTERNAL SENDER + +Are there times on Thursday afternoon or evening that would work? I can move a few things around if he is available. Otherwise, I'm available anytime next week in the the morning from 7:30-8:30, or in the evening from 5:30 p.m. onwards, or anytime on the weekend. Thanks very much for your help arranging the meeting. + +On Nov 9, 2021, at 7:23 PM, Stoddart, Allison wrote: + +Thanks, Alison. Pat is traveling on Friday and Monday unfortunately. I know jury selection is scheduled to be underway next week, but if tomorrow doesn't work, would there be times next week that might? + +Thanks, Allison + +From: + +**EXTERNAL SENDER** + +Hi Allison, + +Thanks very much. We'll be in court most of the day for a hearing tomorrow, but is there a time on Friday that would work? + +Thanks, + +Alison + +--- + +**From:** Stoddart, Allison <[Allison.Stoddart@wilmerhale.com](mailto:Allison.Stoddart@wilmerhale.com)> + +**Sent:** Tuesday, November 9, 2021 3:50 PM + +**To:** [REDACTED] <[REDACTED]> + +**Cc:** Sahni, Anjan <[Anjan.Sahni@wilmerhale.com](mailto:Anjan.Sahni@wilmerhale.com)>; [REDACTED] (USANYS) <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> + +**Subject:** RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +Hi Alison, + +When we last spoke, we discussed setting up a call with your team and Pat McHugh. Would tomorrow afternoon work for that call? + +Thanks very much, +Allison + +--- + +**From:** [REDACTED] <[REDACTED]> + +**Sent:** Wednesday, October 27, 2021 9:02 AM + +**To:** Stoddart, Allison <[Allison.Stoddart@wilmerhale.com](mailto:Allison.Stoddart@wilmerhale.com)> + +**Cc:** Sahni, Anjan <[Anjan.Sahni@wilmerhale.com](mailto:Anjan.Sahni@wilmerhale.com)>; [REDACTED] (USANYS) <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> + +**Subject:** RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +**EXTERNAL SENDER** + +Hi Allison, + +Thanks— would 3 p.m. work for a call today? + +--- + +**From:** Stoddart, Allison <[Allison.Stoddart@wilmerhale.com](mailto:Allison.Stoddart@wilmerhale.com)> + +**Sent:** Wednesday, October 27, 2021 7:48 AM + +**To:** [REDACTED] <[REDACTED]> + +**Cc:** Sahni, Anjan <[Anjan.Sahni@wilmerhale.com](mailto:Anjan.Sahni@wilmerhale.com)>; [REDACTED] (USANYS) <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> + +Thanks, +Allison + +--- + +**From:** Stoddart, Allison + +**Sent:** Monday, October 18, 2021 9:05 PM + +**To:** [REDACTED] <[REDACTED]> + +**Cc:** Sahni, Anjan <[Anjan.Sahni@wilmerhale.com](mailto:Anjan.Sahni@wilmerhale.com)>; [REDACTED] (USANYS) <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> + +**Subject:** RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +Great. Thanks, Alison. Appreciate it. + +Allison + +--- + +**From:** [REDACTED] <[REDACTED]> + +**Sent:** Monday, October 18, 2021 8:58 PM + +**To:** Stoddart, Allison <[Allison.Stoddart@wilmerhale.com](mailto:Allison.Stoddart@wilmerhale.com)> + +**Cc:** Sahni, Anjan <[Anjan.Sahni@wilmerhale.com](mailto:Anjan.Sahni@wilmerhale.com)>; [REDACTED] (USANYS) <[REDACTED]>; [REDACTED] <[REDACTED]> + +**Subject:** RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +**EXTERNAL SENDER** + +Hi Allison, + +Thanks, that's not a problem. I'm attaching a broadly worded subpoena to the bank, but please let me know if you'd like me to direct this more specifically to a particular entity or officer. + +Thanks, + +Alison + +--- + +**From:** Stoddart, Allison <[Allison.Stoddart@wilmerhale.com](mailto:Allison.Stoddart@wilmerhale.com)> + +**Sent:** Monday, October 18, 2021 8:57 AM + +**To:** [REDACTED] <[REDACTED]> + +**Cc:** Sahni, Anjan <[Anjan.Sahni@wilmerhale.com](mailto:Anjan.Sahni@wilmerhale.com)>; [REDACTED] (USANYS) <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> + +**Subject:** RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +Alison, Maurene, Lara, + +Following up on our last discussion, JPMorgan is working on identifying a witness for trial. Are you able to provide JPMorgan with a trial appearance subpoena? + +Thanks very much, + +Allison Stoddart I WilmerHale 7 World Trade Center 250 Greenwich Street New York, NY 10007 USA +1 212 295 6401(t) allison.stoddart@wilmerhale.com + +From: + +Sent: Friday, October 8, 202112:15 PM + +To: Stoddart, Allison + +Cc: Sahni, Anjan • (USANYS) ct > + +Subject: Re: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +EXTERNAL SENDER + +Hi Allison, + +I'm traveling for work for much of next week, but I'm available for a call anytime on Monday, or at 9 a.m. on Tuesday. I'm also available for a call this afternoon anytime from 4 pm onwards if that's easier. + +Thanks. + +On Oct 8, 2021, at 11:18 AM, Stoddart, Allison wrote: + +Thanks, Alison. Could we find some time early next week to discuss? Are there certain windows that would work on your end? + +Thanks, Allison + +Allison Stoddart I WilmerHale 7 World Trade Center 250 Greenwich Street New York, NY 10007 USA +1 212 295 6401(t) allison.stoddart@wilmerhale.com + +From: + +Sent: Friday, October 8, 2021 10:01 AM + +To: Sahni, Anjan • Stoddart, Allison + +Cc: (USANYS) + +Subject: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) + +EXTERNAL SENDER + +Hope you're both doing well. Following up on our last conversation, we wanted to send along a few documents in order to facilitate our conversation about identifying an appropriate witness from JP Morgan. Attached is a zip file containing a few draft exhibits. We are still working on finalizing exhibits, but we thought it made sense to start the conversation about this sooner rather than later. 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Ghislaine Maxwell, 20 Cr. 330 (AJN) +**Date:** Sat, 20 Nov 2021 16:59:41 +0000 + +--- + +Hi Allison, + +Thanks very much for following up on this. I'm free for a call at any point after 12 p.m. tomorrow. + +Thanks, + +Alison + +--- + +**From:** Stoddart, Allison +**Sent:** Saturday, November 20, 2021 11:48 AM +**To:** [REDACTED] <[REDACTED]> +**Cc:** Sahni, Anjan ; [REDACTED] (USANYS) <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> +**Subject:** RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +Hi Alison, + +Apologies for the email over the weekend. We were wondering if you have time for a quick call tomorrow to follow up on our Wednesday meeting. Let us know if there are some times that might work. + +Thanks, +Allison + +--- + +**From:** [REDACTED] <[REDACTED]> +**Sent:** Friday, November 19, 2021 5:33 PM +**To:** Stoddart, Allison +**Cc:** Sahni, Anjan ; [REDACTED] (USANYS) <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> +**Subject:** RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +**EXTERNAL SENDER** + +Hi Allison, + +Thanks very much. Let me look into it, and I'll let you know if Zoom is an issue, but otherwise let's plan for that. + +Best, + +**To:** [REDACTED] <[REDACTED]> + +**Cc:** Sahni, Anjan <[Anjan.Sahni@wilmerhale.com](mailto:Anjan.Sahni@wilmerhale.com)>; [REDACTED] (USANYS) <[REDACTED]>; [REDACTED] + +[REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> + +**Subject:** RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +Alison, + +Monday at 6pm works for us for our next meeting with Pat. To avoid Webex issues, it would be great if we could use Zoom. If that works for you, we can use the following Zoom meeting ID: + +Meeting ID: 3127323168 or ryankusmin + +I'll send an invite to hold the time, but please let me know if that doesn't work. + +Thanks, + +Allison + +**From:** [REDACTED] <[REDACTED]> + +**Sent:** Wednesday, November 17, 2021 8:17 AM + +**To:** Stoddart, Allison <[Allison.Stoddart@wilmerhale.com](mailto:Allison.Stoddart@wilmerhale.com)> + +**Cc:** Sahni, Anjan <[Anjan.Sahni@wilmerhale.com](mailto:Anjan.Sahni@wilmerhale.com)>; [REDACTED] (USANYS) <[REDACTED]>; [REDACTED] + +[REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> + +**Subject:** RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +**EXTERNAL SENDER** + +Thanks, yes. Let's plan to meet at 7. I'm heading to court now and will circulate a webex invitation later today. Thanks very much. + +**From:** Stoddart, Allison <[Allison.Stoddart@wilmerhale.com](mailto:Allison.Stoddart@wilmerhale.com)> + +**Sent:** Wednesday, November 17, 2021 8:15 AM + +**To:** [REDACTED] <[REDACTED]> + +**Cc:** Sahni, Anjan <[Anjan.Sahni@wilmerhale.com](mailto:Anjan.Sahni@wilmerhale.com)>; [REDACTED] (USANYS) <[REDACTED]>; [REDACTED] + +[REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> + +**Subject:** RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +Alison – + +Does tonight still work for a call with Pat? I know you're tied up during the day, but he is available from 6-9pm tonight. + +Thanks, + +Allison + +**From:** Stoddart, Allison + +Thanks, Alison. Pat has been traveling, but returning tomorrow. I'll pass your schedule along, and I expect to get back to you tomorrow with some possible times. + +Thanks, + +Allison + +From: Sent: Monday, November 15, 2021 6:16 PM To: Stoddart, Allison Cc: Sahni, Anjan • (USANYS) Subject: RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) + +EXTERNAL SENDER + +Hi Allison, + +I wanted to follow up on scheduling, since this week is a bit tight and I know everyone is busy. I'm available from 7 p.m. onwards tomorrow evening, Wednesday, or Thursday. I'm also available this weekend, if that's easier. Apologies for proposing evening/weekend times, but jury selection this week makes scheduling a little difficult. I'm also free on Monday from 12-4 if it's not possible to meet sooner. + +Thanks, + +Alison + +From: Stoddart, Allison + +Sent: Wednesday, November 10, 2021 8:35 PM + +To: ) Cc: Sahni, Anjan • (USANYS) Subject: RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +Hi Alison, + +Apologies for not responding sooner. I am still trying to confirm timing, but looking at next week, not tomorrow. + +Thanks, + +Allison + +From: Sent: Wednesday, November 10, 2021 7:48 PM To: Stoddart, Allison Cc: Sahni, Anjan • (USANYS) Subject: RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +Just checking in on timing, in case we're meeting tomorrow. If not, no worries, next week is fine. + +Thanks, + +Alison + +From: Stoddart, Allison + +Sent: Tuesday, November 9, 2021 8:43 PM + +To: ) < =1> + +Cc: Sahni, Anjan ; (USANYS) + +Subject: RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +Thanks, Alison. I'll check and get back to you. + +Allison + +From: + +Sent: Tuesday, November 9, 2021 8:07 PM + +To: Stoddart, Allison + +Cc: Sahni, Anjan • ) (USANYS) > + +Subject: Re: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) + +EXTERNAL SENDER + +Are there times on Thursday afternoon or evening that would work? I can move a few things around if he is available. Otherwise, I'm available anytime next week in the the morning from 7:30-8:30, or in the evening from 5:30 p.m. onwards, or anytime on the weekend. Thanks very much for your help arranging the meeting. + +On Nov 9, 2021, at 7:23 PM, Stoddart, Allison wrote: + +Thanks, Alison. Pat is traveling on Friday and Monday unfortunately. I know jury selection is scheduled to be underway next week, but if tomorrow doesn't work, would there be times next week that might? + +Thanks, Allison + +From: + +Sent: Tuesday, November 9, 20216:32 PM + +To: Stoddart, Allison + +Cc: Sahni, Anjan • (USANYS) + +Subject: RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) + +Thanks very much. We'll be in court most of the day for a hearing tomorrow, but is there a time on Friday that would work? + +Thanks, + +Alison + +--- + +**From:** Stoddart, Allison <[Allison.Stoddart@wilmerhale.com](mailto:Allison.Stoddart@wilmerhale.com)> + +**Sent:** Tuesday, November 9, 2021 3:50 PM + +**To:** [REDACTED] <[REDACTED]> + +**Cc:** Sahni, Anjan <[Anjan.Sahni@wilmerhale.com](mailto:Anjan.Sahni@wilmerhale.com)>; [REDACTED] (USANYS) <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> + +**Subject:** RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +Hi Alison, + +When we last spoke, we discussed setting up a call with your team and Pat McHugh. Would tomorrow afternoon work for that call? + +Thanks very much, +Alison + +--- + +**From:** [REDACTED] <[REDACTED]> + +**Sent:** Wednesday, October 27, 2021 9:02 AM + +**To:** Stoddart, Allison <[Allison.Stoddart@wilmerhale.com](mailto:Allison.Stoddart@wilmerhale.com)> + +**Cc:** Sahni, Anjan <[Anjan.Sahni@wilmerhale.com](mailto:Anjan.Sahni@wilmerhale.com)>; [REDACTED] (USANYS) <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> + +**Subject:** RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +**EXTERNAL SENDER** + +Hi Allison, + +Thanks— would 3 p.m. work for a call today? + +--- + +**From:** Stoddart, Allison <[Allison.Stoddart@wilmerhale.com](mailto:Allison.Stoddart@wilmerhale.com)> + +**Sent:** Wednesday, October 27, 2021 7:48 AM + +**To:** [REDACTED] <[REDACTED]> + +**Cc:** Sahni, Anjan <[Anjan.Sahni@wilmerhale.com](mailto:Anjan.Sahni@wilmerhale.com)>; [REDACTED] (USANYS) <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> + +**Subject:** RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +Hi Alison, + +We wanted to provide an update on the trial witness topic. Do you have any time this afternoon or tomorrow for a brief call? + +**To:** [REDACTED]' <[REDACTED]> + +**Cc:** Sahni, Anjan <[Anjan.Sahni@wilmerhale.com](mailto:Anjan.Sahni@wilmerhale.com)>; [REDACTED] (USANYS) <[REDACTED]>; [REDACTED] + +[REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> + +**Subject:** RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +Great. Thanks, Alison. Appreciate it. + +Allison + +**From:** [REDACTED] <[REDACTED]> + +**Sent:** Monday, October 18, 2021 8:58 PM + +**To:** Stoddart, Allison <[Allison.Stoddart@wilmerhale.com](mailto:Allison.Stoddart@wilmerhale.com)> + +**Cc:** Sahni, Anjan <[Anjan.Sahni@wilmerhale.com](mailto:Anjan.Sahni@wilmerhale.com)>; [REDACTED] (USANYS) <[REDACTED]>; [REDACTED] + +[REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> + +**Subject:** RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +**EXTERNAL SENDER** + +Hi Allison, + +Thanks, that's not a problem. I'm attaching a broadly worded subpoena to the bank, but please let me know if you'd like me to direct this more specifically to a particular entity or officer. + +Thanks, + +Alison + +**From:** Stoddart, Allison <[Allison.Stoddart@wilmerhale.com](mailto:Allison.Stoddart@wilmerhale.com)> + +**Sent:** Monday, October 18, 2021 8:57 AM + +**To:** [REDACTED] <[REDACTED]> + +**Cc:** Sahni, Anjan <[Anjan.Sahni@wilmerhale.com](mailto:Anjan.Sahni@wilmerhale.com)>; [REDACTED] (USANYS) <[REDACTED]>; [REDACTED] + +[REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> + +**Subject:** RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +Alison, Maurene, Lara, + +Following up on our last discussion, JPMorgan is working on identifying a witness for trial. Are you able to provide JPMorgan with a trial appearance subpoena? + +Thanks very much, + +Allison + +**Allison Stoddart | WilmerHale** + +7 World Trade Center + +250 Greenwich Street + +New York, NY 10007 USA + +Sent: Friday, October 8, 2021 12:15 PM + +To: Stoddart, Allison + +Cc: Sahni, Anjan ; (USANYS) + +Subject: Re: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +EXTERNAL SENDER + +Hi Allison, + +I'm traveling for work for much of next week, but I'm available for a call anytime on Monday, or at 9 a.m. on Tuesday. I'm also available for a call this afternoon anytime from 4 pm onwards if that's easier. + +Thanks. + +On Oct 8, 2021, at 11:18 AM, Stoddart, Allison wrote: + +Thanks, Alison. Could we find some time early next week to discuss? Are there certain windows that would work on your end? + +Thanks, Allison + +Allison Stoddart I WilmerHale + +7 World Trade Center 250 Greenwich Street New York, NY 10007 USA +1 212 295 6401(t) anison.stoddart@wilmerhale.com + +From: + +Sent: Friday, October 8, 2021 10:01 AM + +To: Sahni, Anjan • Stoddart, Allison + +Cc: (USANYS) + +Subject: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) + +EXTERNAL SENDER + +Anjan, Allison, + +Hope you're both doing well. Following up on our last conversation, we wanted to send along a few documents in order to facilitate our conversation about identifying an appropriate witness from JP Morgan. Attached is a zip file containing a few draft exhibits. We are still working on finalizing exhibits, but we thought it made sense to start the conversation about this sooner rather than later. 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MAXWELL 357.99 + +Total Amt Due 116.82CR + +Total Current Monthly Charges 1,273.67 TOTAL AMOUNT DUE 116.82CR + +Acct Name: JEFFREY B EPSTEIN 6 CO Account: Wireless AMOUNT DUE: AT&T WIRELESS P.O. BOX 8220 AURORA IL 60572-8220 JEFFREY E EPSTEIN 6 CO 457 MADISON AVE NEW YORK NY 10022-6843 116.82CR + +ACCOUNT NAMA ACCOUNT NUMBER JEFFREY B EPSTEIN & FEB 14, 2004 BILL DATE PAGE 3.0 + +### SIGN UP FOR PAPERLESS BILLING TODAY! + +Pay your bill online anytime, day or night.\* And you can also get instant account information, view your service plans, and change or add features. Sign-up today at www.attwireless.com/ocs \*subject to credit approval + +## PAYMENTS AND ADJUSTMENTS DETAIL OF PAYMENTS + +![](_page_1_Picture_3.jpeg) + +![](_page_1_Picture_4.jpeg) + +1/16/04 PAYMENT RECEIVED - THANK YOU! 1,485.48CR 2/11/04 PAYMENT RECEIVED - THANK YOU! 3,308.41CR TOTAL OF PAYMENTS RECEIVED THROUGH 2/14/04 4,793.89CR + +### DETAIL OF ADJUSTMENTS + +MONTHLY SERVICE CHARGE - ADJ 94.99 TOTAL OF ADJUSTMENTS 94.99 ACCOUNT NAME ACCOUNT NUMBER MOBILE NUMBER BILL DATE PAGE 10.0 JEFFREY E EPSTEIN & FEB 14, 2004 + +### SUMMARY OF CHARGES + +## IMPORTANT MESSAGES: + +You received an adjustment on your account. Please see the Payments and Adjustments detail on a previous page of this invoice. Your wireless service is currently in a canceled status. + +### MONTHLY SERVICE CHARGES + +1/13/04 Through 2/12/04 MONTHLY SE - AT&T DIGITAL ONE RATE \$14 149.99 MONTHLY SE - AT&T DIGITAL ONE RATE \$14 104.99CR CALL FORWARDING .00 THREE WAY CALLING .00 CALL WAITING .00 CALLER ID .00 WORLDCONNECT 2.40 PCS VOICEMAIL W/NUMERIC .00 DETAIL BILLING .00 TEXT MESSAGING \$9.99 3.32 + +TOTAL MONTHLY SERVICE CHARGES 50.72 + +## HOME AIRTIME CHARGES + +1/12/04 Through 1/22/04 - AT&T DIGITAL ONE RATE \$149.99 + +| Category Minutes | Rate | Charge | +|------------------|------|--------| +| 337 | .000 | .00 | +| 168 | .250 | 42.00 | +| 505 | | 42.00 | + +TOTAL HOME AIRTIME CHARGES 42.00 + +HOME LONG DISTANCE CHARGES + +AT&T WIRELESS 37.45 + +TOTAL HOME LONG DISTANCE CHARGES 37.45 + +ACCOUNT NAME ACCOUNT NUMBER MOBILE NUMBER BILL DATE PAGE 11.0 JEFFREY E EPSTEIN & FEB 14, 2004 + +### ROAMING CHARGES + +ROAMING AIR ROAMING LONG DISTANCE CHARGES TOTAL ROAMING CHARGES 135.63 47.60 183.23 + +# TAXES, SURCHARGES & REGULATORY FEES + +FEDERAL TAX 7.34 SALES TAX 17.64 911 SURCHARGE 1.20 NY CITY UTILITY G.R. SUR 4.60 LOCAL WIRELESS SURCHARGE .30 UNIVERSAL CONNECTIVITY CHARGE 5.59 GROSS RECEIPTS SURCHARGE 7.92 + +TOTAL TAXES, SURCHARGES & REGULATORY FEES TOTAL CURRENT MONTHLY CHARGES 44.59 357.99 + +![](_page_2_Picture_2.jpeg) + +### HONE AIRTIME AND LONG DISTANCE CHARGES + +| | | CALL | LONG | +|-----------------------------|----------------|-----------------------------------|------------------| +| REF DATE TINE NUMBER CALLED | CALLS | | | +| | | TO FROM | MIN AIR DISTANCE | +| 0001 1/12 12:37P | INCOMING | NM | 1 | +| 0002 1/12 1:16P | INCOMING | NN | 1 | +| 0003 1/12 1:17P | INCOMING | NN | 4 | +| 0004 1/12 1:67P | INCOMING | NM | 1 | +| 0005 1/12 2:48P | INCOMING | NM | 1 | +| 0006 1/12 5:06P | INCOMING | NM | 2 | +| 0007 1/12 5:39P | INCOMING | NM | 4 | +| 0008 1/12 5:42P W | INCOMING | NM | 3 | +| 0009 1/12 5:48P | INCOMING | NM | 1 | +| 0010 1/12 6:48P | INCOMING | NM | 1 | +| 0011 1/12 10:10P | NEW YORK | NY NN | 1 | +| 0012 1/13 11:02A | INCOMING | NM | 1 | +| 0013 1/13 11:08A | INCOMING | NM | 1 | +| 0014 1/13 11:17A | INCOMING | NM | 7 | +| 0015 1/13 12:34P | INCOMING | NM | 1 | +| 0016 1/13 1:S9P | MORIARTY | NN NM | 1 | +| 0017 1/13 1:S9P | NEW YORK | NY NM | 1 | +| 0018 1/13 2:00P | NEW YORK | NY NM | 1 | +| 0019 1/13 2:00P | NEW YORK | NY NM | 2 | +| 0020 1/13 2:24P | INCOMING | NM | 1 | +| 0021 1/13 2:56P | CHICAGO | IL NM | 3 | +| 0022 1/13 3:12P | NEW YORK | NY NM | 1 | +| 0023 1/13 3:18P | INCOMING | NM | 1 | +| 0024 1/13 3:19P | INCOMING | NM | 6 | +| 0025 1/13 3:36P | INCOMING | NM | 1 | +| 0026 1/13 3:36P | INCOMING | NM | 2 | +| 0027 1/13 3:40P | INCOMING | NM | 2 | +| 0028 1/13 3:56P | INCOMING | NH | 1 | +| ACCOUNT NAME | ACCOUNT NUMBER | MOBILE NUMBER BILL DATE PAGE 12.0 | | +| JEFFREY E EPSTEIN i | | | FEB 14, 2004 | + +| | | CALL | LONG | +|-----------------------------|------------------|-------|------------------| +| REF DATE TIME NUMBER CALLED | CALLS TO FROM | | MIN AIR DISTANCE | +| 0029 1/13 4:08P | INCOMING | NM | 1 | +| 0030 1/13 4:12P | INCOMING | NM | 2 | +| 0031 1/13 6:01P | NEW YORK | NY NM | 1 | +| 0032 1/13 9:09P | NEW YORK | NY NN | 2 | +| 0033 1/14 8:59A | NEW YORK | NY NH | 1 | +| 0034 1/14 9:00k | NEW YORK | NY NM | 1 | +| 0035 1/14 9:00A | NEW YORK | NY NM | 1 | +| 0036 1/14 9:00k | NEW YORK | NY NM | 1 | +| 0037 1/14 9:43A | INCOMING | NM | 4 | +| 0038 1/14 10:21A | NEW YORK | NY NM | 2 | +| 0039 1/14 10:23A | NEW YORK | NY NN | 1 | +| 0040 1/14 10:26A | NEW YORK | NY NH | 1 | +| 0041 1/14 10:27A | NEW YORK | NY NM | 1 | +| 0042 1/14 10:28A | LOSANGELES CA NM | | 2 | +| 0043 1/14 10:30A | QUEENS | NY NM | 3 | +| 0044 1/14 10:3IA | SAN MONICA CA NN | | 1 | +| 0045 1/14 10:32A | NEW YORK | NY NM | 1 | +| 0046 1/14 10:32A | QUEENS | NY NM | 3 | +| 0047 1/14 10:35A | LOSANGELES CA NN | | 1 | + +![](_page_3_Picture_2.jpeg) + +| 0048 1/14 10:39A | INCOMING | NH | 2 | +|----------------------------|------------------|-----------------------------------|--------| +| 0049 1/14 10:47A | NEW YORK | NY NH | 1 | +| 0050 1/14 10:47A | NEW YORK | NY NM | 1 | +| 0051 1/14 1:00P | INCOMING | NM | 1 | +| 0052 1/14 1:02P | INCOMING | NM | 1 | +| 0053 1/14 2:03P | INCOMING | NM | 4 | +| 0054 1/14 2:12P | NEW YORK | NY NN | 3 | +| 0035 1/14 2:19P | NEW YORK | NY NW | 2 | +| 0056 1/14 2:21P | UN. KINGDO | NH | 1 .350 | +| 0057 1/14 2:22P | QUEENS | NY NM | 1 | +| 0058 1/14 2:32P | INCOMING | NM | 5 | +| 0059 1/14 2:56P | NEW YORK | NY NM | 2 | +| 0060 1/14 3:03P | INCOMING | NM | 1 | +| 0061 1/14 3:07P | NEW YORK | NY NM | 1 | +| 0062 1/14 3:17P SRETRIEVAL | NEW YORK C NY NN | | 1 | +| 0063 1/14 3:55P | INCOMING | 114 | 9 | +| 0064 1/14 7:55P | INCOMING | 114 | 25 | +| 0065 1/14 8:17P W | INCOMING | NM | 1 | +| 0066 1/15 5:56A | NEW YORK | NY NM | 1 | +| 0067 1/15 6:06A | MORIARTY | NM NM | 1 | +| 0068 1/15 6:06A | NEW YORK | NY NM | 2 | +| 0069 1/15 6:09A | NEW YORK | NY 114 | 2 | +| 0070 1/15 6:10A | NEW YORK | NY NM | 1 | +| 0071 1/15 6:11A | QUEENS | NY 114 | 1 | +| 0072 1/15 6:13A | QUEENS | NY 114 | 1 | +| 0073 1/15 6:14A | NEW YORK | NY NM | 1 | +| 0074 1/15 6:14A | NEW YORK | NY NM | 1 | +| 0075 1/15 6:I5A | NEW YORK | NY NM | 1 | +| 0076 1/15 6:15A | NEW YORK | NY NM | 1 | +| 0077 1/15 6:I5A | NEW YORK | NY NM | 1 | +| 0078 1/15 6:16A | NEW YORK | NY NM | 1 | +| 0079 1/15 6:16A | NEW YORK | NY NM | 1 | +| 0080 1/15 6:16A | NEW YORK | NY NM | 1 | +| 0081 1/15 6:17A | NEW YORK | NY NM | 1 | +| 0082 1/15 6:17A | NEW YORK | NY NM | 1 | +| 0083 1/15 6:17A | NEW YORK | NY NM | 1 | +| 0084 1/15 6:17A | QUEENS | NY NM | 1 | +| 0085 1/15 6:21A | QUEENS | NY NM | 1 | +| 0086 1/15 6:21A | NEW YORK | NY 114 | 2 | +| 0087 1/15 6:23A W | INCOMING | 114 | 4 | +| 0088 1/15 6:27A | NEW YORK | NY NN | 2 | +| ACCOUNT NAME | ACCOUNT NUMBER | MOBILE NUMBER BILL DATE PAGE 13.0 | | + +JEFFREY E EPSTEIN 4 FEB 14, 2004 + +| | | CALL | LONG | +|-----------------------------|------------------|-------|------------------| +| REF DATE TIME NUMBER CALLED | CALLS TO FROM | | MIN AIR DISTANCE | +| 0089 1/15 6:30A | QUEENS | NY NM | 1 | +| 0090 1/15 6:35A | QUEENS | NY NM | 2 | +| 0091 1/15 6:44A | QUEENS | NY NH | 3 | +| 0092 1/15 6:54A | INCOMING | NH | 1 | +| 0093 1/15 8:01A | INCOMING | NM | 2 | +| 0094 1/15 9:08A SRETRIEVAL | NEW YORK C NY NM | | 1 | +| 0095 1/15 1:36P SRETRIEVAL | NEW YORK C NY IN | | 3 | +| 0096 1/15 1:38P | NEW YORK | NY IN | 4 | +| 0097 1/15 1:47P | CAMBRIDGE MA IN | | 2 | +| 0098 1/15 1:48P | QUEENS | NY IN | 2 | + +![](_page_4_Picture_3.jpeg) + +![](_page_4_Picture_4.jpeg) + +0099 1/15 1:49P YORK NY IN 2 0100 1/1S 1:50P INCOMING IN 1 0101 1/15 1:S2P INCOMING IN 1 0102 1/15 1:52P YORK NY IN 4 0103 1/15 1:56P YORK NY IN 7 0104 1/15 1:57P INCOMING IN 1 0105 1/15 2:02P YORK NY IN 3 0106 1/15 2:05P YORK NY IN 2 0107 1/15 2:07P MORIARTY NM IN 2 0108 1/15 2:09P YORK NY IN 2 0109 1/15 2:11P YORK NY IN 1 0110 1/15 2:11P ONE NY IN 1 0111 1/15 3:48P RETRIEVAL LOCAL 1 0112 1/15 4:09P INCOMING 3 0113 1/15 4:11P RETRIEVAL LOCAL 1 0114 1/15 5:33P INCOMING 2 0115 1/15 6:47P INCOMING 2 0116 1/15 7:52P INCOMING S 0117 1/15 8:03P INCOMING 1 0118 1/15 8:21P INCOMING 2 0119 1/15 8:31P YORK NY 1 0120 1/15 8:33P INCOMING 4 0121 1/15 8:49P INCOMING 1 0122 1/15 9:10P YORK NY 1 0123 1/15 10:04? 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.99 | .35 | +| 0039 1/20 6:47 | INTL NTWK | 2 | 1.98 | .70 | +| 0040 1/20 7:50 | INTL NTWK | 2 | 1.98 | .70 | +| 0041 1/21 12:0 | INTL NTWK | 1 | .99 | .35 | +| 0042 1/21 12:0 | INTL NTWX | 2 | 1.98 | .70 | +| Subtotal for | SWITZERLAND, | 54 | 53.46 | 18.55 .00 | +| Calls Made Prom | SWITZERLAND, | | | | +| 0043 1/21 11:21 | INTL NTWK | 1 | .99 | .35 | +| 0044 1/21 11:27 | INTL NTWK | 2 | 1.98 | .70 | +| 0045 1/21 12:39 | INTL NTWK | 1 | .99 | .35 | +| 0046 1/21 1:49P | INTL NTWX | 1 | .99 | .35 | +| 0047 1/21 1:52P | INTL NTWX | 1 | .99 | .35 | +| 0048 1/21 2:28P | INTL NTWK | 1 | .99 | .35 | +| 0049 1/21 2:56P | INTL NTWX | 1 | .99 | .35 | +| 0050 1/21 2:59P | INTL NTWK | 2 | 1.98 | .70 | +| 0051 1/21 3:19P | INTL NTWK | 1 | .99 | .35 | +| 0052 1/21 3:21P | INTL NTWK | 2 | 1.98 | .70 | +| 0053 1/21 4:05P | INTL NTWK | 1 | .99 | .35 | +| 0054 1/21 4:58P | INTL NTWX | 1 | .99 | .35 | +| 0055 1/21 5:53P | INTL NTWX | 1 | .99 | .35 | +| 0056 1/21 6:40P | INTL NTWX | 2 | 1.98 | .70 | +| 0057 1/21 6:57P | INTL NTWK | 1 | .99 | .35 | +| 0058 1/21 6:58P | INTL NTWK | 1 | .99 | .35 | +| 0059 1/21 6:59P | INTL NTWK | 3 | 2.97 | 1.05 | +| 0060 1/21 7:02P | INTL NTWK | 1 | .99 | .35 | +| 0061 1/21 7:04P | INTL NTWK | 1 | .99 | .35 | +| 0062 1/21 7:05P | INTL NTWX | 20 | 19.80 | 7.00 | +| 0063 1/21 10:40 | INTL NTWX | 1 | .99 | .35 | +| 0064 1/21 10:41 | INTL NTWX | 2 | 1.98 | .70 | + +![](_page_8_Picture_3.jpeg) + +![](_page_8_Picture_4.jpeg) + +0065 1/21 10:44 0066 1/22 12:31 0067 1/22 1:11A 0068 1/22 3:59P 0069 1/22 4:01P 0070 1/22 4:34P 0071 1/22 9:07P ACCOUNT NAME JEFFREY E EPSTEIN INTL NTWK INTL NTWX INTL NTWX INTL NTWX INTL NTWX INTL NTWX INTL NTWX 2 1.98 .70 1 .99 .35 4 3.96 1.40 1 .99 .3S 2 1.98 .70 1 .99 .35 1 .99 .35 ACCOUNT NUMBER MOBILE NUMBER BILL DATE PAGE FEB 14, 2004 17.0 + +REF DATE TIME NUMBER CALLED CALLS TO MIN AIR DISTANCE TAXES + +0072 1/22 9:11P INTL NTWX 0073 1/22 9:12P INTL NTWX 0074 1/23 7:22P INTL NTWX Subtotal for : SWITZERLAND, Calla Made From: 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b/marker2/ds9/EFTA00087132/EFTA00087132.md @@ -0,0 +1,60 @@ +![](_page_0_Picture_0.jpeg) + +United States Attorney Southern District of New York + +The Siltio.1. MoNo Building + +New York New York 10007 + +November 20, 2021 + +## BY ELECTRONIC MAIL + +Christian Everdell, Esq. + +Mark Cohen, Esq. + +Cohen & Gresser LLP + +New York, NY 10022 + +Laura Menninger, Esq. + +Jeffrey Pagliuca, Esq. + +Haddon, Mor an and Foreman, P.C. + +Denver, CO 80203 + +Bobbi Stemheim, Esq. + +Law Offices of Bobbi C. Stemheim + +New York, NY 10007 + +Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +Dear Counsel: + +Today we are producing the materials listed in the below index. These materials are stamped with control numbers SDNY\_GM\_02772262 through SDNY\_GM\_02775031. + +Please note that both this letter and the enclosed materials are governed by the July 31, 2020 Protective Order in this case. This letter is itself designated as "confidential," because it includes information regarding records designated as "confidential" under the Protective Order. The Department of Justice directed this office to cease the dissemination of materials marked with the word "confidential" in order to avoid potential confusion with markings reserved for classified documents. Accordingly, in order to note the appropriate designation of this production under the operative Protective Order in this case, the materials being produced today are marked with the following label: "SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17." This marking directly refers to the specific paragraphs of the Protective Order that govern today's production. + +An index of the materials contained in this production is below: + +| Bates Start | Bates End | Summary Description | Confidential Designation | +|------------------|------------------|---------------------|--------------------------| +| SDNY GM 02772262 | SDNY GM 02774104 | Records relating to | Confidential | +| SDNY GM 02774195 | SDNY GM 02775026 | | | +| | | Service | Confidential | +| SDNY GM 02775027 | SDNY GM 02775031 | Interlochen records | Confidential | + +The Government recognizes that its discovery obligations are ongoing and will promptly produce any additional discoverable material of which it becomes aware. Please do not hesitate to reach out if you have any difficulty accessing these materials. + +Very truly yours, + +United States Attorney + +by: s/ + +Assistant United States Attorneys \ No newline at end of file diff --git a/marker2/ds9/EFTA00087132/EFTA00087132.metadata.json b/marker2/ds9/EFTA00087132/EFTA00087132.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..f8218bc1cc9965d20aaa20b11cd1f59e60e102d2 --- /dev/null +++ b/marker2/ds9/EFTA00087132/EFTA00087132.metadata.json @@ -0,0 +1,149 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087132.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2482, + "elapsed_seconds": 1.28, + "image_assets": [ + "_page_0_Picture_0.jpeg" + ], + 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Please let me know if you're interested in ordering the transcript so we can assign reporters accordingly. 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MATT RILEY + +ow= 0000 oo oxo aro oc0000000 \*root JEFFREY E EPSTEIN C/O FINANCIAL TRUST COMPANY ATTN: JEANNE BRENNAN ST THOMAS VI 00802 + +**Asset Account Portfolio** +June 01, 2002 - June 30, 2002 + +## Portfolio Summary + +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 of your Asset Account, including mutual funds, are FDIC insured or bank deposits, 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. + +### Overview + +| | Market Value USD
Jun 30 | Market Value USD
May 31 | Tax
Cost USD | Estimated Annual
Income USD | Yield
% | +|------------------------------|----------------------------|----------------------------|------------------|--------------------------------|------------| +| Cash & Short Term | 48,909.71 | 48,857.00 | 48,909.71 | 549.74 | 1.1 | +| Total | 48,909.71 | 48,857.00 | 48,909.71 | 549.74 | 1.1 | +| Accrued Income | 45.70 | 52.71 | | | | +| Total Portfolio Value | 48,955.41 | 48,909.71 | | | | + +### Asset Allocation + +100% Cash and Short Term + +![](_page_1_Figure_31.jpeg) + +### Income Summary + +| | This Period USD | Year to Date USD* | +|---------------------------|-----------------|-------------------| +| U.S. Tax Exempt Dividends | 52.71 | 293.34 | +| Total | 52.71 | 293.34 | + +Account Number: + +JEFFREY EPSTEIN June 01, 2002 - June 30, 2002 + +### Asset Account Portfolio Page 3 of + +# Cash and Short Term + +## Summary by Maturity + +| | | | +|----------------------|----------------------|-------------------------| +| Current Market Value | Current Market Value | Estimated Annual Income | +| USD | USD | USD | +| Cash | 48,909.71 | 549.74 | +| Total | 48,909.71 | 549.74 | + +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 + +| | | Una Cost | | Tax Cost | Current | | Estimated | Current | +|----------|----------|----------|--------|----------|-----------------------|-------------|------------|---------| +| | | Rousted | Market | Adjusted | Marker Value USD | Untealaed | Annual | TRW, | +| Currency | Quantity | Original | Price | anginal | Accrued Interest (ISO | Overton USD | Income USD | VTR % | + +### Cash + +JP MORGAN TAX FREE MONEY MARKET USD 48,909.71 1.00 1.00 48,909.71 48,909.71 549.74 1.12 PREMIER CLASS SWEEP FUND (92) 45.70 (SWEEP DEADLINE IS 11:30 AM EST) 7-Day Annualised Yield: 1.16% + +### Imponanf Information about Phan, and Valuations + +Riau some of who're's. paneled by Rene services a otter =UMW .+Fuch -e deem read\* de not guaranteed MR accuracy o r ea teekzerble values + +Account Number: + +JEFFREY EPSTEIN June 01, 2002 - June 30, 2002 + +JPMorgan Chase Bank New York, NY 10154-1002 + +![](_page_3_Picture_5.jpeg) + +### Asset Account Portfolio Page 4 of. + +# Account Transactions + +## Cash Activity Summary + +| | Amount this Period USD | Amount Year to Date USD 1 | +|--------------------------|------------------------|--------------------------------------| +| Beginning Balance | .00 | | +| Credits | | | +| Dividends | 52.71 | 293.34 | +|
Debits | | | +| Sweep Account Purchases | - 52.71 | - 293.34 | +| Ending Balance | .00 | | + +'Year to date information is calculated on a calendar year basis. + +## Activity by Date + +| Settlement | | | | +|------------|----------|------------------------------------------------------------------------------------------------------|-----------| +| Dare | Typo | Otently Ofnalprion | Amount VW | +| Jun 3 | Dividend | JP MORGAN TAX FREE MONEY MARKET PREMIER CLASS SWEEP FUND (92) (SWEEP DEADLINE IS 11:30 AM EST) | | +| Jun 3 | Purchase | 52.71 JP MORGAN TAX FREE MONEY MARKET PREMIER CLASS SWEEP FUND (92) (SWEEP DEADLINE IS 11:30 AM EST) | - 52.71 | + +06 | 2002 + +JPMorgan Chase Bank +██████████, New York, NY 10154-1002 + +![](_page_4_Picture_21.jpeg) + +Account Number: ██████████ +JEFFREY EPSTEIN + +Asset Account Portfolio +June 01, 2002 - June 30, 2002 + +Page 1 of 1 + +**In Case of Errors or Questions About Your Electronic Transfers.** + +Contact your Morgan Team at 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 explain as clearly as you can why you believe it is in error or why you need more information. (3) Tell us the dollar amount of the suspected error. If you contact us orally, you must send us your complaint or question in writing within 10 business days in order to preserve your rights. We will investigate your complaint and will correct any error promptly. If we take more than 10 business days to do this (20 days for purchases using your debit card or for international transactions), we will credit your account for the amount you think is in error, so that you will have the use of money during the time it takes us to complete our investigation. + +**In case of errors or questions about your statement, including your line of credit.** + +If you think that your statement is incorrect or if you need more information about a transaction on your statement including a line of credit transaction, you must write to us on a separate sheet describing the error and send it to: 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 respective fund families. Shares of the funds are not bank deposits and are not guaranteed by any bank, government entity, or the FDIC. Return and share price will fluctuate and redemption value may be more or less than original cost. While the money market funds seek to maintain a stable net asset value of \$1.00 per share, there is no assurance that they will continue to do so. The estimated annual income and dividend yield figures for mutual funds represent the funds' most recent income dividend annualized. + +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. + +Account Number JEFFREY EPSTEIN JPMorgan Chase Bank New York, NY 10154-1002 + +![](_page_5_Picture_4.jpeg) + +# Asset Account Portfolio + +Jul, I - July I, 2002 + +## Table of Contents + +| | Page | +|----------------------|------| +| Portfolio Summary | 2 | +| Cash and Short Term | 3 | +| Account Transactions | 4 | + +### Account Officers + +Service Specialist: RILEY/HORNBECKER + +0000000000 0000000000~20000000 JEFFREY E EPSTEIN C/O FINANCIAL TRUST COMPANY ATTN: JEANNE BRENNAN ST THOMAS VI 00802 + +Account Number: [REDACTED] +JEFFREY EPSTEIN + +**Asset Account Portfolio** +July 01, 2002 - July 31, 2002 + +## Portfolio Summary + +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 of your Asset Account, including mutual funds, are FDIC insured or bank deposits, 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. + +### Overview + +| | Market Value USD
Jul 31 | Market Value USD
Jun 30 | Tax
Cost USD | Estimated Annual
Income USD | Yield
% | +|------------------------------|----------------------------|----------------------------|------------------|--------------------------------|------------| +| Cash & Short Term | 48,955.41 | 48,909.71 | 48,955.41 | 544.38 | 1.1 | +| Total | 48,955.41 | 48,909.71 | 48,955.41 | 544.38 | 1.1 | +| Accrued Income | 43.24 | 45.70 | | | | +| Total Portfolio Value | 48,998.65 | 48,955.41 | | | | + +### Asset Allocation + +100% Cash and Short Term + +![](_page_6_Figure_31.jpeg) + +### Income Summary + +| | This Period USD | Year to Date USD* | +|---------------------------|-----------------|-------------------| +| U.S. Tax Exempt Dividends | 45.70 | 339.04 | +| Total | 45.70 | 339.04 | + +**Asset Account Portfolio** +July 01, 2002 - July 31, 2002 + +## Cash and Short Term + +### Summary by Maturity + +| | Current Market Value
USD | Estimated Annual Income
USD | +|--------------|-----------------------------|--------------------------------| +| Cash | 48,955.41 | 544.38 | +| Total | 48,955.41 | 544.38 | + +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 + +| Description | Currency | Unit Cost
Adjusted
Original | Market
Price | Tax Cost
Adjusted
Original | Current
Market Value USD
Accrued Interest USD | Unrealized
Gain/Loss USD | Estimated
Annual
Income USD | Current
Yield/
YTM % | +|--------------------------|----------|-----------------------------------|-----------------|----------------------------------|-----------------------------------------------------|-----------------------------|-----------------------------------|----------------------------| +| Cusip/S&P/Moody's Rating | | | | | | | | | + +### Cash + +| JP MORGAN TAX FREE MONEY MARKET | USD | 48,955.41 | 1.00 | 1.00 | 48,955.41 | 48,955.41 | | 544.38 | 1.11 | +|----------------------------------|-----|-----------|------|------|-----------|-----------|--|--------|------| +| PREMIER CLASS SWEEP FUND (92) | | | | | | 43.24 | | | | +| (SWEEP DEADLINE IS 11:30 AM EST) | | | | | | | | | | +| 7-Day Annualized Yield: 1.15% | | | | | | | | | | + +*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.* + +JPMorgan Chase Bank New York, NY 10154-1002 + +Account Number: Asset Account Portfolio JEFFREY EPSTEIN July 01, 2002 - July 31, 2002 + +# Account Transactions + +![](_page_8_Picture_5.jpeg) + +## Cash Activity Summary + +| Beginning Balance Credits | Amount lNS Petted USD .00 | Amount Mar To Dare USD' | +|---------------------------|---------------------------|-------------------------| +| Dividends Debits | 45.70 | 339.04 | +| Sweep Account Purchases | - 45.70 | | +| Ending Balance | .00 | | + +'Year to date information is calculated on a calendar year basis. + +## Activity by Date + +| Settlement | | | | +|------------|----------|------------------------------------------------------------------------------------------------------|------------------| +| Dare | Typo | *ant" Ossalption | Amount USD 45 70 | +| Jul 1 | Dividend | JP MORGAN TAX FREE MONEY MARKET PREMIER CLASS SWEEP FUND (92) (SWEEP DEADLINE IS 11:30 AM EST) | | +| Jul 1 | Purchase | 45.70 JP MORGAN TAX FREE MONEY MARKET PREMIER CLASS SWEEP FUND (92) (SWEEP DEADLINE IS 11:30 AM EST) | - 45.70 | + +Asset Account Portfolio +July 01, 2002 - July 31, 2002 + +Page 1 of 1 + +**In Case of Errors or Questions About Your Electronic Transfers.** + +Contact your Morgan Team at 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 explain as clearly as you can why you believe it is in error or why you need more information. (3) Tell us the dollar amount of the suspected error. If you contact us orally, you must send us your complaint or question in writing within 10 business days in order to preserve your rights. We will investigate your complaint and will correct any error promptly. If we take more than 10 business days to do this (20 days for purchases using your debit card or for international transactions), we will credit your account for the amount you think is in error, so that you will have the use of money during the time it takes us to complete our investigation. + +**In case of errors or questions about your statement, including your line of credit.** + +If you think that your statement is incorrect or if you need more information about a transaction on your statement including a line of credit transaction, you must write to us on a separate sheet describing the error and send it to: 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 respective fund families. Shares of the funds are not bank deposits and are not guaranteed by any bank, government entity, or the FDIC. Return and share price will fluctuate and redemption value may be more or less than original cost. While the money market funds seek to maintain a stable net asset value of \$1.00 per share, there is no assurance that they will continue to do so. The estimated annual income and dividend yield figures for mutual funds represent the funds' most recent income dividend annualized. + +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. + +Account Number JEFFREY EPSTEIN JPMorgan Chase Bank , New York, NY 10154-1002 + +![](_page_10_Picture_4.jpeg) + +Confidential Page 1 of I + +# Asset Account Portfolio + +July 1 - July 31, 2002 + +## Table of Contents + +| | Page | +|----------------------|------| +| Portfolio Summary | 2 | +| Cash and Short Term | 3 | +| Account Transactions | 4 | + +### Account Officers + +Service Specialist. RILEYIHORNBECKER + +OG03000090 00 0090 OCOCOCOCOCOO 000X0 JEFFREY E EPSTEIN CIO FINANCIAL TRUST COMPANY ATTN. JEANNE BRENNAN ST THOMAS VI 00802 + +Account Number: [REDACTED] +JEFFREY EPSTEIN + +**Asset Account Portfolio** +July 01, 2002 - July 31, 2002 + +## Portfolio Summary + +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 of your Asset Account, including mutual funds, are FDIC insured or bank deposits, 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. + +--- + +### Overview + +| | Market Value USD
Jul 31 | Market Value USD
Jun 30 | Tax
Cost USD | Estimated Annual
Income USD | Yield
% | +|------------------------------|----------------------------|----------------------------|------------------|--------------------------------|------------| +| Cash & Short Term | 48,955.41 | 48,909.71 | 48,955.41 | 544.38 | 1.1 | +| Total | 48,955.41 | 48,909.71 | 48,955.41 | 544.38 | 1.1 | +| Accrued Income | 43.24 | 45.70 | | | | +| Total Portfolio Value | 48,998.65 | 48,955.41 | | | | + +--- + +### Asset Allocation + +100% Cash and Short Term + +![](_page_11_Figure_31.jpeg) + +--- + +### Income Summary + +| | This Period USD | Year to Date USD* | +|---------------------------|-----------------|-------------------| +| U.S. Tax Exempt Dividends | 45.70 | 339.04 | +| Total | 45.70 | 339.04 | + +## Cash and Short Term + +### Summary by Maturity + +| | Current Market Value
USD | Estimated Annual Income
USD | +|--------------|-----------------------------|--------------------------------| +| Cash | 48,955.41 | 544.38 | +| Total | 48,955.41 | 544.38 | + +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 + +| Description | Currency | Unit Cost
Adjusted
Original | Market
Price | Tax Cost
Adjusted
Original | Current
Market Value USD
Accrued Interest USD | Unrealized
Gain/Loss USD | Estimated
Annual
Income USD | Current
Yield/
YTM % | +|--------------------------|----------|-----------------------------------|-----------------|----------------------------------|-----------------------------------------------------|-----------------------------|-----------------------------------|----------------------------| +| Cusip/S&P/Moody's Rating | | | | | | | | | + +### Cash + +| JP MORGAN TAX FREE MONEY MARKET | USD | 48,955.41 | 1.00 | 1.00 | 48,955.41 | 48,955.41 | | 544.38 | 1.11 | +|----------------------------------|-----|-----------|------|------|-----------|-----------|--|--------|------| +| PREMIER CLASS SWEEP FUND (92) | | | | | | 43.24 | | | | +| (SWEEP DEADLINE IS 11:30 AM EST) | | | | | | | | | | +| 7-Day Annualized Yield: 1.15% | | | | | | | | | | + +*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.* + +JPMorgan Chase Bank New York, NY 10154-1002 + +Account Number: Asset Account Portfolio JEFFREY EPSTEIN July 01, 2002 - July 31, 2002 + +# Account Transactions + +![](_page_13_Picture_5.jpeg) + +## Cash Activity Summary + +| Beginning Balance Credits | Amount lNS Petted USD .00 | Amount Mar To Dare USD' | +|---------------------------|---------------------------|-------------------------| +| Dividends Debits | 45.70 | 339.04 | +| Sweep Account Purchases | - 45.70 | | +| Ending Balance | .00 | | + +'Year to date information is calculated on a calendar year basis. + +## Activity by Date + +| Settlement | | | | +|------------|----------|------------------------------------------------------------------------------------------------------|------------------| +| Dare | Typo | *ant" Ossalption | Amount USD 45 70 | +| Jul 1 | Dividend | JP MORGAN TAX FREE MONEY MARKET PREMIER CLASS SWEEP FUND (92) (SWEEP DEADLINE IS 11:30 AM EST) | | +| Jul 1 | Purchase | 45.70 JP MORGAN TAX FREE MONEY MARKET PREMIER CLASS SWEEP FUND (92) (SWEEP DEADLINE IS 11:30 AM EST) | - 45.70 | + +Asset Account Portfolio +July 01, 2002 - July 31, 2002 + +Page 1 of 1 + +**In Case of Errors or Questions About Your Electronic Transfers.** + +Contact your Morgan Team at one of the telephone numbers on the front of this statement or write us at ██████████. Newark, DE 19713-2107 as soon as you can, if you think your statement is wrong or if you need more information about a transfer on the statement. We must hear from you no later than 60 days after we sent you the FIRST statement on which the error or problem appeared. (1) Tell us your name and account number. (2) Describe the error or the transfer you are unsure about, and explain as clearly as you can why you believe it is in error or why you need more information. (3) Tell us the dollar amount of the suspected error. If you contact us orally, you must send us your complaint or question in writing within 10 business days in order to preserve your rights. We will investigate your complaint and will correct any error promptly. If we take more than 10 business days to do this (20 days for purchases using your debit card or for international transactions), we will credit your account for the amount you think is in error, so that you will have the use of money during the time it takes us to complete our investigation. + +**In case of errors or questions about your statement, including your line of credit.** + +If you think that your statement is incorrect or if you need more information about a transaction on your statement including a line of credit transaction, you must write to us on a separate sheet describing the error and send it to: JPMorgan, Private Bank, ██████████. 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 respective fund families. Shares of the funds are not bank deposits and are not guaranteed by any bank, government entity, or the FDIC. Return and share price will fluctuate and redemption value may be more or less than original cost. While the money market funds seek to maintain a stable net asset value of \$1.00 per share, there is no assurance that they will continue to do so. The estimated annual income and dividend yield figures for mutual funds represent the funds' most recent income dividend annualized. + +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. + +08 JPMorgan Chase Bank + +2002 New York, NY 10154-1002 + +Account Number JEFFREY EPSTEIN + +![](_page_15_Picture_4.jpeg) + +Confidential Page 1 of 8 + +# Asset Account Portfolio + +August I - August 31, 2002 + +# Table of Contents + +| | Page | +|----------------------|-------------------------| +| Portfolio Summary | 2 | +| Cash and Short Term | 3 | +| Trade Activity | ██████████ | +| Account Transactions | 6 | + +# Account Officers + +Service Specialist: RILEY/HORNBECKER + +0000000000 0000000000~20000000 JEFFREY E EPSTEIN C/O FINANCIAL TRUST COMPANY ATTN: JEANNE BRENNAN ST THOMAS VI 00802 + +**Asset Account Portfolio** +August 01, 2002 - August 31, 2002 + +## Portfolio Summary + +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 of your Asset Account, including mutual funds, are FDIC insured or bank deposits, 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. + +### Overview + +| | Market Value USD
Aug 31 | Market Value USD
Jul 31 | Tax
Cost USD | Estimated Annual
Income USD | Yield
% | +|------------------------------|----------------------------|----------------------------|----------------------|--------------------------------|------------| +| Cash & Short Term | 14,816,643.79 | 48,955.41 | 14,816,643.79 | 207,433.01 | 1.4 | +| Total | 14,816,643.79 | 48,955.41 | 14,816,643.79 | 207,433.01 | 1.4 | +| Accrued Income | 22,043.45 | 43.24 | | | | +| Total Portfolio Value | 14,838,687.24 | 48,998.65 | | | | + +### Asset Allocation + +100% Cash and Short Term + +![](_page_16_Figure_31.jpeg) + +### Income Summary + +| | This Period USD | Year to Date USD* | +|---------------------------|-----------------|-------------------| +| U.S. Tax Exempt Dividends | 43.24 | 382.28 | +| Total | 43.24 | 382.28 | + +08 JPMorgan Chase Bank + +2002 New York, NY 10154-1002 + +Account Number: + +JEFFREY EPSTEIN August 01, 2002 - August 31, 2002 + +### Asset Account Portfolio + +# Cash and Short Term + +![](_page_17_Picture_3.jpeg) + +Page 3 of 8 + +## Summary by Maturity + +| | Current Market Value | Estimated Annual Income | +|--------------------|-----------------------------|--------------------------------| +| Cash | USD | USD | +| Less Than 3 Months | 14,816,643.79 | 207,433.01 | +| Total | 14,816,643.79 | 207,433.01 | + +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 + +| Description CusiraSSP Moody's Rating Cash | Currency | Quantity | Linn Cost atA ct Ongrnal | Tax Cost Market Adjusted Price Original | Current Madre( Value USD Accrued Interest USO | Unteakte4 Gam/Loss USO | Estimated Cuntot Annual Wed Income USD % | +|----------------------------------------------------------------|----------|----------|--------------------------|-----------------------------------------|-----------------------------------------------|------------------------|------------------------------------------| +| JP MORGAN TAX FREE MONEY MARKET | USD | 0 | 1.00 | 1.00 | 0.00 | N/A | 1.09 | +| PREMIER CLASS SWEEP FUND (92) (SWEEP DEADLINE IS 11:30 AM EST) | | | | | 7.09 | | | +| US DOLLAR | USD | 0 | 1.00 | 1.00 | 0.00 | N/A | 1.40 | +| Total Cash | | | | | 0.00 | | N/A | + +**Asset Account Portfolio** +August 01, 2002 - August 31, 2002 + +**Cash and Short Term by Type** continued + +| Description
Cusip/S&P/Moody's Rating | Currency | Quantity | Unit Cost
Adjusted
Original | Market
Price | Tax Cost
Adjusted
Original | Current
Market Value USD
Accrued Interest USD | Unrealized
Gain/Loss USD | Estimated
Annual
Income USD | Current
Yield/
YTM % | +|----------------------------------------------------------------------------------|----------|---------------|-----------------------------------|-----------------|----------------------------------|-----------------------------------------------------|-----------------------------|-----------------------------------|----------------------------| +| Short Term by Maturity | | | | | | | | | | +| J P MORGAN TAX FREE MONEY MARKET
FUND INSTITUTIONAL SHARE CLASS
(FUND 840) | USD | 14,816,643.79 | 1.00 | 1.00 | 14,816,643.79 | 14,816,643.79
21,086.37 | | 207,433.01 | 1.40 | +| 7-Day Annualized Yield: 1.32%
██████████ | | | | | | | | | | +| Total Cash and Short Term | | | | | 14,816,643.79 | 14,816,643.79
22,043.45
| 0.00 | 207,433.01 | 1.40 | + +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. + +**Asset Account Portfolio** +August 01, 2002 - August 31, 2002 + +Page **1** of 8 + +## 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 Date | Settlement Date | Type | Description | Currency | Quantity | Price/Unit | Market Cost/Proceeds | Tax Cost | Realized Gain/Loss USD | +|----------------|-----------------|----------|----------------------------------------------------------------------------|----------|---------------|------------|----------------------|-----------------|------------------------| +| Settled | | | | | | | | | | +| Aug 6 | Aug 6 | Purchase | J P MORGAN TAX FREE MONEY MARKET FUND INSTITUTIONAL SHARE CLASS (FUND 840) | USD | 24,816,643.79 | 1.00 | - 24,816,643.79 | | | +| Aug 28 | Aug 28 | Sale | J P MORGAN TAX FREE MONEY MARKET FUND INSTITUTIONAL SHARE CLASS (FUND 840) | USD | - 10,000,000 | 1.00 | 10,000,000.00 | - 10,000,000.00 | | + +08 JPMorgan Chase Bank + +2002 New York, NY 10154-1002 + +Account Number: Asset Account Portfolio JEFFREY EPSTEIN August 01, 2002 - August 31, 2002 + +# Account Transactions + +![](_page_20_Picture_3.jpeg) + +Page Got 8 + +### Cash Activity Summary + +| Beginning Balance Credits | Amount UMe Pinot! USD .00 | Amount Year to Date USD' | +|-------------------------------|---------------------------|--------------------------| +| Dividends | 43.24 | 382.28 | +| Sweep Account Sales | 48,998.65 | 48,998.65 | +| Sales, Matunbes, Redemptions | 10,000,000.00 | 10,000,000.00 | +| Miscellaneous Receipts Debits | 24,767,645.14 | 24,767,645.14 | +| Sweep Account Purchases | - 43.24 | - 382.28 | +| Purchases of Securities | - 24,816,643.79 | - 24,816,643.79 | +| Miscellaneous Disbursements | - 10,000,000.00 | - 10,000,000.00 | +| Ending Balance | .00 | | + +\*Year to date information is calculated on a calendar year basis. + +## Activity by Date + +| Settlement | | | | | +|------------|----------|--------|------------------------------------------------------------------------------------------------------|------------| +| Date | Type | Dumbly | Deserlption | Amount USD | +| Aug 1 | Dividend | | JP MORGAN TAX FREE MONEY MARKET PREMIER CLASS SWEEP FUND (92) (SWEEP DEADLINE IS 11:30 AM EST) | | +| Aug 1 | Purchase | | 43.24 JP MORGAN TAX FREE MONEY MARKET PREMIER CLASS SWEEP FUND (92) (SWEEP DEADLINE IS 11:30 AM EST) | - 43.24 | + +08 JPMorgan Chase Bank + +2002 New York, NY 10154-1002 + +Account Number: Asset Account Portfolio + +JEFFREY EPSTEIN August 01, 2002 - August 31, 2002 + +![](_page_21_Picture_2.jpeg) + +Page 7 of 8 + +### Activity by Date + +| Sealenteen | | | +|------------|--------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------| +| One | type | | +| | | (Joanna, Desatalon Amounr lISD | +| Aug 5 | Misc. Receipt | FED FUNDS RCVD THRU 24,767,645 14 CITIBANK NEW CASTLE MILLENIUM LP | +| Aug 6 | Purchase | 24,816,643.79 J P MORGAN TAX FREE MONEY MARKET - 24,816,643.79 FUND INSTITUTIONAL SHARE CLASS (FUND 840) J.P.MORGAN SECURITIES INC AS AGENT TRADE DATE 08/06/02 | +| Aug 6 | Sale | - 48,998.65 JP MORGAN TAX FREE MONEY MARKET PREMIER CLASS SWEEP FUND (92) (SWEEP DEADLINE IS 11:30 AM EST) | +| Aug 28 | Sale | - 10,000,000 J P MORGAN TAX FREE MONEY MARKET 10,000,000 00 FUND INSTITUTIONAL SHARE CLASS (FUND 840) J.P.MORGAN SECURITIES INC AS AGENT TRADE DATE 08/28/02 | +| Aug 28 | Misc. Disbursement | FUNDS TRANSFERRED FROM BRKRG - 10,000,000 00 | +| | | AC# (PRN TO | +| | | BRKRG AC (PRN) LETTER FROM CLIENT | + +continued + +08 | 2002 + +JPMorgan Chase Bank +[REDACTED], New York, NY 10154-1002 + +![](_page_22_Picture_21.jpeg) + +Account Number: [REDACTED] +JEFFREY EPSTEIN + +Asset Account Portfolio +August 01, 2002 - August 31, 2002 + +Page 8 of 8 + +**In Case of Errors or Questions About Your Electronic Transfers.** + +Contact your Morgan Team at one of the telephone numbers on the front of this statement or write us at [REDACTED]. Newark, DE 19713-2107 as soon as you can, if you think your statement is wrong or if you need more information about a transfer on the statement. We must hear from you no later than 60 days after we sent you the FIRST statement on which the error or problem appeared. (1) Tell us your name and account number. (2) Describe the error or the transfer you are unsure about, and explain as clearly as you can why you believe it is in error or why you need more information. (3) Tell us the dollar amount of the suspected error. If you contact us orally, you must send us your complaint or question in writing within 10 business days in order to preserve your rights. We will investigate your complaint and will correct any error promptly. If we take more than 10 business days to do this (20 days for purchases using your debit card or for international transactions), we will credit your account for the amount you think is in error, so that you will have the use of money during the time it takes us to complete our investigation. + +**In case of errors or questions about your statement, including your line of credit.** + +If you think that your statement is incorrect or if you need more information about a transaction on your statement including a line of credit transaction, you must write to us on a separate sheet describing the error and send it to: JPMorgan, Private Bank, [REDACTED]. 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 respective fund families. Shares of the funds are not bank deposits and are not guaranteed by any bank, government entity, or the FDIC. Return and share price will fluctuate and redemption value may be more or less than original cost. While the money market funds seek to maintain a stable net asset value of \$1.00 per share, there is no assurance that they will continue to do so. The estimated annual income and dividend yield figures for mutual funds represent the funds' most recent income dividend annualized. + +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. + +2002 New York, NY 10154-1002 + +Account Number. JEFFREY EPSTEIN + +![](_page_23_Picture_4.jpeg) + +Confidential Page 1 of 9 + +# Asset Account Portfolio + +September I - September 30, 2002 + +# Table of Contents + +| | Page | +|----------------------|-------------------------| +| Portfolio Summary | 2 | +| Cash and Short Term | 3 | +| Trade Activity | ██████████ | +| Account Transactions | 6 | + +## Account Officers + +Service Specialist RILEY/HORNBECKER + +ow= 0000 oo oxo aro oc0000000 \*root JEFFREY E EPSTEIN C/O FINANCIAL TRUST COMPANY ATTN: JEANNE BRENNAN ST THOMAS VI 00802 + +**Asset Account Portfolio** +September 01, 2002 - September 30, 2002 + +## Portfolio Summary + +*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 of your Asset Account, including mutual funds, are FDIC insured or bank deposits, 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.* + +### Overview + +| | Market Value USD
Sep 30 | Market Value USD
Aug 31 | Tax
Cost USD | Estimated Annual
Income USD | Yield
% | +|------------------------------|----------------------------|----------------------------|---------------------|--------------------------------|------------| +| 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 | +| Accrued Income | 11,992.75 | 22,043.45 | | | | +| Total Portfolio Value | 6,850,679.99 | 14,838,687.24 | | | | + +### Asset Allocation + +100% Cash and Short Term + +![](_page_24_Figure_31.jpeg) + +### Income Summary + +| | 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 | + +Account Number. + +JEFFREY EPSTEIN September 01, 2002 - September 30, 2002 + +JPMorgan Chase Bank New York, NY 10154-1002 + +![](_page_25_Picture_3.jpeg) + +### Asset Account Portfolio Page 3 of 9 + +# Cash and Short Term + +## Summary by Maturity + +| | Current Starner Value USO | Estimated Annual Income USO | +|--------------------|---------------------------|-----------------------------| +| 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 + +| Description | Currency | Quantity | Unit Cost | Market | Current | Estimated | Tax Cost | Current | Estimated | YTM % | +|--------------------------|----------|----------|-----------|----------|----------|----------------------|---------------|------------|-----------|-------| +| | | | | Adjusted | 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 + +J P 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% + +**Asset Account Portfolio** +September 01, 2002 - September 30, 2002 + +**Cash and Short Term by Type** continued + +| Description | Currency | Quantity | Unit Cost
Adjusted
Original | Market
Price | Tax Cost
Adjusted
Original | Current
Market Value USD
Accrued Interest USD | Unrealized
Gain/Loss USD | Estimated
Annual
Income USD | Current
Yield/
YTM % | +|----------------------------------|----------|----------|-----------------------------------|-----------------|----------------------------------|-----------------------------------------------------|-----------------------------|-----------------------------------|----------------------------| +| Total Cash and Short Term | | | | | 6,838,687.24 | 6,838,687.24 | 0.00 | 109,416.12 | 1.60 | +| | | | | | | | | | | + +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. + +09 JPMorgan Chase Bank + +2002 New York, NY 10154-1002 + +Account Number. Asset Account Portfolio JEFFREY EPSTEIN September 01, 2002 - September 30, 2002 + +# Trade Activity + +![](_page_27_Picture_3.jpeg) + +Pagel of 9 + +## Realized Gain/Loss Summary + +Short Term Gain/Loss Long Term Gain/Loss 0.00 0.00 + +Note: S incicates 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 WA. + +Amount USD + +## Trade Activity by Type + +| Trade | Settlement | | | | | | | +|---------------|------------|----------------------------------|-------|-------------|------|------------------------|--------------------| +| Om | MN Typo | CNUMMM | Gunny | Crummy | | PMWWw kfarteCw0Voceeds | Tax Coil GmitossWO | +| Aug 30 Sep 3 | Purchase | J P MORGAN TAX FREE MONEY MARKET | USD | 21,086.37 | 1.00 | - 21,086.37 | | +| Sep 10 Sep 10 | Sale | J P MORGAN TAX FREE MONEY MARKET | USD | - 2,000,000 | 1.00 | 2,000,000.00 | - 2,000,000.00 | +| Sep 16 Sep 16 | Sale | J P MORGAN TAX FREE MONEY MARKET | USD | - 1,000,000 | 1.00 | 1,000,000.00 | - 1,000,000.00 | +| Sep 18 Sep 18 | Sale | J P MORGAN TAX FREE MONEY MARKET | USD | - 1000,000 | 1.00 | 1000,000.00 | - 1000,000.00 | + +Account Number. + +JEFFREY EPSTEIN September 01, 2002 - September 30, 2002 Asset Account Portfolio Page Got 9 + +JPMorgan Chase Bank New York, NY 10154-1002 + +![](_page_28_Picture_3.jpeg) + +# Account Transactions + +### Cash Activity Summary + +| Beginning Balance Credits Dividends | Amount MS Pena! USD .00 21,093 46 | Amount Year to ate USD' 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 Debits | | 24,767,645.14 | +| 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 | rano | Ouannty | Damnation | Amount USD | +| Sep 3 | Dividend | | JP MORGAN TAX FREE MONEY MARKET PREMIER CLASS SWEEP FUND (92) (SWEEP DEADLINE IS 11:30 AM EST) | | +| Sep 3 | Interest | | AVERAGE COLLECTED BALANCE AS OF 09/01/02 | | + +Account Number. + +JEFFREY EPSTEIN September 01, 2002 - September 30, 2002 + +JPMorgan Chase Bank 2002 New York, NY 10154-1002 + +![](_page_29_Picture_2.jpeg) + +### Asset Account Portfolio Page 7 of 9 + +### Activity by Date + +| Sealentenz | | | | +|------------|--------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------| +| One | TYPe | | | +| Sep 3 | Dividend | Gummy DeSCOMM J P MORGAN TAX FREE MONEY MARKET FUND INSTITUTIONAL SHARE CLASS (FUND 840) | Amount VW 21,086 37 | +| Sep 3 | Purchase | 21,086.37 J P MORGAN TAX FREE MONEY MARKET FUND INSTITUTIONAL SHARE CLASS (FUND 840) INCOME DIVIDEND REINVESTED a \$1.00 J.P.MORGAN SECURITIES INC AS AGENT TRADE DATE 08/30/02 | - 21,086.37 | +| Sep 3 | Purchase | 957.08 JP MORGAN TAX FREE MONEY MARKET PREMIER CLASS SWEEP FUND (92) (SWEEP DEADLINE IS 11:30 AM EST) | - 957.08 | +| Sep 10 | Sale | - 2,000,000 J P MORGAN TAX FREE MONEY MARKET FUND INSTITUTIONAL SHARE CLASS (FUND 840) J.P.MORGAN SECURITIES INC AS AGENT a 1.00 TRADE DATE 09/10/02 | 2,000,000 00 | +| Sep 10 | Misc. Disbursement | TRANSFERRED BY WIRE TO PALM BEACH NATL BK 8 TR CO FAO JEFFREY EPSTEIN LETTER FROM CLIENT | - 2,000,000.00 | +| Sep 16 | Sale | - 1,000,000 J P MORGAN TAX FREE MONEY MARKET FUND INSTITUTIONAL SHARE CLASS (FUND 840) J.P.MORGAN SECURITIES INC AS AGENT a 1.00 TRADE DATE 09/16/02 | 1,000,000 00 | + +continued + +Account Number. + +JEFFREY EPSTEIN September 01, 2002 - September 30, 2002 + +JPMorgan Chase Bank + +![](_page_30_Picture_2.jpeg) + +### Asset Account Portfolio Page Sof 9 + +### Activity by Date + +| Sealenteen | | +|------------|---------------------------------------------------------------------------------------------------------------------------------------------| +| One | type | +| | Gummy Descraalon Amounr USD | +| Sep 16 | Misc. Disbursement TRANSFERRED BY WIRE TO - 1,000,000 00 PALM BEACH NATI BK 8 TR CO FAO JEFFREY EPSTEIN LETTER FROM CLIENT | +| Sep 18 | Sale - 5,000,000 J P MORGAN TAX FREE MONEY MARKET 5,000,000 00 FUND INSTITUTIONAL SHARE CLASS (FUND 840) J.P.MORGAN SECURITIES INC AS AGENT | +| Sep 18 | Misc. Disbursement | +| | a 1.00 TRADE DATE 09/18/02 TRANSFERRED BY WIRE TO - 5,000,000.00 PALM BEACH NATL BK 8 TR CO FAO GHISLAINE MAXWELL LETTER FROM CLIENT | + +continued \ No newline at end of file diff --git a/marker2/ds9/EFTA00087147/EFTA00087147.metadata.json b/marker2/ds9/EFTA00087147/EFTA00087147.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..cada208bd74344f67e4245bec623a5e6185f4a7d --- /dev/null +++ b/marker2/ds9/EFTA00087147/EFTA00087147.metadata.json @@ -0,0 +1,3734 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087147.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 31, + "chars": 64262, + "elapsed_seconds": 28.76, + "image_assets": [ + "_page_0_Picture_4.jpeg", + "_page_1_Figure_31.jpeg", + 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b/marker2/ds9/EFTA00087147/_page_8_Picture_5.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:3af852bf98ad620d3762b047fc30112824ebd3cfba58d3ee5f2d81100d017f79 +size 5159 diff --git a/marker2/ds9/EFTA00087178/EFTA00087178.md b/marker2/ds9/EFTA00087178/EFTA00087178.md new file mode 100644 index 0000000000000000000000000000000000000000..765762903bf7f45f5124b6130d84b2561606bb5f --- /dev/null +++ b/marker2/ds9/EFTA00087178/EFTA00087178.md @@ -0,0 +1,31 @@ +To: Nathan NYSD Chambers < + +Cc: Jeff Pa liuca Laura Mennin + +Subject: [EXTERNAL] U.S. v. Maxwell, Case No. 20 Cr. 330 (AJN) [Maxwell's Resp to Ltr. Moms to Quash EVCP Sub ] + +Date: Mon, 22 Nov 2021 18:40:43 +0000 + +Attachments: 2021.11.22 JSP Letter Response to Motions to Quash.pdf + +Inline-Images: image001.jpg + +Dear Judge Nathan: + +At the request of Jeffrey Pagliuca, please see attached Ms. Maxwell's Response to the Letter Motions to Quash her Rule 17(c) subpoena to the Epstein Victims' Compensation Program. + +Pursuant to our established protocol, we are submitting the Response to the Court under temporary seal to allow the government to propose any redactions it deems necessary. + +Regards, + +Nicole + +![](_page_0_Picture_12.jpeg) + +Nicole Simmons Haddon, Morgan and Foreman, P.C. 150 East 10th Avenue + +Denver, Colorado 80203 + +PH FX + +DIRECT: www.hmflaw.com \ No newline at end of file diff --git a/marker2/ds9/EFTA00087178/EFTA00087178.metadata.json b/marker2/ds9/EFTA00087178/EFTA00087178.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..c1efb0dfaf18bd5913720b947945134fdffa1617 --- /dev/null +++ b/marker2/ds9/EFTA00087178/EFTA00087178.metadata.json @@ -0,0 +1,60 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087178.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 856, + "elapsed_seconds": 0.81, + "image_assets": [ + "_page_0_Picture_12.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 49 + ], + [ + "Line", + 25 + ], + [ + "Text", + 16 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087178" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087178/_page_0_Picture_12.jpeg b/marker2/ds9/EFTA00087178/_page_0_Picture_12.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..60f12512457f567bb2e26acda41bc7e27608a381 --- /dev/null +++ b/marker2/ds9/EFTA00087178/_page_0_Picture_12.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:8777b115adccdd6144a7b6c8cedbcd029836f481355f27ec82df12bc6b357a8e +size 4320 diff --git a/marker2/ds9/EFTA00087179/EFTA00087179.md b/marker2/ds9/EFTA00087179/EFTA00087179.md new file mode 100644 index 0000000000000000000000000000000000000000..aeeddbdee1ee6a1ae9767a89260a3a7a346399db --- /dev/null +++ b/marker2/ds9/EFTA00087179/EFTA00087179.md @@ -0,0 +1,47 @@ +To: " (USANYS)" + +Subject: FW: when does Maxwell's trial start? + +Date: Mon, 22 Nov 2021 20:22:35 +0000 + +Importance: High + +Attachments: NYT\_-\_Epstein\_Qs\_FINAL.docx + +From USANYS) + +Sent: Monday, November 22, 2021 3:20 PM + +To: (USANYS) (USANYS) < + +Cc: ) + +Subject: FW: when does Maxwell's trial start? + +Importance: High + +A little uncertain as to how they felt it'd be okay to give us a two-hour turnaround window on this. But that said, their proposed answers are attached. + +From (PAO) + +Sent: Monday, November 22, 2021 2:52 PM + +(USANYS) + +Subject: RE: when does Maxwell's trial start? + +Hese + +Attached are the proposed answers to the NY Times questions re the documents released in July. + +Let me know if any issues/concerns/edits. Their deadline is 5pm today. + +And if you want any Qs other than this referred to you guys, let me know. + +I need to get back to ODAG before going back to the reporter, so if you can get back to me ASAP that would be a huge help. + +Thank youl + +Spokesperson, Office of Public Affairs + +Department of Justice \ No newline at end of file diff --git a/marker2/ds9/EFTA00087179/EFTA00087179.metadata.json b/marker2/ds9/EFTA00087179/EFTA00087179.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..51fa57fe996c176bb88c707e094dc9dab964b646 --- /dev/null +++ b/marker2/ds9/EFTA00087179/EFTA00087179.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087179.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1029, + "elapsed_seconds": 1.27, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 59 + ], + [ + "Line", + 29 + ], + [ + "Text", + 27 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087179" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087180/EFTA00087180.md b/marker2/ds9/EFTA00087180/EFTA00087180.md new file mode 100644 index 0000000000000000000000000000000000000000..165551f5c266afbf68272ced9b65efb95cfb8008 --- /dev/null +++ b/marker2/ds9/EFTA00087180/EFTA00087180.md @@ -0,0 +1,57 @@ +We also would like to offer BOP a chance to respond to what the documents reveal and any remedial steps that have been taken. + +1. Most centrally, the documents paint a picture of mistakes, sloppiness and even incompetence by some BOP employees in their dealings with Epstein -- such as failing to log/monitor/record social calls, delays in getting him requested psych exams and assessments, multiple inaccuracies in Epstein's intake forms and of not responding to directives to provide him with a cellmate on the night he died. + +The BOP records show Epstein repeatedly assured one or more jail psychologists that he was not suicidal and had a lot to live for. But the records also show BOP officials later concluded that they did not appreciate as quickly as they could have the risk factors for suicide that Epstein's case presented (for example, after his admission and later after he was denied bail.) + +A. Has BOP addressed the problems identified in the BOP records, through policy changes or corrective measures or the training of employees? + +The safe, secure, and humane housing of inmates is BOP's highest priority. While we decline to comment specifically as to any inmate, as a general matter, BOP has launched a task force that will address mental health implications of housing individuals alone in a cell, and is committed to improving its suicide prevention program. In addition, BOP is increasing the number of beds available as secure mental health units, which will support moving inmates with serious mental illness out of restrictive housing and into secure treatment programs. BOP is also taking a number of other steps to address mental health issues, including enhancing peer support programs, and continuing to train BOP staff on suicide prevention, risk assessment, and emergency responses. + +B. Does BOP have any other comment on Epstein's period in its custody and/or his suicide? + +We decline to comment + +In addition, we have listed below 9 specific questions that were prompted by references in the documents. (Please see below) + +## SPECIFIC QUESTIONS + +1. INMATE COMPANIONS: The records show MCC utilized "inmate companions" to observe Mr. Epstein when he was on psychological observation and suicide watch, and to write down what he did or said. Are such "inmate companions" specially trained for this task? And how did they monitor Epstein: watching through a window in his cell door? Entering the cell and sitting with him? + +As found in Program Statement 5324.08 "Suicide Prevention Program" here https://www.bop.gov/policv/progstat/5324 008.pdf and BOP Program Statement 531017 "Psychology Services Manual" here httos://www.boD.gov/Dolicy/Drogstat/5310 017.odf the BOP has an extensive suicide prevention program that begins upon an inmate's arrival at each BOP facility, including pretrial facilities. When inmates report suicidal ideation, or are suspected of being at elevated risk of suicide, a suicide risk assessment is completed consistent with the Bureau suicide prevention policy. + +While we decline to comment specifically as to any inmate, as a general matter, the BOP utilizes inmate companions consistent with the policy Suicide Prevention Program. In some circumstances, inmate companions monitor inmates on suicide watch and provide peer support. They do not have direct + +contact with the inmates they monitor. They are able to observe them and communicate through a window. + +2. DISCIPLINARY ACTION REGARDING HIS SUICIDE ATTEMPT: There are suggestions in the records that Mr. Epstein was subjected to a disciplinary process for his attempted suicide. Is that correct? Was he disciplined in any way? If so, why? Did jail officials not believe his attempt was genuine? Is disciplinary action common after a suicide attempt? BOP provided us with a redacted copy of the incident report, which said Epstein was read his rights with regards to the incident. Does that signify that he underwent a disciplinary hearing? There also are references to the incident as "mutilation." Is discipline a common procedure after a suicide attempt? + +While we decline to comment specifically as to any inmate, as a general matter, the BOP's inmate discipline program is authorized by 18 U.S.C. 4042(a)(3), and can be found on our public website here https://www.bop.gov/policv/progstat/5270.90 cnl.pdf. The provisions outlined in the BOP's inmate discipline program helps ensure the safety, security, and orderly operation of correctional facilities, and the protection of the public. Under Chapter 3 of the policy, inmates are referred to a mental health professional for examination if it appears that an inmate is mentally ill. + +3. BOP produced a record that said the incident report for Jeffrey Epstein's attempted suicide was expunged without explanation. Can you explain what this means or why that was done? + +## Option 1. Decline to comment + +4. THE MCC STRUCTURE: BOP produced a record that quoted Jeffrey Epstein as asking an inmatecompanion: "Who's the best cook on 11 North?" Was there a kitchen on 11 North in the MCC? Press accounts describe the MCC as 12 stories tall -- is that correct? + +MCC New York is a 12-story administrative facility. There is a kitchenette on the 11th floor where inmates are able to prepare and consume items from the commissary. + +5. THE SIGN: BOP produced to us one document, labeled "sign", which appears to have been posted somewhere in the jail. We have attached it as a PDF to this email and we would like to know the circumstances of its creation and posting. Was it posted in the jail, where was it put up, and by whom? Do you know who created it and posted it? And do you know the circumstances of the handwritten graffiti on it (the word "mandator( is underlined and there is a question mark after it. The sign refers to "GOD: Does BOP know who, in the context of the sign, GOD refers to? + +We cannot speak to the validity or origination of the signage. + +6. PHONE CALLS: The BOP records conflict in stating the number of social calls Epstein was known to have made. Some records indicate he made 2 and another suggests he made 3. Does BOP know how many social calls Epstein made? Were any of the social calls monitored or recorded by BOP? + +We respectfully decline to comment + +7. PHOTOS OF EPSTEIN WHILE ON SUICIDE WATCH - The inmate companion logs provided by BOP reflected that on two occasions, a jail officer took a photo of Epstein at in his cell. Is it common or proper for inmates on suicide watch to be photographed? Did this violate any rule? + +While we decline to comment specifically as to any inmate, as a general matter, inmate photography is not prohibited in all instances, but there may be circumstances where photography is needed to document events or actions. + +8. CLOSURE OF MCC: Did the irregularities and errors by BOP employees in the lead-up to Epstein's death play any part in the decision to close the MCC earlier this fall? If so, please explain. + +The Department of Justice is committed to ensuring that every facility in the federal prison system is not only safe and secure, but also provides people in custody with the resources and programs they need to make a successful return to society after they have served their time. As part of this effort, the Bureau of Prisons has assessed steps necessary to improve conditions at the Metropolitan Correctional Center (MCC) in New York City. In an effort to address the issues at MCC NY as quickly and efficiently as possible, the Department decided to close the MCC, at least temporarily, until those issues have been resolved. + +9. PSYCH EVALUATIONS: The records show that when Epstein arrived at the MCC, a BOP employee recommended he be evaluated by the psychology department. That was delayed until the following day. Soon after, on July 8, there was another recommendation that he be evaluated for suicide risk. That assessment was delayed until July 9. Are these delays normal? + +While we decline to comment specifically as to any inmate, as a general matter, individuals are commonly referred to Psychology Services upon their arrival. 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NATHAN, United States District Judge: + +WHEREAS the Court has ordered that certain witnesses will be permitted to testify either using pseudonyms or only using first names (the "Protected Witnesses"). See 11/01/21 Tr. at 11:13-17); + +WHEREAS to effectuate that order, it is necessary to prohibit courtroom sketch artists from drawing exact likenesses of the Protected Witnesses; + +IT HEREBY IS ORDERED: + +1. That courtroom sketch artists - whether in the courtroom or overflow rooms - may not draw exact likenesses of the Protected Witnesses; and + +2. For avoidance of doubt, courtroom sketch artists may confer with the Court or counsel for either party to determine whether a witness is a Protected Witness. + +SO ORDERED: + +Dated: New York, New York +November 18, 2021 + +![]() + +--- + +HONORABLE ALISON J. NATHAN +United States District Judge \ No newline at end of file diff --git a/marker2/ds9/EFTA00087183/EFTA00087183.metadata.json b/marker2/ds9/EFTA00087183/EFTA00087183.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..8a1ff186edfd2c32a095780f4d2f786bd5034790 --- /dev/null +++ b/marker2/ds9/EFTA00087183/EFTA00087183.metadata.json @@ -0,0 +1,92 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087183.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 1210, + "elapsed_seconds": 4.56, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 17 + ], + [ + "PageFooter", + 4 + ], + [ + "PageHeader", + 2 + ], + [ + "Form", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 23 + ], + [ + "Line", + 11 + ], + [ + "Text", + 8 + ], + [ + "PageFooter", + 4 + ], + [ + "PageHeader", + 2 + ], + [ + "Caption", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087183" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087185/EFTA00087185.md b/marker2/ds9/EFTA00087185/EFTA00087185.md new file mode 100644 index 0000000000000000000000000000000000000000..4c182b384cc9dc680c0c4d441ce8dd05b7a2c6b1 --- /dev/null +++ b/marker2/ds9/EFTA00087185/EFTA00087185.md @@ -0,0 +1,397 @@ +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +precluding the term "victim" is both unnecessary and impractical. United States v. Dupigny, 18 CR 528, transcript of October 17, 2019, Docket No. 198 at 50. It is appropriate for the government to use the terms as representative of its litigating position. If the government does this in any way that is atypical or unduly prejudicial, I will revisit. + +Defense only cites out-of-circuit or state court decisions for the proposition that those terms are inherently prejudicial and harm the presumption of innocence. Numerous courts of appeal disagree with that argument, particularly when the presentation of evidence and the court's instructions "taken as a whole clarify the government's burden of proving all elements of the crime." United States v. Washburn, 444 F.3d, 1007, 1113 (8th Cir. 2006); see also, Server v. Mizell, 902 F.2d 611, 615, (7th Cir. 1990); United States v. Granbois, 119 F.App'x 35, 38-39 (9th Cir. 2004). + +Defendant's lone district court opinion does not tip the balance of this authority. I will, of course, instruct the jury repeatedly that the defendant is presumed innocent and that it is the government's burden and the government's burden alone to prove guilt beyond a reasonable doubt. Those instructions will eliminate any potential prejudice. See again Judge Furman's decision in Dupigny, Docket No. 198 at 49 + +That matter resolved, I will turn to the government's first motion. This goes to pseudonyms. The government moves + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +pursuant to the Crime Victims Rights Act, 18 USC Section 3771, to permit certain witnesses and certain non-testifying witnesses to be referred to by pseudonyms. And there is also the issue of redacting related exhibits that contain the names or specifically identifying information. Specifically, the government requests that eight individuals be referred to by pseudonyms or their first name. + +The defense is already aware of the identities of all of these individuals, and as the government proposes it, the jury will also be aware of the individuals' real identities. The request only implicates how those individuals are referred to in open court. + +This is well-tread territory, and I will grant the request for the following reasons: + +The burden to justify this type of request, of course, starts with the government. It "must provide a reason for the limitation." United States v. Marcus, which is 2007 WL 330388 at \*1, an Eastern District decision citing United States v. Marti, 421 F.2d 1283 (2d Cir. 1970). + +I agree with the government that limiting disclosure here would protect the alleged victims from potential harassment from the media and others, undue embarrassment and other adverse consequences. The Court has an obligation under the Crime Victims Rights Act to take certain measures at trial to protect the dignity and privacy of alleged victims. 18 USC + +4 + +5 + +6 + +7 + +8 + +9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Let me give a bit of a string cite here. See, for example, United States v. Kelly, No. 19 CR 286, which is a high publicity trial involving adults testifying about sex abuse as minors, and that's in the Eastern District of New York; United States v. Raniere, No. 18 CR 204, a high-publicity trial involving at least one adult testifying about sex abuse as minor; United States v. Dupigny, No. 18 CR 528, involving sex trafficking, United States v. Kelly, No. 7 CR 374, and that could be found at 2008 WL 5068820, which is an Eastern District case involving an adult testifying about sex abuse as a minor; United States v. Graham, No. 14 CR 500, found at 2015 WL 6161292 (S.D.N.Y., October 2015), that involved adults testifying about sex trafficking as minors; United States v. Gardner, No. 16 CR 20135, found at 2016 WL 5404207, an Eastern District case from 2016 involving adults and adults testifying about sex abuse as a minor, and collecting similar cases. + +25 + +Section 3771(a)(8). + +It is quite common for alleged victims, both in cases that have garnered media attention and those involving allegations of sex abuse, to testify or be referred to by pseudonyms or first names. Courts have allowed this whether or not the alleged victims are minors or adults or adults testifying about abuse that allegedly occurred when they were minors. + +The practice has been widely permitted because + +requiring alleged victims to publicly provide their names could chill their willingness to testify for fear of having their personal histories publicized. Raniere, Docket No. 622 at 32. + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +Given the sensitive and inflammatory nature of the conduct alleged, such publicity may cause further harassment or embarrassment, and other alleged victims of sex crimes may be deterred from coming forward. See, Martinez, 17 CR 281, (E.D.N.Y. 2017), Docket No. 34. + +Limiting the disclosure of alleged victims' identities in this case furthers these important interests. The same is true with the identities of certain witnesses, although not alleged victims themselves, because the disclosure of their identities would necessarily reveal the identities of the alleged victims. + +I'm not persuaded by defense counsel's arguments to the contrary. First, the defense notes that Ms. Maxwell does not pose a threat to any of the witnesses. That is plainly true, and the government does not argue or suggest or allege otherwise, but just because that reason for limiting disclosures is absent in this case does not eliminate the possibility of other justifications. And again, there is a need here to prevent undue embarrassment, harassment from the press and third parties, and any resistance of others to come forward and report alleged abuse. Cases establish that this is sufficient + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +Moreover, any potential prejudice in this regard can be cured with an appropriate instruction explaining that the reason for the precaution is regard for the witnesses' and alleged victims' privacy, and that no inference can or should be drawn against the defendant because of these precautions + +My colleagues in this district and elsewhere have used such an instruction in similar cases. The defense's concern that this sort of instruction affords "Court-sanctioned sympathy and credibility" is unfounded. My instructions on the law will clearly and repeatedly instruct the jury on the presumption of innocence and their sole role in assessing witness credibility + +Nor am I persuaded by the defense's arguments that the fact that some alleged victims have previously publicly disclosed some of their allegations obviates the need to limit disclosure. As another district court has held, "just because some victims' names are publicly available does not mean that the details of their experience are already available." Raniere, Docket No. 662 at 34, n. 17 + +As I acknowledged in my protective order for this case, "Not all accusations and public statements are equal. Deciding to participate in or contribute to a criminal investigation or prosecution is a far different matter than simply making a public statement relating to Ms. Maxwell or Jeffrey Epstein." Docket No. 37 in this case at 2. + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +The government anticipates that the alleged victims will "testify in explicit detail and/or be the subject of highly sensitive and personal testimony concerning illegal sexual abuse. Thus, there's good reasons to limit public disclosure of their names and specifically identifying information during trial in this highly publicized case involving highly sensitive issues." + +Since there is a valid reason to limit disclosure in this case, the defense must proffer a particularized need for the disclosure of the relevant information, which is weighed against the risks to the witnesses. I'll cite here, for example, United States v. Marcus, again citing the Second Circuit case in United States v. Marti. + +As both parties acknowledge, the government's request potentially implicates the defendant's right under the Sixth Amendment's confrontation clause which guarantees defendants the right to cross-examine adverse witnesses. The Second Circuit has identified two central interests defendants have in the public airing of identifying information about witnesses. Again referencing the Marti case, 421 F.2d 1263. + +The first is not relevant here because, as I have noted, the defense is aware of the alleged victims' and witnesses' identities. + +The defendant argues that the second interest, however, is implicated. Namely, defense may need the witness + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +to reveal identifying information because knowledge of that information by the jury might be important to its deliberations as to the witness's credibility or knowledgability. That's quoting the Marti case again. In particular, the defense argues that revealing the alleged victims' and witnesses' identities is necessary to probe the nature of the alleged victims' occupations as relevant to the credibility and elicit certain impeachment evidence. + +I agree that such cross-examination cannot be unduly limited and the government concedes the same. The government's motions in limine 15, n. 6; government reply at 17 to 18. And I will ensure that it is not. + +My decision today grants the government's request to limit the public disclosure of the alleged victims and some witnesses' names and other specifically identifying information, such as the specific names of current and past employers, names of family members and addresses. + +Limiting disclosure of the specifically identifying information does not limit the anticipated cross-examination that the defense described in its papers. All lines of inquiry the defense outlined in its response are available without disclosing specific names of employers or other specifically identifying information. For example, the defense can probe the genre, nature, and trajectories of witnesses' careers without eliciting the specific employer name, but the defense's + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +cross-examination should not include specifically identifying information, and counsel must act responsibly doing so. If, after good faith effort in that regard is made and the defense at some point feels they have hit a wall and can articulate a specific need with respect to a particular line of questioning, they can reraise the issue with opposing counsel and with me. + +So that's my ruling on that motion. That said, I do strongly encourage the government to speak candidly with the anticipated witnesses so that they're clear eyed about what this process will entail, the fact that cross-examination will not be curtailed beyond the specific identifying information that form the basis of the government's request, and the possibility that despite these measures their identities may become known and revealed to the public. + +Should any of those witnesses or the government choose not to proceed by pseudonym, the government shall let defense counsel and the Court know. In the meantime, the government and defense counsel shall confer about names that will be used and any additional process for facilitating the clear presentation of evidence. The Court will adopt a clear and straightforward approach and the parties are admonished to come to agreement on the use of pseudonyms and/or first names. + +First assignment, there will be others, by November 10 the parties shall submit a joint letter to the Court under seal explaining the nomenclature that they propose be employed with + +4 5 6 7 As I mentioned, I do agree with the government that limiting instruction explaining the reasons for the precautions is appropriate. In light of my ruling, I expect the parties to confer and jointly propose such a limiting instruction. Homework No. 2. This shall also be filed jointly by November 10, and that can be filed on ECF. + +8 9 10 11 12 13 14 There are some logistics of voir dire related to this. Some of my colleagues have used the list method that the government proposes on page 15, footnote 5 of their motion, and I agree that this proposal makes sense. Once again, the parties shall confer and submit on ECF by November 10 a joint proposal for any logistical issues related to this for voir dire. + +15 16 17 18 19 20 21 22 23 That leaves the issue of sealing unredacted exhibits and the limited redacting of exhibits containing specific personal identifying information. The government shall manage the logistics of this process throughout trial. So think through and include in your November 10 submission on ECF the specifics of this part of the process so that the trial exhibits can be contemporaneously marked with the appropriate limited redactions, and the government will need to manage this on an ongoing basis throughout trial. + +24 25 Government's motion 2, the alleged victims' prior consistent statements. 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Nathan United States District Court Southern District of New York United States Courthouse + +November 10, 2021 + +The parties are ORDERED to submit the lists referenced in this letter on or before November 14, 2021, in accordance with Dkt. No. 427. The parties may continue submitting proposed redactions in accordance with the procedures this Court has previously set. SO ORDERED. + +Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) + +Dear Judge Nathan: + +At the November 1, 2021 pretrial conference, the Court directed the parties to file a joint letter regarding protections for witness identities at trial. In particular, the Court directed the parties to: (I) provide nomenclature for witnesses whose identities should be protected, (2) propose procedures for voir dire related to witness identities, (3) submit a proposed instruction to the jury regarding witnesses testifying under pseudonyms or under their first name only, and (4) address the logistics of offering sealed or redacted exhibits containing personal identifying information. Below are the positions of the parties regarding these logistical considerations. Because this letter contains identifying information relating to victims, the Government respectfully requests that the Court accept the Government's proposed redactions to this letter. + +## Government position: + +## I. Nomenclature + +With respect to nomenclature for witnesses whose identities should be protected at trial, the Government respectfully submits the following chart, which provides the true names of witnesses and the proposed nomenclature for those witnesses at trial. + +AI 11/11/21 + +![](_page_1_Picture_2.jpeg) + +The Government submits that this nomenclature can be used when trial begins on November 29, 2021, but that the parties should be directed to continue referencing victims and witnesses on the public record according to the nomenclature in the Superseding Indictment. The Government further requests that the defense be directed to redact the true names of the witnesses in this chart from all exhibits to filings, and to avoid using the true names of victims in filings with the Court. Using the true names of victims delays public filings and creates otherwise unnecessary redaction projects that waste the Government and the Court's time. Moreover, using victim names in filings increases the risk that victim identities may become public, due to redaction errors or other issues. + +# II. Voir Dire + +Regarding voir dire, the Government proposes that prospective jurors be handed a sheet with a list of names and places that may come up at trial. That sheet, which would be filed under seal. would contain the true names of witnesses. The sheet would not be read aloud; instead, the + +Government requests that the Court direct prospective jurors to read the sheet and to raise a hand if they are familiar with the witnesses or locations. Examination of jurors on this subject would then be conducted at sidebar, with the transcript redacted to remove witness identifying information. + +[REDACTED] + +**III. Limiting Instruction** + +The Government requests that the Court give the jury an instruction that is similar to the instruction Judge Garaufis gave the jury in *United States v. Raniere*, 18 Cr. 204 (E.D.N.Y.). In that case, Judge Garaufis instructed the jury: + +You may have noticed during yesterday's testimony that the witness used first names of certain individuals. That is because the names of certain alleged victims are being withheld from the public and the press to protect the privacy of those individuals. I have therefore instructed the parties to refer to those individuals by their first names only; however, those full names are known to the Government, the defendant, and to the Court. + +An excerpt of the relevant transcript is enclosed as Exhibit A. Here, the Government proposes that the Court instruct the jury: + +At this trial, certain witnesses will be testifying under their first name only. Other witnesses will be testifying under pseudonyms – that is, under different names. That is because the names of certain alleged victims and related witnesses are being withheld from the public and the press to protect the privacy of those individuals. I have therefore instructed the parties to refer to those individuals by their first names only, or in some instances, by using a pseudonym. However, the full names of the witnesses are known to the Government, the defendant, and to the Court. + +prejudice to the defendant, as the instruction makes clear to the jury that the identities of the witnesses are being protected from the public and press only, and that the true names of the witnesses are known to the Government, the Court, and the defendant. + +# IV. Sealed and Redacted Exhibits + +The Government anticipates offering certain exhibits entirely under seal or with redactions to protect the personal identifying information of witnesses and third parties. With respect to logistics, the Government would propose submitting redacted versions of exhibits — along with an index noting which of the Government exhibits will be offered under seal — no later than November 29, 2021. To the extent the defense takes issue with the sealing requests or the proposed redactions, the Court may rule on those exhibits on case-by-case basis during the trial. + +The Government has considered how best to publish sealed exhibits to the jury while protecting the identities of witnesses and the privacy of third parties. On that score, the Government is mindful that exhibits published in electronic format on screens in the courtroom may be seen by the public, since the screens at counsel table — and potentially the jury box— are visible to the public from certain angles. For this reason, the Government requests permission to provide jurors with individual binders containing sealed exhibits. The Government expects that jurors will follow the Court's instruction to only view items in the binder when the Court instructs jurors to do so. + +**Defense position:** + +In light of the Court's ruling on the government's motion in limine, the defense will accept the government's proposed nomenclature for the witnesses referenced above. The defense has no objection to the procedures proposed by the government for voir dire and for sealing and redacting exhibits on the understanding that the defense will have the opportunity to object to particular sealing and redaction requests. The defense also proposes the following limiting instruction in place of the government's proposed instruction: + +This case has received, and will continue to receive, significant attention in the media. To minimize the inconvenience and potential harassment of any witness, the Court has permitted witnesses, if they choose, to be referred to by either their first name or a pseudonym. However, the full names of the witnesses are known to the Government, the defendant, and to the Court, and were shown to you during jury selection. This process should not bear in any way on your evaluation of the evidence in this case. + +Respectfully submitted, + +[REDACTED] + +United States Attorney + +By: s/ + +[REDACTED] + +Assistant United States Attorneys +Southern District of New York + +Cc: Defense Counsel (By email) + +1 2 3 4 5 6 the aspects of the motion we filed, and I think it's a lot for the Court to have to deal with, quite frankly, and I know the Court is going to try and do the best it can with the situation, but I don't think it's tenable and -- I don't ask for mistrials easily, I have probably asked for four in my entire career, I don't see a way out of this problem. + +7 (Pause.) + +8 9 10 11 12 13 14 15 16 17 18 19 THE COURT: All right, I'm going to deny the defendant's motion for a mistrial. Any issues caused by a witness referring to certain individuals by their first name only and by asking the Government if they may use last names of certain other individuals can be cured by a jury instruction, which I will give. Going forward, the Government shall provide the defendant and each witness, including the current witness, with a list of the individuals whose identity should be protected from the public and the press, that way each witness can refer to the list rather than asking the Government whether a particular individual's identity is protected. + +20 You don't have a proposed jury instruction. + +21 MS. PENZA: Not yet, Your Honor. + +22 THE COURT: I have one. + +23 24 25 To the jurors: You may have noticed during yesterday's testimony that the witness used first names of certain individuals. That is because the names of certain + +# Proceedings 245 + +1 2 3 4 5 alleged victims are being withheld from the public and the press to protect the privacy of those individuals. I have therefore instructed the parties to refer to those individuals by their first names only; however, those full names are known to the Government, the defendant, and to the Court. + +6 7 8 9 10 You may also have noticed that the witness was asking the Government whether she should say the last names of certain individuals. Going forward, the witnesses will receive a list of the individuals whose last names are to be protected to which they may refer while testifying. + +11 Anything else you want me to put in there? + +12 MS. PENZA: Not from the Government Your Honor. + +13 THE COURT: You object? + +14 MR. AGNIFILO: I do, Judge. + +15 THE COURT: Your objection is noted. + +16 17 18 Also, I'm going to direct that the parties shall not make any speaking objections. If the basis for an objection is not apparent, the parties may request a sidebar. + +19 MR. AGNIFILO: Very good. Thank you, Judge. + +20 THE COURT: Okay, what else? + +21 22 23 MS. 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NATHAN, District Judge: + +On November I, 2021, the Defense noticed eight expert witnesses. Dkt. No. 418-1. On November 15, 2021, the Government filed a motion to preclude the testimony of six of the experts. See id. The Defense filed a response on November 19, 2021, and the Government filed a motion for leave to file a reply on November 22, 2021.1 The moving papers have been filed temporarily under seal to permit the parties the opportunity to propose sealing or limited redactions in accordance with Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). + +In two Memorandum Opinions and Orders temporarily filed under seal, the Court GRANTS the Government's motion to preclude as to Dr. Ryan Hall's testimony and GRANTS the Government's motion to preclude as to Bennett Gershman's testimony. + +The Court will send the temporarily sealed Memorandum Opinions and Orders to the parties. By November 24, 2021, the parties are ORDERED to inform the Court whether either seeks sealing or limited redactions of the Memorandum Opinions and Orders, justifying any such request by reference to the three-part test articulated by the Second Circuit in Lugosch v. + +The Court denies the Government's request to file a reply because the Government's motion to preclude and the Defendant's response are sufficient for this Court to rule on the motion. + +*Pyramid Co. of Onondaga*, 435 F.3d 110 (2d Cir. 2006). In addition, by that date, the parties are FURTHER ORDERED to file any proposed redactions to the moving papers and/or supporting exhibits on the public docket, again justifying any such request by reference to the *Lugosch* test. + +SO ORDERED. + +Dated: November 22, 2021 +New York, New York + +![]() + +--- + +ALISON J. 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NATHAN, District Judge: + +The Defense on November 1, 2021, noticed eight expert witnesses. Def. Br., Ex. 1 ("Notice"). Two of those experts, Dr. Park Dietz and Dr. Elizabeth Loftus, are expected to offer opinions that rebut opinions of the Government's expert witness, Dr. Lisa Rocchio. The Government on November 8, 2021, filed a motion to partially preclude the testimony of Dr. Dietz and Dr. Loftus. Dkt. No. 424. The Court has already addressed that motion. + +On November 15, 2021, the Government moved to fully or partially preclude the testimony of the remaining six experts. The Defense filed a response on November 19, 2021. + +The Court addresses the motion to preclude Dr. Hall in this separate opinion. It will address the other five experts in public rulings. + +### I. Legal standard + +Federal Rule of Evidence 702 governs the admissibility of expert testimony. That rule states: + +A witness who is qualified as an expert by knowledge, skill, experience, training, or education may testify in the form of an opinion or otherwise if: + +- (a) the expert's scientific, technical, or other specialized knowledge will help the trier of fact to understand the evidence or to determine a fact in issue; +- (b) the testimony is based on sufficient facts or data; +- (c) the testimony is the product of reliable principles and methods; and +- (d) the expert has reliably applied the principles and methods to the facts of the case. + +The Court exercises a "gatekeeper function" in assessing the admissibility of expert testimony. Restivo v. Hessemann, 846 F.3d 547, 575 (2d Cir. 2017). To determine whether an expert's method is reliable, the Court considers the non-exhaustive list provided by the Supreme Court in Dauber!, including whether the expert's method has been tested, whether it has been subjected to peer review, the rate of error, standards controlling the method's operation, and whether the method is accepted by the expert community. United States v. Kidd, 385 F. Supp. 3d 259, 263 (S.D.N.Y. 2019) (citing Dauber! v. Merrell Dow Pharms., Inc., 509 U.S. 579, 593-94 (1993)). + +But Rule 702 ultimately sets a "liberal" and "permissive" standard of admissibility. Nimely v. City of New York, 414 F.3d 381, 395-96 (2d Cir. 2005). In particular, not every expert admissible under Daubert need rely on a method that conforms with "the exactness of hard science methodologies." E.E.O.C. v. Bloomberg L.P., No. 07-CV-8383 (LAP), 2010 WL 3466370, at \*13-14 (S.D.N.Y. Aug. 31, 2010) (quoting United States v. Simmons, 470 F.3d 1115, 1123 (5th Cir. 2006)). + +Additionally, the procedure for disclosing expert witnesses is governed by Federal Rule of Criminal Procedure 16. That rule states that when the Government makes a request, the Defense "must ... give to the government a written summary of any testimony that the defendant intends to use under Rules 702... . This summary must describe the witness's opinions, the bases and reasons for those opinions, and the witness's qualifications." Fed. R. + +Crim. P. 16(b)(1)(C). The purpose of this rule is to "minimize surprise that often results from unexpected expert testimony, reduce the need for continuances, and to provide the opponent with a fair opportunity to test the merit of the expert's testimony through focused cross-examination." Fed. R. Civ. P. 16(b)(1)(C) advisory committee's note to 1993 amendment. Thus, to satisfy Rule 16, a notice must not merely describe the "general topics" on which experts will testify but actually "summarize the experts' opinions about those topics" and "describe the bases for the experts' opinions." United States v. Ulbricht, 858 F.3d 71, 115 (2d Cir. 2017) (emphasis added); United States v. Valle, No. 12-CR-847 (PGG), 2013 WL 440687, at \*5 (S.D.N.Y. Feb. 2, 2013) ("Merely identifying the general topics about which the expert will testify is insufficient; rather, the summary must reveal the expert's actual opinions."). + +If the Defense's disclosure of an expert witness does not satisfy Rule 16, the Court has "broad discretion" to fashion an appropriate remedy. Ulbricht, 858 F.3d at 115. That discretion is guided by factors including "why disclosure was not made, the extent of the prejudice, if any, to the opposing party, the feasibility of rectifying that prejudice by a continuance, and any other relevant circumstances." Id. (quoting United States v. Lee, 834 F.3d 145, 159 (2d Cir. 2016)). When a disclosure merely lists general topics on which the expert might testify, the Second Circuit has several times held that the district court has discretion to exclude the expert entirely. See id. at 118; United States v. Vaccarelli, No. 20-3768-CR, 2021 WL 4805218, at \*2 (2d Cir. Oct. 15, 2021). + +# II. Discussion + +As a preliminary matter, the Defense argues that the Government's motion is "premature" because the Government's arguments are about the relevance and prejudice of the witnesses' testimony, not their qualifications or the reliability of their methods under Rule 702. Def. Br. at 1,5-6. But one aspect of the Rule 702 and Daubert inquiry is "fit," which asks "whether expert testimony proffered in the case is sufficiently tied to the facts of the case that it will aid the jury in resolving a factual dispute." Alto v. Sun Pharm. Indus., Inc., No. 1:19-CV-09758 (GHW), 2021 WL 4803582, at \*3 (S.D.N.Y. Oct. 13, 2021) (quoting Daubert, 509 U.S. at 591). Fit is satisfied if the expert's opinion would assist the jury's decision on a relevant question of fact without "usurp[ing] either the role of the trial judge in instructing the jury as to the applicable law or the role of the jury in applying that law to the facts before it." Id. (quoting United States v. Duncan, 42 F.3d 97,101 (2d Cir. 1994)). The Court finds that at least some of the Government's arguments that go to fit are ripe for preliminary resolution now. Other aspects of the Government's motion can be resolved only with additional information and the context of trial. + +## A. The Court will preclude the expert testimony of Dr. Ryan Hall + +The Government moves to preclude the expert testimony of Dr. Ryan Hall. Dr. Hall was retained by Jeffrey Epstein to evaluate Alleged Victim 4, which Dr. Hall did in 2009, in connection with Alleged Victim 4's civil suit against Epstein. Epstein admitted liability for sexually abusing Alleged Victim 4 and the dispute was about the extent of damages only. Dr. Hall issued a report in 2009 that summarized his interview with Alleged Victim 4 and came to several conclusions about her mental health. The Defense anticipates that Dr. Hall will testify as to approximately four opinions. First, "[h]e will offer the opinions and diagnoses contained in his report." Notice at 12. Second, he will testify on "the bases for those opinions[ and the significance of the diagnoses and opinions." Id. Third, "[h]e will testify about the facts and circumstances surrounding the evaluation" and "disclosures made [Alleged Victim 4]." Id. And fourth, he will testify to "the fact that [Alleged Victim 4] did not identify Ms. Maxwell as a perpetrator of any abuse." Id. + +The Government argues, and the Court agrees, that the first two opinions based on Dr. Hall's training and experience as a psychiatrist and so are expert opinions subject to Rule 702. The latter two opinions are not expert opinions but instead testimony of fact that may or may not be admissible under other rules of evidence. + +The Court will address the expert opinions first. The Government argues that Dr. Hall's testimony on psychological diagnoses is irrelevant and prejudicial under Rules 401 and 403. The Second Circuit has set out controlling case law to guide the Court's decision: + +Evidence of a witness's psychological history may be admissible when it goes to her credibility. In assessing the probative value of such evidence, the court should consider such factors as the nature of the psychological problem, the temporal recency or remoteness of the history, and whether the witness suffered from the problem at the time of the events to which she is to testify, so that it may have affected her ability to perceive or to recall events or to testify accurately. + +United States v. Sasso, 59 F.3d 341,347-48 (2d Cir. 1995) (cleaned up); see also United States v. Hamlett, No. 19-3069,2021 WL 5105861, at \*2 (2d Cir. Nov. 3,2021); United States v. Vitale, 459 F.3d 190, 196 (2d Cir. 2006). + +Even if psychological history is probative according to these factors, the Court still retains discretion to exclude the evidence if it is substantially prejudicial under Rule 403. Sasso, 59 F.3d at 347-48. + +Dr. Hall's report lists the following diagnoses: narcissistic personality disorder, borderline personality disorder, oppositional defiant disorder, depression, bulimia, and polysubstance abuse and dependence. Gov't Br., Ex. B ("Report") at 93-98,104-06. The report also considers, but apparently rejects, diagnoses for bipolar disorder, anxiety disorder, and posttraumatic stress disorder. Id. at 93-94. But see id. at 107 (listing bipolar disorder). Dr. Hall concluded that Epstein's conduct was responsible for "0-5%" of Alleged Victim 4's "total psychiatric picture." Id. at 108. + +The Court will preclude Dr. Hall's testimony on these psychological diagnoses. + +Applying the considerations in Sasso, the diagnoses have little probative value. First, the report is now over 12 years old. Courts in this circuit regularly find that diagnoses more than 10 years old lack probative value. E.g., United States v. Bari, 750 F.2d 1169, 1179 (2d Cir. 1984) (finding that more than 10 years is too remote); United States v. Glover, 588 F.2d 876, 878 (2d Cir. 1978) (per curiam) (12 years too remote); United States v. Dupree, 833 F. Supp. 2d 255, 264 (E.D.N.Y. 2011), vacated and remanded on other grounds, 706 F.3d 131 (2d Cir. 2013) (13 years too remote); United States v. Paredes, No. 99-CR-290 (PKL), 2001 WL 1478810, at \*1 (S.D.N.Y. Nov. 20, 2001) ("A psychological condition from ten years earlier, however, is likely to be irrelevant."). The diagnoses are therefore too remote to bear on Alleged Victim 4's credibility as a witness at trial. + +Second, the nature of the conditions and their effect on memory or perception at the time of the events in question do not favor admission. Dr. Hall's report does not delineate clearly which conditions existed at the time of Epstein's abuse, but it appears that at least the oppositional defiant disorder, depression, and substance abuse predate the conduct alleged in the Indictment. Report at 104-05. But at no point in his report does Dr. Hall suggest that these conditions—or any other diagnosed conditions—may have affected Alleged Victim 4's perception of events or her recollection of those events. Like in Sasso, "there was no indication that [the witness] was delusional or paranoid, or had any difficulties in memory or perception." 59 F.3d at 348. + +In its response, the Defense homes in first on narcissistic personality disorder. Def. Br. 8-9. Dr. Hall reports that individuals with this diagnosis "believe their needs are special and beyond the ken of ordinary people," have "a sense of entitlement and unreasonable expectations of favorable treatment," "expect to be given whatever they want or feel they need, no matter what it might mean to others," and "form friendships or romantic relationships only when other people seem to advance their purposes." Report at 94-95. But none of these traits affect memory or recall, which is the primary purpose for admitting evidence of mental conditions identified in Sasso, 59 F.3d at 348. + +The Defense also emphasizes the diagnosis for borderline personality disorder. Def. Br. at 9-10. Individuals with the disorder "are very sensitive to environmental circumstances and may experience intense abandonment fears and inappropriate anger, even when faced with realistic time limited separation," they "have a pattern of unstable and intense relationships," including "sudden and dramatic shifts concerning their perceptions of others, who are alternately seen as beneficent supporters or cruelly punitive." Report at 95-96. But based on the current record, Dr. Hall's description falls short of demonstrating that this disorder "affect[s] her ability to perceive or to recall events or to testify accurately." Vitale, 459 F.3d at 196 (quoting Sasso, 59 F.3d at 348); see United States v. Lopez, 611 F.2d 44,45 (4th Cir. 1979) ("[M]any psychiatric problems ... which a witness may have had are without any relevancy to the witness' credibility, concerned as it is with whether the witness' mental impairment is related to his capacity to observe the event at the time of its occurrence, to communicate his observations accurately and truthfully at trial, or to maintain a clear recollection in the meantime." (cleaned up)). Indeed, the First Circuit in a case cited favorably both by the Second Circuit and by the Defense concluded that there was an inadequate link between borderline personality disorder and a witness's credibility. United States v. Butt, 955 F.2d 77,83,85 (1st Cir. 1992) (stating that the diagnosis did not prevent the witness "from perceiving matters truthfully and testifying about them"). + +The Defense also argues that Dr. Hall diagnosed Alleged Victim 4 with bipolar disorder, De£ Br. at 10, a characterization that the Government disputes, Gov't Br. at 9. The Court agrees with the Government that there is significant ambiguity as to this diagnosis. To be sure, Dr. Hall in his "summary" lists that Alleged Victim 4 has been diagnosed with "Bipolar II Disorder . . . by history." Report at 107. But in his own "diagnostic impression" of Alleged Victim 4, Dr. Hall states that Victim 4 "is not able to describe any discrete periods" consistent with bipolar disorder. Report at 93. He states further that Alleged Victim 4 reports only "irritability," but "does not demonstrate the other required symptoms" of bipolar disorder. Id. Such apparent contradictions in the report reduce its relevance and increase the risk of confusing jurors. See Hamlett, 2021 WL 5105861, at \*2. + +Regardless, based on Dr. Hall's report, a diagnosis of bipolar disorder is not relevant under Sasso. The Defense cites Dr. Hall's statements that link bipolar disorder with "racing thoughts," "distractibility," and "depression." Report at 93; Def. Br. at 11. But these scattered symptoms do not meaningfully impeach Alleged Victim 4's memory or perception of reality. Federal courts have repeatedly excluded diagnoses of bipolar disorder as irrelevant to a witness's credibility. E.g., United States v. Fattah, 187 F. Supp. 3d 563, 568-69 (E.D. Pa. 2016) ("[T]here is no basis to infer that [bipolar disorder] has affected the [witness's] memory, competence, or ability or tendency to tell the truth in connection with the facts in this case."); United States v. Baxter, 761 F.3d 17, 23 (D.C. Cir. 2014); United States v. George, 532 F.3d 933, 937 (D.C. Cir. 2008) ("Nothing in [the defendant's] proffer at trial indicated why bipolar disorder would cause . .. difficulty in perceiving reality or motivate [violence]."). In a similar line of cases, courts in this circuit have held that expert diagnoses of depression are not probative of credibility. E.g., Sasso, 49 F.3d at 348 (finding that a diagnosis of depression lacked probative value); United + +States v. Giovinco, No. 18-CR-14 (JSR), 2020 WL 832920, at \*2 (S.D.N.Y. Feb. 20, 2020) (finding that depression did not impact the witness's "ability to accurately perceive or recall" relevant events); see also United States v. Cooper, No. 15-CR-152 (RMC), 2017 WL 11496709, at \*1 (D.D.C. Jan. 27, 2017) (excluding diagnosis of major depressive disorder). + +Last, the Defense points to the diagnosis for oppositional defiant disorder, which the Defense and the Government say includes a criterion of "vindictiveness." Def. Br. at 11 (quoting Gov't Br. at 10). But, again, this is not a basis for impeaching Alleged Victim 4's ability to testify truthfully under Sasso. 59 F.3d at 348; see also Hernandez v. Kelly, No. 09 CV 1576 TLM LB, 2011 WL 2117611, at \*5 (E.D.N.Y. May 27, 2011) (explaining that a condition must "bear[ ] on [a witness's] ability to rationally perceive events at the time and to accurately recollect and report his perceptions"). + +In assessing the relevance of each of these diagnoses, the Court also takes account of Dr. Hall's conclusion that despite her several conditions, Alleged Victim 4 has no "psychotic believes [sic], hallucinations or delusions." Report at 92; see also id. at 80 ("she reports no period of... hallucinations"). Further, Dr. Hall several times commented that Alleged Victim 4's memory was very accurate. E.g., id. at 85 ("No . . alterations in memory, or changes in orientation or level of attention."); 92 ("Her memory was impeccable and at multiple times during the evaluation she pointed out to the examiner questions he did or didn't ask. She reported her memory is `perfect' and that she will remember every detail of the room in which the evaluation was done." (emphases in original)). On review, the Court cannot identify any point in the report at which Dr. Hall doubts Alleged Victim 4's account of events. Instead, he appears to summarize and accept her story of sexual conduct with Epstein. Id. at 100-01. In short, none of + +the diagnoses in Dr. Hall's report are adequately tied to Alleged Victim 4's credibility as a witness. See Hamlett, 2021 WL 5105861, at \*2. + +Even if any diagnosis were probative, the Court further finds that Rule 403 prejudice outweighs. First, the testimony may confuse jurors with old diagnoses that have little connection to the conduct at issue or Alleged Victim 4's credibility today. See id. Confusion is particularly likely here given that Dr. Hall's report is at times unclear and even contradictory, as with the confusion over bipolar disorder explained above. Id. Second, the Court takes account of the risk that jurors will stereotype a witness with a history of mental illness or incorrectly assume that a diagnosed mental condition renders the witness untrustworthy. See Hernandez, 2011 WL 2117611, at \*5. Third, mental health diagnoses are of a particularly sensitive nature and, if not relevant, the witness's privacy should not be invaded. Paredes, 2001 WL 1478810, at \*2 (citing In re Doe, 964 F.2d 1325,1328-29 (2d Cir. 1992)). + +And fourth, Dr. Hall's testimony would be cumulative and cause undue delay. The Government anticipates that several aspects of Alleged Victim 4's mental health history will be admitted either on direct or cross-examination, including that Alleged Victim 4 currently takes medication for bipolar disorder and her history of substance abuse. Gov't Br. at 9-10. The Second Circuit has previously held that where relevant issues of mental conditions can be aired on cross-examination, the district court may preclude the witness's medical records and expert testimony. Vitale, 459 F.3d at 196; Dupree, 833 F. Supp. 2d at 265 (applying Vitale and Sasso). The Court concludes that here, the cross-examination identified by the Government on Alleged Victim 4's current medication for bipolar disorder, along with lines of cross-examination unrelated to mental health, will provide the jury a sufficiently "discriminating appraisal" of Alleged Victim 4's credibility such that Dr. Hall's testimony and report is unnecessary. Drake v. + +Woods, 547 F. Supp. 2d 253, 266-67 (S.D.N.Y. 2008) (quoting United States v. Roldan-Zapata, 916 F.2d 795, 806 (2d Cir. 1990)). The Court therefore concludes that the minimal probative value of each of Dr. Hall's diagnoses of Alleged Victim 4 is substantially outweighed by the risk of unfair prejudice. + +But this balancing of Rules 401 and 403 is based on the present record. It is conceivable that an additional proffer from the Defense that raises the probative value of a diagnosis, such as that for borderline personality disorder, would change the Court's calculation. Cf. George, 532 F.3d at 937 ("We do not foreclose the possibility that testimony by an expert ... could have shown evidence of [the witness's] condition to be relevant to her credibility . . . . But without such testimony, [defense] counsel had only words such as 'episodes of rage' and `racing thoughts."); Hamlett, 2021 WL 5105861, at \*2 (affirming exclusion of a psychological witness that failed to show a "clear link between any particular mental health diagnosis and a witness's credibility"). + +The Defense argues that apart from diagnoses of her mental health conditions, the Defense should be permitted to admit Dr. Hall's conclusion as to Alleged Victim 4's substance abuse and addiction. Def. Br. at 12-13 (collecting cases). The Second Circuit instructs: + +It is, of course, within the proper scope of cross-examination to determine whether a witness was under the influence of drugs or narcotics or alcohol at the time of observation of events in dispute or at the time the witness is testifying. As Wigmore points out, however, a general habit of intemperance tells us nothing of the witness's testimonial incapacity unless it involves actual intoxication at the time of the event observed or at the time of testifying. + +United States v. DiPaolo, 804 F.2d 225, 229-30 (2d Cir. 1986) (cleaned up) (cited in Gov't Br. at 11 and Def. Br. at 12); accord United States v. Robinson, 583 F.3d 1265, 1272 (10th Cir. 2009) ("Illegal drug use does not merely bear on the [confidential informant's] veracity but also on his capacity as a witness."). + +The Court will therefore permit the Defense to cross-examine Alleged Victim 4 about her use of substances during and after the conduct in question. Indeed, the Court was already under the impression that the Defense intended to pursue this line of cross-examination after the Dauber! hearing. Nov. 10 Tr. at 157 ("[D]o you intend to impeach any witnesses based on substance abuse? ... Yes."). + +But the extensive case law cited by the Defense about cross-examining witnesses on their substance use does not justify the request to admit Dr. Hall's testimony on substance use and addiction. For example, in United States v. Vitale, the district court gave the defense "wide latitude when cross-examining [the witness] about his drug use and rehabilitation, including questions about the effects that the drugs had on his ability to perceive events when they occurred as well as on his memory at the time of trial." 459 F.3d at 196. The district court did not, however, permit the defense to admit the witness's drug rehabilitation treatment records into evidence. Id. Citing Sasso, the Second Circuit affirmed, explaining that through crossexamination alone, "the jury was well aware of... [the witness's] drug abuse and treatment history." Id. The Second Circuit has made such a distinction—permitting cross-examination on drug use but excluding a formal diagnosis of addiction—in several cases. E.g., DiPaolo, 804 F.2d at 230; Dobson v. Walker, 150 F. App'x 49,52 (2d Cir. 2005) (explaining that crossexamination about a witness's drug use before witnessing a murder would be admissible, but the general fact that the witness uses drugs is not). The Defense does not cite any case law to the contrary. Even the nonbinding authority that the Defense refers to as "instructive," Def. Br. at 13, held only that a defendant had the right to review a witness's medical records and crossexamine the witness about his drug use, Robinson, 583 F.3d at 1271-75. + +In addition to diagnosing Alleged Victim 4's mental conditions, Dr. Hall also concluded that Epstein's behavior had only a minimal impact on Alleged Victim 4's psychiatric profile. The Government moved to exclude this conclusion and the Defense does not make a case for admitting it. The Court will also preclude the opinion. In this circumstance, the lasting mental impact of a crime is at best "minimally probative" of whether that crime was committed. United States v. Hendricks, 921 F.3d 320, 329 (2d Cir. 2019). It also carries a high risk of Rule 403 prejudice by suggesting that the psychological impact on Alleged Victim 4 is relevant to Ms. Maxwell's guilt beyond a reasonable doubt. It would also cause substantial delay by opening the door to rebuttal evidence by the Government on Alleged Victim 4's mental health, which would likely lead to mini-trials on irrelevant issues. + +Next, the disclosure states that Dr. Hall will testify to the "significance" of Alleged Victim 4's diagnoses. Notice at 12. First, the Court understands that Dr. Hall could not testify to the "significance" of mental health diagnoses without first testifying to what those diagnoses are. Because the Court is precluding Dr. Hall's testimony on Alleged Victim 4's diagnoses, the Court will also preclude Dr. Hall's testimony on their significance. Additionally, the current disclosure on this point does not satisfy Rule 16's requirement that the Defense provide Dr. Hall's opinion rather than just the general topic of the testimony. Even if the Court admitted Dr. Hall's testimony as to Alleged Victim 4's diagnoses, the Court would preclude his testimony on significance until more specific opinions are disclosed to the Government. + +Next, the Defense anticipates that Dr. Hall will testify to the "bases for those opinions" in his report. Id. Dr. Hall's report refers not only to what Alleged Victim 4 told him during their in-person interview but also other records like prior psychiatric reports, other medical records, criminal records, school records, and a deposition of a non-testifying witness. E.g., Report at 2963. These out of court statements would be hearsay if admitted for their truth, and so are presumptively inadmissible at trial. Fed. R. Evid. 802. The Defense identifies several means by which it may admit these hearsay statements. Def. Br. at 14-17. + +First, "[u)nder Rule 703, experts can testify to opinions based on inadmissible evidence, including hearsay, if `experts in the field reasonably rely on such evidence in forming their opinions!" United States v. Mejia, 545 F.3d 179, 197 (2d Cir. 2008). But Rule 703 does not permit an expert to "simply transmit that hearsay to the jury." Id. Rather, those underlying facts and data that would otherwise be inadmissible may be disclosed to the jury "if their probative value in helping the jury evaluate the opinion substantially outweighs their prejudicial effect." Fed. R. Evid. 703. Here, the hearsay underlying Dr. Hall's diagnoses, including the medical records, criminal records, and depositions, would have little probative value unless the Government were to challenge the accuracy of Dr. Hall's diagnoses. See United States v. Chai, No. 13-CR-290 (PAC), 2015 WL 293995, at \*3 (S.D.N.Y. Jan. 22, 2015). The Government represents in its brief that it would not do so in the event that Dr. Hall's diagnoses are admitted. Gov't Br. at 13. And admitting the underlying hearsay, without a relevant need to substantiate the accuracy of Dr. Hall's conclusions, would result in significant prejudice, including confusing the jury and delaying the trial with a large volume of unnecessary details. The Court therefore concludes that, based on the parties' current proffers, the facts and data underlying Dr. Hall's opinions are not admissible via Rule 703. + +Second, the Defense says that Alleged Victim 4's statements are admissible under one of two hearsay exceptions in Rule 803. Def. Br. at 15. It says the statements were statements of her "then-existing state of mind ... or emotional, sensory, or physical condition." Fed. R. Evid. 803(3). But while a number of Alleged Victim 4's statements to Dr. Hall may pertain to motives + +or emotional condition, her statements made to Dr. Hall in 2009 about events that took place years earlier cannot be said to be "then-existing." Id. The Defense also says Alleged Victim 4's statements were "made for medical diagnosis or treatment." Fed. R. Evid. 803(4). The Court finds that this may be a permissible basis for admitting some of Alleged Victim 4's statements, though they must be "made for ... medical diagnosis or treatment," must "describe[ ] medical history; past or present symptoms or sensations; their inception; or their general cause," and must otherwise satisfy Rules 401 and 403. Fed. R. Evid. 803(4)(A), (B); see In re Agent Orange Prod. Liab. Litig., 611 F. Supp. 1223, 1245-46 (E.D.N.Y. 1985), aff'd sub nom., 818 F.2d 187 (2d Cir. 1987) (Weinstein, C.J.).' But without additional detail from the Defense on which portions of Dr. Hall's testimony it would seek to admit under this exception, the Court cannot make a definitive ruling. + +The Defense does not mention Alleged Victim 4's criminal records cited by Dr. Hall in his report. The Court concludes that Alleged Victim 4's criminal records are inadmissible under Federal Rule of Evidence 609. Dr. Hall's report is not clear on the details of Alleged Victim 4's criminal history, but her criminal history includes at least assault with a deadly weapon while she was a minor and possession of illegal narcotics both as a minor and as an adult. These incidents, however, are now all over 10 years old, none appear to require proving "a dishonest act or false statement," and, for her juvenile offenses, admitting the evidence is not necessary to fairly determine the guilt or innocence of Ms. Maxwell. Fed. R. Evid. 609 (a), (b), (d). + +&#x27; The Defense also argues that Alleged Victim 4's statements would be "admissible for their effect on Dr. Hall in forming his opinion." Def. Br. at 15. But, like Rule 703, this justification is a relevant basis for admission only if the validity of Dr. Hall's diagnoses is put in question. + +### B. The Court reserves judgment on the admissibility of Dr. Hall's fact testimony + +Finally, two of Dr. Hall's anticipated opinions are fact testimony not subject to Rule 702. Specifically, Dr. Hall would testify that Alleged Victim 4 told him that she previously disclosed other sexual abuse to a prior mental health provider, Dr. Susan Pope, but did not disclose abuse by Epstein to Dr. Pope. Def. Br. at 16.2 Further, Dr. Hall would testify that in their interview Alleged Victim 4 "did not identify Ms. Maxwell as a perpetrator of any abuse." Notice at 12. The Defense argues these statements are admissible as prior inconsistent statements. Def. Br. at 16-17. The Government concedes that Dr. Hall's testimony here would be admissible, including potentially as a prior inconsistent statement, if relevant and not otherwise excludable. Gov't Br. at 16, 18. + +The Court reserves judgment on this question, but provides this guidance. The Defense will cross-examine Alleged Victim 4 and, as the Court has previously ruled, it may ask whether Alleged Victim 4 on previous occasions implicated Ms. Maxwell in the alleged sexual abuse by Epstein. Nov. 1 Tr. at 27. Whether the Defense may then admit any of Dr. Hall's testimony will depend on Alleged Victim 4's response to that question, whether any prior statement is actually "inconsistent" with her response, see United States v. Trzaska, 111 F.3d 1019,1024-25 (2d Cir. 1997) (reversing a district court's admission of prior statements that were not inconsistent), and whether the Defense satisfies the other requirements of admitting extrinsic evidence of a prior inconsistent statement under Federal Rule of Evidence 613. + +2 From the parties' briefing, the Court understands that the Defense would not seek to admit Dr. Hall's testimony about what Alleged Victim 4 told Dr. Pope for the truth of the matter asserted, as that would be hearsay with no apparent exception. See Def. Br. at 16 (referring to Alleged Victim 4's statements to Dr. Pope and stating It]his evidence is admissible as a prior inconsistent statement"). Even then, however, the Court is skeptical that a situation would arise in which this statement could be used to contradict Alleged Victim 4' testimony without assuming the statement's truth. + +### **III. Conclusion** + +The Court therefore grants the Government's motion to preclude Dr. Hall's expert testimony. Because this is a preliminary pre-trial ruling, it is possible that facts and circumstances at trial would alter the Court's analysis. In that event, the Defense must re-raise its request to admit Dr. Hall as an expert witness. + +SO ORDERED. + +Dated: November 22, 2021 + +New York, New York + +![]() + +--- + +ALISON J. NATHAN +United States District Judge \ No newline at end of file diff --git a/marker2/ds9/EFTA00087203/EFTA00087203.metadata.json b/marker2/ds9/EFTA00087203/EFTA00087203.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..68a3d1b6d5b28bee6a8962ccf5b833b79d816160 --- /dev/null +++ b/marker2/ds9/EFTA00087203/EFTA00087203.metadata.json @@ -0,0 +1,719 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087203.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 17, + "chars": 32680, + "elapsed_seconds": 4.23, + "image_assets": [ + "_page_0_Picture_5.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 71.28 + ], + [ + 281.019775390625, + 71.28 + ], + [ + 281.019775390625, + 99.603515625 + ], + [ + 68.544, + 99.603515625 + ] + ] + }, + { + "title": "I. 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NATHAN, District Judge: + +The Defense on November 1, 2021, noticed eight expert witnesses. Def. Br., Ex. I ("Notice"). Two of those experts, Dr. Park Dietz and Dr. Elizabeth Loftus, are expected to offer opinions that rebut opinions of the Government's expert witness, Dr. Lisa Rocchio. The Government on November 8, 2021, filed a motion to partially preclude the testimony of Dr. Dietz and Dr. Loftus. Dkt. No. 424. The Court has already addressed that motion. + +On November 15, 2021, the Government moved to fully or partially preclude the testimony of the remaining six experts. The Defense filed a response on November 19, 2021. + +The Court addressed the admissibility of Dr. Ryan Hall in a separate written opinion. In this opinion, the Court addresses the preliminary admissibility of Bennett Gershman based on the parties' current proffers. + +## I. Legal standard + +Federal Rule of Evidence 702 governs the admissibility of expert testimony. That rule states: + +A witness who is qualified as an expert by knowledge, skill, experience, training, or education may testify in the form of an opinion or otherwise if: + +- (a) the expert's scientific, technical, or other specialized knowledge will help the trier of fact to understand the evidence or to determine a fact in issue; +- (b) the testimony is based on sufficient facts or data; +- (c) the testimony is the product of reliable principles and methods; and +- (d) the expert has reliably applied the principles and methods to the facts of the case. + +The Court exercises a "gatekeeper function" in assessing the admissibility of expert testimony. Restivo v. Hessernann, 846 F.3d 547, 575 (2d Cir. 2017). To determine whether an expert's method is reliable, the Court considers the non-exhaustive list provided by the Supreme Court in Daubert, including whether the expert's method has been tested, whether it has been subjected to peer review, the rate of error, standards controlling the method's operation, and whether the method is accepted by the expert community. United States v. Kidd, 385 F. Supp. 3d 259, 263 (S.D.N.Y. 2019) (citing Daubert v. Merrell Dow Phanns., Inc., 509 U.S. 579, 593-94 (1993)). + +But Rule 702 ultimately sets a "liberal" and "permissive" standard of admissibility. Nimely v. City of New York, 414 F.3d 381, 395-96 (2d Cir. 2005). In particular, not every expert admissible under Daubert need rely on a method that conforms with "the exactness of hard science methodologies." E.E.O.C. v. Bloomberg L.P., No. 07-CV-8383 (LAP), 2010 WL 3466370, at \*13-14 (S.D.N.Y. Aug. 31, 2010) (quoting United States v. Simmons, 470 F.3d 1115, 1123 (5th Cir. 2006)). + +Additionally, the procedure for disclosing expert witnesses is governed by Federal Rule of Criminal Procedure 16. That rule states that when the Government makes a request, the Defense "must ... give to the government a written summary of any testimony that the defendant intends to use under Rule[ ] 702. . . . This summary must describe the witness's + +opinions, the bases and reasons for those opinions, and the witness's qualifications." Fed. R. Crim. P. 16(b)(1)(C). The purpose of this rule is to "minimize surprise that often results from unexpected expert testimony, reduce the need for continuances, and to provide the opponent with a fair opportunity to test the merit of the expert's testimony through focused cross-examination." Fed. R. Civ. P. 16(b)(1)(C) advisory committee's note to 1993 amendment. Thus, to satisfy Rule 16, a notice must not merely describe the "general topics" on which experts will testify but actually "summarize the experts' opinions about those topics" and "describe the bases for the experts' opinions." United States v. Ulbricht, 858 F.3d 71, 115 (2d Cir. 2017) (emphasis added); United States v. Valle, No. 12-CR-847 (PGG), 2013 WL 440687, at \*5 (S.D.N.Y. Feb. 2, 2013) ("Merely identifying the general topics about which the expert will testify is insufficient; rather, the summary must reveal the expert's actual opinions."). + +If the Defense's disclosure of an expert witness does not satisfy Rule 16, the Court has "broad discretion" to fashion an appropriate remedy. Ulbricht, 858 F.3d at 115. That discretion is guided by factors including "why disclosure was not made, the extent of the prejudice, if any, to the opposing party, the feasibility of rectifying that prejudice by a continuance, and any other relevant circumstances." Id. (quoting United States v. Lee, 834 F.3d 145, 159 (2d Cir. 2016)). When a disclosure merely lists general topics on which the expert might testify, the Second Circuit has several times held that the district court has discretion to exclude the expert entirely. See id. at 118; United States v. Vaccarelli, No. 20-3768-CR, 2021 WL 4805218, at \*2 (2d Cir. Oct. 15, 2021). + +## II. Discussion + +As a preliminary matter, the Defense argues that the Government's motion is "premature" because the Government's arguments are about the relevance and prejudice of the witnesses' testimony, not their qualifications or the reliability of their methods under Rule 702. Def. Br. at 1, 5-6. But one aspect of the Rule 702 and Daubert inquiry is "fit," which asks "whether expert testimony proffered in the case is sufficiently tied to the facts of the case that it will aid the jury in resolving a factual dispute." Alto v. Sun Phann. Indus., Inc., No. 1:19-CV-09758 (GHW), 2021 WL 4803582, at \*3 (S.D.N.Y. Oct. 13, 2021) (quoting Daubed, 509 U.S. at 591). Fit is satisfied if the expert's opinion would assist the jury's decision on a relevant question of fact without "usurp[ing] either the role of the trial judge in instructing the jury as to the applicable law or the role of the jury in applying that law to the facts before it." Id. (quoting United States v. Duncan, 42 F.3d 97, 101 (2d Cir. 1994)). The Court finds that at least some of the Government's arguments that go to fit are ripe for preliminary resolution now. Other aspects of the Government's motion can be resolved only with additional information and the context of trial. + +The Government moves to exclude the testimony of Bennett Gershman in its entirety. As explained in the notice, Professor Gershman "is a leading authority on prosecutorial misconduct." Notice at 12. The Defense expects that he will testify "on best practices to ensure the integrity of any prosecution, focusing on investigation, witness preparation, media contact, neutrality, obligations to provide accurate information, and relationship with crime victims, their counsel, and case-related civil litigation." Id. + +The Court will grant the Government's motion and exclude Gershman. First, his expected testimony is irrelevant. At the November 1 pretrial conference, the Court ruled that it would "preclude affirmative evidence by the defense that goes to the thoroughness of the investigation." Nov. 1 Tr. at 17. As the Court explained, "[t]he length of the investigation, the investigative techniques used, and the fact that the defendant was not initially a target of the + +investigation are all irrelevant" to Ms. Maxwell's guilt. Id. at 19 (quoting United States v. Duncan, No. 18-CR-289, 2019 WL 2210663 (S.D.N.Y. 2019)). The Court concludes that the expected topics of Gershman's testimony—investigation, witness preparation, media contact, being neutral and accurate, and relationships with victims-all fall within the rubric of attacking the thoroughness of the investigation rather than being probative of Ms. Maxwell's guilt of the crimes charged. In short, this testimony would run afoul of the instruction that the jury will receive that "the government is not on trial." Id. at 23 (quoting United States v. Knox, 687 F. App'x 51, 54 (2d Cir. 2017)). + +The Court notes that a court in this district recently excluded Gershman's testimony in a civil case in which he would have similarly criticized the SEC's investigation, including the use of cooperating witnesses. SEC v. Collector's Coffee Inc., No. 19-CV-4355 (VM) (GWG), 2021 WL 3418829 (S.D.N.Y. Aug. 5, 2021). That case differs from this one in several respects, but that court's basic reasoning informs and supports the Court's decision here. + +The Defense argues that the Court "expressly denied" prohibiting the Defense from calling an expert witness like Gershman. Def. Br. at 17. Tellingly, the Defense quotes no language from the Court for this proposition and instead cites only those pages of the Court's oral ruling in which the Court explained that it "will permit relevant cross-examination of the government's witnesses." Nov. 1 Tr. at 27. This language in no fashion supports the Defense's request to admit an expert to testify about government investigative techniques. The Court reiterates, however, that it will permit the Defense to pursue "lines of cross-examination of government witnesses [that] would be relevant to impeach a witness by suggesting bias or otherwise implicating their credibility," which could include the Defense's theory of witnesses' motives for "implicating Ms. Maxwell after Jeffrey Epstein's death." Id. at 28-29. + +Second, even if Gershman's testimony was relevant, Rule 403 prejudice would substantially outweigh for the reasons given at the November 1 conference. Id. at 21-24. Gershman's testimony would be likely to confuse the jury by suggesting that the Government's choices of investigative techniques are relevant to guilt, it would conflict with the Court's anticipated jury instruction that the Government is not on trial, it would substantially delay the trial, and it would, at most, be cumulative of the Defense's arguments that there is inadequate evidence on which to find Ms. Maxwell guilty. Indeed, placing an expert imprimatur on these arguments would only enhance the Rule 403 prejudice. + +Third, apart from Rule 401 and 403, the Defense's disclosure of Gershman does not satisfy Rule 16. The Defense has listed only the general topics on which Gershman will testify, like "investigation," "media contact," and "neutrality." Notice at 12. It does not mention Gershman's actual opinions on these topics or the bases for those opinions. Nor does the Defense's response brief add any detail about the content of Gershman's opinions. Def. Br. at 18. Indeed, the Defense's briefing on this issue mentions very little of Gershman's anticipated testimony. Therefore, even if Rules 401 and 403 were satisfied, the Court would exclude Gershman's testimony because the Defense has not yet satisfied Rule 16. + +## III. Conclusion + +The Court therefore grants the Government's motion to preclude Gershman's expert testimony. Because this is a preliminary pre-trial ruling, it is possible that facts and circumstances at trial would alter the Court's analysis. In that event, the Defense must re-raise its request to admit Gershman as an expert witness. + +SO ORDERED. + +Dated: November 22, 2O21 + +New York, New York + +ALISON J. NATHAN United States District Judge \ No newline at end of file diff --git a/marker2/ds9/EFTA00087220/EFTA00087220.metadata.json b/marker2/ds9/EFTA00087220/EFTA00087220.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..d6bb1502498df3f558a7132113d15f124bf07784 --- /dev/null +++ b/marker2/ds9/EFTA00087220/EFTA00087220.metadata.json @@ -0,0 +1,357 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087220.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 7, + "chars": 11126, + "elapsed_seconds": 1.22, + "image_assets": [ + "_page_0_Picture_5.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 71.28 + ], + [ + 281.41961669921875, + 71.28 + ], + [ + 281.41961669921875, + 99.603515625 + ], + [ + 68.544, + 99.603515625 + ] + ] + }, + { + "title": "I. 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Maxwell, 20cr330, Opinion & Order + +Date: Fri, 25 Jun 2021 21:09:44 +0000 + +Attachments: 20cr330\_Order 6.25.21.pdf; 20cr330\_Sealed\_Opinion\_&\_Order 6.25.21.pdf + +Chiefs —Judge Nathan denied Maxwell's motions to suppress. See attached. + +From: Nathan NYSD Chambers + +Sent: Friday, June 25, 2021 5:07 PM + +To Jeff Pa liuca Laura Menninge + +Subject: U.S. v. Maxwell, 20cr330, Opinion & Order + +Dear Counsel, + +Please find attached an Opinion and an Order from Judge Nathan. The Order will appear on the public docket shortly, and the Opinion will be filed under temporary seal. Please confirm receipt. + +Kind regards, + +Law Clerk to the Hon. Alison J. Nathan \ No newline at end of file diff --git a/marker2/ds9/EFTA00087227/EFTA00087227.metadata.json b/marker2/ds9/EFTA00087227/EFTA00087227.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..a5cbf93ee69c4ed701603146487554059a3f1318 --- /dev/null +++ b/marker2/ds9/EFTA00087227/EFTA00087227.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087227.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 702, + "elapsed_seconds": 0.68, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 39 + ], + [ + "Line", + 17 + ], + [ + "Text", + 14 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087227" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087228/EFTA00087228.md b/marker2/ds9/EFTA00087228/EFTA00087228.md new file mode 100644 index 0000000000000000000000000000000000000000..5a78d033b08d41ccd73c314e7d69aea857a3f92e --- /dev/null +++ b/marker2/ds9/EFTA00087228/EFTA00087228.md @@ -0,0 +1,35 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +United States of America, + +—v— + +Ghislaine Maxwell, + +Defendant. + +USDC SONY DOCUMENT ELECTRONICALLY FILED DOC DATE FILED: 6/25/2021 + +20-cr-330 (AJN) + +ORDER + +ALISON J. NATHAN, District Judge: + +Maxwell's motions to suppress evidence (Dkt. Nos. 133, 139) are DENIED. The Court sets out its reasoning in an opinion concurrently filed under temporary seal to allow Maxwell and the Government the opportunity to propose redactions. The parties may file under seal any proposed redactions to the opinion within three days. + +The Court further ORDERS that the April 9, 2019 memorandum decision and order on the Government's application to modify the protective order in v. Maxwell, No. as well as the transcripts of the March 26, 2019 and April 9, 2019 ex parte hearings on that application shall be unsealed. These documents were previously filed under seal as Exhibits D, E, F, and G to the memorandum of law in support of Maxwell's first motion to suppress (Dkt. No. 134). Within one week, the parties shall confer and file under seal any proposed redactions to the memorandum decision, order, and transcripts. + +Any proposed redactions shall be narrowly tailored and shall be supported with reference to the Second Circuit's opinion in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). The parties' proposed redactions should not include any information that has already been made public. + +SO ORDERED. + +Dated: June 25, 2021 +New York, New York + +![]() + +--- + +ALISON J. NATHAN +United States District Judge \ No newline at end of file diff --git a/marker2/ds9/EFTA00087228/EFTA00087228.metadata.json b/marker2/ds9/EFTA00087228/EFTA00087228.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..0ac138e73413ecfc775ab889f6131b16ff413080 --- /dev/null +++ b/marker2/ds9/EFTA00087228/EFTA00087228.metadata.json @@ -0,0 +1,116 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087228.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 1575, + "elapsed_seconds": 1.63, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 71.28 + ], + [ + 281.0284118652344, + 71.28 + ], + [ + 281.0284118652344, + 99.7330322265625 + ], + [ + 68.544, + 99.7330322265625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 60 + ], + [ + "Line", + 30 + ], + [ + "Text", + 11 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 13 + ], + [ + "Text", + 7 + ], + [ + "Line", + 7 + ], + [ + "PageFooter", + 4 + ], + [ + "Caption", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087228" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087230/EFTA00087230.md b/marker2/ds9/EFTA00087230/EFTA00087230.md new file mode 100644 index 0000000000000000000000000000000000000000..954af82b04dd61c1b16dd46935233b087abe4167 --- /dev/null +++ b/marker2/ds9/EFTA00087230/EFTA00087230.md @@ -0,0 +1,173 @@ +#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +United States of America, + +—v— + +Ghislaine Maxwell, + +Defendant. + +USDC SONY DOCUMENT ELECTRONICALLY FILED DOC DATE FILED: 6/25/2021 + +20-cr-330 (AJN) + +OPINION & ORDER + +ALISON J. NATHAN, District Judge: + +Maxwell moves to suppress evidence obtained through a grand jury subpoena to a law firm involved in earlier civil litigation against her. She contends that because the documents sought by the subpoena were previously subject to a protective order, the Government obtained them in violation of her rights against compelled self-incrimination, against unreasonable searches and seizures, and to due process of law. For the reasons that follow, the Court concludes that the evidence should not be suppressed and that Maxwell is not entitled to an evidentiary hearing. + +# I. Background + +In late 2015, sued Maxwell for defamation. See v. Maxwell, No. 15-cv-7433 (S.D.N.Y.). alleged that Maxwell defamed her by accusing her of lying about Maxwell and Jeffrey Epstein sexually abusing her. The law firm Boies Schiller Flexner LLP (BSF) represented in the dispute. The parties litigated the case for about two years before signing a confidential settlement agreement. + +Early in the civil litigation, one of the attorneys representing approached an Assistant United States Attorney (AUSA) in the Southern District of New York and requested a meeting to provide the Government information on possible criminal conduct. The AUSA met with three attorneys who represented on February 29, 2016. The AUSA's notes from the meeting reflect that it focused primarily on Epstein. However, the notes also identify Maxwell as Epstein's "head recruiter" of underage girls. The attorneys sent a few follow-up emails to the AUSA in the following weeks. The United States Attorney's Office did not pursue a criminal investigation at that time. + +Maxwell claims based on a New York Daily News article published in October 2020 that a second meeting took place between federal prosecutors and a principal of BSF in the summer of 2016. The Government has represented to the Court that the AUSA who participated in the February 29, 2016 meeting did not participate in a second meeting with BSF attorneys and that the Government has "uncovered no evidence that such a meeting ever occurred." Dkt. No. 204, at 92. However, for purposes of deciding this motion, the Court assumes that it occurred. + +About two weeks after the February 29, 2016 meeting, the judge presiding over the civil case entered a protective order that allowed the parties in that case to designate documents produced in discovery as confidential. See Dkt. No. 134-1. That order prohibited the parties from disclosing confidential documents to anyone other than people involved in the case. Although BSF initially proposed language that would allow disclosure of documents to law enforcement without a court order, the final version of the protective order included no such exception. The protective order did not require the parties to obtain the court's approval to mark a document as confidential. It allowed the court to modify the order at any time for good cause after notice to the parties. It also allowed the parties to use any confidential information at trial, at which point that information would become public. It required the parties to return or destroy confidential records after the case ended. + +Following entry of the protective order, Maxwell testified in two depositions in the civil case. The parties designated the depositions as confidential under the protective order. Counts five and six of the SI superseding indictment in this case (and counts seven and eight of the S2 superseding indictment) charge that Maxwell made false statements under oath in each of the depositions. + +The Government represents that the Office of the U.S. Attorney for the Southern District of New York formally opened its investigation into Epstein on November 30, 2018, following a series of articles in the Miami Herald about Epstein's conduct and the lenient plea deal he received in the Southern District of Florida. The same day, the AUSA who attended the February 2016 meeting forwarded the emails she received from attorneys in the civil case to the prosecutors working on the fledgling investigation. There is no indication that she was involved in the decision to begin the investigation into Epstein in 2018. + +About two months later, the Government served a grand jury subpoena on BSF seeking to obtain documents for its investigation of Epstein. BSF informed the Government that many of the requested documents fell under the protective order. The Government then applied for an ex parte order modifying the protective order to allow BSF to comply with the subpoena. The Government made a second, similar application in connection with a protective order in a different case. + +The judge who presided over the civil case passed away in March 2019, and so then-Chief Judge McMahon heard the Government's ex parte application. In a hearing on March 26, 2019, Judge McMahon explained that she believed the Second Circuit's decision in Martindell v. International Telephone & Telegraph Coip., 594 F.2d 291 (2d Cir. 1979), governed the Government's application. Martindell held that a party should not provide documents subject to + +a protective order to the Government absent a formal motion or subpoena. It further held that a court should modify a protective order that a party reasonably relied on only if the order had been improvidently granted or upon a showing of extraordinary circumstances or compelling need. + +Judge McMahon held a second ex parte hearing on April 9, 2019. At that hearing, citing a district court case called Chemical Bank for the proposition that civil litigants ought not foment criminal investigations against their opponents to gain strategic advantage, she asked the Government about contacts between the U.S. Attorney's Office and BSF on the subject of the Government's investigation. The Government explained that BSF had informed the Government that some of the documents the Government sought were covered by a protective order. The Government did not mention any of the communications with BSF attorneys in 2016. + +Judge McMahon issued a sealed order granting the Government's application followed by a sealed opinion dated April 9, 2019. In the opinion, she explained that Martindell governed the Government's application, but that two of the Martindell factors supported modification of the protective order. First, Maxwell did not reasonably rely on the protective order because it was subject to modification. Second, the Government had shown extraordinary circumstances supporting modification of the protective order because it could not otherwise obtain information about the high-profile targets of its investigation without tipping them off. Magistrate Judge Netbum denied the Government's similar application in another case, applying the same standard but concluding that the Government had not shown extraordinary circumstances or compelling need. + +Following Judge McMahon's order, BSF turned over its records from the civil litigation to the Government. Those documents included transcripts of Maxwell's depositions. The + +Second Circuit later held that the court in the civil case withheld far too many documents from public view and ordered that many of them be made publicly available. Brown v. Maxwell, 929 F.3d 41, 53 (2d Cir. 2019). Much of what the Government obtained through its subpoena, including the bulk of the deposition transcripts Maxwell now seeks to suppress, have since been unsealed by court order in the civil case. See , No. 15-cv-7433, Dkt. Nos. 1137, 1212. + +# II. Discussion + +Maxwell objects both to the Government obtaining documents covered by the protective order and to the Government's conduct in doing so. She contends that she agreed to testify in the civil case only because of the protective order, and thus that the Government's use of her deposition testimony against her would violate her right against compelled self-incrimination. She contends that she had a reasonable expectation of privacy in the documents covered by the protective order, and thus that the Government should not have been able to obtain them without a warrant. And she contends that the Government circumvented the requirements of Martindell and violated her due process rights by misleading Judge McMahon about the Government's prior communications with BSF. + +The Court finds that none of these arguments support suppression of evidence or justify an evidentiary hearing. The Court begins with Maxwell's claim that the Government violated her right against compelled self-incrimination by obtaining her deposition testimony from the civil case. It next turns to her claim that the Government violated her right against unreasonable searches and seizures. Finally, it addresses Maxwell's claim that the Government misled Judge McMahon in seeking modification of the protective order in the earlier civil case. + +## A. The Government did not violate Maxwell's right against self-incrimination + +The Fifth Amendment provides that "[n]o person . . . shall be compelled in any criminal case to be a witness against himself." U.S. Const. amend. V. "The [Supreme] Court has held repeatedly that the Fifth Amendment is limited to prohibiting the use of 'physical or moral compulsion' exerted on the person asserting the privilege." Fisher v. United States, 425 U.S. 391, 397 (1976) (quoting Perlman v. United States, 247 U.S. 7, 15 (1918)). It does not prohibit the Government from using a defendant's voluntary statements in a subsequent criminal prosecution. + +To establish a violation of the right against compelled self-incrimination, Maxwell must "demonstrate the existence of three elements: I) compulsion, 2) a testimonial communication, and 3) the incriminating nature of that communication." In re Grand Jury Subpoena, 826 F.2d 1166, 1168 (2d Cir. 1987). Maxwell contends that the Government violated her right against compelled self-incrimination by obtaining copies of her deposition transcripts from her earlier civil case. She acknowledges that she could have, but did not, invoke her Fifth Amendment rights to avoid providing incriminating testimony. See, e.g., Pillsbury Co. v. Conboy, 459 U.S. 248, 263-24 & n.24 (1983). However, she contends that she testified only because she believed the protective order in that case would prevent the Government from obtaining her testimony and using it in a subsequent criminal case against her. + +Second Circuit precedent expressly forecloses Maxwell's argument. "A Rule 26(c) protective order, no matter how broad its reach, provides no guarantee that compelled testimony will not somehow find its way into the government's hands for use in a subsequent criminal prosecution." Andover Data Servs. v. Stat. Tabulating Corp., 876 F.2d 1080, 1083 (2d Cir. 1989). As the Second Circuit has explained, a civil protective order may (as here) be overturned or modified by another court in another proceeding. Id. A civil protective order may (as here) be limited by its terms to pretrial proceedings, in which case the parties must expect that confidential documents will come to light as the case progresses. See In re Agent Orange Prod. Liab. Litig., 821 F.2d 139, 147 (2d Cir. 1987); Dkt. No. 134-1 ¶ 13. A court may (as here) unseal documents covered by a civil protective order in the public interest. See Brown, 929 F.3d at 47; v. Maxwell, 827 F. App'x 144, 145 (2d Cir. 2020); Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 126 (2d Cir. 2006). Civil litigants have neither a reasonable basis nor legal entitlement to rely on a civil protective order against the use of their testimony in a subsequent criminal proceeding. + +Maxwell thus has failed to establish the first and most fundamental element of a violation of her right against compelled self-incrimination: compulsion. Because the protection typically afforded by a civil protective order is both porous and ephemeral, the Second Circuit has held that "a non-consenting witness may not be forced to answer potentially incriminating questions in reliance upon such an order." Andover, 876 F.2d at 1084. Maxwell was free to assert her Fifth Amendment rights in her civil case and refuse to offer incriminating testimony. Longstanding precedent made clear that if she did not do so, the Government could use any such testimony that it learned of against her in a later criminal case. Because the Government did not compel Maxwell to offer incriminating testimony, it did not violate her right against compelled self-incrimination. + +Maxwell's alternative argument that BSF's act of turning over her deposition transcripts was itself compelled testimony is likewise without merit. The Supreme Court has held that the act of producing documents in response to a subpoena implicates the Fifth Amendment only in narrow circumstances—when the existence of responsive documents, rather than their content, is + +inculpatory. Fisher, 425 U.S. at 410-11. This is no such case. The existence of deposition transcripts in Maxwell's civil case is not inculpatory. It is the content of those transcripts that is at issue. + +In the face of these straightforward precedents, Maxwell relies primarily on a single district court case decided the year before the Second Circuit's decision in Andover that quashed a subpoena for deposition testimony covered by a civil protective order. See Dkt. No. 140, at 16-17 (citing United States v. Oshatz, 700 F. Supp. 696 (S.D.N.Y. 1988)); Dkt. No. 212, at 12- 13 (same). Oshatz does not suggest that the use of civil deposition testimony in a subsequent criminal trial would violate a defendant's right against compelled self-incrimination—and if it did, that view would be plainly inconsistent with the Second Circuit's later, precedential opinions. Instead, the case simply describes the standard for whether a court should modify a protective order to allow a government subpoena. Maxwell cites no case in which a court has suppressed evidence because another court erred in modifying a protective order. Even if Maxwell were right that the protective order should not have been modified, it would not transform her earlier deposition testimony into the product of coercion. + +The Government would also be entitled to use Maxwell's deposition testimony against her in her perjury trial notwithstanding any violation of her right against compelled selfincrimination. The Supreme Court has held that a defendant may be prosecuted for false statements in unlawfully compelled testimony. See United States v. Wong, 431 U.S. 174,179 (1977); United States v. Knox, 396 U.S. 77,82 (1969). As in Knox, Maxwell seeks to suppress her deposition transcripts not because they are inculpatory "for a prior or subsequent criminal act" but because her statements in those depositions were themselves allegedly criminal. Knox, 396 U.S. at 82. In these circumstances, the Fifth Amendment does not bar the Government's use of her testimony in a prosecution for perjury. + +The Court thus concludes that Maxwell is not entitled to suppress her deposition transcripts based on her right against compelled self-incrimination. + +#### B. Maxwell had no reasonable expectation of privacy in documents produced in civil litigation + +"The Fourth Amendment protects `[t]he right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures.'" Carpenter v. United States, 138 S. Ct. 2206, 2213 (2018) (alteration in original) (quoting U.S. Const. amend. IV). Government activity qualifies as a search under the Fourth Amendment only if it involves a physical intrusion into a constitutionally protected space or the violation of a person's "reasonable expectation of privacy." United States v. Jones, 565 U.S. 400, 406-07 (2012) (quoting Katz v. United States, 389 U.S. 347, 360 (1967) (Harlan, J., concurring)). Thus, government agents need a warrant to rummage through someone's home, listen in on their phone calls, or search through their phones seized incident to arrest. The Fourth Amendment imposes no limitation on their ability to gather evidence of public activity or review public records. + +A person has a reasonable expectation of privacy only if they seek to keep something private and have an objectively reasonable expectation that it will remain private. Smith v. Maryland, 442 U.S. 735, 740 (1979). The Supreme Court has held that people generally lack a reasonable expectation of privacy in information they voluntarily disclose to others. See id. at 743-44; United States v. Miller, 425 U.S. 435, 440 (1976). This is true even if they expect that information to be safeguarded and used only for specific purposes. Thus, the Supreme Court has held that police may obtain bank records or a list of phone numbers a person has dialed without a warrant. Smith, 442 U.S. at 742; Miller, 425 U.S. at 440. In a lone exception to this rule, the + +Supreme Court has held that people have a reasonable expectation of privacy in geographical information obtained from their cell phones, because that information provides a comprehensive account of a person's movements akin to invasive physical surveillance. See Carpenter, 138 S. Ct. at 2219-20. + +Under this standard, Maxwell had no reasonable expectation of privacy in the documents produced during the civil litigation. Those documents may not have been public, but they were hardly private. The protective order allowed them to be shared freely with each of the following categories of people: + +- The parties to the case. +- Attorneys involved in the case. +- People employed by or associated with attorneys involved in the case. +- Expert witnesses. +- Fact witnesses. +- Potential witnesses. +- Court personnel and stenographers. + +It also allowed any documents to be publicly used at trial. This is not a case like Carpenter where new technology has allowed police to access heretofore "unknowable" information about a person's private life. Id. at 2218. This is a case where Maxwell shared information with third parties through the routine process of civil litigation and now objects that they shared it with the Government, too. + +Second Circuit precedent makes clear that Maxwell had no reasonable expectation that documents covered by the protective order would remain shielded from view of the public or prosecutors. The Second Circuit has cautioned civil litigants that a civil protective order is no guarantee against the use of evidence in a subsequent criminal prosecution. See Andover, 876 F.2d at 1083. Second Circuit precedent allows a court in a subsequent proceeding to modify a protective order. Id. And if confidential materials turn out to be relevant to a court's ruling, Second Circuit precedent creates a strong presumption that they will be made public notwithstanding any protective order. See Lugosch, 435 F.3d at 126. These are not remote or theoretical possibilities. Each of them predictably came to pass in this case. See Brown, 929 F.3d at 48 & n.22; 827 F. App'x at 145. It is "unrealistic" to believe that deposition testimony central to a civil case of high public interest will remain effectively sealed indefinitely. Andover, 876 F.2d at 1083. + +Maxwell claims that she did not expect the Government to be able to obtain her deposition testimony, and that if she knew it would, she never would have testified. If Maxwell subjectively harbored this belief, it was nonetheless unreasonable. See Smith, 442 U.S. at 743. The Court further notes that Maxwell was ably represented by a number of attorneys during the civil litigation, who the Court is confident were familiar with the precedents governing protective orders and public access to judicial documents. + +Because Maxwell had no reasonable expectation of privacy in documents shared with third parties during the civil case, the Government did not engage in a search when it obtained those documents from a third party by subpoena. Maxwell also makes a half-hearted argument that obtaining those documents was a seizure of her personal property. Copies of documents held by a law firm that represented Maxwell's adversary in a civil case were not Maxwell's personal property. Thus, the Government engaged in neither a search nor a seizure, and so it did not violate Maxwell's Fourth Amendment right against unreasonable searches and seizures. + +The Government also contends that even if it improperly obtained documents pursuant to the grand jury subpoena, the Court should not suppress those documents because the Government acted in good faith and would have obtained the documents anyway. See Nix v. + +Williams, 467 U.S. 431, 446 (1984); United States v. Leon, 468 U.S. 897, 922 (1984). The Court agrees that, at the very least, the exception to the exclusionary rule for inevitable discovery applies to the documents that have since been unsealed and made public in the civil case. But because the Court finds no violation of the Fourth Amendment, it concludes that none of the documents should be suppressed. + +## C. Maxwell is not entitled to suppression under due process or the Court's inherent authority + +Maxwell next argues that the materials must be suppressed because the Government violated her due process rights in obtaining them. The gravamen of this claim is that the Government misrepresented its prior contacts with BSF to Judge McMahon. Maxwell contends that this misrepresentation violated her due process rights, or alternatively that the Court should exercise its inherent authority to suppress the evidence obtained through the subpoena as a sanction for governmental misconduct. She contends that even an inadvertent misstatement to a court requires suppression of evidence obtained as a result. She further seeks an evidentiary hearing to explore whether any misrepresentation by the Government in that hearing was intentional. + +The Supreme Court has recognized that federal courts have a limited inherent authority to suppress evidence obtained in "willful disobedience of law." United States v. Payner, 447 U.S. 727, 735 n.7 (1980) (quoting McNabb v. United States, 318 U.S. 332, 345 (1943)). But it has also cautioned that courts must exercise this power with restraint. Id. Thus, "the court should not exercise its inherent or supervisory power `as a substitute for Fourth Amendment jurisprudence!" United States v. Lambus, 897 F.3d 368, 401 (2d Cir. 2018) (quoting United States v. Ming He, 94 F.3d 782, 792 (2d Cir. 1996)). In situations where the Fourth Amendment + +or another substantive constitutional provision supplies a standard for the suppression of evidence, courts must follow that standard, not invent their own. See Payner, 447 U.S. at 735. + +Maxwell has not established a violation of due process or justified the exercise of the Court's inherent supervisory authority. Not every misstep by the Government during a criminal investigation justifies suppressing relevant evidence. The Supreme Court has repeatedly explained that the exclusionary rule weighs the interest in deterring investigatory misconduct against the truth-seeking function of the judicial process. That balance "do[es] not change because a court has elected to analyze the question under the supervisory power instead of" some other constitutional provision. Id. at 736. Due process provides an independent basis to suppress evidence only when the Government engages in conduct that is "fundamentally unfair or shocking to our traditional sense of justice" or is "so outrageous that common notions of fairness and decency would be offended were judicial processes invoked to obtain a conviction against the accused." United States v. Schmidt, 105 F.3d 82, 91 (2d Cir. 1997) (internal quotation marks omitted). "Ordinarily such official misconduct must involve either coercion or violation of the defendant's person." Id. (citations omitted). This case involves neither. Omitting information about communications with BSF years earlier falls well short of the sort of extreme misconduct supporting suppression as a matter of due process. + +To the extent Maxwell asks the Court to engage in a freewheeling exercise of its inherent supervisory power instead, the Court declines to do so. To begin with, suppression under a court's supervisory authority is only appropriate, if at all, when the Government has engaged in "willful disobedience of law." Payner, 447 U.S. at 735 n.7 (emphasis added). Maxwell all but concedes that the present record does not show willful misconduct, contending instead that it "doesn't matter whether the prosecutor knew his statements to Judge McMahon were + +misleading. Dkt. No. 134, at 14. In any event, the Court is not without guidance on when a prosecutor's misrepresentation requires a court to suppress evidence. Precedent requires courts to adhere to the standards governing analogous Fourth Amendment claims when asked to suppress evidence under their inherent authority. See Lambus, 897 F.3d at 401-02. + +The Supreme Court has set out a clear standard governing when a misrepresentation to a magistrate in a warrant affidavit justifies suppression of evidence obtained as a result. See Franks v. Delaware, 438 U.S. 154 (1978). That standard requires more than an inadvertent misstatement. "To suppress evidence obtained pursuant to an affidavit containing erroneous information, the defendant must show that: (I) the claimed inaccuracies or omissions are the result of the affiant's deliberate falsehood or reckless disregard for the truth; and (2) the alleged falsehoods or omissions were necessary to the issuing judge's probable cause finding." United States v. Canfield, 212 F.3d 713,717-18 (2d Cir. 2000) (cleaned up). The Supreme Court's decision in Franks forecloses the argument that all misstatements to a court—even all intentional misstatements—necessarily require suppression. A defendant cannot circumvent this standard by couching the same arguments in due process or the court's inherent authority instead. See Payner, 447 U.S. at 736. + +Franks also defines the standard governing when a defendant is entitled to an evidentiary hearing on a motion to suppress based on the Government's misrepresentation to a court. To justify an evidentiary hearing, a defendant must make a "substantial preliminary showing" of a deliberately or recklessly false statement and that the alleged false statement was necessary to the court's decision. Franks, 438 U.S. at 155. "Allegations of negligence or innocent mistake are insufficient." Id. at 171. + +Although Maxwell relied on Franks in her opening brief, she argues in reply that she need not satisfy that standard. See Dkt. No. 134, at 16; Dkt. No. 285, at 23. However, she provides no explanation for why Franks should not apply. To the extent she offers any alternative framework in her reply, it is that an evidentiary hearing is required whenever any factual issue related to a motion to suppress is in dispute. That formulation is far too broad. + +The Court agrees with the Government (and the suggestion in Maxwell's opening brief) that Franks provides the appropriate standard for whether Maxwell is entitled to an evidentiary hearing on her motion. To be sure, these cases are not identical. Franks dealt with an alleged false statement in a warrant affidavit. This case involves an alleged false statement in a hearing to modify a protective order to allow a grand jury subpoena. Franks involved a claim under the Fourth Amendment, while Maxwell couches hers in the Fifth. But while not identical, these settings are closely analogous. Each involves alleged misstatements to a court that allowed the Government to obtain evidence. Each presents a risk of a defense fishing expedition where no wrongdoing appears on the face of the Government's application. Each requires balancing similar interests—deterrence of deliberate misconduct on the one hand, and suppression of evidence inevitably discovered or obtained through innocent error on the other. The Second Circuit has already extended Franks past its precise factual context to a motion to suppress based on alleged misrepresentations in a wiretap application. See United States v. Rajaratnam, 719 F.3d 139, 151 (2d Cir. 2013). The Court concludes that Maxwell must at least meet this standard for a similar claim invoking the Court's inherent authority. + +Maxwell must thus make a substantial preliminary showing on each of Franks' requirements to justify an evidentiary hearing. United States v. Salamelz, 152 F.3d 88, 113 (2d Cir. 1998). That is, she must first make a substantial preliminary showing that the Government deliberately or recklessly misrepresented facts to Judge McMahon. Second, she must make a substantial preliminary showing that Judge McMahon would have denied the Government's application absent any such misrepresentation. The Court finds that Maxwell has not made a substantial preliminary showing on either prong. + +Maxwell's argument here centers on the Government's statements to Judge McMahon during the second proceeding on April 9, 2019, concerning its application to modify the protective order. At that proceeding, Judge McMahon explained that she wanted to make sure the Government's request did not present a similar situation to that in Chemical Bank v. Affiliated FM Ins. Co., 154 F.R.D. 91 (S.D.N.Y. 1994), where a party in civil litigation urged prosecutors to instigate a criminal investigation and then provided confidential documents in violation of a protective order. To that end, she asked the Government to explain "contacts between the United States Attorney's Office and the Boies Schiller firm prior to the issuance of the subpoena on the subject of your investigation." The prosecutor at that hearing informed Judge McMahon about all communications between the U.S. Attorney's Office and BSF after the current investigation began—namely, that the Government told the firm that it intended to make a document request and that the firm told the Government that some of the materials were subject to a protective order. Although the prosecutor was included on an email several months earlier from the AUSA who met with attorneys in 2016, he did not inform Judge McMahon about any communications with BSF before the current investigation began. + +Maxwell has not made a substantial preliminary showing that the Government's statement was a deliberate or reckless misrepresentation. The AUSA could reasonably have understood Judge McMahon's question to concern only communications about the Government's current investigation. Maxwell contends that the question asked for any + +communications between BSF and the Government related to Epstein or Maxwell. But an equally plausible understanding of the phrase "on the subject of your investigation" is "related to the investigation itself." That interpretation is all the more reasonable in context, because Chemical Bank involved communications between a party subject to a protective order and prosecutors during a pending criminal investigation. See Chemical Bank, 154 F.R.D. at 93. It was not unreasonable for the prosecutor to assume that Judge McMahon was concerned with those sorts of communications, not communications years earlier that did not lead to a criminal investigation. The Government has represented that its present investigation into Epstein (and later Maxwell) began only following publication of the Miami Herald exposé in 2018. Maxwell has made no substantial preliminary showing to the contrary. + +The Court also concludes that Maxwell has made no substantial preliminary showing that Judge McMahon would have denied the Government's application to modify the protective order if she knew about the 2016 communications. Materiality under Franks requires more than that a fact be important. It allows suppression only if "the allegedly false statement is necessa?y" to the court's finding. Franks, 438 U.S. at 156 (emphasis added). If Judge McMahon would still have ruled that the Government was entitled to ex pane modification of the protective order even after setting aside the Government's alleged misrepresentation, then Maxwell is not entitled to suppression. Judge McMahon's opinion reflects that she would have. + +Judge McMahon's ruling rested on two independent grounds. Analyzing the Government's application under Martindell, she first held that Maxwell could not have reasonably relied on the protective order to keep the Government from obtaining documents produced during the civil litigation. Judge McMahon reasoned that a civil litigant ordinarily may not rely on a protective order subject to modification to keep evidence out of the hands of + +prosecutors. As the Court has explained above, this is consistent with the Second Circuit's statement that a protective order "provides no guarantee that [evidence] will not somehow find its way into the government's hands for use in a subsequent criminal prosecution." Andover, 876 F.2d at 1083. Judge McMahon further reasoned that Maxwell could only have reasonably relied on the protective order insofar as it prohibited BSF from fomenting an investigation against her with confidential documents. If Judge McMahon had known of the 2016 meeting, it is arguable—albeit far from certain—that she might have instead concluded that BSF breached Maxwell's reasonable reliance interests. + +But Judge McMahon also held that the Government had shown extraordinary circumstances justifying ex parte modification of the protective order. She observed that modification of the protective order would serve a "significant public interest" and that the Government had demonstrated good cause to obtain the sought materials through a grand jury subpoena without alerting potential targets of its criminal investigation. Extraordinary circumstances or compelling need provide a sufficient, independent basis to modify a protective order under Martindell notwithstanding the parties' reasonable reliance on that order. See Minpeco S.A. v. Conticommodity Servs., Inc., 832 F.2d 739, 742 (2d Cir. 1987) (citing Martindell, 594 F.2d at 296). Thus, even assuming that the Government should have told Judge McMahon about communications with BSF in 2016, and even assuming that information was material to her analysis of Maxwell's reasonable reliance on the protective order, Judge McMahon would still have granted the Government's application. Because the Government's alleged misrepresentation was not necessary to Judge McMahon's ruling, it cannot support suppression under Franks. + +The Court thus finds that Maxwell has not made a substantial preliminary showing under either prong of Franks, and thus that she is not entitled to an evidentiary hearing. For the same reasons, and because the present record does not establish a violation of due process, the Court declines to suppress the evidence obtained by the Government's grand jury subpoena. + +## D. Martindell provides no independent basis for suppression + +The Court turns finally to Maxwell's argument that Martindell provides an independent basis for suppression. Maxwell cites no authority in her opening brief for the proposition that a court may suppress evidence because it disagrees with another court's decision to modify a protective order under Martindell. Indeed, there is no such authority. No court has ever granted a motion to suppress on this ground. The Court declines to review Judge McMahon's decision, because Martindell provides no basis to suppress evidence even if this Court were to disagree with it. + +Even if Maxwell were right that this Court should review Judge McMahon's decision on the merits, that decision—like a magistrate's probable cause determination—would be entitled to "great deference." Leon, 468 U.S. at 914. Courts will uphold another judge's decision to allow the Government to obtain evidence on a motion to suppress so long as there is a "substantial basis" for the decision. Salameh, 152 F.3d at 113 (quoting Illinois v. Gates, 462 U.S. 213, 238- 39 (1983)). Judge McMahon found that the Government had established exceptional circumstances to modify the protective order based on the factual record before her. Judge McMahon concluded that modification was necessary under the circumstances to allow the Government to investigate a high-profile matter in secrecy and so not to tip off the target of the investigation. Although reasonable minds may differ—indeed, Judge Netbum reached the opposite conclusion—there was a substantial basis for Judge McMahon's decision and it is thus + +entitled to deference. As discussed, the Court is aware of no authority suggesting review of Judge McMahon's modification order is necessary or appropriate in these circumstances. If necessary, the Court would afford it deference and would not disturb Judge McMahon's reasoned and supported decision. + +Maxwell's reply brief recasts her claim for suppression under Martindell as simply another argument for suppression under due process or the Court's inherent authority. Because, in her view, the Government did not satisfy the requirements of Martindell, its attempt to modify the protective order violated her due process rights. And because, she alleges, the Government misrepresented facts to Judge McMahon, this Court should exercise its inherent authority to suppress evidence as a sanction for governmental misconduct. + +The Court is not persuaded. For the reasons set forth above, the Government's application for modification of the protective order did not violate Maxwell's due process rights. Due process does not categorically bar an ex parte modification to a protective order, and Judge McMahon found that the Government had shown extraordinary circumstances to do so. To the extent Maxwell seeks suppression based on an alleged misrepresentation to Judge McMahon, for the reasons set forth above, she has not met the high bar for a due process violation or made the required showing under Franks that would entitle her to an evidentiary hearing. Whether Maxwell advances these arguments under Martindell or directly under due process, they do not support suppression. + +# Conclusion + +For the foregoing reasons, the Court finds that the Government did not violate Maxwell's constitutional rights when it obtained evidence covered by a protective order in her earlier civil case. It further finds that Maxwell is not entitled to suppression of any evidence or to an + +evidentiary hearing. The Court thus DENIES Maxwell's motions to suppress (Dkt. Nos. 133, 139). + +SO ORDERED. + +Dated: June 25, 2021 +New York, New York + +![]() + +--- + +ALISON J. NATHAN +United States District Judge \ No newline at end of file diff --git a/marker2/ds9/EFTA00087230/EFTA00087230.metadata.json b/marker2/ds9/EFTA00087230/EFTA00087230.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..26c5fc852b4770ba0bca0ecd40cb58028c76dd77 --- /dev/null +++ b/marker2/ds9/EFTA00087230/EFTA00087230.metadata.json @@ -0,0 +1,879 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087230.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 21, + "chars": 38755, + "elapsed_seconds": 3.91, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 71.28 + ], + [ + 281.019775390625, + 71.28 + ], + [ + 281.019775390625, + 99.603515625 + ], + [ + 68.544, + 99.603515625 + ] + ] + }, + { + "title": "I. 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NATHAN, District Judge: + +Maxwell moves to suppress evidence obtained through a grand jury subpoena to a law firm involved in earlier civil litigation against her. She contends that because the documents sought by the subpoena were previously subject to a protective order, the Government obtained them in violation of her rights against compelled self-incrimination, against unreasonable searches and seizures, and to due process of law. For the reasons that follow, the Court concludes that the evidence should not be suppressed and that Maxwell is not entitled to an evidentiary hearing. + +# I. Background + +In late 2015, sued Maxwell for defamation. See v. Maxwell, No. 15-cv-7433 (S.D.N.Y.). alleged that Maxwell defamed her by accusing her of lying about Maxwell and Jeffrey Epstein sexually abusing her. The law firm Boies Schiller Flexner LLP (BSF) represented in the dispute. The parties litigated the case for about two years before signing a confidential settlement agreement. + +Early in the civil litigation, one of the attorneys representing approached an Assistant United States Attorney (AUSA) in the Southern District of New York and requested a meeting to provide the Government information on possible criminal conduct. The AUSA met with three attorneys who represented on February 29, 2016. The AUSA's notes from the meeting reflect that it focused primarily on Epstein. However, the notes also identify Maxwell as Epstein's "head recruiter" of underage girls. The attorneys sent a few follow-up emails to the AUSA in the following weeks. The United States Attorney's Office did not pursue a criminal investigation at that time. + +Maxwell claims based on a New York Daily News article published in October 2020 that a second meeting took place between federal prosecutors and a principal of BSF in the summer of 2016. The Government has represented to the Court that the AUSA who participated in the February 29, 2016 meeting did not participate in a second meeting with BSF attorneys and that the Government has "uncovered no evidence that such a meeting ever occurred." Dkt. No. 204, at 92. However, for purposes of deciding this motion, the Court assumes that it occurred. + +About two weeks after the February 29, 2016 meeting, the judge presiding over the civil case entered a protective order that allowed the parties in that case to designate documents produced in discovery as confidential. See Dkt. No. 134-1. That order prohibited the parties from disclosing confidential documents to anyone other than people involved in the case. Although BSF initially proposed language that would allow disclosure of documents to law enforcement without a court order, the final version of the protective order included no such exception. The protective order did not require the parties to obtain the court's approval to mark a document as confidential. It allowed the court to modify the order at any time for good cause after notice to the parties. It also allowed the parties to use any confidential information at trial, at which point that information would become public. It required the parties to return or destroy confidential records after the case ended. + +Following entry of the protective order, Maxwell testified in two depositions in the civil case. The parties designated the depositions as confidential under the protective order. Counts five and six of the SI superseding indictment in this case (and counts seven and eight of the S2 superseding indictment) charge that Maxwell made false statements under oath in each of the depositions. + +The Government represents that the Office of the U.S. Attorney for the Southern District of New York formally opened its investigation into Epstein on November 30, 2018, following a series of articles in the Miami Herald about Epstein's conduct and the lenient plea deal he received in the Southern District of Florida. The same day, the AUSA who attended the February 2016 meeting forwarded the emails she received from attorneys in the civil case to the prosecutors working on the fledgling investigation. There is no indication that she was involved in the decision to begin the investigation into Epstein in 2018. + +About two months later, the Government served a grand jury subpoena on BSF seeking to obtain documents for its investigation of Epstein. BSF informed the Government that many of the requested documents fell under the protective order. The Government then applied for an ex parte order modifying the protective order to allow BSF to comply with the subpoena. The Government made a second, similar application in connection with a protective order in a different case. + +The judge who presided over the civil case passed away in March 2019, and so then-Chief Judge McMahon heard the Government's ex parte application. In a hearing on March 26, 2019, Judge McMahon explained that she believed the Second Circuit's decision in Martindell v. International Telephone & Telegraph Coip., 594 F.2d 291 (2d Cir. 1979), governed the Government's application. Martindell held that a party should not provide documents subject to + +a protective order to the Government absent a formal motion or subpoena. It further held that a court should modify a protective order that a party reasonably relied on only if the order had been improvidently granted or upon a showing of extraordinary circumstances or compelling need. + +Judge McMahon held a second ex parte hearing on April 9, 2019. At that hearing, citing a district court case called Chemical Bank for the proposition that civil litigants ought not foment criminal investigations against their opponents to gain strategic advantage, she asked the Government about contacts between the U.S. Attorney's Office and BSF on the subject of the Government's investigation. The Government explained that BSF had informed the Government that some of the documents the Government sought were covered by a protective order. The Government did not mention any of the communications with BSF attorneys in 2016. + +Judge McMahon issued a sealed order granting the Government's application followed by a sealed opinion dated April 9, 2019. In the opinion, she explained that Martindell governed the Government's application, but that two of the Martindell factors supported modification of the protective order. First, Maxwell did not reasonably rely on the protective order because it was subject to modification. Second, the Government had shown extraordinary circumstances supporting modification of the protective order because it could not otherwise obtain information about the high-profile targets of its investigation without tipping them off. Magistrate Judge Netbum denied the Government's similar application in another case, applying the same standard but concluding that the Government had not shown extraordinary circumstances or compelling need. + +Following Judge McMahon's order, BSF turned over its records from the civil litigation to the Government. Those documents included transcripts of Maxwell's depositions. The + +Second Circuit later held that the court in the civil case withheld far too many documents from public view and ordered that many of them be made publicly available. Brown v. Maxwell, 929 F.3d 41, 53 (2d Cir. 2019). Much of what the Government obtained through its subpoena, including the bulk of the deposition transcripts Maxwell now seeks to suppress, have since been unsealed by court order in the civil case. See , No. 15-cv-7433, Dkt. Nos. 1137, 1212. + +# II. Discussion + +Maxwell objects both to the Government obtaining documents covered by the protective order and to the Government's conduct in doing so. She contends that she agreed to testify in the civil case only because of the protective order, and thus that the Government's use of her deposition testimony against her would violate her right against compelled self-incrimination. She contends that she had a reasonable expectation of privacy in the documents covered by the protective order, and thus that the Government should not have been able to obtain them without a warrant. And she contends that the Government circumvented the requirements of Martindell and violated her due process rights by misleading Judge McMahon about the Government's prior communications with BSF. + +The Court finds that none of these arguments support suppression of evidence or justify an evidentiary hearing. The Court begins with Maxwell's claim that the Government violated her right against compelled self-incrimination by obtaining her deposition testimony from the civil case. It next turns to her claim that the Government violated her right against unreasonable searches and seizures. Finally, it addresses Maxwell's claim that the Government misled Judge McMahon in seeking modification of the protective order in the earlier civil case. + +### A. The Government did not violate Maxwell's right against self-incrimination + +The Fifth Amendment provides that "[n]o person . . . shall be compelled in any criminal case to be a witness against himself." U.S. Const. amend. V. "The [Supreme] Court has held repeatedly that the Fifth Amendment is limited to prohibiting the use of 'physical or moral compulsion' exerted on the person asserting the privilege." Fisher v. United States, 425 U.S. 391, 397 (1976) (quoting Perlman v. United States, 247 U.S. 7, 15 (1918)). It does not prohibit the Government from using a defendant's voluntary statements in a subsequent criminal prosecution. + +To establish a violation of the right against compelled self-incrimination, Maxwell must "demonstrate the existence of three elements: I) compulsion, 2) a testimonial communication, and 3) the incriminating nature of that communication." In re Grand Jury Subpoena, 826 F.2d 1166, 1168 (2d Cir. 1987). Maxwell contends that the Government violated her right against compelled self-incrimination by obtaining copies of her deposition transcripts from her earlier civil case. She acknowledges that she could have, but did not, invoke her Fifth Amendment rights to avoid providing incriminating testimony. See, e.g., Pillsbury Co. v. Conboy, 459 U.S. 248, 263-24 & n.24 (1983). However, she contends that she testified only because she believed the protective order in that case would prevent the Government from obtaining her testimony and using it in a subsequent criminal case against her. + +Second Circuit precedent expressly forecloses Maxwell's argument. "A Rule 26(c) protective order, no matter how broad its reach, provides no guarantee that compelled testimony will not somehow find its way into the government's hands for use in a subsequent criminal prosecution." Andover Data Servs. v. Stat. Tabulating Corp., 876 F.2d 1080, 1083 (2d Cir. 1989). As the Second Circuit has explained, a civil protective order may (as here) be overturned or modified by another court in another proceeding. Id. A civil protective order may (as here) be limited by its terms to pretrial proceedings, in which case the parties must expect that confidential documents will come to light as the case progresses. See In re Agent Orange Prod. Liab. Litig., 821 F.2d 139, 147 (2d Cir. 1987); Dkt. No. 134-1 ¶ 13. A court may (as here) unseal documents covered by a civil protective order in the public interest. See Brown, 929 F.3d at 47; v. Maxwell, 827 F. App'x 144, 145 (2d Cir. 2020); Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 126 (2d Cir. 2006). Civil litigants have neither a reasonable basis nor legal entitlement to rely on a civil protective order against the use of their testimony in a subsequent criminal proceeding. + +Maxwell thus has failed to establish the first and most fundamental element of a violation of her right against compelled self-incrimination: compulsion. Because the protection typically afforded by a civil protective order is both porous and ephemeral, the Second Circuit has held that "a non-consenting witness may not be forced to answer potentially incriminating questions in reliance upon such an order." Andover, 876 F.2d at 1084. Maxwell was free to assert her Fifth Amendment rights in her civil case and refuse to offer incriminating testimony. Longstanding precedent made clear that if she did not do so, the Government could use any such testimony that it learned of against her in a later criminal case. Because the Government did not compel Maxwell to offer incriminating testimony, it did not violate her right against compelled self-incrimination. + +Maxwell's alternative argument that BSF's act of turning over her deposition transcripts was itself compelled testimony is likewise without merit. The Supreme Court has held that the act of producing documents in response to a subpoena implicates the Fifth Amendment only in narrow circumstances—when the existence of responsive documents, rather than their content, is + +inculpatory. Fisher, 425 U.S. at 410-11. This is no such case. The existence of deposition transcripts in Maxwell's civil case is not inculpatory. It is the content of those transcripts that is at issue. + +In the face of these straightforward precedents, Maxwell relies primarily on a single district court case decided the year before the Second Circuit's decision in Andover that quashed a subpoena for deposition testimony covered by a civil protective order. See Dkt. No. 140, at 16-17 (citing United States v. Oshatz, 700 F. Supp. 696 (S.D.N.Y. 1988)); Dkt. No. 212, at 12- 13 (same). Oshatz does not suggest that the use of civil deposition testimony in a subsequent criminal trial would violate a defendant's right against compelled self-incrimination—and if it did, that view would be plainly inconsistent with the Second Circuit's later, precedential opinions. Instead, the case simply describes the standard for whether a court should modify a protective order to allow a government subpoena. Maxwell cites no case in which a court has suppressed evidence because another court erred in modifying a protective order. Even if Maxwell were right that the protective order should not have been modified, it would not transform her earlier deposition testimony into the product of coercion. + +The Government would also be entitled to use Maxwell's deposition testimony against her in her perjury trial notwithstanding any violation of her right against compelled selfincrimination. The Supreme Court has held that a defendant may be prosecuted for false statements in unlawfully compelled testimony. See United States v. Wong, 431 U.S. 174,179 (1977); United States v. Knox, 396 U.S. 77,82 (1969). As in Knox, Maxwell seeks to suppress her deposition transcripts not because they are inculpatory "for a prior or subsequent criminal act" but because her statements in those depositions were themselves allegedly criminal. Knox, 396 U.S. at 82. In these circumstances, the Fifth Amendment does not bar the Government's use of her testimony in a prosecution for perjury. + +The Court thus concludes that Maxwell is not entitled to suppress her deposition transcripts based on her right against compelled self-incrimination. + +#### B. Maxwell had no reasonable expectation of privacy in documents produced in civil litigation + +"The Fourth Amendment protects `[t]he right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures.'" Carpenter v. United States, 138 S. Ct. 2206, 2213 (2018) (alteration in original) (quoting U.S. Const. amend. IV). Government activity qualifies as a search under the Fourth Amendment only if it involves a physical intrusion into a constitutionally protected space or the violation of a person's "reasonable expectation of privacy." United States v. Jones, 565 U.S. 400, 406-07 (2012) (quoting Katz v. United States, 389 U.S. 347, 360 (1967) (Harlan, J., concurring)). Thus, government agents need a warrant to rummage through someone's home, listen in on their phone calls, or search through their phones seized incident to arrest. The Fourth Amendment imposes no limitation on their ability to gather evidence of public activity or review public records. + +A person has a reasonable expectation of privacy only if they seek to keep something private and have an objectively reasonable expectation that it will remain private. Smith v. Maryland, 442 U.S. 735, 740 (1979). The Supreme Court has held that people generally lack a reasonable expectation of privacy in information they voluntarily disclose to others. See id. at 743-44; United States v. Miller, 425 U.S. 435, 440 (1976). This is true even if they expect that information to be safeguarded and used only for specific purposes. Thus, the Supreme Court has held that police may obtain bank records or a list of phone numbers a person has dialed without a warrant. Smith, 442 U.S. at 742; Miller, 425 U.S. at 440. In a lone exception to this rule, the + +Supreme Court has held that people have a reasonable expectation of privacy in geographical information obtained from their cell phones, because that information provides a comprehensive account of a person's movements akin to invasive physical surveillance. See Carpenter, 138 S. Ct. at 2219-20. + +Under this standard, Maxwell had no reasonable expectation of privacy in the documents produced during the civil litigation. Those documents may not have been public, but they were hardly private. The protective order allowed them to be shared freely with each of the following categories of people: + +- The parties to the case. +- Attorneys involved in the case. +- People employed by or associated with attorneys involved in the case. +- Expert witnesses. +- Fact witnesses. +- Potential witnesses. +- Court personnel and stenographers. + +It also allowed any documents to be publicly used at trial. This is not a case like Carpenter where new technology has allowed police to access heretofore "unknowable" information about a person's private life. Id. at 2218. This is a case where Maxwell shared information with third parties through the routine process of civil litigation and now objects that they shared it with the Government, too. + +Second Circuit precedent makes clear that Maxwell had no reasonable expectation that documents covered by the protective order would remain shielded from view of the public or prosecutors. The Second Circuit has cautioned civil litigants that a civil protective order is no guarantee against the use of evidence in a subsequent criminal prosecution. See Andover, 876 F.2d at 1083. Second Circuit precedent allows a court in a subsequent proceeding to modify a protective order. Id. And if confidential materials turn out to be relevant to a court's ruling, Second Circuit precedent creates a strong presumption that they will be made public notwithstanding any protective order. See Lugosch, 435 F.3d at 126. These are not remote or theoretical possibilities. Each of them predictably came to pass in this case. See Brown, 929 F.3d at 48 & n.22; 827 F. App'x at 145. It is "unrealistic" to believe that deposition testimony central to a civil case of high public interest will remain effectively sealed indefinitely. Andover, 876 F.2d at 1083. + +Maxwell claims that she did not expect the Government to be able to obtain her deposition testimony, and that if she knew it would, she never would have testified. If Maxwell subjectively harbored this belief, it was nonetheless unreasonable. See Smith, 442 U.S. at 743. The Court further notes that Maxwell was ably represented by a number of attorneys during the civil litigation, who the Court is confident were familiar with the precedents governing protective orders and public access to judicial documents. + +Because Maxwell had no reasonable expectation of privacy in documents shared with third parties during the civil case, the Government did not engage in a search when it obtained those documents from a third party by subpoena. Maxwell also makes a half-hearted argument that obtaining those documents was a seizure of her personal property. Copies of documents held by a law firm that represented Maxwell's adversary in a civil case were not Maxwell's personal property. Thus, the Government engaged in neither a search nor a seizure, and so it did not violate Maxwell's Fourth Amendment right against unreasonable searches and seizures. + +The Government also contends that even if it improperly obtained documents pursuant to the grand jury subpoena, the Court should not suppress those documents because the Government acted in good faith and would have obtained the documents anyway. See Nix v. + +Williams, 467 U.S. 431, 446 (1984); United States v. Leon, 468 U.S. 897, 922 (1984). The Court agrees that, at the very least, the exception to the exclusionary rule for inevitable discovery applies to the documents that have since been unsealed and made public in the civil case. But because the Court finds no violation of the Fourth Amendment, it concludes that none of the documents should be suppressed. + +#### C. Maxwell is not entitled to suppression under due process or the Court's inherent authority + +Maxwell next argues that the materials must be suppressed because the Government violated her due process rights in obtaining them. The gravamen of this claim is that the Government misrepresented its prior contacts with BSF to Judge McMahon. Maxwell contends that this misrepresentation violated her due process rights, or alternatively that the Court should exercise its inherent authority to suppress the evidence obtained through the subpoena as a sanction for governmental misconduct. She contends that even an inadvertent misstatement to a court requires suppression of evidence obtained as a result. She further seeks an evidentiary hearing to explore whether any misrepresentation by the Government in that hearing was intentional. + +The Supreme Court has recognized that federal courts have a limited inherent authority to suppress evidence obtained in "willful disobedience of law." United States v. Payner, 447 U.S. 727, 735 n.7 (1980) (quoting McNabb v. United States, 318 U.S. 332, 345 (1943)). But it has also cautioned that courts must exercise this power with restraint. Id. Thus, "the court should not exercise its inherent or supervisory power `as a substitute for Fourth Amendment jurisprudence!" United States v. Lambus, 897 F.3d 368, 401 (2d Cir. 2018) (quoting United States v. Ming He, 94 F.3d 782, 792 (2d Cir. 1996)). In situations where the Fourth Amendment + +or another substantive constitutional provision supplies a standard for the suppression of evidence, courts must follow that standard, not invent their own. See Payner, 447 U.S. at 735. + +Maxwell has not established a violation of due process or justified the exercise of the Court's inherent supervisory authority. Not every misstep by the Government during a criminal investigation justifies suppressing relevant evidence. The Supreme Court has repeatedly explained that the exclusionary rule weighs the interest in deterring investigatory misconduct against the truth-seeking function of the judicial process. That balance "do[es] not change because a court has elected to analyze the question under the supervisory power instead of" some other constitutional provision. Id. at 736. Due process provides an independent basis to suppress evidence only when the Government engages in conduct that is "fundamentally unfair or shocking to our traditional sense of justice" or is "so outrageous that common notions of fairness and decency would be offended were judicial processes invoked to obtain a conviction against the accused." United States v. Schmidt, 105 F.3d 82, 91 (2d Cir. 1997) (internal quotation marks omitted). "Ordinarily such official misconduct must involve either coercion or violation of the defendant's person." Id. (citations omitted). This case involves neither. Omitting information about communications with BSF years earlier falls well short of the sort of extreme misconduct supporting suppression as a matter of due process. + +To the extent Maxwell asks the Court to engage in a freewheeling exercise of its inherent supervisory power instead, the Court declines to do so. To begin with, suppression under a court's supervisory authority is only appropriate, if at all, when the Government has engaged in "willful disobedience of law." Payner, 447 U.S. at 735 n.7 (emphasis added). Maxwell all but concedes that the present record does not show willful misconduct, contending instead that it "doesn't matter whether the prosecutor knew his statements to Judge McMahon were + +misleading. Dkt. No. 134, at 14. In any event, the Court is not without guidance on when a prosecutor's misrepresentation requires a court to suppress evidence. Precedent requires courts to adhere to the standards governing analogous Fourth Amendment claims when asked to suppress evidence under their inherent authority. See Lambus, 897 F.3d at 401-02. + +The Supreme Court has set out a clear standard governing when a misrepresentation to a magistrate in a warrant affidavit justifies suppression of evidence obtained as a result. See Franks v. Delaware, 438 U.S. 154 (1978). That standard requires more than an inadvertent misstatement. "To suppress evidence obtained pursuant to an affidavit containing erroneous information, the defendant must show that: (I) the claimed inaccuracies or omissions are the result of the affiant's deliberate falsehood or reckless disregard for the truth; and (2) the alleged falsehoods or omissions were necessary to the issuing judge's probable cause finding." United States v. Canfield, 212 F.3d 713,717-18 (2d Cir. 2000) (cleaned up). The Supreme Court's decision in Franks forecloses the argument that all misstatements to a court—even all intentional misstatements—necessarily require suppression. A defendant cannot circumvent this standard by couching the same arguments in due process or the court's inherent authority instead. See Payner, 447 U.S. at 736. + +Franks also defines the standard governing when a defendant is entitled to an evidentiary hearing on a motion to suppress based on the Government's misrepresentation to a court. To justify an evidentiary hearing, a defendant must make a "substantial preliminary showing" of a deliberately or recklessly false statement and that the alleged false statement was necessary to the court's decision. Franks, 438 U.S. at 155. "Allegations of negligence or innocent mistake are insufficient." Id. at 171. + +Although Maxwell relied on Franks in her opening brief, she argues in reply that she need not satisfy that standard. See Dkt. No. 134, at 16; Dkt. No. 285, at 23. However, she provides no explanation for why Franks should not apply. To the extent she offers any alternative framework in her reply, it is that an evidentiary hearing is required whenever any factual issue related to a motion to suppress is in dispute. That formulation is far too broad. + +The Court agrees with the Government (and the suggestion in Maxwell's opening brief) that Franks provides the appropriate standard for whether Maxwell is entitled to an evidentiary hearing on her motion. To be sure, these cases are not identical. Franks dealt with an alleged false statement in a warrant affidavit. This case involves an alleged false statement in a hearing to modify a protective order to allow a grand jury subpoena. Franks involved a claim under the Fourth Amendment, while Maxwell couches hers in the Fifth. But while not identical, these settings are closely analogous. Each involves alleged misstatements to a court that allowed the Government to obtain evidence. Each presents a risk of a defense fishing expedition where no wrongdoing appears on the face of the Government's application. Each requires balancing similar interests—deterrence of deliberate misconduct on the one hand, and suppression of evidence inevitably discovered or obtained through innocent error on the other. The Second Circuit has already extended Franks past its precise factual context to a motion to suppress based on alleged misrepresentations in a wiretap application. See United States v. Rajaratnam, 719 F.3d 139, 151 (2d Cir. 2013). The Court concludes that Maxwell must at least meet this standard for a similar claim invoking the Court's inherent authority. + +Maxwell must thus make a substantial preliminary showing on each of Franks' requirements to justify an evidentiary hearing. United States v. Salamelz, 152 F.3d 88, 113 (2d Cir. 1998). That is, she must first make a substantial preliminary showing that the Government deliberately or recklessly misrepresented facts to Judge McMahon. Second, she must make a substantial preliminary showing that Judge McMahon would have denied the Government's application absent any such misrepresentation. The Court finds that Maxwell has not made a substantial preliminary showing on either prong. + +Maxwell's argument here centers on the Government's statements to Judge McMahon during the second proceeding on April 9, 2019, concerning its application to modify the protective order. At that proceeding, Judge McMahon explained that she wanted to make sure the Government's request did not present a similar situation to that in Chemical Bank v. Affiliated FM Ins. Co., 154 F.R.D. 91 (S.D.N.Y. 1994), where a party in civil litigation urged prosecutors to instigate a criminal investigation and then provided confidential documents in violation of a protective order. To that end, she asked the Government to explain "contacts between the United States Attorney's Office and the Boies Schiller firm prior to the issuance of the subpoena on the subject of your investigation." The prosecutor at that hearing informed Judge McMahon about all communications between the U.S. Attorney's Office and BSF after the current investigation began—namely, that the Government told the firm that it intended to make a document request and that the firm told the Government that some of the materials were subject to a protective order. Although the prosecutor was included on an email several months earlier from the AUSA who met with attorneys in 2016, he did not inform Judge McMahon about any communications with BSF before the current investigation began. + +Maxwell has not made a substantial preliminary showing that the Government's statement was a deliberate or reckless misrepresentation. The AUSA could reasonably have understood Judge McMahon's question to concern only communications about the Government's current investigation. Maxwell contends that the question asked for any + +communications between BSF and the Government related to Epstein or Maxwell. But an equally plausible understanding of the phrase "on the subject of your investigation" is "related to the investigation itself." That interpretation is all the more reasonable in context, because Chemical Bank involved communications between a party subject to a protective order and prosecutors during a pending criminal investigation. See Chemical Bank, 154 F.R.D. at 93. It was not unreasonable for the prosecutor to assume that Judge McMahon was concerned with those sorts of communications, not communications years earlier that did not lead to a criminal investigation. The Government has represented that its present investigation into Epstein (and later Maxwell) began only following publication of the Miami Herald exposé in 2018. Maxwell has made no substantial preliminary showing to the contrary. + +The Court also concludes that Maxwell has made no substantial preliminary showing that Judge McMahon would have denied the Government's application to modify the protective order if she knew about the 2016 communications. Materiality under Franks requires more than that a fact be important. It allows suppression only if "the allegedly false statement is necessa?y" to the court's finding. Franks, 438 U.S. at 156 (emphasis added). If Judge McMahon would still have ruled that the Government was entitled to ex pane modification of the protective order even after setting aside the Government's alleged misrepresentation, then Maxwell is not entitled to suppression. Judge McMahon's opinion reflects that she would have. + +Judge McMahon's ruling rested on two independent grounds. Analyzing the Government's application under Martindell, she first held that Maxwell could not have reasonably relied on the protective order to keep the Government from obtaining documents produced during the civil litigation. Judge McMahon reasoned that a civil litigant ordinarily may not rely on a protective order subject to modification to keep evidence out of the hands of + +prosecutors. As the Court has explained above, this is consistent with the Second Circuit's statement that a protective order "provides no guarantee that [evidence] will not somehow find its way into the government's hands for use in a subsequent criminal prosecution." Andover, 876 F.2d at 1083. Judge McMahon further reasoned that Maxwell could only have reasonably relied on the protective order insofar as it prohibited BSF from fomenting an investigation against her with confidential documents. If Judge McMahon had known of the 2016 meeting, it is arguable—albeit far from certain—that she might have instead concluded that BSF breached Maxwell's reasonable reliance interests. + +But Judge McMahon also held that the Government had shown extraordinary circumstances justifying ex parte modification of the protective order. She observed that modification of the protective order would serve a "significant public interest" and that the Government had demonstrated good cause to obtain the sought materials through a grand jury subpoena without alerting potential targets of its criminal investigation. Extraordinary circumstances or compelling need provide a sufficient, independent basis to modify a protective order under Martindell notwithstanding the parties' reasonable reliance on that order. See Minpeco S.A. v. Conticommodity Servs., Inc., 832 F.2d 739, 742 (2d Cir. 1987) (citing Martindell, 594 F.2d at 296). Thus, even assuming that the Government should have told Judge McMahon about communications with BSF in 2016, and even assuming that information was material to her analysis of Maxwell's reasonable reliance on the protective order, Judge McMahon would still have granted the Government's application. Because the Government's alleged misrepresentation was not necessary to Judge McMahon's ruling, it cannot support suppression under Franks. + +The Court thus finds that Maxwell has not made a substantial preliminary showing under either prong of Franks, and thus that she is not entitled to an evidentiary hearing. For the same reasons, and because the present record does not establish a violation of due process, the Court declines to suppress the evidence obtained by the Government's grand jury subpoena. + +## D. Martindell provides no independent basis for suppression + +The Court turns finally to Maxwell's argument that Martindell provides an independent basis for suppression. Maxwell cites no authority in her opening brief for the proposition that a court may suppress evidence because it disagrees with another court's decision to modify a protective order under Martindell. Indeed, there is no such authority. No court has ever granted a motion to suppress on this ground. The Court declines to review Judge McMahon's decision, because Martindell provides no basis to suppress evidence even if this Court were to disagree with it. + +Even if Maxwell were right that this Court should review Judge McMahon's decision on the merits, that decision—like a magistrate's probable cause determination—would be entitled to "great deference." Leon, 468 U.S. at 914. Courts will uphold another judge's decision to allow the Government to obtain evidence on a motion to suppress so long as there is a "substantial basis" for the decision. Salameh, 152 F.3d at 113 (quoting Illinois v. Gates, 462 U.S. 213, 238- 39 (1983)). Judge McMahon found that the Government had established exceptional circumstances to modify the protective order based on the factual record before her. Judge McMahon concluded that modification was necessary under the circumstances to allow the Government to investigate a high-profile matter in secrecy and so not to tip off the target of the investigation. Although reasonable minds may differ—indeed, Judge Netbum reached the opposite conclusion—there was a substantial basis for Judge McMahon's decision and it is thus + +entitled to deference. As discussed, the Court is aware of no authority suggesting review of Judge McMahon's modification order is necessary or appropriate in these circumstances. If necessary, the Court would afford it deference and would not disturb Judge McMahon's reasoned and supported decision. + +Maxwell's reply brief recasts her claim for suppression under Martindell as simply another argument for suppression under due process or the Court's inherent authority. Because, in her view, the Government did not satisfy the requirements of Martindell, its attempt to modify the protective order violated her due process rights. And because, she alleges, the Government misrepresented facts to Judge McMahon, this Court should exercise its inherent authority to suppress evidence as a sanction for governmental misconduct. + +The Court is not persuaded. For the reasons set forth above, the Government's application for modification of the protective order did not violate Maxwell's due process rights. Due process does not categorically bar an ex parte modification to a protective order, and Judge McMahon found that the Government had shown extraordinary circumstances to do so. To the extent Maxwell seeks suppression based on an alleged misrepresentation to Judge McMahon, for the reasons set forth above, she has not met the high bar for a due process violation or made the required showing under Franks that would entitle her to an evidentiary hearing. Whether Maxwell advances these arguments under Martindell or directly under due process, they do not support suppression. + +# Conclusion + +For the foregoing reasons, the Court finds that the Government did not violate Maxwell's constitutional rights when it obtained evidence covered by a protective order in her earlier civil case. It further finds that Maxwell is not entitled to suppression of any evidence or to an + +evidentiary hearing. The Court thus DENIES Maxwell's motions to suppress (Dkt. Nos. 133, 139). + +SO ORDERED. + +Dated: June 25, 2021 +New York, New York + +![]() + +--- + +ALISON J. NATHAN +United States District Judge \ No newline at end of file diff --git a/marker2/ds9/EFTA00087251/EFTA00087251.metadata.json b/marker2/ds9/EFTA00087251/EFTA00087251.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..3d513ce9d93c8543a904914141a6408266ca8392 --- /dev/null +++ b/marker2/ds9/EFTA00087251/EFTA00087251.metadata.json @@ -0,0 +1,879 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087251.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 21, + "chars": 38758, + "elapsed_seconds": 3.83, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 71.28 + ], + [ + 281.019775390625, + 71.28 + ], + [ + 281.019775390625, + 99.603515625 + ], + [ + 68.544, + 99.603515625 + ] + ] + }, + { + "title": "I. 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We can call you then. + +From ‹ > Sent: Tuesday, May 19, 2020 8:09 AM To: (USANYS) < Cc: (USANYS) Subject: Re: estate liquidation + +I can't do 10. I could probably do 11. + +On May 19, 2020, at 7:58 AM, (USANYS) < > wrote: + +Me too. 10? 11? + +Sent from my iPhone + +On May 18, 2020, at 6:57 PM, (USANYS) < > wrote: + +Good for me. + +Sent from my iPhone + +On May 18, 2020, at 5:54 PM (USANYS) < > wrote: + +Sure. Perhaps tomorrow morning? + +From: (USANYS) Sent: Monday. May 18. 2020 4:46 PM To: Cc: Subject: FW: RE: estate liquidation + +See below re: Epstein properties. If you have some time, I'd like to talk whether/how best to elevate. + +From: Sent: Monday, May 18, 2020 4:18 PM To: (USANYS) Cc: Subject: RE: estate liquidation (USANYS) + +We wanted to follow up on our email from May 2 about the estate letting us know that they plan to move forward with taking steps to prepare for sales of the New York and Florida properties, particularly in light of the estate's upcoming tax deadline. The trustees' counsel contacted us today to follow up on that and to let us know that they expect to start taking those steps formally in the near future, including by retaining a broker and listing the New York property. + +As we mentioned in that prior email, the estate tried to get the IRS to hold off on the tax enforcement until the estate settles its (massive) contingent liabilities, but the IRS is taking the position that the estate has to pay the taxes and then recoup any overpayment based on the subsequent expenditures on liabilities that would have retroactive tax implications. And in particular for the New York house, they think there may be interest from museums in purchasing that property. The attorneys wanted to let us know so we weren't taken by surprise in the event their initial steps are picked up by media. As always, we think it would be productive to engage with the estate to start the ball rolling on whatever the Office wants to achieve (this being one of the subjects where perhaps there's an ultimate goal we're not privy to), but in the meantime we've continued to only receive information from the estate. + +In any event, we wanted to make sure that the brass was updated on this, as well as the info we conveyed previously, and please let us know if there's anything Geoff wants us to convey to them. + +thanks, + +Assistant U.S. Attorney Southern District of New York \ No newline at end of file diff --git a/marker2/ds9/EFTA00087272/EFTA00087272.metadata.json b/marker2/ds9/EFTA00087272/EFTA00087272.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..9251e92c53fcdf776916160df18f1736d89e9be2 --- /dev/null +++ b/marker2/ds9/EFTA00087272/EFTA00087272.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087272.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2499, + "elapsed_seconds": 0.83, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 73 + ], + [ + "Line", + 34 + ], + [ + "Text", + 16 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 37 + ], + [ + "Line", + 19 + ], + [ + "Text", + 5 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087272" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087274/EFTA00087274.md b/marker2/ds9/EFTA00087274/EFTA00087274.md new file mode 100644 index 0000000000000000000000000000000000000000..9ce78711aa6d850c302ec8f566498b303ab839a0 --- /dev/null +++ b/marker2/ds9/EFTA00087274/EFTA00087274.md @@ -0,0 +1,11 @@ +From: To: (USANYS) [Contractor]" USANYS - SANYS + +Subject: Epstein Call Tomorrow + +Date: Thu, 21 May 2020 13:10:29 +0000 + +All, + +I've been asked to set up a call with all of you and the brass for tomorrow. llam or 1pm would work best for them. Do either work for all of you? + +Thanks, \ No newline at end of file diff --git a/marker2/ds9/EFTA00087274/EFTA00087274.metadata.json b/marker2/ds9/EFTA00087274/EFTA00087274.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..3a582e994087e85181c25f3b5a4978661c37088f --- /dev/null +++ b/marker2/ds9/EFTA00087274/EFTA00087274.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087274.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 280, + "elapsed_seconds": 0.42, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 25 + ], + [ + "Line", + 13 + ], + [ + "Text", + 7 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087274" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087275/EFTA00087275.md b/marker2/ds9/EFTA00087275/EFTA00087275.md new file mode 100644 index 0000000000000000000000000000000000000000..aeae12e786bfffd6d21da2237bcd4a643514ef0a --- /dev/null +++ b/marker2/ds9/EFTA00087275/EFTA00087275.md @@ -0,0 +1,15 @@ +**From:** [REDACTED] (USANYS) [Contractor]" < [REDACTED] > +**To:** [REDACTED] (USANYS)" < [REDACTED] >, [REDACTED] (USANYS)" + < [REDACTED] >, [REDACTED] (USANYS)" < [REDACTED] >, [REDACTED] + [REDACTED] (USANYS)" < [REDACTED] >, " [REDACTED] (USANYS)" + < [REDACTED] >, " [REDACTED] (USANYS)" < [REDACTED] >, [REDACTED] + " [REDACTED] )" < [REDACTED] >, " [REDACTED] )" + [REDACTED] )" < [REDACTED] >, " [REDACTED] )" + +**Subject:** Epstein Call + +**Date:** Thu, 21 May 2020 13:34:24 +0000 + +**Importance:** Normal + +**Attachments:** unnamed \ No newline at end of file diff --git a/marker2/ds9/EFTA00087275/EFTA00087275.metadata.json b/marker2/ds9/EFTA00087275/EFTA00087275.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..35dc27a314b74bcc1c43d9e0c810ab46cfdf8b91 --- /dev/null +++ b/marker2/ds9/EFTA00087275/EFTA00087275.metadata.json @@ -0,0 +1,46 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087275.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 547, + "elapsed_seconds": 153.47, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 10 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087275" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087276/EFTA00087276.md b/marker2/ds9/EFTA00087276/EFTA00087276.md new file mode 100644 index 0000000000000000000000000000000000000000..950e6149ea7a22d02033a686163f7fb935101c51 --- /dev/null +++ b/marker2/ds9/EFTA00087276/EFTA00087276.md @@ -0,0 +1,23 @@ +Start Date: 2020-05-22 17:00:00 +0000 + +End Date: 2020-05-22 18:00:00 +0000 + +Organizer: (USANYS) [Contractor] < + +Location: 877-720-9282 - 8146826 + +Class: X-PERSONAL + +Date Created: 2020-05-21 13:54:26 +0000 + +Date Modified: 2020-05-21 13:54:26 +0000 + +Priority: 5 + +DTSTAMP: 2020-05-21 13:34:21 +0000 + +Attendee: (USANYS) ) < USANYS USANYS) < (USANYS) USANYS) + +Alarm: Display the following message 15m before start + +Reminder \ No newline at end of file diff --git a/marker2/ds9/EFTA00087276/EFTA00087276.metadata.json b/marker2/ds9/EFTA00087276/EFTA00087276.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..3e4e39584bb39056daba8e305aa9f6350650c00d --- /dev/null +++ b/marker2/ds9/EFTA00087276/EFTA00087276.metadata.json @@ -0,0 +1,82 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087276.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 418, + "elapsed_seconds": 0.65, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Event: Epstein Call", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 33.048, + 36.23907470703125 + ], + [ + 170.34262084960938, + 36.23907470703125 + ], + [ + 170.34262084960938, + 54.4989013671875 + ], + [ + 33.048, + 54.4989013671875 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 39 + ], + [ + "Line", + 20 + ], + [ + "Text", + 12 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087276" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087277/EFTA00087277.md b/marker2/ds9/EFTA00087277/EFTA00087277.md new file mode 100644 index 0000000000000000000000000000000000000000..f85dfc7ec30ee02087b2e1e6bb3a2bd2126676d9 --- /dev/null +++ b/marker2/ds9/EFTA00087277/EFTA00087277.md @@ -0,0 +1,165 @@ +From: "MM. (USANYS)" To: "r (USANYS)" Cc: ' (USANYS)" + +Subject: RE: Jeffrey Epstein-Related Touhy Requests + +Date: Fri, 22 May 2020 22:27:10 +0000 + +Thanks for the further info. With apologies, I now think was right in the first place: if plaintiffs ask us for the does and we don't have them then I guess it does make most sense for us to simply say, we don't have them, try SDFla and/or NDGA. SDFLa and NDGA may say, pound sand, and if plaintiffs subpoena one or the other of those districts, then we see if the subpoenaed district Touhy-refers the subpoena to Geoff as the "responsible" USA, and take it from there. So I am OK with plan for dealing with plaintiff's further requests as he outlines in his May 20 email. + +From: + +Sent: Friday, May 22, 2020 5:37 PM + +To: (USANYS) ; S =(usANYs)< > + +Cc: ) < >; (USANYS)< >: (USANYS) + +Subject: RE: Jeffrey Epstein-Related Touhy Requests + +We do possess the FBI investigative files from the SDFL investigation. What we do not have, and avoided obtaining for a variety of reasons (including conflict issues, discovery issues, and a desire not to create even an appearance that we were stepping into the shoes of a district that was unable to prosecute due to the prior non-prosecution agreement) are any files specifically from the U.S. Attorney's Office in SDFL. As relevant here, for example, we do not have any materials relating to the purported immunity discussions relating to we have not identified any such materials in the FBI files, and we assume that any discussions or correspondence on that issue likely would have been between defense counsel and the SDFL USAO. + +On the civil side, I can't immediately think of a reason you guys shouldn't be able to make a request to either SDFL or NDGA, whichever is the right entity, for any such materials. We've just avoided literally any contact with SDFL on the criminal side. + +Let us know if any additional questions on this at all, we realize it's a little complex. + +From: (USANYS) < + +Sent: Friday, May 22, 2020 17:16 + +To: (USANYS) (USANYS) (USANYS) + +Cc: < + +Subject: RE: Jeffrey Epstein-Related Touhy Requests + +Understood. Thanks, M. thought this approach was reasonable, but I'll check with too. Overall, I don't think we have a ton of precedent for referring folks to another USAO on a Touhy, and certainly not to a third USAO in the referral context. + +Some information that might be useful in this that I don't have a complete understanding of—are the materials from the S.D. Fla. investigation available to us? As in, have we ever seen or used them? If not, is there a particular reason for that? We may be in the odd situation of technically having some purview over those materials by virtue of the Touhy regs, but without access to them. But please let me know if I'm overlooking some dimension of our cooperation (if any) with the other USAOs. + +Thanks, + +From: (USANYS) + +Sent: Friday, May 22, 2020 4:34 PM + +To: (USANYS) > (USANYS) + +Cc: > ) <->; + +(USANYS) < + +Subject: RE: Jeffrey Epstein-Related Touhy Requests + +I have some hesitation on just referring them to NDGa for the SDFla investigative stuff. First, under Touhy section 16.22(b), the responsible USA is the USA for the district "where the issuing authority" is located. They actually have an action filed in this district, no? Like it or not, we may be stuck with dealing with their requests for does from the Florida investigation. , you might want to consult wiser Touhy heads in civ div, like for instance. Also, it is possible that Touhy does not fall within the scope of SDFla's recusal. I can't see NDGA racing to embrace doing Touhys on this. + +From: (USANYS) < + +Sent: Wednesday, May 20, 2020 7:24 PM + +To: M = (USANYS) ; (USANYS) < + +(USANYS) + +Cc: <->; + +Subject: RE: Jeffrey Epstein-Related Touhy Requests + +All, + +Closing the loop on this: we produced documents responsive to an Epstein victim's Touhy request about a month ago. The requesters got back to us (by phone) with a fairly lengthy list of follow-up questions about what we produced and additional/related demands. We don't have much responsive to many of their follow-ups, or do not think it would be appropriate to produce additional material they're seeking—for example, materials that are part of the ongoing investigation. MI and I intend to have a call with requester's counsel to explain to them that we will not be producing anything further at this time. At this point, we don't plan to send them anything else in writing. + +One small wrinkle: they have asked us for materials from S.D. Fla.'s investigation (which we don't have) and asked whether they need to submit a separate request to that office. We intend to tell them that N.D. Ga. has stepped into the shoes of S.D. Fla. For Epstein purposes, that they can submit a request there (or to S.D. Fla.) for the materials they're seeking, and possibly provide them with a contact at N.D. Ga. if they ask. + +Please let us know if you have any concerns. We hope that this will be the last step on this request. + +Thanks, + +To: (USANYS) < (USANYS) (USANYS) Cc: ) Subject: RE: Jeffrey Epstein-Related Touhy Requests + +I take it we fully know that Jane Doe is + +I had a little pause on handing out the GJ subpoena, but since it's something previously disclosed to her, I can't see much of a problem disclosing it to her again. + +So I don't have a problem with you sending this out. Thanks for your work on this, + +From: (USANYS) Sent: Thursday, April 16, 2020 7:07 PM To: S (USANYS) (USANYS) Cc: < Subject: RE: Jeffrey Epstein-Related Touhy Requests (USANYS) ) + +All, + +Please find attached a letter responding to the Touhy request for documents related to Jeffrey Epstein submitted by a victim who is a plaintiff in a civil suit against Epstein's estate. I am also attaching the documents to be produced in response to the request. Please let me know if you have any edits or concerns. If not, I plan to contact requester's counsel next week, let them know about the production, and send them the letter and the documents. I'm also attaching their request letter here. (M, M, and are signed off on the letter and gathered the documents.) + +Thanks, + +From: Sent: Friday, January 3, 2020 8:49 PM To: (USANYS) Cc: S (USANYS) Subject: RE: Jeffrey Epstein-Related Touhy Requests c >; (USANYS) ; (USANYS) + +Thanks very much for drafting this, and I think generally it looks great. My only small thought would near the end, in the penultimate paragraph, where I'd suggest replacing the first two sentences with (something like): "My understanding is that you may intend to make a formal written request pursuant to the above-described regulations. [If you choose to submit . .]" I say that only because the current language makes it sound like they were supposed to submit something in writing, or that they otherwise erred, when in fact what they actually asked for was just an explanation of the appropriate form in which to make a formal request—which they can do consistent with the regulations set forth in the letter. Does that sound alright? And of course on any of these I also entirely defer to =. + +From: (USANYS) < + +Sent: Friday, January 03, 2020 12:55 + +To: + +Cc: (USANYS) ; (USANYS) (USANYS) + +Subject: RE: Jeffrey Epstein-Related Touhy Requests + +All, + +Please find attached an initial letter to Kaplan Hecker re: the request for information related to Epstein. Please let me know if you have any edits or concerns. Once I have sign-off, I'll send to Robbie Kaplan (by mail and at or let me know if I should use a different address). + +M, assuming there are not huge changes to be made here, I think the letter/email could just go out as the next contact with Robbie on this, but I leave it up to you if/how you want to separately give her notice that it's on the way. + +Thanks, + +From: (USANYS) + +Sent: Thursday, January 2, 2020 7:16 PM + +To: + +Cc: a, (USANYS) (USANYS) (USANYS) + +Subject: RE: Jeffrey Epstein-Related Touhy Requests + +All sounds good to me—thanks for the call and note. I'll circulate a draft of the initial letter. + +Thanks, + +From: + +Sent: Thursday, January 2, 2020 7:10 PM + +To: (USANYS) + +Cc: (USANYS) >; (USANYS) (USANYS) + +Subject: RE: Jeffrey Epstein-Related Touhy Requests + +\_• + +Thanks for talking with me this evening about this, we appreciate it. To briefly memorialize our discussion, and to loop in everybody on the case on the criminal side, you'll be the point person for requests from civil plaintiffs / victims in connection with Epstein lawsuits, and we'll work with you on those requests given our knowledge of the relevant facts and materials. + +In terms of this first question from the plaintiff, which was essentially presented as a question of how they should go about making a request for certain materials possibly in the possession of the Government, we'll plan to take a look at the letter you draft that will essentially set forth the requirements for making a Touhy request (e.g., similar to, or including, the kind of information in example below), and separately sometime early next week I'll let plaintiff's counsel (Robbie Kaplan at Kaplan & Hecker) know that they can expect to hear from someone in our Civil Division, within approximately a week or so (of when that conversation occurs), and that we anticipate that communication will include the relevant requirements of making such a request. + +Please let me know if I'm forgetting anything, thanks again, and talk soon. + +From: (USANYS) •= => + +Sent: Thursday, January 02, 2020 10:01 + +To: I < >; (USANYS) + +Subject: Jeffrey Epstein-Related Touhy Requests + +I spoke to about continuing to use as the POC to outsiders for Touh requests for information relating to Jeffrey Epstein. (Thank you , please give a call. FWIW, following is a markup of a "please give us a Touhy statement" email that I have used in the past. anticipates that we will be getting additional renests stemming from civil litigation by alleged victims, so it would be useful to have some consistency here knows that the criminal AUSAs will have to do all the work digging for any pertinent information, but it will be useful to have another AUSA handle the actual communications, particularly since the criminal AUSAs may be dealing with the alleged victims as victim-witnesses in ongoing criminal matters. Thanks again, + +Here's some draft language you may or may not find useful: + +Dear XXX: + +I am the Assistant U.S. Attorney who will be handling the request that you made to AUSA for certain information relating to Jeffrey Epstein. To assist us in evaluating your request, we ask that you provide us with a detailed written statement of the litigation for which you seek this information; the pertinence of the information sought to your litigation; and the availability (or absence) of means in that litigation, including discovery, to obtain the information in question. This statement should be relatively thorough—Le., it should not assume that the persons reviewing your request will have any particular familiarity with the litigation in question. + +For your information, following are the general principles that govern disclosure, in unrelated litigation, of information obtained during the course of our official duties. Specifically, the response of federal agencies to subpoenas and other third-party discovery demands is largely governed by Department of Justice regulations, commonly referred to as Touhy regulations. See generally 5 U.S.C.A. § 301; United States a rel. Touhy v. Ragen, 340 U.S. 462 (1951) (authorizing such regulations). These regulations dictate the procedure for obtaining a government employee's testimony or government records in state or federal proceedings. The Department of Justice has its own Touhy regulations that set out the procedure it follows in responding to demands for "production or disclosure" of information from the Department and its employees for use in state or federal court proceedings. See 28 C.F.R. §§ 16.21-16.29. These Touhy regulations channel review of such demands to the responsible United States Attorney, and then provide a set of procedures for the United States Attorney to follow when considering such demands. See id. §§ 16.22(b), 16.24. These regulations apply to both current and former Government employees. See id. §§ 16.21(a), 16.22(a), 16.28. The Department's Touhy regulations prohibit any Department employee from testifying or producing documents in a case in which the Government is not a party, even in response to a subpoena, "without prior approval of the proper Department official in accordance with §§ + +16.24 and 16.25 of this part.” *Id.* § 16.22(a). For matters concerning our Office, the proper official is the United States Attorney for the Southern District of New York. *Id.* § 16.22(b). To facilitate the process of determining whether such approval will be given, a party seeking such information must provide this Office with an affidavit or written statement setting forth the testimony sought and its relevance to the proceeding for which it is sought. *See id.* § 16.22(c), (d). We will then evaluate the request in light of governing rules of procedure in the case for which the information is sought, substantive law, and privilege; specific statutory prohibitions such as may apply to federal tax information, grand jury matters, or classified information; and the requirement of Deputy or Associate Attorney General approval where the disclosure would identify a confidential source over the objection of the agency or source, would interfere with enforcement proceedings or reveal sensitive investigative techniques, or would reveal trade secrets without the owner’s consent. See 28 C.F.R. § 16.26. To the extent information sought derives from a criminal investigation, such information may be subject to, *inter alia*, the law enforcement privilege. The law enforcement privilege protects against the disclosure of information that would “reveal a confidential source or informant, . . . reveal investigatory records compiled for law enforcement purposes . . . interfere with enforcement proceedings[,] or disclose investigative techniques and procedures . . .” *Id.* § 16.26(b)(4)-(5); *see also In re City of New York*, 607 F.3d 923 (2d Cir. 2010); *In re Dep’t of Investigation of the City of New York*, 856 F.2d 481, 484 (2d Cir. 1988); *Tuite v. Henry*, 181 F.R.D. 175, 176 (D.D.C. 1998) (“The federal law enforcement privilege is a qualified privilege designed to prevent disclosure of information that would be contrary to the public interest in the effective functioning of law enforcement”), *aff’d*, 203 F.3d 53 (D.C. Cir. 1999). The Government’s privilege not to disclose material contained in the files of criminal investigations is well-recognized. *See In re Department of Investigation of the City of New York*, 856 F.2d at 483; *Friedman v. Bache Halsey Stuart Shields, Inc.*, 738 F.2d 1336, 1341 (D.C. Cir. 1984); *Kinoy v. Mitchell*, 67 F.R.D. 1, 11 (S.D.N.Y. 1975) (discussing privilege for files compiled in connection with a criminal investigation). To the extent documents are sought for use in state court proceedings, note that the Department’s decision whether to authorize testimony or produce documents is not reviewable in state court. Review of the agency’s decision may only be had pursuant to the federal Administrative Procedure Act in federal court. *See U.S. EPA v. Gen. Elec. Co.*, 197 F.3d 592, 598-99 (2d Cir. 1999) (review pursuant to Administrative Procedure Act), modified in part, 212 F.3d 689 (2d Cir. 2000); 5 U.S.C. § 702 (sovereign immunity waived to permit Administrative Procedure Act only in “a court of the United States”). Federal sovereign immunity bars any proceeding in state court to enforce a subpoena or otherwise compel testimony or production of documents. *See Louisiana v. Sparks*, 978 F.2d 226, 234-36 (5th Cir. 1992); *Boron Oil Co.*, 873 F.2d at 69-71; *see also*, e.g., *People v. Rodriguez*, 546 N.Y.S.2d 861, 862-63 (1st Dep’t 1989) (holding that “state courts are without authority to compel production of such files without the federal government’s consent”); *People v. Carbonaro*, 427 N.Y.S.2d 701, 702-03 (Kings Co. Sup. Ct. 1980) (quashing subpoena served on federal employee where Department of Justice ordered him not to comply); *Jacoby v. Delfiner*, 51 N.Y.S.2d 478, 479 (N.Y. Co. Sup. 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Can one of you connect with him tonight and then put him in touch with the agent and defense counsel? Also give them the background re Mark Epstein. + +Thanks! + +Sent from my iPhone \ No newline at end of file diff --git a/marker2/ds9/EFTA00087283/EFTA00087283.metadata.json b/marker2/ds9/EFTA00087283/EFTA00087283.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..f7e37d537461b2eb574ea45b1267ce97053ff158 --- /dev/null +++ b/marker2/ds9/EFTA00087283/EFTA00087283.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087283.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 365, + "elapsed_seconds": 0.37, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 29 + ], + [ + "Line", + 11 + ], + [ + "Text", + 6 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087283" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087286/EFTA00087286.md b/marker2/ds9/EFTA00087286/EFTA00087286.md new file mode 100644 index 0000000000000000000000000000000000000000..2cf8b04f0139d15aad57b6d85632686998f30b86 --- /dev/null +++ b/marker2/ds9/EFTA00087286/EFTA00087286.md @@ -0,0 +1,430 @@ +IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS +DIVISION OF ST. THOMAS & ST. JOHN + +\*\*\*\*\* + +SUPERIOR COURT +OF THE VIRGIN ISLANDS +20 FEB 11 PM 5:25 + +IN THE MATTER OF THE ESTATE OF ) +JEFFREY E. EPSTEIN, ) +) +) +Deceased. ) +\_\_\_\_\_ ) + +NOTICE TO THE COURT + +COMES NOW, the Government of the Virgin Islands, by and through its undersigned counsel, Virgin Islands Department of Justice, Office of the Attorney General and advise the Court of its efforts to meet, confer and cooperate with counsel for the Estate of Jeffrey E. Epstein ("Estate"), in light of the Court's oral directive related to the filed "Criminal Activity Lien Notice" and the voluntary victims compensation fund ("Fund"). The purpose of this notice is to advise the court of the Government's endeavor to work cooperatively with the victims as well as the Estate on the above concerns. Since the hearing on February 4, 2020, the Government has reached out to and met with the counsel for the Estate and counsels for victims to begin the dialogue for a fair and just resolution of the following issues: + +A. CRIMINAL ACTIVITY LIEN NOTICE ON ESTATE ACCOUNT + +By way of recent background, the Court, on Tuesday, February 4, 2020, held a hearing on all outstanding motions in this matter. On Wednesday, February 5, 2020, Shauna Betz, Legal Assistant at Kellerhauls, Ferguson Kroblin (Attorneys for the Estate) sent email correspondence to the Attorney General from Estate attorney Christopher Kroblin, Esq, objecting to the Criminal Activity Lien hold ("Lien") that, that the Government placed on accounts at the First Bank of Puerto Rico on January 31, 2020, in the name of the "The Estate of Jeffrey E. Epstein," "Nautilus, Inc." and "Great St. Jim, LLC",. (See Exhibit 1) On February 6, 2020, the Attorney General responded by email, and offered to schedule a meeting with the Estate the following day, which + +Attorney Kroblin accepted. (See Exhibit 2). On Friday, February 7, 2020, the Attorney General met, in person, with Attorney Christopher Kroblin at the Office of the Attorney General. Attorney Kroblin expressed the concern that the Lien prevents the Estate from paying its expenses to maintain and preserve the Estate. The Attorney General expressed the importance of the Estate to meet its expenses for maintenance and preservation of the estate and offered, pursuant to her legal authority, to release sufficient funds to meet such expenses once the Estate identifies the expenses and the amount of funds needed. On Sunday February 9, 2020 the Attorney General followed up and memorialized that , meeting by sending an email again expressing her willingness to accommodate an immediate release of sufficient funds to pay the necessary expenses so that the executors could continue to manage, maintain and preserve estate assets, and stated that that the Attorney General's office was eagerly awaiting the listing of expenses to facilitate prompt release of funds for payment. In that same email, the Attorney General also indicated her intention to send follow-up correspondence on the victims' program fund that was briefly discussed in the Friday meeting. . (See Exhibit 3) + +The CICO statute grants the Attorney General the authority to release, in whole or in part, any personal or real property from the notice. 14 V.I.C. § 610 (r). As the Government's underlying CICO action is still pending, only the Attorney General may release any property or interest from the Criminal Activity Liens. This is the express command of the statute, which provides in relevant part that: + +The Attorney General . filing the Criminal Activity Lien Notice may release, in whole or in part, any Criminal Activity Lien Notice or may release any personal or real property or beneficial interest in it from the Criminal Activity Lien Notice upon such terms and conditions as he may determine. + +14 V.I.C. § 610(r) (emphasis added). The Act thus is clear and unambiguous that where, as here, a Criminal Activity Lien Notice has commenced and attached upon the Attorney General's filing of an action and Notice, the Attorney General has sole authority to release the Liens upon such terms and conditions as she may determine to be appropriate. + +On Monday, February 11, 2020, at 4:26 pm, Counsel for the Estate, Christopher iCroblin, Esquire, sent an email to the Attorney General stating that it was seeking an Order from the Court because FirstBank has informed them that the hold will remain absent a court order. In that email, Estate Counsel notably did not attach by email a courtesy copy of its filed motion. (See Exhibit 4). At 4:39 p.m., the Attorney General specifically requested a copy of the motion. More than one hour later, at 5:45 p.m., Estate Counsel did provide a copy of the motion, which had been emailed to all other counsel, except counsel for the Government. (See Exhibit 5) To date, the Estate has not responded to the Attorney General's request for the listing of expenses as discussed. + +#### B. VICTIMS' COMPENSATON FUND — ALTERNATIVE + +On Monday, February 10, 2020, the Attorney General, as promised in her previous email, sent a four (4) page letter via email to the Estate counsel, detailing the Government's concerns with the victim's compensation fund as proposed by the Estate and setting forth alternative victim compensation program protocols and guidelines for a more fair and just program fund for Epstein victims. . (See Exhibit 6). Jordana Feldman, proposed Fund administrator, was copied on this correspondence. + +After the February 4, 2020 hearing, the Attorney General also had a very productive meeting with a counsel for victims. The Attorney General shared the government's program plan with said counsel, which was very well received. There are plans for further discussions and meetings with the victims and counsels in an effort to attain a more fair, impartial and just compensation program. (Exhibit 7) + +Respectfully submitted, + +DENISE N. GEORGE, ESQUIRE +ATTORNEY GENERAL +VIRGIN ISLANDS DEPARTMENT OF JUSTICE + +Dated: February 11, 2020 + +By [REDACTED] + +[REDACTED] +Virgin Islands Department of Justice +Office of the Attorney General +34-38 Kronprindsens Gade +St. Thomas, U.S. Virgin Islands 00802 +[REDACTED] + +**CERTIFICATE OF SERVICE** + +IT IS HEREBY CERTIFIED that the foregoing Motion complies with the word and page requirements of V.I.R. Civ. P. 6-1(e) and, a true and correct copy of the Motion was served via regular mail, postage prepaid, with a courtesy copy sent by email to counsel of record on February 11, 2020 to: + +CHRISTOPHER ALLEN KROBLIN, ESQ. +ANDREW W. HEYMANN, ESQ., +WILLIAM BLUM, ESQ. +SHARI D'ANDRADE, ESQ. +MARJORIE WHALEN, ESQ. +KELLERHALS FERGUSON KROBLIN PLLC + +Email: [REDACTED] + +Exhibit 1 + +From: Sent: To: Cc Subject: Attachments: Shauna Betz < Wednesday, February 05, 2020 4:33 PM Denise George: Denise George Chris kroblin; Shari D'Andrade [EXTERNAL MAIL1Notice of Criminal Activity Lien 2020-02.05 Ltr to Denise George re lien on bank accountl.pdf + +Good Day Attorney General George: + +Please see the attached correspondence. + +Regards, Shauna Betz Legal Assistant &Herbals Fe son monun + +![](_page_5_Picture_5.jpeg) + +Notice•. This communication may contain privileged or other confidential information. If you are not the intended recipient, or believe that you have received this communication in error, please do not print, copy, re-transmit, disseminate, or otherwise use this information. Also, please indicate to the sender that you have received this e-mail in error, and delete the copy you received. Thank you. + +Circular 230: To ensure compliance with the requirements imposed by the IRS, we inform you that any tax advice contained in our communication (including any attachments) was not intended or written to be used, and cannot be used, for the purpose of (i) avoiding any tax penalty or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein. + +Caution: This e-mail has originated outside of GVI network. Do not click on links or open any attachment (s) that might look suspicious unless you have knowledge of who the sender is. + +![](_page_6_Picture_0.jpeg) + +![](_page_6_Picture_2.jpeg) + +February 5, 2019 + +Via Email and Hand Delivery + +The Honorable Denise N. George, Esq. Attorney General VI Department of Justice + +![](_page_6_Picture_6.jpeg) + +RE: Notice ofCriminal Activity Lien + +Dear Attorney General George: + +While we are aware that you were not present at the Estate of Jeffrey E. Epstein (the "Estate') hearing before Judge Percell yesterday, Civil Chief Ariel Smith, Esq. appeared on behalf of the Government and the issue of the impact of the Notice of Criminal Activity Lien ("Lien") on the Estate arose. Attorney Smith clarified on the record that the V.I. Department of Justice, with the filing of the Criminal Activity Lien in the probate case, has no intention of prohibiting the co-Executors from paying expenses associated with the administration of the Estate and that the Estate could continue to function, pay employees, and pay attorneys, among other things. The Court echoed that sentiment and directed from the bench that the Lien does not interfere with the estate administration, as contemplated by the Decedent's Last Will and Testament, V.I. Code Ann. tit. 15, §S 421, 568, and the Virgin Islands Rules for Probate and Fiduciary Proceedings. + +Unfortunately, that is exactly what has occurred. Immediately following the hearing, and in stark contrast to the Government's explicit representation made on the record and the Court's instruction, the Estate received notification from Dudley Newman Feuerzeig, counsel to First Bank, that a hold has been placed on certain accounts, including, most importantly, the Estate of Jeffrey E Epstein account. See attached correspondence. We demand that you immediately direct First Bank, through its counsel, that a lien of the Estate account is inappropriate and the account should be restored to active status. Your failure to do so will result in our filing an emergency motion with the Court seeking a declaration that the lien does not attach to the Estate account, as well as sanctions for acting in direct contravention to your office's representations to the Court and the Court's statement that administrative expenses must and should be paid by the Estate. + +Sincerely, + +CE.,a,174.. + +Christopher A. Kroblin + +cc: Deputy Attorney General , Assistant Attorney Gent + +![](_page_7_Picture_24.jpeg) + +**KURT E. PETRI** +Partner + +![](_page_7_Picture_26.jpeg) + +**Physical Address** + Low House + 1000 Frederickstree Suite + Charlotte Avenue St. Thomas + US Toronto Bureau 20002 6176 + +**Mailing Address** + P.O. Box 156 + St. Thomas, VI 00804 0756 + + T: 360-114-4422 + www.DNF-LLC.com + +February 4, 2020 + +**VIA EMAIL AND U.S. POST** + +Darren K. Indyke + Richard D. Kahn + The Estate of Jeffrey E. Epstein + Great St. Jim LLC + Nautilus, Inc. + +![](_page_7_Picture_31.jpeg) + +Re: Criminal Activity Lien Notices +DNF File No. 4100-36 + +Dear Mr. Indyke and Mr. Kahn: + +This letter is being sent to notify you that, as a result of the attached Criminal Activity Lien Notices (ST-2020-CV-14) (the "Notices") served upon FirstBank on January 31, 2020, a hold has been placed on the following accounts: + +| Account Name | Account Number | Address | +|------------------------------|-----------------------|-----------------------------------------------------| +| Great St. Jim LLC | [REDACTED] | 6100 Red Hook Quarter
B3
St. Thomas, VI 00802 | +| Nautilus, Inc. | [REDACTED] | 6100 Red Hook Quarter
B3
St. Thomas, VI 00802 | +| Estate of Jeffrey E. Epstein | [REDACTED] | 9053 Estate Thomas
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St. Thomas, VI 00802 | + +... The Estate of Jeffrey E. Epstein and Mated EntitiesCnminal Aetwily Lien January IS. 2020 Page 2 + +This hold will remain in place until FirstBank receives an Order from a court of appropriate jurisdiction releasing the lien claims upon these accounts set forth in the Notices. + +Sincerely. + +cc: Christopher A. Krohlin. Esq. + +RNDOCT6602l51TR,10F47R102.00CX + +## EXHIBIT 2 + +From: Sent To: Cc Chris Kroblin < Thursday, February 06, 2020 9:06 PM Denise George > + +Subject: Re: (EXTERNAL MAIL)Notice of Criminal Activity Lien + +Attorney George, + +Thanks for the response. Happy to do so. + +Best regards, + +Chris + +Sent from my iPhone + +On Feb 6, 2020, at 7:51 PM, Denise George < > wrote: + +Good evening Attorney Kroblin: + +I just noticed this email correspondence from your legal assistant whose name I did not recognize. Please have Ms. Betz contact my Executive Assistant Jennifer Springette to set a time to meet tomorrow afternoon to discuss this matter. + +Have a good evening. + +DEMME N. GrOPZE, FAQ. Attorney General Virgin Islands Department of Justice Office of the Attorney General + +From: Shauna Betz Sent: Wednesday, Februa 05 20204:33 PM To: Denise Geor e Cc >; Shari D'Andrade Subject: (EXTERNAL MAIL)Notice of Criminal Activity Lien >• Denise Geor e >; Chris Kroblin + +From: Sent To: Cc Subiat Denise George Sunday, February 09, 2020 8:15 AM Chris Kroblin GVI v. Epstein Estate et al + +Good day Attorney Kroblin, + +It was great meeting with you Friday afternoon as we discussed the importance to all concerned for the estate to meet its day to day maintenance expenses and our willingness to accommodate for an immediate release of funds sufficient to pay these expenses so that the executors may continue to manage and preserve estate assets. We eagerly await your response regarding those expenses are costs so we can expeditiously move forward. + +You can also expect written correspondence from me on the victims' program fund as a follow up to our brief discussion. + +Dom N. Grata, Ess Attorney General Virgin Islands Department of Justice + +![](_page_12_Picture_6.jpeg) + +### EXHIBIT 4 + +From: Chris Kroblin < Sent: Monday, February 10, 2020 4:26 PM To: Denise George Cc: Subject: [EXTERNAL MAILIRE:GVI v. Epstein Estate et al + +Attorney General George, + +We appreciate your recognition of the critical importance of paying the ongoing maintenance expenses of the Epstein Estate. Because the Estate cannot survive the indefinite "hold" placed on the Estate's account at FirstBank as the result of the Criminal Activity Lien Notices recently issued by your office, and because FirstBank has informed us that it will maintain that hold absent "an Order from a court of appropriate jurisdiction releasing the [Government's] lien claims," the Co-Executors have today sought an order from the Superior Court releasing all funds necessary for the routine administration of the Estate and the preservation of its assets. + +We received your communication yesterday afternoon regarding the voluntary compensation program proposed by the Co-Executors and endorsed by the Court and claimants' counsel at the hearing on February 4. We will consult with our clients and expect to respond shortly. + +Best regards, + +Christopher Allen Kroblin + +Member KELLERHALS FERGUSON KROBLIN PL. + +Direct: Office: Fax: EmaiL tens/Lie lfer.com + +Of Counsel to: Solomon Btum Heymann LLP + +Notice: This communication may contain privileged or other confidential information If you are not the intended recipient. or believe that you have received this communication in error. please do not print, copy. re-transmit, disseminate. or otherwise use this information. Also. please indicate to the sender that you have received this e-mai: in error, and delete the copy you received Thank you. Circular 230: To ensure compliance with the requirements :mposed by the IRS, we inform you that any tax advice contained in our communication (inducing any attachments) was not intended or wntton to be used. and cannot be used. for the purpose of (i) avoiding any tax penalty or Cu) promoting. marketing or recommending to another party any transaction or matter addressed herein + +## EXHIBIT 5 + +Front Denise George Sent Monday, February 10, 2020 4:39 PM To: Chris Kroblin Cc: Subject: RE: [EXTERNAL MAILIRE:GVl v. Epstein Estate et al + +Good day Attorney Kroblin, + +Please provide us with a copy of that motion. Thank you. + +DEMISE N. Gtoatz, En Attorney General Virgin Islands Department of Justice Office of the Attorney General + +![](_page_16_Picture_5.jpeg) + +From: Chris Kroblin < Sent: Monday, Februa To: Denise Geo e Cc 10, 2020 4:26 PM Subject: (EXTERNAL MAIL)RE: GVI v. Epstein Estate et al + +Attorney General George, + +We appreciate your recognition of the critical importance of paying the ongoing maintenance expenses of the Epstein Estate. Because the Estate cannot survive the indefinite "hold" placed on the Estate's account at FirstBank as the result of the Criminal Activity Lien Notices recently issued by your office, and because FirstBank has informed us that it will maintain that hold absent "an Order from a court of appropriate jurisdiction releasing the [Government's] lien claims," the Co-Executors have today sought an order from the Superior Court releasing all funds necessary for the routine administration of the Estate and the preservation of its assets. + +We received your communication yesterday afternoon regarding the voluntary compensation program proposed by the Co-Executors and endorsed by the Court and claimants' counsel at the hearing on February 4. We will consult with our clients and expect to respond shortly. + +From: Chris Kroblin < Sent Monday, February 10.2020 5:45 PM To: Denise Georoe Cc Subject Attachments: [EXTERNAL MAIL]RE: [EXTERNAL MAIL]RE: GVI v. Epstein Estate et al DS Emergency M for Order Releasing Funds for Administration.pdf + +Please see the attached. + +Best regards, + +Christopher Allen Kroblin + +Member KELLERHALS FERGUSON KROBLIN PLLC Ro al Palms Professional Buildin + +Direct Office: Fax Email• + +Of Counsel to: Solomon Blum Heymann LLP + +Notice: This communication may contain privileged or other confidential information. If you are not the intended redPient. Of believe that youhave received this communication In trot please do not print. copy. re-transmit flisseminele. or When\*, use this ififOrrnatiOn. Also, please indicate to the sender that you have received this canal in error. and delete the copy you received. Thank you. Circular 230: To ensure compliance with the requirements imposed by the RS. we Infomi you that any tax advice contained in ow cornmunkation (including any anachmente)was not Intended or written to be used, and cannot be used. (or the purpose o( (q avoiding any tax penalty or (II) promoting. marketing or reconvnencling to another party any transaction or matter addressed heron. + +From: Denise George Sent: Monday, Februa 10, 2020 4:39 PM To: Chris Kroblin Cc Subject: RE: [EXTERNAL MAILIRE: GVI v. Epstein Estate et al + +Good day Attorney Kroblin, + +# Exhibit 6 + +From: + +Sent: Monday, February 0, 202010:19 AM + +To: r. Kr lIn + +Cc: Denise George + +Subject: 2-10-2020 Letter to Christopher Kroblin (Estate of Jeffrey E. Epstein) + +Attachments: 02-10-2020 Letter to Christopher Kroblin (Estate of Jeffrey E. Epstein).pctf + +Tracking: Recipient Delivery Read + +Chris Kroblin + +Denise George + +Good Morning Attorney Kroblin: + +Delivered: 2/10/2020 10:19 AM Read: 2/10/2020 10:21 AM + +Attached please find letter dated February 10, 2020 from Attorney General Denise George. Thank you. + +KRVOEST REGARDS, + +![](_page_19_Picture_22.jpeg) + +jouttfer o. spriagette + +Executive Assistant to the Attorney General + +Virgin Islands Department of Justice + +Office of the Attorney General + +Live Your Life With Purpose: Count your blessings, not your problems, and you will realize how beautiful your lye truly is. + +![](_page_20_Picture_0.jpeg) + +#### THE UNITED STATES VIRGIN ISLANDS DEPARTMENT OF JUSTICE OFFICE OF THE ATTORNEY GENERAL + +February 10, 2020 + +Christopher Allen Kroblin, Esq. Kellerhals Ferguson Kroblin PLL + +![](_page_20_Picture_4.jpeg) + +RE: Estate of Jeffrey E. Epstein + +Dear Attorney Kroblin: + +It was good to meet with you on Friday as we discussed matters involving the Estate of Jeffrey Epstein ("Estate"). As we discussed briefly, Judge Carolyn Hermon-Percell requested that the Attorney General's Office and the Estate confer on the issues related to a victims' compensation fund ("Fund"). I write to begin that dialogue by laying out in detail my concerns about and recommendations for the Fund. + +Iexpect and certainly understand why some victims will want an expedited process that provides compensation — however incomplete for the harm done to them. However, to be credible and to comport with the law and policies of the Virgin Islands, that process must also be fair, just, and independent. The Fund, as proposed by the Estate, does not meet those standards. + +Among the issues raised in the Government's opposition to the Fund were four critical issues. + +Frist, the Fund must set aside sufficient funds to pay claims of victims who may come forward in the future or may proceed through civil litigation. Particularly given the nature of the trauma suffered by these victims, many of whom were children when they were trafficked, there needs to be sufficient time and alternate venues available to victims. While some victims have stepped forward now, others may require more time and support. To make the Fund truly voluntary, the Estate must preserve assets for those who choose not to participate in it. Otherwise, many victims will be coerced into the process, believing that the Fund provides the only chance to ensure that their claims are paid. To the extent that additional victims do not seek or obtain funding, those funds can support organizations that advocate for or support victims of human trafficking - a far more meaningful and appropriate use of an Estate so tied to its fundcr's criminal activities. + +Second, public policy does not permit the Estate to require broad third-party releases from victims in exchange for compensation. These releases serve no permissible purpose and will only silence victims and prevent them from seeking accountability and recovery from other individuals and + +![](_page_20_Picture_12.jpeg) + +entities that participated in, facilitated, or covered up Jeffrey Epstein's crimes. I understand that, after I raised this issue, the Epstein Fund has now offered to remove those broad releases from its protocol. That is a positive step, but the commitment must be made binding. + +Third, the Epstein Estate, whose executors arc directly associated with entities that are defendants in the Government's lawsuit and which allegedly facilitated or participated in Epstein's criminal activity, should play no role in choosing a claims administrator or in designing a compensation program. While the Estate has indicated that the program administrator will have full authority to evaluate and set claim amounts, the fact that the administrators were chosen by, advised by and would be paid handsomely by the Estate creates an unavoidable appearance of impropriety. To ensure the integrity and credibility of the process, the Estate must disavow any role in the process, and allow the victims and the Attorney Genera], with the Court's approval, to collectively select an appropriate administrator. Further, payments to the administrator, now disclosed to be up to \$200,000 per month, with \$1.7 million for just two months of work to the attorney who designed the Fund, as well as administrative staffing and other business expenses that could amount to millions, are excessive and disproportionate to the nature of the case and anticipated number of victims. The costs to run the Fund should be capped at a reasonable amount that ensures that the Estate's assets will not be unnecessarily and unreasonably dissipated. + +Fourth, the Epstein Estate must commit not only to a providing compensation, but cooperating with law enforcement. Otherwise, the Fund's primary purpose can be seen as limiting the Estate's exposure, protecting Epstein's associates, paying for victims' silence and avoiding further public exposure. That is a debt owed not only to Epstein's victims, but to all those who may avoid becoming victims of other sexual predators in the future. + +Specifically, an acceptable, fair and appropriate victims' program fund would have to be consistent with these principles and include the following commitments from the Estatc: + +- 1. The Estate must provide a complete inventory and accounting of the assets that are held by the Estate, 1953 Trust and by Jeffrey Epstein or any other entities that he owned or controlled, whether or not a part of the probate. The Estate in good faith should be open and honest with the victims, the Court and the Government regarding the assets of the estate and the value of each asset as Virgin Islands probate law requires. The victims should not be asked to evaluate appropriate compensation, nor can the Government blindly release funds from its criminal activity liens without knowing the true nature and total value of Epstein's assets. +- 2. The Estate must agree to set aside a sufficient fixed fund prior to the close of the probate proceedings to compensate victims who do not accept payment from the Fund or do not come forward within the probate claims period of the Estate. In the event that such victims do not come forward or obtain judgments, the balance of the fund would be donated, through cypres, to organizations providing support to victims of human trafficking, sexual exploitation and sexual assault. The timing for payments must be centered on victims' relief, not deadlines dictated by the probate process. + +- 3. The Estate may not transfer ownership of Great St. James and Little St. James and other instrumentalities of Epstein's crimes in the Virgin Islands and must set aside a fixed sum sufficient to satisfy any potential judgment in favor of the Government of the Virgin Islands. The Government preserves its authority to enforce its laws to curtail human trafficking, sexual assaults and criminal enterprises, to hold Epstein and other violators accountable, to protect the safety and wellbeing of the Virgin Islands, to guide how victims are cared for and to protect our children—those who live here, as well as those who are brought here—from the scourge of human trafficking and sexual exploitation, now and in the future. +- 4. The Fund administrator and the protocol and criteria for the Fund must be chosen by Epstein's victims and the Attorney General, informed by experts in human trafficking, and/or survivors of human trafficking, and approved by the Court. The Fund administrator herself must be knowledgeable and experienced in the administration and settlement of funds for victims of crimes of human trafficking and sexual exploitation/assault of women and children. +- 5. Because of the existing conflicts of interest of the Estate and executors, as laid out in the Government's opposition to the Fund, there must be an absolute firewall between the Fund and the Estate. Furthermore, because of these conflicts, the Executors of the Estate should have no role at all in the Fund, including in selecting or approving the administrator, the protocol or criteria for the fund, or oversight or approval of the Fund's administration. +- 6. The Fund must provide full reporting on its criteria, process, awards, and expenses to the Court and the public while protecting the privacy of any claimants who choose to remain anonymous. +- 7. The program administrator must, in consultation with victims and non-profit or government organizations focused on human trafficking, identify a plan to adequately publicize the existence of the Fund. +- 8. Once a claim reaches settlement, victims will not be asked or required to release any person or entity from liability other than the Estate. +- 9. The Estate will set aside funds to provide counseling to any victim who wishes to discuss coming forward to the Fund or to law enforcement. The individual or entity providing such counseling will be approved by the Attorney General, victims' counsel, and the Court. The identity of all such victims will not be disclosed to the Estate. +- 10. Claimants will be provided with the Virgin Islands Crime Victims' Bill of Rights and be provided with contact information for the Virgin Islands Office of the Attorney General should they care to cooperate with Virgin Islands law enforcement. + +- 11. The Estate will agree that no records obtained in the claims or counseling process will be used against any victim or in defending any claim against the Estate or related entities or individuals. +- 12. Expenses of setting up and administering the Epstein Fund will be capped at a reasonable amount. This is absolutely necessary to avoid the excessive costs proposed to run the Fund, which would deplete the funds in the Estate and place significant resources from the Fund in the pockets of the Estate's associates and hand-picked administrators and attorneys. The costs of the program should be commensurate with the nature of the claims and the number of victims addressed. +- 13. The Estate will agree to preserve, identify, and make available to the Virgin Islands all documents (including electronically stored information and video/audio recordings) related to Epstein's criminal conduct in the Virgin Islands, and will not seek to prevent disclosure of such information, though no information that might reveal the identity of his victims will be publicly disclosed, as required by Virgin Islands law. +- 14. The Estate will agree to cooperate to provide information against any individuals or other entities that participated in the conduct described in the Government's complaint. +- 15. The Estate will waive any non-disclosure agreements signed by former employees of Epstein or related entities and will notify such employees that thcy arc not bound by confidentiality and are encouraged to cooperate fully and truthfully with the Attorney General and her representatives. + +I sincerely hope that the Estate will find these commitments to be uncontroversial and consistent with its commitment to ensure swift, fair and lawful resolution for Epstein's victims, and we look forward to talking with you about these issues and any other suggestions you may have to address the Government's concerns and interests. + +Sincerely, + +Denise N. George, Esq. Attorney General of the U.S. Virgin Islands + +cc. Esq. + +# Exhibit 7 + +From: Sent: To: Cc: Subject: Brittany Henderson < Monday, February 10, 2020 11:37 AM Denise George Re: Epstein Estate > + +Attorney General George, + +After our meeting, I am confident we all agree that there is nothing more powerful than the voices of the victims. As a testament, one of our clients reached out late last week and asked if she could speak with you directly or write you a letter sharing her feelings on the events that have recently transpired. The next day, another client called with similar requests. Hearing that these women welcome the opportunity to speak with you not only instills in me a great sense of pride, but it is also a reminder that we are all stronger together. Please let me know if you are interested in meeting so that we can figure out the best way to make that happen. + +Thank you for your time, + +![](_page_25_Picture_5.jpeg) + +Brittany N. Henderson Trial Attorney + +![](_page_25_Picture_7.jpeg) + +Caution: This e-mail has originated outside of GVI net-work. Do not click on links or open any attachment (s) that might look suspicious unless you have knowledge of who the sender is. + +From: Sent: To: Cc: Subject: Attachments: Denise George Monday, February 10, 2020 12:46 PM Brittany Henderson Brad Edwards; RE: Epstein Estate 02-10-2020 AG Letter to Christopher Kroblin (Estate of Jeffrey E. Epstein).pdf + +Good day Ms. Henderson and Attorney Edwards: + +We are indeed very interested in meeting with the victims and I thank you for the productive and encouraging conversation in our February 4rn meeting. I agree that this is so important to ensure that we maintain an open dialogue with a goal of reaching a resolution that best serves all of the victims of Jeffrey Epstein's conduct and provides a model for how cases and conduct like this may be resolved in the future. + +To that end, I have attached a letter that I want to share with you which I sent to Epstein's Estate to establish the kind of specific commitments that would be required of the Estate to address the Government's concerns regarding their program as proposed. I welcome your thoughts and feedback. I also welcome you to contact my Executive Assistant Jennifer Springette to coordinate a meeting with the victims as soon as possible. + +I look forward to meeting with you again on this very important matter. + +Sincerely, + +&Nat N. Goo a, ESQ. Attorney General Virgin Islands Department of Justice Office riffle Attorney General + +![](_page_26_Picture_8.jpeg) + +From: Brittany Henderson < Sent: Monday, Februa 10, 2020 11:37 AM To: Denise Geor e < Cc:a >; Brad Edwards < Subject: Re: Epstein Estate + +From: Sent To: Cc: Subject: Brittany Henderson < Monday, February 10, 2020 2:13 PM Denise Gear. e Re: Epstein Estate > + +Attorney General George, + +Thank you very much for the quick reply. It is evident in reading your correspondence to the Estate that you and your team have put a significant amount of time Into reviewing the proposed claims fund in its current form. Your suggestions and requested commitments, as outlined, demonstrate that the best interests of the victims are at the forefront of your mission. That alone is comforting to us as we wade through conversations with our clients regarding the current status of affairs. + +That being said, I reached out to both of our clients immediately, who appreciate tremendously your willingness to meet with them. We look forward to facilitating an even more expansive free flow of ideas in an effort to reach a resolution that is most advantageous to the survivors. At your direction, we will contact Ms. Springette today to coordinate a time that works best for you and your office. + +In the meantime, please let us know if you are available this afternoon for a short call to discuss which portions of your letter, if any, you would feel comfortable with us sharing with the court tomorrow during the status conference for all currently pending cases being litigated in the Southern District of New York. Alternatively, we can speak in the morning prior to the conference which is set to begin at 10am EST. + +We look forward to speaking and continuing to work with you. + +Brittany Henderson, Esq. Edwards Pottin er LLC + +On Feb 10, 2020, at 11:45 AM, Denise George
+ +Subject: RE: Epstein probate update + +I would be happy to chat about this tomorrow (with and EL I have a court conference tomorrow from 9:30- 11:00 and a NYCHA conference call at noon; otherwise am available. + +We were just talking about whether we should replace on this matter. We were not sure how much work would be needed going forward. Maybe we could figure that out after the call. + +Sent: Thursday, May 28, 2020 12:24 PM + +Tod USANYS) + +Cc: + +Subject: FW: Epstein probate update + +Geoff would like to have a Webex tomorrow with ■and **(theoretically) .which he would like you to attend, so I start with you knowing how busy you are.** + +**We are getting to the point where we need to more concretely plan our litigation with the estate.** + +**Did I hear you say that to give birth? If so, wonderful!, but should we get someone else assigned to this matter?** + +**From: Sent: Thursda , Februa 20, 2020 12:47 PM** + +**To:** + +**u jec : pstein pro ate up ate** + +**All,** + +**Recent filings in the Epstein probate case reflect the following developments, which might be of interest.** + +**First, the probate court denied the Virgin Islands Attorney General's motion to intervene in the probate proceedings.** + +**Second, it appears that the court directed the AG to ensure that its criminal activity liens on the estate's property did not prevent the executors from paying administrative expenses or preserving the estate's assets. However, the estate's bank accounts are currently frozen due to the AG's liens, and the AG is taking the position that it will only allow funds to be released if the AG first approves all of the executors' proposed expenditures. The executors have moved the probate court for emergency relief, asking that they be given full access to the estate's funds to pay administrative expenses and preserve assets without the AG's prior approval.** + +**Third, the AG sent a letter to the executors laying out the AG's demands for a fair victim compensation program. Those include the following, which may be of particular interest (the full letter can be found at Ex. 6 of the attached document):** + +- **The estate must cooperate with the AG's investigations into Epstein and his affiliates.** +- **The estate must waive any non-disclosure agreements signed by former employees of Epstein or his affiliates, and notify such employees that they are encouraged to fully cooperate with the AG's investigation.** +- **Participants in the compensation program will not be required to sign any third-party releases (apparently, the current proposal would involve such releases).** +- **The estate must provide a complete inventory of assets held by the estate, the 1953 Trust, Epstein, and any entities he controlled, even if those assets are exempt from the probate process.** +- **The executors cannot play any role in establishing the victim compensation program or selecting its administrators.** + +**I have not seen evidence of the executors' response to the AG's letter.** + +From: USANYS) < Sent: Thursday, February 13, 2020 9:54 AM To: (USANYS) usa.doj,gai> Subject: FW: SDNY News Clips, Wednesday, February 12, 2020 + +Would you please send around the AG's filing accusing the executors of complicity? + +Last month, George brought charges against Epstein's estate and alleged that his lawyers, Darren Indyke and Richard Kahn, may have been part of Epstein's alleged fraud. George also put claims on Epstein's two islands. + +Thanks. + +Epstein's lawyers in dispute with Virgin Islands over settlements with victims + +The Guardian By Edward Helmore 2/12/2020 + +Efforts to settle sex abuse claims against Jeffrey Epstein's estate are being thwarted by the attorney general of the US Virgin Islands, lawyers for the disgraced late financier have claimed in court. + +The dispute arises from efforts by the territory's attorney general, Denise George, to claim that Epstein, who owned two islands in the Virgin Islands and where monetary claims on his estate are focused, fraudulently obtained benefits related to a banking licence as part of his alleged criminal enterprise. + +In court documents, George said she planned to name the disgraced financier's lawyers as co-defendants and fight his estate's involvement in creating a victims' compensation fund. + +In July last year, Epstein was arrested on fresh federal sex trafficking and conspiracy charges. He had previously pleaded guilty in 2008 to a Florida state prostitution charge and completed a 13-month jail sentence. Epstein pleaded not guilty to the new allegations but died by suicide in a New York jail cell in August. + +His death has triggered a wide-ranging investigation into his associates and members of his powerful social circle and also many victim claims for compensation. + +Bennet Moskowitz, who is representing Epstein's estate, claimed that liens against the estate have left him unable to release money from Epstein's \$570m fortune to a victim's compensation fund. + +"The attorney general for the Virgin Islands has decided for whatever reason to impede the program;' Moskowitz said at the hearing in Manhattan federal court. + +But George countered that claim, saying she was in fact looking out for victims who may yet come forward. + +"The attorney general's office has opposed the approval of the fund as currently proposed because it lacks fairness, accountability, impartiality and sensitivity to victims at a level they deserve," George said in the statement. + +"Further, victims who have not yet come forward or who may not wish to use the fund must be supported and protected, with funds for counseling and for their claims, too," she said, adding: "There must be full accountability, not only of the estate, but those who participated in, facilitated, and covered up Epstein's crimes." + +Last month, George brought charges against Epstein's estate and alleged that his lawyers, Darren Indyke and Richard Kahn, may have been part of Epstein's alleged fraud. George also put claims on Epstein's two islands. + +Epstein named Indyke and Kahn as his executors to a will he modified so that it would be executed in the Caribbean territory two days before he was found dead in a Manhattan jail cell on 10 August. + +In November, it was reported that Epstein's estate had asked the courts to allow a voluntary resolution program for the late sex offender's accusers overseen by Ken Feinberg, the settlement's expert who oversaw claims from victims of the 9/11 terrorist attacks, the Catholic church's sex abuse scandals, and the BP-Blue Water Horizon oil spill. + +But lawyers for several victims have argued that a victims fund would maintain the shroud of secrecy over Epstein's alleged crimes and prevent the release of any new information while minimizing the threat of large jury awards from individual legal actions. \ No newline at end of file diff --git a/marker2/ds9/EFTA00087314/EFTA00087314.metadata.json b/marker2/ds9/EFTA00087314/EFTA00087314.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..fa14dd754d05cc3e0bbdd7295e8f9ba379718281 --- /dev/null +++ b/marker2/ds9/EFTA00087314/EFTA00087314.metadata.json @@ -0,0 +1,152 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087314.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 4, + "chars": 7954, + "elapsed_seconds": 1.59, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 87 + ], + [ + "Line", + 40 + ], + [ + "Text", + 30 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 77 + ], + [ + "Line", + 37 + ], + [ + "Text", + 18 + ], + [ + "ListItem", + 5 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 73 + ], + [ + "Line", + 37 + ], + [ + "Text", + 17 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 3, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 17 + ], + [ + "Line", + 9 + ], + [ + "Text", + 3 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087314" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087318/EFTA00087318.md b/marker2/ds9/EFTA00087318/EFTA00087318.md new file mode 100644 index 0000000000000000000000000000000000000000..2dffdeee6ed1653c0940fcf8afb4395c132228e8 --- /dev/null +++ b/marker2/ds9/EFTA00087318/EFTA00087318.md @@ -0,0 +1,125 @@ +To: (USANYS)" + +Subject: RE: Epstein probate update + +Date: Thu, 28 May 2020 17:40:51 +0000 + +Note that if we do this afternoon, it won't be able to be a webex given the tight timeframe. It takes at least a couple of hours to request a webex. + +From: (USANYS) [Contractor] + +Sent: Thursda Ma 28, 2020 12 56 PM + +To (USANYS) < > + +Subject: Re: Epstein probate update + +\_-is out tomorrow for a religious holiday but has availability this afternoon after 230 or next week. Would you like to do one of those options, or go ahead tomorrow without her? + +On May 28, 2020, at 12:35 PM, USANYS) c › wrote: + +Ok; I will ask =, by copy of this email, to schedule 30 minutes with tomorrow on this. + +Epstein estate. + +attendees are Eland me. + +Thanks. + +From: (USANYS). > + +Sent: Thursday, May 28, 2020 12:32 PM + +To: (USANYS). > + +Ca(USANYS) < M> + +Subject: RE: Epstein probate update + +I would be happy to chat about this tomorrow (with and I have a court conference tomorrow from 9:30- 11:00 and a NYCHA conference call at noon; otherwise I am available. + +We were just talking about whether we should replace Mon this matter. We were not sure how much work would be needed going forward. Maybe we could figure that out after the call. + +From: USANYS) + +Sent: Thursday, May 28, 2020 12:24 PM + +To: USANYS) + +Cc: (USANYS) < > + +Subject: FW: Epstein probate update + +• would like to have a Webex tomorrow with and (theoretically)Mwhich he would like you to attend, so I start with you knowing how busy you are. + +We are getting to the point where we need to more concretely plan our litigation with the estate. + +Did I hear you say that about to give birth? If so, wonderful!, but should we get someone else assigned to this matter? + +Sent: Thursda , February 20, 2020 12:47 PM + +To: (USANYS) < >; (USANYS) causa.dobgcLi> (USANYS) + +Subject: Epstein probate update + +All, + +Recent filings in the Epstein probate case reflect the following developments, which might be of interest. + +First, the probate court denied the Virgin Islands Attorney General's motion to intervene in the probate proceedings. + +Second, it appears that the court directed the AG to ensure that its criminal activity liens on the estate's property did not prevent the executors from paying administrative expenses or preserving the estate's assets. However, the estate's bank accounts are currently frozen due to the AG's liens, and the AG is taking the position that it will only allow funds to be released if the AG first approves all of the executors' proposed expenditures. The executors have moved the probate court for emergency relief, asking that they be given full access to the estate's funds to pay administrative expenses and preserve assets without the AG's prior approval. + +Third, the AG sent a letter to the executors laying out the AG's demands for a fair victim compensation program. Those include the following, which may be of particular interest (the full letter can be found at Ex. 6 of the attached document): + +- The estate must cooperate with the AG's investigations into Epstein and his affiliates. +- The estate must waive any non-disclosure agreements signed by former employees of Epstein or his affiliates, and notify such employees that they are encouraged to fully cooperate with the AG's investigation. +- Participants in the compensation program will not be required to sign any third-party releases (apparently, the current proposal would involve such releases). +- The estate must provide a complete inventory of assets held by the estate, the 1953 Trust, Epstein, and any entities he controlled, even if those assets are exempt from the probate process. +- The executors cannot play any role in establishing the victim compensation program or selecting its administrators. + +I have not seen evidence of the executors' response to the AG's letter. + +From: USANYS) < + +Sent: Thursda , February 13, 2020 9:54 AM + +To: (USANYS) a@usa.doLgov> + +Subject: FW: SDNY News Clips, Wednesday, February 12, 2020 + +Would you please send around the AG's filing accusing the executors of complicity? + +Last month, George brought charges against Epstein's estate and alleged that his lawyers, Darren Indyke and Richard Kahn, may have been part of Epstein's alleged fraud. George also put claims on Epstein's two islands. + +Thanks. + +The Guardian By Edward Helmore 2/12/2020 + +Efforts to settle sex abuse claims against Jeffrey Epstein's estate are being thwarted by the attorney general of the US Virgin Islands, lawyers for the disgraced late financier have claimed in court. + +The dispute arises from efforts by the territory's attorney general, Denise George, to claim that Epstein, who owned two islands in the Virgin Islands and where monetary claims on his estate are focused, fraudulently obtained benefits related to a banking licence as part of his alleged criminal enterprise. + +In court documents, George said she planned to name the disgraced financier's lawyers as co-defendants and fight his estate's involvement in creating a victims' compensation fund. + +In July last year, Epstein was arrested on fresh federal sex trafficking and conspiracy charges. He had previously pleaded guilty in 2008 to a Florida state prostitution charge and completed a 13-month jail sentence. Epstein pleaded not guilty to the new allegations but died by suicide in a New York jail cell in August. + +His death has triggered a wide-ranging investigation into his associates and members of his powerful social circle and also many victim claims for compensation. + +Bennet Moskowitz, who is representing Epstein's estate, claimed that liens against the estate have left him unable to release money from Epstein's \$570m fortune to a victim's compensation fund. + +"The attorney general for the Virgin Islands has decided for whatever reason to impede the program;' Moskowitz said at the hearing in Manhattan federal court. + +But George countered that claim, saying she was in fact looking out for victims who may yet come forward. + +"The attorney general's office has opposed the approval of the fund as currently proposed because it lacks fairness, accountability, impartiality and sensitivity to victims at a level they deserve," George said in the statement. + +"Further, victims who have not yet come forward or who may not wish to use the fund must be supported and protected, with funds for counseling and for their claims, too," she said, adding: "There must be full accountability, not only of the estate, but those who participated in, facilitated, and covered up Epstein's crimes." + +Last month, George brought charges against Epstein's estate and alleged that his lawyers, Darren Indyke and Richard Kahn, may have been part of Epstein's alleged fraud. George also put claims on Epstein's two islands. + +Epstein named Indyke and Kahn as his executors to a will he modified so that it would be executed in the Caribbean territory two days before he was found dead in a Manhattan jail cell on 10 August. + +In November, it was reported that Epstein's estate had asked the courts to allow a voluntary resolution program for the late sex offender's accusers overseen by Ken Feinberg, the settlement's expert who oversaw claims from victims of the 9/11 terrorist attacks, the Catholic church's sex abuse scandals, and the BP-Blue Water Horizon oil spill. + +But lawyers for several victims have argued that a victims fund would maintain the shroud of secrecy over Epstein's alleged crimes and prevent the release of any new information while minimizing the threat of large jury awards from individual legal actions. \ No newline at end of file diff --git a/marker2/ds9/EFTA00087318/EFTA00087318.metadata.json b/marker2/ds9/EFTA00087318/EFTA00087318.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..3f279bf65e876c294b05d4b86533c27ae3bcd24f --- /dev/null +++ b/marker2/ds9/EFTA00087318/EFTA00087318.metadata.json @@ -0,0 +1,122 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087318.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 7528, + "elapsed_seconds": 1.76, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 91 + ], + [ + "Line", + 40 + ], + [ + "Text", + 31 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 75 + ], + [ + "Line", + 38 + ], + [ + "Text", + 18 + ], + [ + "ListItem", + 5 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 71 + ], + [ + "Line", + 36 + ], + [ + "Text", + 15 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087318" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087321/EFTA00087321.md b/marker2/ds9/EFTA00087321/EFTA00087321.md new file mode 100644 index 0000000000000000000000000000000000000000..f351984833dcf50e464cf9a16a75bc8637adfe99 --- /dev/null +++ b/marker2/ds9/EFTA00087321/EFTA00087321.md @@ -0,0 +1,114 @@ +From: JSANYS)" < To:iIIIIIM((USANYS) [Contractor]" < Subject: RE: Epstein probate update Date: Thu, 28 May 2020 18:04:22 +0000 + +Waiting for reply from to suggestion of staying on 3 call and having that; yes sorry, I left you off I guess. and join; so may need your help with + +From: (USANYS) [Contractor] Sent: Thursday, May 28, 2020 2:03 PM To:- (USANYS) Subject: RE: Epstein probate update + +No I did not, I must have been left off a chain. Is it all sorted? + +From USANYS) Sent: Thursday, May 28, 2020 2:02 PM To (USANYS) [Contractor] cz > Subject: RE: Epstein probate update + +But we can stay on 3 pm call — you saw my email? + +From: (USANYS) [Contractor] Sent: Thursda Ma 28, 2020 1:41 PM To: USANYS) < Subject: RE: Epstein probate update + +Note that if we do this afternoon, it won't be able to be a webex given the tight timeframe. It takes at least a couple of hours to request a webex. + +From (USANYS) [Contractor] Sent: Thursday, May 28, 2020 12:56 PM To: (USANYS) Subject: Re: Epstein probate update + +s out tomorrow for a religious holiday but has availability this afternoon after 230 or next week. Would you like to do one of those options, or go ahead tomorrow without her? + +On May 28, 2020, at 12:35 PM, USANYS) ‹ > wrote: + +Ok; I will ask by copy of this email, to schedule 30 minutes with Epstein estate. attendees are Thanks. tomorrow on this. + +From: USANYS) < Sent: Thursday, May 28, 2020 12:32 PM To: (USANYS) < Cc iSANYS) c > Subject: RE: Epstein probate update + +I would be happy to chat about this tomorrow (with -ands. I have a court conference tomorrow from 9:30- 11:00 and a NYCHA conference call at noon; otherwise I am available. + +We were just talking about whether we should replace Mon this matter. We were not sure how much work would be needed going forward. Maybe we could figure that out after the call. + +From: (USANYS) Sent: Thursday, May 28, 2020 12:24 PM To: USANYS) Cc: (USANYS)\*ca Subject: FW: Epstein probate update + +would like to have a Webex tomorrow with. and (theoretically) which he would like you to attend, so I start with you knowing how busy you are. + +We are getting to the point where we need to more concretely plan our litigation with the estate. + +Did I hear you say that about to give birth? If so, wonderful!, but should we get someone else assigned to this matter? + +From USANYS) + +Sent: Thursda , February 20, 2020 12:47 PM + +To: USANYS) < >; (USANYS) < >: + +Subject: Epstein probate update + +All, + +Recent filings in the Epstein probate case reflect the following developments, which might be of interest. + +First, the probate court denied the Virgin Islands Attorney General's motion to intervene in the probate proceedings. + +Second, it appears that the court directed the AG to ensure that its criminal activity liens on the estate's property did not prevent the executors from paying administrative expenses or preserving the estate's assets. However, the estate's bank accounts are currently frozen due to the AG's liens, and the AG is taking the position that it will only allow funds to be released if the AG first approves all of the executors' proposed expenditures. The executors have moved the probate court for emergency relief, asking that they be given full access to the estate's funds to pay administrative expenses and preserve assets without the AG's prior approval. + +Third, the AG sent a letter to the executors laying out the AG's demands for a fair victim compensation program. Those include the following, which may be of particular interest (the full letter can be found at Ex. 6 of the attached document): + +- The estate must cooperate with the AG's investigations into Epstein and his affiliates. +- The estate must waive any non-disclosure agreements signed by former employees of Epstein or his affiliates, and notify such employees that they are encouraged to fully cooperate with the AG's investigation. +- Participants in the compensation program will not be required to sign any third-party releases (apparently, the current proposal would involve such releases). +- The estate must provide a complete inventory of assets held by the estate, the 1953 Trust, Epstein, and any entities he controlled, even if those assets are exempt from the probate process. + +- The executors cannot play any role in establishing the victim compensation program or selecting its administrators. + +I have not seen evidence of the executors' response to the AG's letter. + +From:(USANYS) + +Sent: Thursday, February 13, 2020 9:54 AM + +To (USANYS) + +Subject: FW: SDNY News Clips, Wednesday, February 12, 2020 + +Would you please send around the AG's filing accusing the executors of complicity? + +Last month, George brought charges against Epstein's estate and alleged that his lawyers, Darren Indyke and Richard Kahn, may have been part of Epstein's alleged fraud. George also put claims on Epstein's two islands. + +Thanks. + +## Epstein's lawyers in dispute with Virgin Islands over settlements with victims + +The Guardian + +By Edward Helmore + +2/12/2020 + +Efforts to settle sex abuse claims against Jeffrey Epstein's estate are being thwarted by the attorney general of the US Virgin Islands, lawyers for the disgraced late financier have claimed in court. + +The dispute arises from efforts by the territory's attorney general, Denise George, to claim that Epstein, who owned two islands in the Virgin Islands and where monetary claims on his estate are focused, fraudulently obtained benefits related to a banking licence as part of his alleged criminal enterprise. + +In court documents, George said she planned to name the disgraced financier's lawyers as co-defendants and fight his estate's involvement in creating a victims' compensation fund. + +In July last year, Epstein was arrested on fresh federal sex trafficking and conspiracy charges. He had previously pleaded guilty in 2008 to a Florida state prostitution charge and completed a 13-month jail sentence. Epstein pleaded not guilty to the new allegations but died by suicide in a New York jail cell in August. + +His death has triggered a wide-ranging investigation into his associates and members of his powerful social circle and also many victim claims for compensation. + +Bennet Moskowitz, who is representing Epstein's estate, claimed that liens against the estate have left him unable to release money from Epstein's \$570m fortune to a victim's compensation fund. + +"The attorney general for the Virgin Islands has decided for whatever reason to impede the program;' Moskowitz said at the hearing in Manhattan federal court. + +But George countered that claim, saying she was in fact looking out for victims who may yet come forward. + +"The attorney general's office has opposed the approval of the fund as currently proposed because it lacks fairness, accountability, impartiality and sensitivity to victims at a level they deserve," George said in the statement. + +"Further, victims who have not yet come forward or who may not wish to use the fund must be supported and protected, with funds for counseling and for their claims, too," she said, adding: "There must be full accountability, not only of the estate, but those who participated in, facilitated, and covered up Epstein's crimes." + +Last month, George brought charges against Epstein's estate and alleged that his lawyers, Darren Indyke and Richard Kahn, may have been part of Epstein's alleged fraud. George also put claims on Epstein's two islands. + +Epstein named Indyke and Kahn as his executors to a will he modified so that it would be executed in the Caribbean territory two days before he was found dead in a Manhattan jail cell on 10 August. + +In November, it was reported that Epstein's estate had asked the courts to allow a voluntary resolution program for the late sex offender's accusers overseen by Ken Feinberg, the settlement's expert who oversaw claims from victims of the 9/11 terrorist attacks, the Catholic church's sex abuse scandals, and the BP-Blue Water Horizon oil spill. + +But lawyers for several victims have argued that a victims fund would maintain the shroud of secrecy over Epstein's alleged crimes and prevent the release of any new information while minimizing the threat of large jury awards from individual legal actions. \ No newline at end of file diff --git a/marker2/ds9/EFTA00087321/EFTA00087321.metadata.json b/marker2/ds9/EFTA00087321/EFTA00087321.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..164d4d43399f81c634c101c3a33db3d981e1ebf4 --- /dev/null +++ b/marker2/ds9/EFTA00087321/EFTA00087321.metadata.json @@ -0,0 +1,188 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087321.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 4, + "chars": 8222, + "elapsed_seconds": 1.43, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Epstein's lawyers in dispute with Virgin Islands over settlements with victims", + "heading_level": null, + "page_id": 2, + "polygon": [ + [ + 34.272, + 314.28000000000003 + ], + [ + 389.64581298828125, + 314.28000000000003 + ], + [ + 389.64581298828125, + 328.5840759277344 + ], + [ + 34.272, + 328.5840759277344 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 94 + ], + [ + "Line", + 41 + ], + [ + "Text", + 13 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 77 + ], + [ + "Line", + 38 + ], + [ + "Text", + 15 + ], + [ + "ListItem", + 4 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 69 + ], + [ + "Line", + 35 + ], + [ + "Text", + 23 + ], + [ + "ListGroup", + 1 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ], + [ + "ListItem", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 3, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 27 + ], + [ + "Line", + 14 + ], + [ + "Text", + 5 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087321" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087325/EFTA00087325.md b/marker2/ds9/EFTA00087325/EFTA00087325.md new file mode 100644 index 0000000000000000000000000000000000000000..76ca572d73d0e646fae42fcd74ebcbdc2a7c3ff8 --- /dev/null +++ b/marker2/ds9/EFTA00087325/EFTA00087325.md @@ -0,0 +1,97 @@ +From: To: USANYS)" < USANYS) [Contractor]" < Subject: RE: Epstein probate update Date: Thu, 28 May 2020 18:01:33 +0000 + +But we can stay on 3 pm call — you saw my email? + +From: (USANYS) [Contractor] Sent: Thursday, May 28, 2020 1:41 PM To: USANYS) Subject: RE: Epstein probate update < < + +Note that if we do this afternoon, it won't be able to be a webex given the tight timeframe. It takes at least a couple of hours to request a webex. + +From: (USANYS) [Contractor] Sent: Thursda May 28, 2020 12:56 PM To: (USANYS) Subject: Re: Epstein probate update + +=, IN is out tomorrow for a religious holiday but has availability this afternoon after 230 or next week. Would you like to do one of those options, or go ahead tomorrow without her? + +On May 28, 2020, at 12:35 PM, (USANYS) wrote: + +Ok; I will ask= by copy of this email, to schedule 30 minutes with Epstein estate. attendees are and me. Thanks. tomorrow on this. + +From: USANYS) Sent: Thursday, May 28, 2020 12:32 PM To: (USANYS) Cc: [USANYS) Subject: RE: Epstein probate update + +I would be happy to chat about this tomorrow (with and.). I have a court conference tomorrow from 9:30- 11:00 and a NYCHA conference call at noon; otherwise I am available. + +We were just talking about whether we should replace Mon this matter. We were not sure how much work would be needed going forward. Maybe we could figure that out after the call. + +From: (USANYS) Sent: Thursday, May 28, 2020 12:24 PM To: (USANYS) Cc: (USANYS) < > Subject: FW: Epstein probate update + +We are getting to the point where we need to more concretely plan our litigation with the estate. + +Did I hear you say that about to give birth? If so, wonderful!, but should we get someone else assigned to this matter? + +From: (USANYS) + +Sent: Thursda February 20, 2020 12:47 PM + +To: (USANYS) < (USANYS) (USANYS) + +Subject: Epstein probate update + +All, + +Recent filings in the Epstein probate case reflect the following developments, which might be of interest. + +First, the probate court denied the Virgin Islands Attorney General's motion to intervene in the probate proceedings. + +Second, it appears that the court directed the AG to ensure that its criminal activity liens on the estate's property did not prevent the executors from paying administrative expenses or preserving the estate's assets. However, the estate's bank accounts are currently frozen due to the AG's liens, and the AG is taking the position that it will only allow funds to be released if the AG first approves all of the executors' proposed expenditures. The executors have moved the probate court for emergency relief, asking that they be given full access to the estate's funds to pay administrative expenses and preserve assets without the AG's prior approval. + +Third, the AG sent a letter to the executors laying out the AG's demands for a fair victim compensation program. Those include the following, which may be of particular interest (the full letter can be found at Ex. 6 of the attached document): + +- The estate must cooperate with the AG's investigations into Epstein and his affiliates. +- The estate must waive any non-disclosure agreements signed by former employees of Epstein or his affiliates, and notify such employees that they are encouraged to fully cooperate with the AG's investigation. +- Participants in the compensation program will not be required to sign any third-party releases (apparently, the current proposal would involve such releases). +- The estate must provide a complete inventory of assets held by the estate, the 1953 Trust, Epstein, and any entities he controlled, even if those assets are exempt from the probate process. +- The executors cannot play any role in establishing the victim compensation program or selecting its administrators. + +I have not seen evidence of the executors' response to the AG's letter. + +From: (USANYS) < + +Sent: Thursday, February 13, 2020 9:54 AM + +ToMMIEUSANYS) + +Subject: FW: SDNY News Clips, Wednesday, February 12, 2020 + +Last month, George brought charges against Epstein's estate and alleged that his lawyers, Darren Indyke and Richard Kahn, may have been part of Epstein's alleged fraud. George also put claims on Epstein's two islands. + +Thanks. + +## Epstein's lawyers in dispute with Virgin Islands over settlements with victims + +The Guardian By Edward Helmore 2/12/2020 + +Efforts to settle sex abuse claims against Jeffrey Epstein's estate are being thwarted by the attorney general of the US Virgin Islands, lawyers for the disgraced late financier have claimed in court. + +The dispute arises from efforts by the territory's attorney general, Denise George, to claim that Epstein, who owned two islands in the Virgin Islands and where monetary claims on his estate are focused, fraudulently obtained benefits related to a banking licence as part of his alleged criminal enterprise. + +In court documents, George said she planned to name the disgraced financier's lawyers as co-defendants and fight his estate's involvement in creating a victims' compensation fund. + +In July last year, Epstein was arrested on fresh federal sex trafficking and conspiracy charges. He had previously pleaded guilty in 2008 to a Florida state prostitution charge and completed a 13-month jail sentence. Epstein pleaded not guilty to the new allegations but died by suicide in a New York jail cell in August. + +His death has triggered a wide-ranging investigation into his associates and members of his powerful social circle and also many victim claims for compensation. + +Bennet Moskowitz, who is representing Epstein's estate, claimed that liens against the estate have left him unable to release money from Epstein's \$570m fortune to a victim's compensation fund. + +"The attorney general for the Virgin Islands has decided for whatever reason to impede the program;' Moskowitz said at the hearing in Manhattan federal court. + +But George countered that claim, saying she was in fact looking out for victims who may yet come forward. + +"The attorney general's office has opposed the approval of the fund as currently proposed because it lacks fairness, accountability, impartiality and sensitivity to victims at a level they deserve," George said in the statement. + +"Further, victims who have not yet come forward or who may not wish to use the fund must be supported and protected, with funds for counseling and for their claims, too," she said, adding: "There must be full accountability, not only of the estate, but those who participated in, facilitated, and covered up Epstein's crimes." + +Last month, George brought charges against Epstein's estate and alleged that his lawyers, Darren Indyke and Richard Kahn, may have been part of Epstein's alleged fraud. George also put claims on Epstein's two islands. + +Epstein named Indyke and Kahn as his executors to a will he modified so that it would be executed in the Caribbean territory two days before he was found dead in a Manhattan jail cell on 10 August. + +In November, it was reported that Epstein's estate had asked the courts to allow a voluntary resolution program for the late sex offender's accusers overseen by Ken Feinberg, the settlement's expert who oversaw claims from victims of the 9/11 terrorist attacks, the Catholic church's sex abuse scandals, and the BP-Blue Water Horizon oil spill. + +But lawyers for several victims have argued that a victims fund would maintain the shroud of secrecy over Epstein's alleged crimes and prevent the release of any new information while minimizing the threat of large jury awards from individual legal actions. \ No newline at end of file diff --git a/marker2/ds9/EFTA00087325/EFTA00087325.metadata.json b/marker2/ds9/EFTA00087325/EFTA00087325.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..08b99ab4a2dca1b7f6f2ebc6a092e58467f270ff --- /dev/null +++ b/marker2/ds9/EFTA00087325/EFTA00087325.metadata.json @@ -0,0 +1,180 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087325.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 4, + "chars": 7543, + "elapsed_seconds": 1.19, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Epstein's lawyers in dispute with Virgin Islands over settlements with victims", + "heading_level": null, + "page_id": 2, + "polygon": [ + [ + 34.272, + 106.92 + ], + [ + 389.64581298828125, + 106.92 + ], + [ + 389.64581298828125, + 120.0841064453125 + ], + [ + 34.272, + 120.0841064453125 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 86 + ], + [ + "Line", + 42 + ], + [ + "Text", + 12 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 77 + ], + [ + "Line", + 39 + ], + [ + "Text", + 18 + ], + [ + "ListItem", + 5 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 73 + ], + [ + "Line", + 37 + ], + [ + "Text", + 16 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 3, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 7 + ], + [ + "Line", + 4 + ], + [ + "Text", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087325" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087329/EFTA00087329.md b/marker2/ds9/EFTA00087329/EFTA00087329.md new file mode 100644 index 0000000000000000000000000000000000000000..78b023c129f3b9844ed18be4f4e511dc4fd79a93 --- /dev/null +++ b/marker2/ds9/EFTA00087329/EFTA00087329.md @@ -0,0 +1,97 @@ +From (USANYS)" •rz To: USANYS) [Contractor]" Subject: FW: Epstein probate update Date: Thu, 28 May 2020 18:16:47 +0000 + +Pls alert . We will start this Webex when 3pm call ends.Mwill stay on and we will call or email and tojoin. + +From: Berman, Geoffrey (USANYS) Sent: Thursday, May 28, 2020 2:10 PM To: USANYS) Subject: Re: Epstein probate update + +Yes. Today after Webex + +On May 28, 2020, at 2:00 PM (USANYS) ca wrote: + +Friday does not work. Your choice. Today after 2:30 — which means working around the 3pm call. We could ask.to stay on the Webex and have —join? + +From USANYS) [Contractor] Sent: Thursday, May 28, 2020 12:56 PM To: ISANYS) < Subject: Re: Epstein probate update + +is out tomorrow for a religious holiday but has availability this afternoon after 230 or next week. Would you like to do one of those options, or go ahead tomorrow without her? + +On May 28, 2020, at 12:35 PM, USANYS) wrote: + +Ok; I will ask by copy of this email, to schedule 30 minutes with Geoff tomorrow on this. 'lin estate. + +attendees are Geoff, Thanks. + +From: (USANYS). Sent: Thursda Ma 28, 2020 12:32 PM To (USANYS) > Cc: (USANYS) < => Subject: RE: Epstein probate update + +I would be happy to chat about this tomorrow (with . I have a court conference tomorrow from 9:30- 11:00 and a NYCHA conference call at noon; otherwise I am available. + +We were just talking about whether we should replace=on this matter. We were not sure how much work would be needed going forward. Maybe we could figure that out after the call. + +From SANYS) Sent: Thursda , Ma 28, 2020 12:24 PM To: (USANYS) c › Cc: USANYS) < > Subject: FW: Epstein probate update + +Geoff would like to have a Webex tomorrow wit hich he would like you to attend, so I start with you knowing how busy you are. + +We are getting to the point where we need to more concretely plan our litigation with the estate. + +Did I hear you say that-about to give birth? If so, wonderful!, but should we get someone else assigned to this matter? + +From• Sent: Thursda , Februa 20, 2020 12:47 PM To: + +Subject: Epstein probate update + +All, + +Recent filings in the Epstein probate case reflect the following developments, which might be of interest. + +First, the probate court denied the Virgin Islands Attorney General's motion to intervene in the probate proceedings. + +Second, it appears that the court directed the AG to ensure that its criminal activity liens on the estate's property did not prevent the executors from paying administrative expenses or preserving the estate's assets. However, the estate's bank accounts are currently frozen due to the AG's liens, and the AG is taking the position that it will only allow funds to be released if the AG first approves all of the executors' proposed expenditures. The executors have moved the probate court for emergency relief, asking that they be given full access to the estate's funds to pay administrative expenses and preserve assets without the AG's prior approval. + +Third, the AG sent a letter to the executors laying out the AG's demands for a fair victim compensation program. Those include the following, which may be of particular interest (the full letter can be found at Ex. 6 of the attached document): + +- The estate must cooperate with the AG's investigations into Epstein and his affiliates. +- The estate must waive any non-disclosure agreements signed by former employees of Epstein or his affiliates, and notify such employees that they are encouraged to fully cooperate with the AG's investigation. +- Participants in the compensation program will not be required to sign any third-party releases (apparently, the current proposal would involve such releases). +- The estate must provide a complete inventory of assets held by the estate, the 1953 Trust, Epstein, and any entities he controlled, even if those assets are exempt from the probate process. +- The executors cannot play any role in establishing the victim compensation program or selecting its administrators. + +I have not seen evidence of the executors' response to the AG's letter. + +From:MMINEM(USANYS) < Sent: Thursda February 13, 2020 9:54 AM To: USANYS) Subject: FW: SDNY News Clips, Wednesday, February 12, 2020 + +Would you please send around the AG's filing accusing the executors of complicity? + +Last month, George brought charges against Epstein's estate and alleged that his lawyers, Darren Indyke and Richard Kahn, may have been part of Epstein's alleged fraud. George also put claims on Epstein's two islands. + +Thanks. + +## Epstein's lawyers in dispute with Virgin Islands over settlements with victims + +The Guardian By Edward Helmore 2/12/2020 + +Efforts to settle sex abuse claims against Jeffrey Epstein's estate are being thwarted by the attorney general of the US Virgin Islands, lawyers for the disgraced late financier have claimed in court. + +The dispute arises from efforts by the territory's attorney general, Denise George, to claim that Epstein, who owned two islands in the Virgin Islands and where monetary claims on his estate are focused, fraudulently obtained benefits related to a banking licence as part of his alleged criminal enterprise. + +In court documents, George said she planned to name the disgraced financier's lawyers as co-defendants and fight his estate's involvement in creating a victims' compensation fund. + +In July last year, Epstein was arrested on fresh federal sex trafficking and conspiracy charges. He had previously pleaded guilty in 2008 to a Florida state prostitution charge and completed a 13-month jail sentence. Epstein pleaded not guilty to the new allegations but died by suicide in a New York jail cell in August. + +His death has triggered a wide-ranging investigation into his associates and members of his powerful social circle and also many victim claims for compensation. + +Bennet Moskowitz, who is representing Epstein's estate, claimed that liens against the estate have left him unable to release money from Epstein's \$570m fortune to a victim's compensation fund. + +"The attorney general for the Virgin Islands has decided for whatever reason to impede the program;' Moskowitz said at the hearing in Manhattan federal court. + +But George countered that claim, saying she was in fact looking out for victims who may yet come forward. + +"The attorney general's office has opposed the approval of the fund as currently proposed because it lacks fairness, accountability, impartiality and sensitivity to victims at a level they deserve," George said in the statement. + +"Further, victims who have not yet come forward or who may not wish to use the fund must be supported and protected, with funds for counseling and for their claims, too," she said, adding: "There must be full accountability, not only of the estate, but those who participated in, facilitated, and covered up Epstein's crimes." + +Last month, George brought charges against Epstein's estate and alleged that his lawyers, Darren Indyke and Richard Kahn, may have been part of Epstein's alleged fraud. George also put claims on Epstein's two islands. + +Epstein named Indyke and Kahn as his executors to a will he modified so that it would be executed in the Caribbean territory two days before he was found dead in a Manhattan jail cell on 10 August. + +In November, it was reported that Epstein's estate had asked the courts to allow a voluntary resolution program for the late sex offender's accusers overseen by Ken Feinberg, the settlement's expert who oversaw claims from victims of the 9/11 terrorist attacks, the Catholic church's sex abuse scandals, and the BP-Blue Water Horizon oil spill. + +But lawyers for several victims have argued that a victims fund would maintain the shroud of secrecy over Epstein's alleged crimes and prevent the release of any new information while minimizing the threat of large jury awards from individual legal actions. \ No newline at end of file diff --git a/marker2/ds9/EFTA00087329/EFTA00087329.metadata.json b/marker2/ds9/EFTA00087329/EFTA00087329.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..0488c77365d164485c4620651f12fc5ce6f79c33 --- /dev/null +++ b/marker2/ds9/EFTA00087329/EFTA00087329.metadata.json @@ -0,0 +1,180 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087329.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 4, + "chars": 7828, + "elapsed_seconds": 1.16, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Epstein's lawyers in dispute with Virgin Islands over settlements with victims", + "heading_level": null, + "page_id": 2, + "polygon": [ + [ + 37.331999999999994, + 217.89000000000004 + ], + [ + 393.39581298828125, + 217.89000000000004 + ], + [ + 393.39581298828125, + 231.8341064453125 + ], + [ + 37.331999999999994, + 231.8341064453125 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 76 + ], + [ + "Line", + 35 + ], + [ + "Text", + 14 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 77 + ], + [ + "Line", + 37 + ], + [ + "Text", + 12 + ], + [ + "ListItem", + 5 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 75 + ], + [ + "Line", + 37 + ], + [ + "Text", + 16 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 3, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 17 + ], + [ + "Line", + 9 + ], + [ + "Text", + 3 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087329" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087333/EFTA00087333.md b/marker2/ds9/EFTA00087333/EFTA00087333.md new file mode 100644 index 0000000000000000000000000000000000000000..0ae3937b1bc772c6194b58ea6aeef2c1fc3c4cbb --- /dev/null +++ b/marker2/ds9/EFTA00087333/EFTA00087333.md @@ -0,0 +1,92 @@ +To: (USANYS)" + +Subject: RE: Epstein probate update + +Date: Thu, 28 May 2020 16:31:58 +0000 + +I would be happy to chat about this tomorrow (with and MI). I have a court conference tomorrow from 9:30-11:00 and a NYCHA conference call at noon; otherwise I am available. + +We were just talking about whether we should replace IM on this matter. We were not sure how much work would be needed going forward. Maybe we could figure that out after the call. + +From: (USANYS) + +Sent: Thursday, May 28, 2020 12:24 PM + +To: (USANYS) + +Cc: (USANYS) < > + +Subject: FW: Epstein probate update + +• Geoff would like to have a Webex tomorrow with =I and (theoretically)M which he would like you to attend, so I start with you knowing how busy you are. + +We are getting to the point where we need to more concretely plan our litigation with the estate. + +Did I hear you say that MI about to give birth? If so, wonderful!, but should we get someone else assigned to this + +From: (USANYS) II I=M> + +Sent: Thursda February 20, 2020 12:47 PM + +To: ,C>, US M=e (USANYS) > (USANYS) + +Subject: Epstein probate update + +All, + +Recent filings in the Epstein probate case reflect the following developments, which might be of interest. + +First, the probate court denied the Virgin Islands Attorney General's motion to intervene in the probate proceedings. + +Second, it appears that the court directed the AG to ensure that its criminal activity liens on the estate's property did not prevent the executors from paying administrative expenses or preserving the estate's assets. However, the estate's bank accounts are currently frozen due to the AG's liens, and the AG is taking the position that it will only allow funds to be released if the AG first approves all of the executors' proposed expenditures. The executors have moved the probate court for emergency relief, asking that they be given full access to the estate's funds to pay administrative expenses and preserve assets without the AG's prior approval. + +Third, the AG sent a letter to the executors laying out the AG's demands for a fair victim compensation program. Those include the following, which may be of particular interest (the full letter can be found at Ex. 6 of the attached document): + +- The estate must cooperate with the AG's investigations into Epstein and his affiliates. + +- The estate must waive any non-disclosure agreements signed by former employees of Epstein or his affiliates, and notify such employees that they are encouraged to fully cooperate with the AG's investigation. +- Participants in the compensation program will not be required to sign any third-party releases (apparently, the current proposal would involve such releases). +- The estate must provide a complete inventory of assets held by the estate, the 1953 Trust, Epstein, and any entities he controlled, even if those assets are exempt from the probate process. +- The executors cannot play any role in establishing the victim compensation program or selecting its administrators. + +I have not seen evidence of the executors' response to the AG's letter. + +From: (USANYS) < Sent: Thursday, February 13, 2020 9:54 AM To: (USANYS) < Subject: FW: SDNY News Clips, Wednesday, February 12, 2020 + +Would you please send around the AG's filing accusing the executors of complicity? + +Last month, George brought charges against Epstein's estate and alleged that his lawyers, Darren Indyke and Richard Kahn, may have been part of Epstein's alleged fraud. George also put claims on Epstein's two islands. + +Epstein's lawyers in dispute with Virgin Islands over settlements with victims + +The Guardian By Edward Helmore 2/12/2020 + +Efforts to settle sex abuse claims against Jeffrey Epstein's estate are being thwarted by the attorney general of the US Virgin Islands, lawyers for the disgraced late financier have claimed in court. + +The dispute arises from efforts by the territory's attorney general, Denise George, to claim that Epstein, who owned two islands in the Virgin Islands and where monetary claims on his estate are focused, fraudulently obtained benefits related to a banking licence as part of his alleged criminal enterprise. + +In court documents, George said she planned to name the disgraced financier's lawyers as co-defendants and fight his estate's involvement in creating a victims' compensation fund. + +In July last year, Epstein was arrested on fresh federal sex trafficking and conspiracy charges. He had previously pleaded guilty in 2008 to a Florida state prostitution charge and completed a 13-month jail sentence. Epstein pleaded not guilty to the new allegations but died by suicide in a New York jail cell in August. + +His death has triggered a wide-ranging investigation into his associates and members of his powerful social circle and also many victim claims for compensation. + +Bennet Moskowitz, who is representing Epstein's estate, claimed that liens against the estate have left him unable to release money from Epstein's \$570m fortune to a victim's compensation fund. + +"The attorney general for the Virgin Islands has decided for whatever reason to impede the program;' Moskowitz said at the hearing in Manhattan federal court. + +But George countered that claim, saying she was in fact looking out for victims who may yet come forward. + +"The attorney general's office has opposed the approval of the fund as currently proposed because it lacks fairness, accountability, impartiality and sensitivity to victims at a level they deserve," George said in the statement. + +"Further, victims who have not yet come forward or who may not wish to use the fund must be supported and protected, with funds for counseling and for their claims, too," she said, adding: "There must be full accountability, not only of the estate, but those who participated in, facilitated, and covered up Epstein's crimes." + +Last month, George brought charges against Epstein's estate and alleged that his lawyers, Darren Indyke and Richard Kahn, may have been part of Epstein's alleged fraud. George also put claims on Epstein's two islands. + +Epstein named Indyke and Kahn as his executors to a will he modified so that it would be executed in the Caribbean territory two days before he was found dead in a Manhattan jail cell on 10 August. + +In November, it was reported that Epstein's estate had asked the courts to allow a voluntary resolution program for the late sex offender's accusers overseen by Ken Feinberg, the settlement's expert who oversaw claims from victims of the 9/11 terrorist attacks, the Catholic church's sex abuse scandals, and the BP-Blue Water Horizon oil spill. + +But lawyers for several victims have argued that a victims fund would maintain the shroud of secrecy over Epstein's alleged crimes and prevent the release of any new information while minimizing the threat of large jury awards from individual legal actions. \ No newline at end of file diff --git a/marker2/ds9/EFTA00087333/EFTA00087333.metadata.json b/marker2/ds9/EFTA00087333/EFTA00087333.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..741b983dbbe946aa25f31074930bbb1629b6713f --- /dev/null +++ b/marker2/ds9/EFTA00087333/EFTA00087333.metadata.json @@ -0,0 +1,130 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087333.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 6860, + "elapsed_seconds": 1.39, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 81 + ], + [ + "Line", + 38 + ], + [ + "Text", + 24 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ], + [ + "ListItem", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 69 + ], + [ + "Line", + 35 + ], + [ + "Text", + 13 + ], + [ + "ListItem", + 4 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 37 + ], + [ + "Line", + 19 + ], + [ + "Text", + 8 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087333" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087336/EFTA00087336.md b/marker2/ds9/EFTA00087336/EFTA00087336.md new file mode 100644 index 0000000000000000000000000000000000000000..be693db9cd101a946148dd6eb8347b8a59982900 --- /dev/null +++ b/marker2/ds9/EFTA00087336/EFTA00087336.md @@ -0,0 +1,43 @@ +To + +Cc + +Subject: Re: Virgin Island case + +Date: Fri, 29 May 2020 12:52:53 +0000 + +Thanks works for Talia. is out today so let's plan for Monday. The windows you gave work for me so let's see what + +Best. + +On May 29, 2020, at 8:47 AM, (USANYS) > wrote: + +Thanks for the update= Could we find some time either later today or early next week to discuss? I'm fairly flexible this afternoon from about 2:30-5:30. Monday I could do 10-12:30 or 3-5:30. Let me know if anything in any of those windows works for you two. + +Best, Ted + +From: + +Sent: Thursday, May 28, 2020 4:09 PM + +To: (USANYS) + +Cc: Kraemer, Talia (USANYS) + +Subject: Virgin Island case + +Him + +Talia and I just met with Geoff to discuss the Virgin Islands case and our proposed course of action. We are going to prepare a statement of interest/motion that addresses 2 primary points: + +1) we would attach the various iterations of the trust agreement that show the addition of employees/beneficiaries over time, particularly since Epstein's arrest, and explain our concerns about the disloyalty clause and how it should be interpreted, thus putting those employees on notice that cooperating with the government should not interfere with any bequest made to them on grounds of "disloyalty." As part of the background explaining our concerns about this unusual trust and the disloyalty provision, we would also point out that the trustees are making exorbitant and highly unusual sums, which further renders the document suspect and suggests that the disloyalty provision may be used for nefarious purposes. + +2) we will also combine the above statement of interest points with a motion seeking to enjoin any bequest to Maxwell assuming that a criminal action has been filed already against Maxwell. + +In order to prepare our statement of interest, we will need to figure out which series of trust agreements are needed to show the addition of employees and beneficiaries who may be subject to the disloyalty provision. Didn't =prepare an excel chart already that would have this information? + +Would you in combination wits be able to prepare a 6(e) order to the Court allowing us to use key trust agreements in our public filing in the Virgin Islands? Because sometimes it's not clear when submitted documents are "filed," we should make sure the language in the 6(e) order is worded in such a way that after we "submit" the document to the surrogate's order for the purpose of filing it, we can simultaneously make it public such that any press release we file after submitting our document to the Surrogate's Court would not inadvertently disclose materials still covered by the 6(e) order. + +Happy to discuss tomorrow morning if you would like. + +Thanks, \ No newline at end of file diff --git a/marker2/ds9/EFTA00087336/EFTA00087336.metadata.json b/marker2/ds9/EFTA00087336/EFTA00087336.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..e1574cc4adda9335ae36178031c3290185f2eccf --- /dev/null +++ b/marker2/ds9/EFTA00087336/EFTA00087336.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087336.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2724, + "elapsed_seconds": 0.95, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 73 + ], + [ + "Line", + 36 + ], + [ + "Text", + 20 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 17 + ], + [ + "Line", + 9 + ], + [ + "Text", + 3 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087336" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087338/EFTA00087338.md b/marker2/ds9/EFTA00087338/EFTA00087338.md new file mode 100644 index 0000000000000000000000000000000000000000..9e3df2b7ac8aab276d2de478c048e5cf5563851c --- /dev/null +++ b/marker2/ds9/EFTA00087338/EFTA00087338.md @@ -0,0 +1,177 @@ +Dear Mr. Lane, + +Washington D.C. August 17, 2020 + +I am the project manager and editor of the International Consortium of Investigative Journalists (ICIJ), a nonprofit news organization based in Washington, DC. You can read our work here: www.icii.org + +I am writing because ICIJ in collaboration with other media outlets, including BuzzFeed News, NBC News and others are working on an investigation about bank compliance and anti-money-laundering systems around the world. We are examining numerous transactions with involvement of various banks, companies and people globally. + +Our investigation is based on thousands of suspicious activity reports. These reports were generated by various banks and submitted to the U.S. Treasury Department's Financial Crimes Enforcement Network. We understand that information contained in suspicious activity reports is not necessarily evidence of wrongdoing or criminality. We have closely examined information contained in these reports to identify financial transactions and financial relationships that help inform news stories in the public interest. + +Below we have a number of questions that we hope you will answer by our deadline of 6 p.m. GMT on August 27th, 2020. We would also like to request an interview with a Barclays Bank senior executive to discuss the issues raised in this article. + +## GENERAL + +- 1. In the suspicious activity reports we reviewed, Barclays filed the fifth-most in number, or 104 reports identifying more than \$21 billion in suspicious activity. Do you have any comment? +- 2. Between January 13th 2009 and August 11th 2017, Barclays facilitated \$12.5 billion in money transfers that involved nine billionaires appearing on the Forbes list anytime since 2010, according to suspicious activity reports filed between mid-2011 + +and September 2017, ICIJ analysis reveals. The \$12.5 billion, which was part of more than \$100 billion in comparable transfers via 16 banks, included transactions for the billionaires' companies and other entities and subjects related to them. Please comment on these money transfers Barclays facilitated. + +## BARCLAYS TRANSACTIONS FOR IVOR ICHIKOWITZ AND HIS COMPANIES + +- 3. ICIJ's reporting, which also draws on SAR 31000116798393, has uncovered that in the spring of 2017 Barclays UK Wealth received an Enhanced Due Diligence report from Christopher Steele's firm Orbis Business Intelligence as part of its Politically Exposed Persons (PEP) review into South African businessman Ichikowitz and his companies which Barclays services as a bank. The EDD3 report we are told is similar to the ones banks typically commission on high-risk clients. In the report, Steele firm's said it interviewed sources who said Ichikowitz benefited from donations to the African National Congress by being awarded major contracts. Did Barclays take any action in response to the concerns cited in the Orbis report? +- 4. An ICIJ analysis showed that between 2011 and 2017 Barclays facilitated more than \$256 million in transactions tied to Ivor Ichikowitz and his companies even after the bank was made aware of corruption allegations raised against Ichikowitz. Most of the transactions involved his company, Paramount Group, with more than \$181 million that was transacted from August 2011 to November 2017. That amount included more than \$25 million in 2017, of which \$24,370,490.91 was in the May-to-November period after the report was received. It also included more than \$2.8 million Paramount Logistics sent to Socintra, a firm owned by Ichikowitz and his brother, in 2017. Socintra used a Barclays Bank Plc account to receive these funds. All the transactions were reported by Barclays New York in SARs 31000116798393, 31000098991452, and 31000111126348. All told, Barclays was involved in transactions totaling a half a billion dollars for Ichikowitz and companies over the past decade. Please explain the reason Barclays continued to move money for Ichikowitz and his empire in light of the concerns articulated in a report commissioned by the bank and even as the bank's compliance officers declared in + +a SAR dated December 5th, 2017 that it is "concerned with lchikowitz and his companies' source of wealth and lchikowitz's possible involvement in bribery and corruption"? Please note that this was one of several SARs articulating similar concerns by Barclays New York. Why were the concerns overridden and money moved for Ichikowitz and his companies? To what extent does the power in banks held by bankers in the so-called front office result in transactions like this flowing through the back-office compliance department which is staffed by officers who are not as well remunerated? + +- 5. Barclays in its own review of Ichikowitz and his company, Paramount's business, said in SAR 31000116798393 that it found 29 payments totaling \$585,245 from Paramount to a public relations firm named Bell Pottinger between January 2012 and December 2013. In light of reports in Britain's Daily Telegraph at that time that lchikowitz's family foundation had paid Bell Pottinger to help Malawian leader Joyce Banda burnish her image, did Barclays ask lchikowitz and/or Paramount about the purpose of these payments? Did Barclays in the course of its investigation learn of any payments from lchikowitz or his companies to Banda in the run-up to the awarding of the patrol boat contract as this was singled out as an area of particular concern in the Orbis report? +- 6. Barclays Corporate moved to cut its relationship with Kemet Global Ltd. after Barclays Corporate determined that Ichikowitz had masked his link to Kemet and that it was "related to his businesses." Barclays Corporate said the relationship with Kemet was "outside of risk appetite." Why would one arm of Barclays cut its relationship with a company that has links to lchikowitz because it is outside its risk appetite while another part of Barclays continues to do business with Ichikowitz? Do the risk standards vary between Barclays Corporate and Barclays Wealth and, if they do, in what way? Why is that the case? Please respond to the on-the-record observation by a former Justice Department official that if "a client is too risky for one part of the bank, it should be risky for all parts of the bank." +- 7. Did Barclays eventually exit its relationship with Ichikowitz? If so, when? Please explain. + +- 8. A 2009 Organisation for Economic Cooperation and Development report said Barclays had 14 revolving door connections in the U.K. mostly with government, legislators and civil servants, making it the second most connected company after Deutsche Bank. What is your comment? +- 9. Does Barclays Wealth try to lure private clients with the offerings in its "Little Book of Wonders" which have included a getaway to ultra-luxury villas in the Maldives and even the possibility of a space holiday with Virgin Galactic? +- 10. In an SEC case last year, Barclays was cited for giving a spot in its coveted work experience program to the nephew of a key private client in Asia who didn't get a spot in the merit-based intern program. How often is a "soft" perk like this given to private clients of the bank? Please also comment on the claim in the SEC action. +- 11. Former UBS AG private banker Bradley Birkenfeld, who pled in court papers that he worked at Barclays between 1998 and 2001, recalled travelling to London's wealth spots—Knightsbridge, Pall Mall and Sloane Square—two or three times a month for Barclays. He said: "We were going to London to get the biggest fish and get them to Switzerland." The pitch, he said, "was if you put your money in Switzerland, we can put you in the same investments but you won't pay any tax." How do you respond to Birkenfeld's remarks? + +## BARCLAYS' FACILITATION OF MONEY TRANSFERS FOR RINAT AKHMETOV'S COMPANIES + +- 12. In SAR, 31000055568734, dated October 22, 2014, it says that between December 28th, 2011 and March 6th 2014, Barclays was involved in 38 money transfers totalling \$1.4 billion for Rinat Akhmetov's System Capital Management Ltd. via an account maintained at Barclays Switzerland. In the SAR, Barclays cited a Ukranian Internal Affairs Ministry dossier that identified Akhmetov as a leader of an organized crime group. The dossier tied Akhmetov to money laundering and financial fraud, among other illicit activities. Barclays also references in the same SAR, a 2006 U.S. + +diplomatic cable which describes the Party of Regions, a political party Akhmetov once headed and financed, as "a haven for mobsters and oligarchs." Please explain Barclays's decision to move money for one of Akhmetov's companies in light of the Ukranian report linking him to money laundering and financial fraud and his alleged ties to organized crime. + +- 13. The October 2014 SAR said due to the concerns about Akhmetov and System Capital, Barclays Switzerland had placed a "block" on the accounts of System Capital Management and a related company, System Family Management Ltd., which also had an account at Barclays Switzerland. The bank said it was in the midst of terminating its relationship with both entities. However, our reporting and review of records shows that in June and July 2015, the Barclays Switzerland account of System Family Management sent and received nearly \$9 million in wire transfers. Please comment on how those transfers were processed in light of remarks made in a February 2015 SAR by Barclays New York which said the bank "maintains concerns" that the funds transferred by Akhmetov's companies "could possibly contain illicit proceeds." To what extent did different approaches between Barclays Switzerland and Barclays New York lead to the money movements occurring? +- 14. As of July 27th 2015, Akhmetov and some of his companies, System Capital, System Family Management, and Metinvest International SA, were put under what Barclays called its "Payment Rejection Filter." Why did it take nine months after Barclays New York identified concerns about Akhmetov and his companies for the Payment Rejection Filter to be placed? Also, in some records reviewed by ICIJ, Barclays said that Akhmetov and some of his companies, System Capital, System Family Management and Metinvest International SA, were put under "USD Payment Rejection Filters." Were Akhmetov and some of his companies disallowed from moving money only in dollars or moving money in any currency? Please clarify in light of the varying descriptions in your records. +- 15. In SAR 31000078935501, Barclays Switzerland confirmed the System Capital Management account was closed in May 2015. If the account was closed, why was + +it put on the payment rejection filter two months later? Surely if the account is closed it can't send or receive payments? And in SAR 31000078935501, dated January 11th, 2016, Barclays says that the "primary suspects were banking away from Barclays with the exception of SCM (System Capital Management), SCM Consulting, and SCM Holdings who were identified to maintain accounts at Barclays Switzerland. If the account for System Capital Management was closed in May 2015, why did Barclays in a January 11th 2016 SAR say the company, SCM Consulting and SCM Holdings were all banking at Barclays Switzerland. Please explain and confirm if the System Capital Management account was closed in May 2015. + +- 16. Despite the actions Barclays took, it appears that an Akhmetov company account at another bank was able to receive money from a Barclays client account. Between September 28th 2015 and November 12th 2015, SCM Consulting engaged in four USD wire transfers totaling a little over \$22 million, according to SAR 31000078935501. About \$17.8 million was sent from a Barclays account in the name of K1 Associates Ltd. In SAR 31000096263772 Barclays said it added SCM Consulting in February 2016 to its USD payment rejection filter. This SAR also reflected the involvement of the Federal Bureau of Investigation. Please comment on Barclays role in moving funds from K1 to SCM Consulting given its concerns about Akhmetov and please explain the interest of the FBI in Akhmetov's money transfers and his companies. +- 17. In SAR 31000078935501, Barclays said Akhmetov and his companies moved nearly \$2 billion through Barclays. Please comment on the grounds on which Barclays facilitated money transfers for a man the bank had knowledge of allegedly being involved in money laundering and financial fraud and was described as a leader of an organized crime group in an official Ukranian document that the bank was aware of? + +# BARCLAYS ROLE IN TRANSACTIONS BY AYRTON DEVELOPMENT LTD. + +The International Consortium of Investigative Journalists 1710 Rhode Island Ave NW 1 11th floor I Washington DC 20006 I USA +1 (202) 320- 3006 I www.icij.org I fshiel@icij.org + +- 18. In 2016, in SAR 31000096424906, Barclays New York asked about three wire transfers that were received by a Barclays UK Wealth account. The wires were received by an account variously named in the payment details as Mark Omelnitski or Ayrton Development Ltd., Barclays said in the November 29, 2016, suspicious activity report. Barclays New York flagged the transfers because it believed Ayrton was owned by Arkady Rotenberg. But Barclays UK Wealth said that Ayrton's real owner was Andrey Dubrovskiy. The owner of Ayrton that Barclays UK Wealth cited was not "conclusively identified," compliance officers in New York wrote in the SAR. Given that banks are supposed to know their customer, how is it there was a difference of opinion between Barclays New York and Barclays UK Wealth about the identity of a client after money was moved? How did it come to pass that Barclays' client in this case was not "conclusively identified" during onboarding? +- 19. Was Ayrton ultimately owned by Arkady Rotenberg as Barclays New York believed? +- 20. Barclays New York in SAR 31000096424906 cited other reasons the money transfers were problematic. The nearly \$114,000 that was transferred represented a loan to the owner of Ayrton and was intended for the purchase of equipment. No purchase was made and the money sat in Ayrton's account, Barclays UK Wealth informed New York. Since the borrower and lender were friends, the loan was allegedly interest free. Interest free loans are often a red flag for money laundering. Please explain the reason Barclays UK Wealth may have facilitated the transfer despite this obvious red flag which even the New York SAR writer spotted and remarked on: "This explanation appears to be indicative of a classic money laundering scheme wherein a loan is used to launder illicit proceeds." +- 21. Barclays continued to move money for Ayrton even after the November 2016 SAR was filed. Between February 7th 2014 and March 9th 2017, Barclays facilitated \$19,085,165.94 in money transfers across 219 transactions for Ayrton. Please comment on the reason Barclays continued to process wire transfers for Ayrton despite its inability to identify its client? + +- 22. A recent report by the Senate's Permanent Subcommittee on Investigations said that after the release of the Panama Papers in April 2016 Barclays launched an investigation into links among the Rotenbergs, Mark Omelnitski, whose firm Markom Group, set up a number of Rotenberg-owned shell companies. A year and four months later, in August 2017, Barclays, following its own probe, worked to close all 198 accounts under the Markom relationship of which 59 were U.S. dollar accounts. Why did it take so long to close the accounts and, as one former Justice Department official, why were the necessary questions about client identity not asked before money transfers were processed? + +## REGULATORY ISSUES AT BARCLAYS WEALTH AMERICAS + +- 23. In 2011, the Securities and Exchange Commission found "serious deficiencies" at Barclays Wealth Americas at an onsite examination. And, in 2012, an independent report commissioned from a firm named Genesis Ventures, said current leadership "pursued a course of revenue at all costs." The report also criticized the division for placing "compliance as the lowest possible priority by actively blocking compliance and building a social reward structure that ignores everything not sales related." Do you think the criticisms cited in the independent report contributed to Barclays UK Wealth facilitating money transfers for clients with red flags despite articulated concerns by compliance in New York? +- 24. Would the shortcomings identified by Genesis Ventures also explain the reason then-CEO Antony Jenkins was not fully briefed on the report? An email sent to then CEO Antony Jenkins, in response to allegations by a whistleblower that a report into the culture at Barclays Wealth had been suppressed, made no mention of the critical report. Also, Barclays Wealth initially delayed sending the report to the Federal Reserve Bank of New York. Please comment on both those incidents and what they reflect about the culture at Barclays Wealth. +- 25. More broadly, a Barclays investor, Denis O'Connor, who owns a little less than 1,000 shares of the bank's stock and who is involved in compliance, told ICIJ on the + +record that he recalled discussing a legal case involving Barclays with a peer from the bank a couple of years ago. The shareholder said he did not think the facts were consistent with Barclays stated culture. A compliance employee of Barclays allegedly responded: "Well, if you are stupid enough to believe what the bank says about culture, you are going to be very disappointed." Please respond to the alleged statement about Barclays' culture by the bank's compliance employee. + +## BARCLAYS CHIEF EXECUTIVE JAMES STALEY'S COMPLIANCE IMPROPRIETIES + +- 26. Barclays new chief executive James "Jes" Staley was rebuked and personally fined for trying to unmask the authors of two anonymous letters received by Barclays that questioned the fitness of a prospective hire. More recently, Barclays said that UK authorities are investigating Staley's ties to sex offender, the late Jeffrey Epstein. Please comment on these two incidents involving the chief executive of Barclays and if the bank thinks his actions have an impact on the robustness of the bank's compliance culture. + +## BARCLAYS AND THE FACILITATION OF TRANSACTIONS FOR THE ROTENBERGS + +- 27. Is it true that Barclays reported to FinCEN at the end of November 2016 that from March 2012 to March 2016 it had done transactions worth \$728,288.65 to offshore companies Stormont Systems Ltd., Highland Ventures Group Ltd. and Highland Business Group Ltd.? +- 28. The Panama Papers revealed in April 2016 that Boris and Igor Rotenberg were behind these companies. Why did it take almost six months after the revelations for you to report it? Is Barclays aware that transactions to a sanctioned person or entities have to be reported immediately? +- 29. The Panama Papers revealed that Arkady, Boris and Igor Rotenberg were behind at least nine offshore companies. Is it a fact that in your report you attributed 26 additional shell companies to the Rotenbergs? The Panama Papers don't say these + +26 entities belonged to the Rotenbergs. It only said in the Panama Papers that the companies were represented by Dmitry Protsenko. How do you know these 26 companies belonged to the Rotenbergs? + +- 30. Between 2012 and 2016, Barclays New York facilitated more than \$61 million in 135 transactions for companies owned by Russian billionaire brothers Arkady and Boris Rotenberg, as well as Arkady's son, Igor. The Rotenbergs were sanctioned by the U.S.'s OFAC in March 2014 after Russia invaded Crimea in Ukraine. Barclays reported the transactions in SARs 31000096424901 and 31000096424899. What is your reaction to Barclays facilitating those transactions? +- 31. Between March 6th 2012 and May 27th 2016, Advantage Alliance Ltd., a client of Barclays Corporate and a company which a Senate investigation strongly suggested was controlled by the Rotenbergs, was involved in 129 wire transfers totaling \$60,972.491.89. How much of that money was moved after sanctions were imposed? + +# BARCLAYS AND ITS INVOLVEMENT WITH KALOTI + +- 32. On October 4, 2013, Barclays New York Branch filed a Suspicious Activity Report (BSA # 31000034527046) on Kaloti Jewellery International. The SAR mentioned that Kaloti had a corporate account with Barclays Dubai and a commodities trading account with Barclays Capital Inc. UK. What due diligence did Barclays conduct on Kaloti in order to accept and retain this company as a client? +- 33. The above mentioned SAR stated that Barclays Capital Inc. UK was going to close Kaloti's account and that Barclays UAE was waiting for approval from the UAE Central Bank to close Kaloti's account in the UAE. Did Barclays close both of these accounts? If so, when? If not, why not? +- 34. Has Barclays subsequently opened any accounts for Kaloti? If so, when? Does Kaloti currently have any open accounts or a commodities trading relationship with Barclays? + +- 35. In 2013, Barclays New York facilitated a \$4.9 million transaction for Munir Kaloti. Barclays reported the transaction in SAR 31000034527046. What is your reaction to Barclays facilitating this transaction? +- 36. The above-mentioned SAR also stated that Kaloti founder and chairman Munir Al Kaloti had an account with Barclays Bank Suisse that was under review. What was the outcome of this review? Was Mr. Al Kaloti's account closed? If so, when and why? + +#### BARCLAYS AND SUSPICIOUS TRANSACTIONS BY MUKHTAR ABLYAZOV + +- 37. An ICIJ analysis showed that Barclays New York anti-money-laundering officers raised suspicions about \$22,266.45 in 16 transactions sent between 2013 and 2016 on behalf of Kazakh Mukhtar Ablyazov to registration agents like Mossack Fonseca and Commonwealth Trust Limited. Ablyazov is the former chairman of Kazakh bank BTA, which has accused him of embezzling millions of dollars. In 2012, a British judge sentenced Ablyazov in absentia to 22 months in prison for failing to reveal his assets. Ablyazov has allegedly hidden embezzled funds using shell companies and offshore bank accounts. Barclays New York reported the transactions in SARs 31000058666857, 31000069278166, 31000098301745, 31000083623410, 31000085225922, and 31000078183970. What is your reaction to Barclays New York facilitating those transactions? + +## BARCLAYS FACILITATING SUSPICIOUS TRANSACTIONS FOR DMYTRO FIRTASH + +- 38. Between 2008 and 2013, Barclays New York facilitated more than \$15.6 million in 12 transactions for companies controlled by Ukrainian businessman Dmytro Firtash, who was indicted in 2013 on U.S. charges that he had bribed Indian officials to gain access to mining licenses. Barclays reported the 12 transactions, which did not include those tied to the corruption case, in SAR 31000037709600. The indictment was unsealed in April 2014. For years before this, Firtash was publicly alleged to + +have ties to organized crime. What is your reaction to Barclays facilitating those transactions? + +## BARCLAYS CLIENT JANMOHAMED RAHEMTULLA + +- 39. Between 2013 and 2016, a Tanzanian resident named Janmohamed Mohamedali Rahemtulla received over \$175 million on his accounts at Barclays Bank in Switzerland. What was the purpose of these transfers, and whom was this money ultimately flowing to? +- 40. Within the bank, Janmohamed Mohamedali Rahemtulla,residing at 124 Uganda Avenue, Dar es Salaam, was identified as a Senior Custodian of imamat assets. What does this title mean? +- 41. Why were the transfers on Mr. Rahemtulla's accounts suddenly interrupted in 2016? +- 42. The large sums from high-risk jurisdictions remitted by Mr. Rahemtulla seem to have raised compliance questions within Barclays about potential terrorism financing. Were the funds received by Mr Rahemtulla somehow suspect? Did the transfers to his accounts continue, maybe in other countries, or on other accounts? + +## BARCLAYS AND FBME + +FBME, formerly Federal Bank of the Middle East, Ltd. , based in Cyprus, was proposed by FinCEN fora Section 311 special measure on July 15, 2014. + +Barclays was involved in a series of wire transfers involving FBME after that date. + +From the documents, we see correspondent banking transactions totalling \$25.9 million for one FBME customer in a series of wire transactions more than a year later, in August and September 2015. (SAR Number 31000079188754, 31000073087182). + +Barclays Cyprus and Barclays Knightsbridge maintained open accounts for Nelbon Trading Limited ("Nelbon")and Antoria Investments Limited ("Antoria"). The Section 311 designation was made public on July 17, 2014. The SARs showed money flowed in and out of Nelbon's Barclays account from and to FBME through July 2014--two weeks after the Section 311 proposal. And it shows money flowed in and out of Antoria's Barclays accounts to and from FBME November 2014--four months after the Section 311 proposal. + +Also, Barclays filed a continuing activity report of those SARs, noting that FBME customer Sopase Management Ltd. of the UK moved \$25.9 million in August and September 2015 through the bank and the transfers involved intentional, repetitive splintering. + +- 43. Can you comment on these transactions? Can you comment on the amounts after the Section 311 proposal? Can you comment on why Barclays was involved in these transactions after the Section 311 proposal? + +# BARCLAYS AND POSSIBLE VIOLATION OF US SANCTIONS TO SUDAN + +We intend to report that in 2013, Barclays may have helped to violate US sanctions in Sudan, enabling the purchase of military-capable helicopters by a Sudanese-affiliated firm. Barclays Cyprus banked a company called Genetechma, which was owned by the Russian state bank VEB. A SAR filed in August 2014 shows that Genetechma used its Cyprus account to conduct US dollar wire transactions, which were cleared through Barclays US. The SAR shows that Genetechma purchased four helicopters from Russian entity, JSC Russian Helicopter, for \$34.6 million. The helicopters were known to be MI-171E models, a transport unit with armed assault capabilities. Barclays US was aware that the helicopters were supposed to be leased to a company called Aero Kamov, but after signing the lease, the company said it could not meet the terms. The company arranged for Al Amyal Aviation Services FZE to purchase the helicopters in September 2013. The bank's own research found that Al Amyal, the purchaser, was identified to be the 'general agent' for an entity in the name of SAFAT Aircraft Plant, located in Sudan. + +We also intend to report that Barclays US suspected Genetechma to be engaged in money laundering after the helicopter purchases. After the deal was done, Genetechma sent a payment of \$10.2 million to Improm Cyprus, a company owned by Aero Kamov, telling Barclays that the payment was part of the helicopter leasing contract. Soon after, Improm Cyprus paid the exact same amount, \$10.2 million to Vantana Investment, claiming that it was a payment for "scrap metal." The compliance officers at Barclays wrote that "the payment appeared unusual" and were concerned that it was linked to North Sudan. + +44. Did Barclays conduct appropriate KYC on Al Amyal Aviation Services? + +45. Why did Barclays clear these payments when they knew that Al Amyal had these associations? Did Barclays violate US sanctions against the Sudanese government as a result of these transactions? + +### BARCLAYS AND AN OLYMPICS BRIBERY SCHEME + +This question concerns Olympic-related bribery, including alleged bribes involving Lamine Diack, the then-head of the international track and field federation, now the subject of prosecution stemming from the Russian doping scandal and the selection of Tokyo for the Olympics: + +Barclays Bank reported \$4.2 million going through Barclays accounts in Monaco and Botswana, and through correspondent banking accounts with Barclays Bank in New York, according to a look-back SARs filed with FinCEN. These funds have been identified as part of the bribery of Olympics officials. + +46. Why was Barclays unable to detect at the time that this money stemmed from a bribery scheme? + +47. Has Barclays continued banking through those accounts in Monaco and Botswana, and correspondent banking for those accounts through its branch in New York? + +#### ASHISH CHORDIA + +We reviewed a SAR that showed two branches of Barclays New York and London flagged seven transfers totaling \$1.34 million in 2014 involving Vertu Investment Ltd (UK) and Shreyans Lifestyle Private Limited (India), Uber LLC (USA) and Streamline Global Holdings Limited (Hong Kong) for "heightened money laundering risk." + +The SAR noted that Indian businessman Ashish Chordia, owner of Vertu, Shreyans and Uber, failed to provide any documentation for these transactions which did not appear to have any economic, business or lawful purpose. It also noted that Barclays Knightsbridge-London was in the process of exiting its relationship with Vertu Investment Ltd (UK), and Barclays NY continued to monitor any USD payments involving the companies identified in the SAR. + +According to the Registrar of Companies records, Barclays Mumbai granted a secured (mortgage) loan of Rs 14.25 crore (then \$3.2 million) to Shreyans Lifestyle in October 2008 and enhanced the facility to Rs 37.67 crore (then \$8.3 million) in October 2009. + +- 48. Did Ashish Chordia subsequently provide any documentation/justification for these transactions? +- 49. Did Shreyans Lifestyle satisfy the charge/mortgage to Barclays Mumbai? +- 50. Does Shreyans Lifestyle continue to be a client of Barclays Mumbai? +- 51. When did Barclays Knightsbridge-London file a SAR on these transactions to the UK regulator? +- 52. When did Barclays Knightsbridge-London exit its relationship with Vertu Investment Ltd (UK)? + +The International Consortium of Investigative Journalists 1710 Rhode Island Ave NW 1 11th floor I Washington DC 20006 I USA +1 (202) 320- 3006 I www.icij.org I fshiel@icij.org + +53. Did Barclays NY find any suspicious activity in its subsequent monitoring of the SAR suspects? + +ICIJ and its media partners intend to publish the results of this investigation in the United States, United Kingdom and other countries. + +If we do not hear from you by 6 P.M. GMT on August 27th (preferably by email to this address), we shall proceed on the basis that you do not wish to comment on or otherwise respond to our information. + +We would be happy to discuss any questions you may have. Please feel free to email any questions or to reach out to me at +1 202 320 3006 phone number at any point. + +We would be grateful if you would acknowledge receipt of this message. + +Yours faithfully, + +Fergus Shiel + +E: fshiel@icij.org + +M: +1 (202) 320- 3006 \ No newline at end of file diff --git a/marker2/ds9/EFTA00087338/EFTA00087338.metadata.json b/marker2/ds9/EFTA00087338/EFTA00087338.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..446c3dcb4de8ef898b60dbdb783c23daac492fd7 --- /dev/null +++ b/marker2/ds9/EFTA00087338/EFTA00087338.metadata.json @@ -0,0 +1,998 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087338.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 16, + "chars": 30664, + 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District of New York, and how it is being characterized by Geoffrey Berman. + +I was wondering whether you would be prepared to comment on the following excerpts from Mr Green's story. He attempted to contact the press office earlier today but was not able to get through to anyone: + +'Berman has actively misled the global media and the global audience, 'my source alleges. 'The Duke's legal team has dozens of email exchanges with the Southern District, proving that there has been full cooperation.' + +On January 27, Berman denounced the Duke from the steps ofEpstein's Manhattan townhouse. Berman claimed to be facing a 'wall of silence' and 'zero co-operation 'from Andrew. But this, my source tells me, wasn't true: 'Berman must have known we had an email trail.' + +\*\*\* + +...the DOJ made no effort to contact Prince Andrew durin Je re E stein's lifitime. Only after Epstein's death in August 2019 and the BBC's broadcast o accusations in November 2019, did the DOJ approach the Prince — not as a suspect, but as a witness. + +'The lawyers responded immediately,' I'm told. In early January, the Prince's new legal team suggested that they draft a proposal for how Andrew would deliver his witness statement. The DOJ, my source reports, accepted this approach. + +Although the DOJ wanted to talk with Andrew as a witness, Berman seemed to imply that Andrew had aided Epstein's crimes: Epstein couldn't have done what he did without the assistance of others.' This, I'm told, was an 'overt breach of the DOJ:s own rules on how to engage with witnesses, and the need to maintain privacy and confidentiality'. + +After Berman's attack in January, there was a every frank exchange of views' between Andrew's lawyers and the Southern District. But Andrew's team played by the rules and didn t release entails that would prove they were negotiating with the Southern District in good faith. + +We plan to publish the story at 3pm ET, but can update the story to include any response. If this request for comment should be directed towards your press office, I'd appreciate it if you could pass it onto them - there is + +Yours sincerely, + +Matt McDonald + +Matt McDonald + +Managing Editor The Spectator US + +![](_page_1_Picture_8.jpeg) + +![](_page_1_Picture_9.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00087354/EFTA00087354.metadata.json b/marker2/ds9/EFTA00087354/EFTA00087354.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..b39ab33b75cc7d94c3da6d5a48269d7ddab0c7cf --- /dev/null +++ b/marker2/ds9/EFTA00087354/EFTA00087354.metadata.json @@ -0,0 +1,91 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087354.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2433, + "elapsed_seconds": 0.79, + "image_assets": [ + "_page_1_Picture_8.jpeg", + "_page_1_Picture_9.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 63 + ], + [ + "Line", + 31 + ], + [ + "Text", + 15 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 14 + ], + [ + "Text", + 8 + ], + [ + "Line", + 7 + ], + [ + "Picture", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087354" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087354/_page_1_Picture_8.jpeg b/marker2/ds9/EFTA00087354/_page_1_Picture_8.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..7ed99ed6537f588d46ec6386c2875cd04a52c226 --- /dev/null +++ b/marker2/ds9/EFTA00087354/_page_1_Picture_8.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:b4ef5f9a2ffc401bd8d7d6251cc16f496e71841ab5bf5299d523187aeddf2f87 +size 1057 diff --git a/marker2/ds9/EFTA00087354/_page_1_Picture_9.jpeg b/marker2/ds9/EFTA00087354/_page_1_Picture_9.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..be5d919e0a2daee6d61bdbc5e162945a382db022 --- /dev/null +++ b/marker2/ds9/EFTA00087354/_page_1_Picture_9.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:c37c1aa68cfc8b27d71c63cd661f3042c3aa53adf6094909e1fa39f18b430204 +size 2720 diff --git a/marker2/ds9/EFTA00087356/EFTA00087356.md b/marker2/ds9/EFTA00087356/EFTA00087356.md new file mode 100644 index 0000000000000000000000000000000000000000..5d6fc341b94da5594af320187bbe03b7aa67c579 --- /dev/null +++ b/marker2/ds9/EFTA00087356/EFTA00087356.md @@ -0,0 +1,37 @@ +![](_page_0_Picture_73.jpeg) + +**Subject:** FW: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +**Date:** Thu, 03 Sep 2020 22:22:46 +0000 + +**Attachments:** 2020.09.03\_Notice\_of\_Appeal-Denial\_of\_Motion\_to\_Modify\_PO.pdf + +**Inline-Images:** image001.jpg + +Maxwell is appealing Judge Nathan's denial of her most recent motion. + +**From:** Nicole Simmons + +**Sent:** Thursday, September 3, 2020 5:57 PM + +![](_page_0_Picture_81.jpeg) + +**Cc:** Laura Menninger [REDACTED], Jeff Pagliuca [REDACTED], Ann Lundberg + +![](_page_0_Picture_83.jpeg) + +**Subject:** United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +Dear Counsel: + +At the request of Laura A. Menninger, please see attached Ms. Maxwell's Notice of Appeal that has been sent via Overnight Delivery to the SDNY-Clerk for filing. + +Thank you, + +Nicole + +Nicole Simmons +Haddon, Morgan and +Foreman, P.C. + +![](_page_0_Picture_90.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00087356/EFTA00087356.metadata.json b/marker2/ds9/EFTA00087356/EFTA00087356.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..9949b707184e9c8c84cf6c02fd16ead65970c429 --- /dev/null +++ b/marker2/ds9/EFTA00087356/EFTA00087356.metadata.json @@ -0,0 +1,63 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087356.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 890, + "elapsed_seconds": 4.26, + "image_assets": [ + "_page_0_Picture_73.jpeg", + "_page_0_Picture_81.jpeg", + "_page_0_Picture_83.jpeg", + "_page_0_Picture_90.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 35 + ], + [ + "Text", + 32 + ], + [ + "Line", + 18 + ], + [ + "Picture", + 5 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087356" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087356/_page_0_Picture_73.jpeg b/marker2/ds9/EFTA00087356/_page_0_Picture_73.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..48cb2b679c9cda49969d9f6dfa740cc7ad340cdd --- /dev/null +++ b/marker2/ds9/EFTA00087356/_page_0_Picture_73.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:4fd75b63072c69740eeda1a630545e0808e0e32dc1cd341f523e3bdc9db66ee4 +size 9382 diff --git a/marker2/ds9/EFTA00087356/_page_0_Picture_81.jpeg b/marker2/ds9/EFTA00087356/_page_0_Picture_81.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..be407cc5195f9e7c8a7c17e19061b2851a704b35 --- /dev/null +++ b/marker2/ds9/EFTA00087356/_page_0_Picture_81.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:9bce87b1fc2a211ac3160e15921ce7f2e1cc00991a53f44009e6bdc5f95033b0 +size 4846 diff --git a/marker2/ds9/EFTA00087356/_page_0_Picture_83.jpeg b/marker2/ds9/EFTA00087356/_page_0_Picture_83.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..9dec6307d7c9b084271397b5a139067a7cb62b2e --- /dev/null +++ b/marker2/ds9/EFTA00087356/_page_0_Picture_83.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:5c4d551a79938d766e09d108802d921c21ed31df32d12d2c2ad76ccd13b50abe +size 3111 diff --git a/marker2/ds9/EFTA00087356/_page_0_Picture_90.jpeg b/marker2/ds9/EFTA00087356/_page_0_Picture_90.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..3590a1c9b5090366c4f2ab0f3653cdecd1b525c8 --- /dev/null +++ b/marker2/ds9/EFTA00087356/_page_0_Picture_90.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:616ad0800421eeb99d9c361ce2b8392844d13531af0a660dfb372110d5520a67 +size 6531 diff --git a/marker2/ds9/EFTA00087357/EFTA00087357.md b/marker2/ds9/EFTA00087357/EFTA00087357.md new file mode 100644 index 0000000000000000000000000000000000000000..f382a701b8aaa4f5c13eaefe62eaa250e72a8ea5 --- /dev/null +++ b/marker2/ds9/EFTA00087357/EFTA00087357.md @@ -0,0 +1,31 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +X UNITED STATES OF AMERICA, Plaintiff, v. GHISLAINE MAXWELL, Defendant. X + +20-CR-330 (AJN) + +## NOTICE OF APPEAL + +PLEASE TAKE NOTICE that Ghislaine Maxwell, Defendant in the above-captioned case, hereby appeals to the United States Court of Appeals for the Second Circuit from the district court's September 2, 2020, Memorandum Opinion and Order denying her motion to modify the protective order. Pichler v. UNITE, 585 F.3d 741, 746 n.6 (3d Cir. 2009) ("We have jurisdiction under the collateral order doctrine to review the denial of the motion to modify the Protective Order and the denial of the motion to reconsider."); Minpeco S.A. v. Conticommodity Servs., Inc., 832 F.2d 739, 742 (2d Cir. 1987) (denial of motion to modify protective order is immediately appealable under the collateral order doctrine) (citing Cohen v. Beneficial Industrial Loan Corp., 337 U.S. 541, 545-47 (1949)); see also Brown v. Maxwell, 929 F.3d 41,44 (2d Cir. 2019) (appeal by intervenors challenging denial of motions to modify protective order and unseal). + +Dated: September 3, 2020. + +Respectfully submitted, + +s/ Laura A. Menninger + +Laura A. Menninger (LM-I374) + +Jeffrey S. Pagliuca (pro hac vice) + +HADDON, MORGAN AND FOREMAN, P.C. + +![](_page_1_Picture_5.jpeg) + +Attorneys for Ghislaine Maxwell + +## CERTIFICATE OF SERVICE + +I certify that on September 3, 2020, I filed this Notice of Appeal with the Clerk of Court by mail pursuant to Section 17 of the CM/ ECF Rules and served all parties of record by email. + +/s/ Nicole Simmons \ No newline at end of file diff --git a/marker2/ds9/EFTA00087357/EFTA00087357.metadata.json b/marker2/ds9/EFTA00087357/EFTA00087357.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..f2737e58d148d342f912e572aa292e29dd875d1e --- /dev/null +++ b/marker2/ds9/EFTA00087357/EFTA00087357.metadata.json @@ -0,0 +1,198 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087357.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 1573, + "elapsed_seconds": 0.53, + "image_assets": [ + "_page_1_Picture_5.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 184.82399999999998, + 72.08999999999999 + ], + [ + 428.1668701171875, + 72.08999999999999 + ], + [ + 428.1668701171875, + 101.853515625 + ], + [ + 184.82399999999998, + 101.853515625 + ] + ] + }, + { + "title": "NOTICE OF APPEAL", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 239.904, + 319.95000000000005 + ], + [ + 373.4131774902344, + 319.95000000000005 + ], + [ + 373.4131774902344, + 334.35357666015625 + ], + [ + 239.904, + 334.35357666015625 + ] + ] + }, + { + "title": "CERTIFICATE OF SERVICE", + "heading_level": null, + "page_id": 2, + "polygon": [ + [ + 216.036, + 71.28 + ], + [ + 395.9810485839844, + 71.28 + ], + [ + 395.9810485839844, + 86.9830322265625 + ], + [ + 216.036, + 86.9830322265625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 49 + ], + [ + "Line", + 25 + ], + [ + "Text", + 4 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 15 + ], + [ + "Line", + 8 + ], + [ + "Text", + 6 + ], + [ + "PageFooter", + 2 + ], + [ + "Picture", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 11 + ], + [ + "Line", + 6 + ], + [ + "Text", + 2 + ], + [ + "PageFooter", + 2 + ], + [ + "SectionHeader", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087357" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087357/_page_1_Picture_5.jpeg b/marker2/ds9/EFTA00087357/_page_1_Picture_5.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..cd9b4492a412e40737d72f84e985fa2f84723c75 --- /dev/null +++ b/marker2/ds9/EFTA00087357/_page_1_Picture_5.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:3b9c6b366418eb4c290819c13b2a5d74e2b413a6acb71d798c0091b4d8b51123 +size 3466 diff --git a/marker2/ds9/EFTA00087360/EFTA00087360.md b/marker2/ds9/EFTA00087360/EFTA00087360.md new file mode 100644 index 0000000000000000000000000000000000000000..a456392368678dee8770dbe19f01f663438b67e9 --- /dev/null +++ b/marker2/ds9/EFTA00087360/EFTA00087360.md @@ -0,0 +1,27 @@ +From: "M., (USANYS)" To: "IMEMIr )" .<1 (USANYS)" Cc: " ( USANYS SANYS)" (USANYS)" + +Subject: RE: Jeffrey Epstein-Related Touhy Requests + +Date: Thu, 10 Sep 2020 18:16:30 +0000 + +Thanks, I will call Brad and tell him to submit a written request, without pseudonyms. Thanks, all. + +From: Sent: Thursday, September 10, 2020 2:13 PM To: (USANYS) < Cc: (USANYS) ; (USANYS) (USANYS) Subject: RE: Jeffrey Epstein-Related Touhy Requests ; ,-(USANYS) + +Thanks all. We do not have any specifics for the request to address. And we do not believe that it is possible for us to accept this request under pseudonyms. + +Thanks, + +From: (USANYS) < Sent: Wednesday, September 9, 2020 7:00 PM To: SMEI (USANYS) < Cc: >; Subject: RE: Jeffrey Epstein-Related Touhy Requests >; (USANYS) (USANYS) >; (USANYS) + +Thanks, =. Sounds good. Once I hear from the Maxwell team re: any specifics for the request to address, I'll give Brad a call and tell him to submit a written request. + +Thanks, + +From: S (USANYS) Sent: Wednesday, September 9, 2020 3:56 PM To: (USANYS) Cc: > >; >; (USANYS) (USANYS) < >; (USANYS) Subject: RE: Jeffrey Epstein-Related Touhy Requests + +This string is a mile long so I'm going to tnmcate it. + +I think at this point we need to ask Brad Evans to make a formal Touhy request, with specifics of what he wants, in connection with what proceeding, and naming names, so that we can know exactly what he wants and evaluate + +Criminals, anything in particular you would like Evans' Touhy request to address? You will have to consider (i) whether disclosing anything under the Touhy request would have an impact on your case; (ii) whether it would have any impact on any of your witnesses (e.g., sharing info with a wit as affecting the wit's credibility; sharing info with the wit for the wit's civil case as a disclosable benefit); and (iii) keep in mind that responding to the request is likely to involve a great deal of your time. \ No newline at end of file diff --git a/marker2/ds9/EFTA00087360/EFTA00087360.metadata.json b/marker2/ds9/EFTA00087360/EFTA00087360.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..5ff1aa0d7bb110ef81ad7a4f62d8bc826b3514bc --- /dev/null +++ b/marker2/ds9/EFTA00087360/EFTA00087360.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087360.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 1921, + "elapsed_seconds": 0.7, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 92 + ], + [ + "Line", + 45 + ], + [ + "Text", + 13 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 13 + ], + [ + "Line", + 7 + ], + [ + "Text", + 3 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087360" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087362/EFTA00087362.md b/marker2/ds9/EFTA00087362/EFTA00087362.md new file mode 100644 index 0000000000000000000000000000000000000000..f19282e246e614495e7cc2c79049c4eb0f0d2a41 --- /dev/null +++ b/marker2/ds9/EFTA00087362/EFTA00087362.md @@ -0,0 +1,29 @@ +From: "O > To:' Subject: RE: Out of money Date: Thu, 10 Sep 2020 19:50:24 +0000 + +Diceespond to your email on this earlier? + +Ori inal Messa e + +From: Sent: Thursda , Se tember 10, 2020 3:50 PM To: ; Subject: RE: Out of money + +It's about 10k. + +Ori inal Messa e + +From: Sent: Thursday,September 10, 2020 3:39 PM To: Cc: Subject: RE: Out of money + +Rays we are seriously out of money. That said, he also said he'll deal with the emergencies. And Maxwell is is radar. So depending on how much money we are talking about, there will be some play in the joints. + +Ori inal Messa e + +From: Sent: Thursday,September 10, 2020 3:38 PM To: Cc: Subject: FW: Out of money + +Do you know if there is any play in the joints on this? We were hoping to hire an SDFL vendor immediately to start work on scanning the SDFL Epstein stuff and to help process the OPR Epstein stuff. Would prefer not to put that off until October if possible. + +Ori inal Messa e + +From: Sent: Thursda , Se tember 10, 2020 2:48 PM To: Cc: Subject: Out of money + +We are out of money through the end of the fiscal. Everything new will have to wait. + +Ed \ No newline at end of file diff --git a/marker2/ds9/EFTA00087362/EFTA00087362.metadata.json b/marker2/ds9/EFTA00087362/EFTA00087362.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..d0874ca8f1c559433db116f6c4bfe4a917a213ee --- /dev/null +++ b/marker2/ds9/EFTA00087362/EFTA00087362.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087362.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1099, + "elapsed_seconds": 0.81, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 79 + ], + [ + "Line", + 38 + ], + [ + "Text", + 16 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087362" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087363/EFTA00087363.md b/marker2/ds9/EFTA00087363/EFTA00087363.md new file mode 100644 index 0000000000000000000000000000000000000000..234594df47bc9f1a62cc8ca4aaa35198a4bb3d58 --- /dev/null +++ b/marker2/ds9/EFTA00087363/EFTA00087363.md @@ -0,0 +1,17 @@ +To + +Cc + +Subject: Epstein FOIA + +Date: Thu, 01 Jul 2021 15:05:58 +0000 + +Morning. Just for your awareness, I got a call regarding the FOIA litigation from one of our press counterparts at Main. She asked if it would be okay to refer press inquiries to SDNY, I told her it wasn't a problem. Other than process questions, and I anticipate declining to comment anyway. + +Do we have a sense of timing as to when this will happen? (I was having a hard time hearing during the call, but my impression was tomorrow and it would be voluminous and take the Times a while to get through?) Thanks. + +Spokesman + +United States Department of Justice + +U.S. Attorney's Office I Southern District of New York \ No newline at end of file diff --git a/marker2/ds9/EFTA00087363/EFTA00087363.metadata.json b/marker2/ds9/EFTA00087363/EFTA00087363.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..a78c2890e9673444f0578b0e6ffa1fd9514a11fd --- /dev/null +++ b/marker2/ds9/EFTA00087363/EFTA00087363.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087363.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 686, + "elapsed_seconds": 0.54, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 27 + ], + [ + "Line", + 14 + ], + [ + "Text", + 10 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087363" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087364/EFTA00087364.md b/marker2/ds9/EFTA00087364/EFTA00087364.md new file mode 100644 index 0000000000000000000000000000000000000000..11324bcd3182eedcc27f2196c6c9680a258eac7d --- /dev/null +++ b/marker2/ds9/EFTA00087364/EFTA00087364.md @@ -0,0 +1,11 @@ +To: + +Subject: Child Exploitation & Porn Update Report I II + +Date: Mon, 05 Jul 2021 20:56:13 +0000 + +Attachments: Child\_Exploitation\_&\_Pom\_Update\_Report\_111.pdf + +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! \ No newline at end of file diff --git a/marker2/ds9/EFTA00087364/EFTA00087364.metadata.json b/marker2/ds9/EFTA00087364/EFTA00087364.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..c9263d3fb038b38895bc58add918ff29ce09ab37 --- /dev/null +++ b/marker2/ds9/EFTA00087364/EFTA00087364.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087364.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 373, + "elapsed_seconds": 0.4, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 19 + ], + [ + "Line", + 9 + ], + [ + "Text", + 7 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087364" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087365/EFTA00087365.md b/marker2/ds9/EFTA00087365/EFTA00087365.md new file mode 100644 index 0000000000000000000000000000000000000000..b91ec9588af8f64045d2e0742f0e8b58b3bd7460 --- /dev/null +++ b/marker2/ds9/EFTA00087365/EFTA00087365.md @@ -0,0 +1,135 @@ +From: ' (USANYS) [Contractor]" To: l apar (NY) (FBI)" Cc: :a (USANYS)" + +Subject: RE: Maxwell To-dos + +Date: Tue, 06 Jul 2021 18:35:18 +0000 + +I have not. be around the rest of the day today and the whole week. Let me know when you're free to drop the files off. + +From: Sent: Tuesday, July 6, 2021 2:06 PM To: (USANYS) [Contractor] Cc: < )'; Subject: RE: Maxwell To-dos (NY) (FBI) (USANYS)< > + +Checking in on this—Will, were you able to get these files from + +From: (USANYS) [Contractor] < Sent: Friday, July 2, 2021 10:03 AM To: Cc: < .>; Subject: RE: Maxwell To-dos (USANYS) (NY) (FBI) < >; + +Sure thing! — I'll be around until 230 today if you're available to drop them off. + +From: Sent: Friday, July 2, 2021 9:55 AM To: (NY) (FBI) (USANYS) [Contractor] Cc: •c )'; (USANYS) Subject: RE: Maxwell To-dos + +Thanks + +Will, would you please coordinate getting these from S then circle up with me to discuss prepping for production? + +From: Amanda Young < > Sent: Thursday, July 1, 2021 3:23 PM To: ) < ›; (USANYS) [Contractor] > Cc: ) (USANYS) Subject: RE: Maxwell To-dos + +Special Agent Amanda Young FBI New York Field Office Child Exploitation/Human Trafficking Desk: + +From: + +Sent: Friday, June 4, 2021 12:47 PM + +To: Byrne, MI (NYPD) •(: > + +Cc: (NY) (FBI) < >; (USANYS) + +Subject: (EXTERNAL EMAIL) - RE: Maxwell To-dos + +Thanks! + +From: BYRNE, + +Sent: Friday, June 4, 2021 10:12 AM + +To: + +Cc: (NY) (FBI) ; (USANYS) + +Subject: Re: Maxwell To-dos + +Sure let me check on that today when I'm in. + +On Jun 3, 2021, at 21:57, > wrote: + +Hi M, + +Checking in again on the .avi files from CART. Any update? + +Thanks, + +From: + +Sent: Monday, April 19, 2021 2:40 PM + +To: BYRNE, (NY) (FBI) < > + +Cc: (USANYS) < + +Subject: RE: Maxwell To-dos + +Hi + +Any update from CART regarding the .avi files, please? And any luck with the review of images for + +Thanks, + +To: . (NY) (FBI) < > + +Cc: >; (USANYS) < + +Subject: Re: Maxwell To-dos + +Hey guys, + +To answer your questions: + +- you should have 302's from by now. +- These photos are still under review. +- We have not forgotten about the .avi files they are also still being processed. +- Palm Beach PD Captain is the POC for this task. His phone number is (cell) (office) and email is + +We will let you know as soon as the photo and video tasks are completed. Let us know if there's anything else. + +Detective + +NYPD / FBI + +## Child Exploitation Human Trafficking Task Force + +Office: + +Cell: + +Fax: + +From: + +Sent: Tuesday, February 2, 2021 4:03 PM + +To: (NY) (FBI) < >; BYRNE, + +Cc: < (USANYS) + +Subject: Maxwell To-dos + +Hi ands, + +Just wanted to check in on a few tasks for Maxwell. Not a huge rush, but wanted to make sure these stay on your radar: + +- Please send me the draft 302s from the 1/20 and 1/21 interviews of for review +- Review of images in FBI office for photos of +- The .avi files from Reiter (E, I know CART has been under water with the Capitol investigation, but wanted to ping on this to make sure we don't forget it) +- Finding PBPD witness who can authenticate the message pads and other items that were seized from Epstein's Palm Beach residence. On this, I've gone through the reports, and below are the PBPD personnel who I think might be able to provide this testimony. If you could please get me contact information for a point of contact at + +PBPD, I'm happy to hound them for contact info for these individuals (ranked in order of how likely they are to be useful witnesses for these purposes): + +o Evidence Specialist (inventory return, documentation of property receipts, and collection and bagging of evidence — ideally we could just call her to authenticate everything that was seized from the property) (searched garage, towel closet and pantry off the kitchen, kitchen phone message book, office room, green bathroom on first floor, closet by green bathroom, two bedrooms on second floor with sex toys, pool cabana, Banasiak's living quarters) (searched garage, towel closet and pantry off the kitchen, kitchen phone message book, officer room, green bathroom on first floor, closet by green bathroom, two bedrooms on second floor with sex toys, pool cabana, Banaskiak's living quarters) (read warrant, video scene) o CSI (photographer) (pantry next to kitchen, yellow and blue room with photos, main entrance, blue room with photos, sliding glass door room, cars) (pantry next to kitchen, yellow and blue room with photos, main entrance, blue room with photos, sliding glass door room, cars) o (electronic devices) + +Thanks very much, + +Assistant United States Attorney + +Southern District of New York + +1 St. Andrew's Plaza + +New York, NY 10007 \ No newline at end of file diff --git a/marker2/ds9/EFTA00087365/EFTA00087365.metadata.json b/marker2/ds9/EFTA00087365/EFTA00087365.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..7f42abc083d587c8566a812dab741bbf95380103 --- /dev/null +++ b/marker2/ds9/EFTA00087365/EFTA00087365.metadata.json @@ -0,0 +1,184 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087365.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 4, + "chars": 4564, + "elapsed_seconds": 1.46, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Child Exploitation Human Trafficking Task Force", + "heading_level": null, + "page_id": 2, + "polygon": [ + [ + 34.884, + 414.72 + ], + [ + 306.2921142578125, + 414.72 + ], + [ + 306.2921142578125, + 427.46759033203125 + ], + [ + 34.884, + 427.46759033203125 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 93 + ], + [ + "Line", + 41 + ], + [ + "Text", + 14 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 73 + ], + [ + "Line", + 33 + ], + [ + "Text", + 27 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 79 + ], + [ + "Line", + 38 + ], + [ + "Text", + 21 + ], + [ + "ListItem", + 8 + ], + [ + "ListGroup", + 2 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 3, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 47 + ], + [ + "Line", + 24 + ], + [ + "Text", + 11 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087365" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087369/EFTA00087369.md b/marker2/ds9/EFTA00087369/EFTA00087369.md new file mode 100644 index 0000000000000000000000000000000000000000..5ac5028bd6b37227a3e4706ad68e017c84e20ca7 --- /dev/null +++ b/marker2/ds9/EFTA00087369/EFTA00087369.md @@ -0,0 +1,75 @@ +To: + +Cc: "-(USANYS)" < + +Subject: FW: Epstein probate update + +Date: Thu, 20 Feb 2020 18:02:09 +0000 + +Attachments: 02.11.2020.004 Notice to the Court.pdf + +If of interest... + +From: (USANYS + +Sent: Thursda February 20, 2020 12:47 PM + +To: (USANYS) >; (USANYS) < (USANYS) + +Subject: Epstein probate update + +All, + +Recent filings in the Epstein probate case reflect the following developments, which might be of interest. + +First, the probate court denied the Virgin Islands Attorney General's motion to intervene in the probate proceedings. + +Second, it appears that the court directed the AG to ensure that its criminal activity liens on the estate's property did not prevent the executors from paying administrative expenses or preserving the estate's assets. However, the estate's bank accounts are currently frozen due to the AG's liens, and the AG is taking the position that it will only allow funds to be released if the AG first approves all of the executors' proposed expenditures. The executors have moved the probate court for emergency relief, asking that they be given full access to the estate's funds to pay administrative expenses and preserve assets without the AG's prior approval. + +Third, the AG sent a letter to the executors laying out the AG's demands for a fair victim compensation program. Those include the following, which may be of particular interest (the full letter can be found at Ex. 6 of the attached document): + +- The estate must cooperate with the AG's investigations into Epstein and his affiliates. +- The estate must waive any non-disclosure agreements signed by former employees of Epstein or his affiliates, and notify such employees that they are encouraged to fully cooperate with the AG's investigation. +- Participants in the compensation program will not be required to sign any third-party releases (apparently, the current proposal would involve such releases). +- The estate must provide a complete inventory of assets held by the estate, the 1953 Trust, Epstein, and any entities he controlled, even if those assets are exempt from the probate process. +- The executors cannot play any role in establishing the victim compensation program or selecting its administrators. + +I have not seen evidence of the executors' response to the AG's letter. + +Would you please send around the AG's filing accusing the executors of complicity? + +Last month, George brought charges against Epstein's estate and alleged that his lawyers, Darren Indyke and Richard Kahn, may have been part of Epstein's alleged fraud. George also put claims on Epstein's two islands. + +Thanks. + +Epstein's lawyers in dispute with Virgin Islands over settlements with victims + +The Guardian By Edward Helmore 2/12/2020 + +Efforts to settle sex abuse claims against Jeffrey Epstein's estate are being thwarted by the attorney general of the US Virgin Islands, lawyers for the disgraced late financier have claimed in court. + +The dispute arises from efforts by the territory's attorney general, Denise George, to claim that Epstein, who owned two islands in the Virgin Islands and where monetary claims on his estate are focused, fraudulently obtained benefits related to a banking licence as part of his alleged criminal enterprise. + +In court documents, George said she planned to name the disgraced financier's lawyers as co-defendants and fight his estate's involvement in creating a victims' compensation fund. + +In July last year, Epstein was arrested on fresh federal sex trafficking and conspiracy charges. He had previously pleaded guilty in 2008 to a Florida state prostitution charge and completed a 13-month jail sentence. Epstein pleaded not guilty to the new allegations but died by suicide in a New York jail cell in August. + +His death has triggered a wide-ranging investigation into his associates and members of his powerful social circle and also many victim claims for compensation. + +Bennet Moskowitz, who is representing Epstein's estate, claimed that liens against the estate have left him unable to release money from Epstein's \$570m fortune to a victim's compensation fund. + +"The attorney general for the Virgin Islands has decided for whatever reason to impede the program;' Moskowitz said at the hearing in Manhattan federal court. + +But George countered that claim, saying she was in fact looking out for victims who may yet come forward. + +"The attorney general's office has opposed the approval of the fund as currently proposed because it lacks fairness, accountability, impartiality and sensitivity to victims at a level they deserve," George said in the statement. + +"Further, victims who have not yet come forward or who may not wish to use the fund must be supported and protected, with funds for counseling and for their claims, too," she said, adding: "There must be full accountability, not only of the estate, but those who participated in, facilitated, and covered up Epstein's crimes." + +Last month, George brought charges against Epstein's estate and alleged that his lawyers, Darren Indyke and Richard Kahn, may have been part of Epstein's alleged fraud. George also put claims on Epstein's two islands. + +Epstein named Indyke and Kahn as his executors to a will he modified so that it would be executed in the Caribbean territory two days before he was found dead in a Manhattan jail cell on 10 August. + +In November, it was reported that Epstein's estate had asked the courts to allow a voluntary resolution program for the late sex offender's accusers overseen by Ken Feinberg, the settlement's expert who oversaw claims from victims of the 9/11 terrorist attacks, the Catholic church's sex abuse scandals, and the BP-Blue Water Horizon oil spill. + +But lawyers for several victims have argued that a victims fund would maintain the shroud of secrecy over Epstein's alleged crimes and prevent the release of any new information while minimizing the threat of large jury awards from individual legal actions. \ No newline at end of file diff --git a/marker2/ds9/EFTA00087369/EFTA00087369.metadata.json b/marker2/ds9/EFTA00087369/EFTA00087369.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..5733e2f0b7662f120a9fb173935566a73278adfd --- /dev/null +++ b/marker2/ds9/EFTA00087369/EFTA00087369.metadata.json @@ -0,0 +1,122 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087369.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 5933, + "elapsed_seconds": 1.28, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 73 + ], + [ + "Line", + 37 + ], + [ + "Text", + 20 + ], + [ + "ListItem", + 5 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 73 + ], + [ + "Line", + 36 + ], + [ + "Text", + 17 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 17 + ], + [ + "Line", + 9 + ], + [ + "Text", + 3 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087369" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087372/EFTA00087372.md b/marker2/ds9/EFTA00087372/EFTA00087372.md new file mode 100644 index 0000000000000000000000000000000000000000..8651af3b7ab758310916cb3a4cc6610f4b489c9b --- /dev/null +++ b/marker2/ds9/EFTA00087372/EFTA00087372.md @@ -0,0 +1,465 @@ +IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS +DIVISION OF ST. THOMAS & ST. JOHN + +\*\*\*\*\* + +SUPERIOR COURT +OF THE VIRGIN ISLANDS +20 FEB 11 PM 5:25 + +IN THE MATTER OF THE ESTATE OF ) +JEFFREY E. EPSTEIN, ) +) +) +Deceased. ) +\_\_\_\_\_ ) + +NOTICE TO THE COURT + +COMES NOW, the Government of the Virgin Islands, by and through its undersigned counsel, Virgin Islands Department of Justice, Office of the Attorney General and advise the Court of its efforts to meet, confer and cooperate with counsel for the Estate of Jeffrey E. Epstein ("Estate"), in light of the Court's oral directive related to the filed "Criminal Activity Lien Notice" and the voluntary victims compensation fund ("Fund"). The purpose of this notice is to advise the court of the Government's endeavor to work cooperatively with the victims as well as the Estate on the above concerns. Since the hearing on February 4, 2020, the Government has reached out to and met with the counsel for the Estate and counsels for victims to begin the dialogue for a fair and just resolution of the following issues: + +A. CRIMINAL ACTIVITY LIEN NOTICE ON ESTATE ACCOUNT + +By way of recent background, the Court, on Tuesday, February 4, 2020, held a hearing on all outstanding motions in this matter. On Wednesday, February 5, 2020, Shauna Betz, Legal Assistant at Kellerhauls, Ferguson Kroblin (Attorneys for the Estate) sent email correspondence to the Attorney General from Estate attorney Christopher Kroblin, Esq, objecting to the Criminal Activity Lien hold ("Lien") that, that the Government placed on accounts at the First Bank of Puerto Rico on January 31, 2020, in the name of the "The Estate of Jeffrey E. Epstein," "Nautilus, Inc." and "Great St. Jim, LLC", (See Exhibit 1) On February 6, 2020, the Attorney General responded by email, and offered to schedule a meeting with the Estate the following day, which + +Attorney Kroblin accepted. (See Exhibit 2). On Friday, February 7, 2020, the Attorney General met, in person, with Attorney Christopher Kroblin at the Office of the Attorney General. Attorney Kroblin expressed the concern that the Lien prevents the Estate from paying its expenses to maintain and preserve the Estate. The Attorney General expressed the importance of the Estate to meet its expenses for maintenance and preservation of the estate and offered, pursuant to her legal authority, to release sufficient funds to meet such expenses once the Estate identifies the expenses and the amount of funds needed. On Sunday February 9, 2020 the Attorney General followed up and memorialized that , meeting by sending an email again expressing her willingness to accommodate an immediate release of sufficient funds to pay the necessary expenses so that the executors could continue to manage, maintain and preserve estate assets, and stated that that the Attorney General's office was eagerly awaiting the listing of expenses to facilitate prompt release of funds for payment. In that same email, the Attorney General also indicated her intention to send follow-up correspondence on the victims' program fund that was briefly discussed in the Friday meeting. . (See Exhibit 3) + +The CICO statute grants the Attorney General the authority to release, in whole or in part, any personal or real property from the notice. 14 V.I.C. § 610 (r). As the Government's underlying CICO action is still pending, only the Attorney General may release any property or interest from the Criminal Activity Liens. This is the express command of the statute, which provides in relevant part that: + +The Attorney General . filing the Criminal Activity Lien Notice may release, in whole or in part, any Criminal Activity Lien Notice or may release any personal or real property or beneficial interest in it from the Criminal Activity Lien Notice upon such terms and conditions as he may determine. + +14 V.I.C. § 610(r) (emphasis added). The Act thus is clear and unambiguous that where, as here, a Criminal Activity Lien Notice has commenced and attached upon the Attorney General's filing of an action and Notice, the Attorney General has sole authority to release the Liens upon such terms and conditions as she may determine to be appropriate. + +On Monday, February 11, 2020, at 4:26 pm, Counsel for the Estate, Christopher iCroblin, Esquire, sent an email to the Attorney General stating that it was seeking an Order from the Court because FirstBank has informed them that the hold will remain absent a court order. In that email, Estate Counsel notably did not attach by email a courtesy copy of its filed motion. (See Exhibit 4). At 4:39 p.m., the Attorney General specifically requested a copy of the motion. More than one hour later, at 5:45 p.m., Estate Counsel did provide a copy of the motion, which had been emailed to all other counsel, except counsel for the Government. (See Exhibit 5) To date, the Estate has not responded to the Attorney General's request for the listing of expenses as discussed. + +### B. VICTIMS' COMPENSATON FUND — ALTERNATIVE + +On Monday, February 10, 2020, the Attorney General, as promised in her previous email, sent a four (4) page letter via email to the Estate counsel, detailing the Government's concerns with the victim's compensation fund as proposed by the Estate and setting forth alternative victim compensation program protocols and guidelines for a more fair and just program fund for Epstein victims. . (See Exhibit 6). Jordana Feldman, proposed Fund administrator, was copied on this correspondence. + +After the February 4, 2020 hearing, the Attorney General also had a very productive meeting with a counsel for victims. The Attorney General shared the government's program plan with said counsel, which was very well received. There are plans for further discussions and meetings with the victims and counsels in an effort to attain a more fair, impartial and just compensation program. (Exhibit 7) + +Respectfully submitted, + +DENISE N. GEORGE, ESQUIRE +ATTORNEY GENERAL +VIRGIN ISLANDS DEPARTMENT OF JUSTICE + +Dated: February 11, 2020 + +By: + +[REDACTED] + +Assistant Attorney General +Virgin Islands Department of Justice +Office of the Attorney General + +[REDACTED] + +**CERTIFICATE OF SERVICE** + +IT IS HEREBY CERTIFIED that the foregoing Motion complies with the word and page requirements of V.I.R. Civ. P. 6-1(e) and, a true and correct copy of the Motion was served via regular mail, postage prepaid, with a courtesy copy sent by email to counsel of record on February 11, 2020 to: + +CHRISTOPHER ALLEN KROBLIN, ESQ. +ANDREW W. HEYMANN, ESQ., +WILLIAM BLUM, ESQ. +SHARI D'ANDRADE, ESQ. +MARJORIE WHALEN, ESQ. +KELLERHALS FERGUSON KROBLIN PLLC + +[REDACTED] + +Email: + +[REDACTED] + +[REDACTED] + +Exhibit 1 + +From: Sent: To: Cc Subject: Attachments: Shauna Betz Wednesday, February 05, 2020 4:33 PM Denise George: Denise George Chris Kroblin; Shari D'Andrade [EXTERNAL MAILINotice of Criminal Activity Lien 2020-02.05 Ltr to Denise George re lien on bank accountl.pdf + +Good Day Attorney General George: + +Please see the attached correspondence. + +Regards, Shauna Betz Legal Assistant ICellerhah Fer son Kroblin PLLC + +![](_page_5_Picture_5.jpeg) + +Notice: This communication may contain privileged or other confidential information. If you are not the intended recipient, or believe that you have received this communication in error, please do not print, copy, re-transmit, disseminate, or otherwise use this information. Also, please indicate to the sender that you have received this e-mail in error, and delete the copy you received. Thank you. + +Circular 230: To ensure compliance with the requirements imposed by the IRS, we inform you that any tax advice contained in our communication (including any attachments) was not intended or written to be used, and cannot be used, for the purpose of (i) avoiding any tax penalty or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein. + +Caution: This e-mail has originated outside of GVI network. Do not click on links or open any attachment (s) that might look suspicious unless you have knowledge of who the sender is. + +![](_page_6_Picture_109.jpeg) + +**Kellerhals Ferguson Kroblin PLLC** + +![](_page_6_Picture_111.jpeg) + +February 5, 2019 + +**Via Email and Hand Delivery** + +The Honorable Denise N. George, Esq. +Attorney General +V.I. Department of Justice + +![](_page_6_Picture_115.jpeg) + +**RE: Notice of Criminal Activity Lien** + +Dear Attorney General George: + +While we are aware that you were not present at the Estate of Jeffrey E. Epstein (the "Estate") hearing before Judge Percell yesterday, Civil Chief Ariel Smith, Esq. appeared on behalf of the Government and the issue of the impact of the Notice of Criminal Activity Lien ("Lien") on the Estate arose. Attorney Smith clarified on the record that the V.I. Department of Justice, with the filing of the Criminal Activity Lien in the probate case, has no intention of prohibiting the co-Executors from paying expenses associated with the administration of the Estate and that the Estate could continue to function, pay employees, and pay attorneys, among other things. The Court echoed that sentiment and directed from the bench that the Lien does not interfere with the estate administration, as contemplated by the Decedent's Last Will and Testament, V.I. Code Ann. tit. 15, §§ 421, 568, and the Virgin Islands Rules for Probate and Fiduciary Proceedings. + +Unfortunately, that is exactly what has occurred. Immediately following the hearing, and in stark contrast to the Government's explicit representation made on the record and the Court's instruction, the Estate received notification from Dudley Newman Feuerzeig, counsel to First Bank, that a hold has been placed on certain accounts, including, most importantly, the Estate of Jeffrey E. Epstein account. *See* attached correspondence. We demand that you immediately direct First Bank, through its counsel, that a lien of the Estate account is inappropriate and the account should be restored to active status. Your failure to do so will result in our filing an emergency motion with the Court seeking a declaration that the lien does not attach to the Estate account, as well as sanctions for acting in direct contravention to your office's representations to the Court and the Court's statement that administrative expenses must and should be paid by the Estate. + +Sincerely, + +![]()Christopher A. Kroblin + +cc: + +![](_page_6_Picture_124.jpeg) + +![](_page_7_Picture_27.jpeg) + +**KURT E. PETRI** + Partner + +![](_page_7_Picture_29.jpeg) + +**Physical Address** + Low House + 1000 Frederickstree Suite + Charlotte Avenue St. Thomas + US Toronto Bureau 20002 6176 + +**Mailing Address** + P.O. Box 156 + St. Thomas, VI 00804 0756 + +T: 360 114 4422 + www.DNF-LLC.com + +February 4, 2020 + +**VIA EMAIL AND U.S. POST** + +Darren K. Indyke + Richard D. Kahn + The Estate of Jeffrey E. Epstein + Great St. Jim LLC + Nautilus, Inc. + +![](_page_7_Picture_34.jpeg) + +Re: Criminal Activity Lien Notices +DNF File No. 4100-36 + +Dear Mr. Indyke and Mr. Kahn: + +This letter is being sent to notify you that, as a result of the attached Criminal Activity Lien Notices (ST-2020-CV-14) (the "Notices") served upon FirstBank on January 31, 2020, a hold has been placed on the following accounts: + +| Account Name | Account Number | Address | +|------------------------------|-----------------------|-----------------------------------------------------| +| Great St. Jim LLC | [REDACTED] | 6100 Red Hook Quarter
B3
St. Thomas, VI 00802 | +| Nautilus, Inc. | [REDACTED] | 6100 Red Hook Quarter
B3
St. Thomas, VI 00802 | +| Estate of Jeffrey E. Epstein | [REDACTED] | 9053 Estate Thomas
#101
St. Thomas, VI 00802 | + +... The Estate of Jeffrey E. Epstein and Mated EntitiesCnminal Aetwily Lien January IS. 2020 Page 2 + +This hold will remain in place until FirstBank receives an Order from a court of appropriate jurisdiction releasing the lien claims upon these accounts set forth in the Notices. + +Sincerely. + +cc: Christopher A. Krohlin. Esq. + +RNDOCT6602l51TR,10F47R102.00CX + +# EXHIBIT 2 + +From: Sent To: Cc Chris Kroblin Thursday, February 06, 2020 9:06 PM D ni eGeogm + +Subject Re: [EXTERNAL MAILINotice of Criminal Activity Lien + +Attorney George, + +Thanks for the response. Happy to do so. + +Best regards, + +Chris + +Sent from my iPhone + +On Feb 6, 2020, at 7:51 PM, Denise George wrote: + +Good evening Attorney Kroblin: + +I just noticed this email correspondence from your legal assistant whose name I did not recognize. Please have Ms. Betz contact my Executive Assistant Jennifer Springette to set a time to meet tomorrow afternoon to discuss this matter. + +Have a good evening. + +Data[ N. GEORGE, Ess Attorney General Virgin Islands Department of Justice Office of the Attorney General + +From: Shauna Betz Sent: Wednesday, Februa 05 2 204:33 PM To: Denise George ; Denise George Cc: Shari D'Andrade Subject: (EXTERNAL MAIL1Notice of Crimina Activity Lien hris Kroblin Exhibit 3 + +From: Denise George Stint Sunday, February 09, 2020 8:15 AM To: Chris Kroblin Cc Subiat GVI v. Epstein Estate et al + +Good day Attorney Kroblin, + +It was great meeting with you Friday afternoon as we discussed the importance to all concerned for the estate to meet its day to day maintenance expenses and our willingness to accommodate for an immediate release of funds sufficient to pay these expenses so that the executors may continue to manage and preserve estate assets. We eagerly await your response regarding those expenses are costs so we can expeditiously move forward. + +You can also expect written correspondence from me on the victims' program fund as a follow up to our brief discussion. + +Dam N. Qom, Esg. Attorney General Virgin Islands Department of Justice of the General + +![](_page_12_Picture_6.jpeg) + +## EXHIBIT 4 + +From: Sent: To: Cc: Subject: Chris Kroblin Monday, February 10, 2020 4:26 PM Denise Genrne [EXTERNAL MAILIRE:GVI v. Epstein Estate et al + +Attorney General George, + +We appreciate your recognition of the critical importance of paying the ongoing maintenance expenses of the Epstein Estate. Because the Estate cannot survive the indefinite "hold" placed on the Estate's account at FirstBank as the result of the Criminal Activity Lien Notices recently issued by your office, and because FirstBank has informed us that it will maintain that hold absent "an Order from a court of appropriate jurisdiction releasing the [Government's] lien claims," the Co-Executors have today sought an order from the Superior Court releasing all funds necessary for the routine administration of the Estate and the preservation of its assets. + +We received your communication yesterday afternoon regarding the voluntary compensation program proposed by the Co-Executors and endorsed by the Court and claimants' counsel at the hearing on February 4. We will consult with our clients and expect to respond shortly. + +Best regards, + +Christopher Allen Kroblin + +Member KELLERHALS FERGUSON KROBLIN PL. C + +![](_page_14_Picture_8.jpeg) + +Of Counsel to: Solomon Btum Heymann LLP + +![](_page_14_Picture_10.jpeg) + +Notice: This communication may contain privileged or other confidential information If you are not the intended recipient. or believe that you have received this communication in error, please do not print, copy, re-transmit, disseminate. or otherwise use this information. Also. please indicate to the sender that you have received this eimai: in error, and delete the copy you received Thank you. + +Circular 230: To ensure compliance with the requirements :mposed by the IRS, we inform you that any lax advice contained in our communication (inciuding any attachments) was not intended or wntton to be used, and cannot be used. for the purpose of (i) avoiding any lax penalty or (a) promoting. marketing or recommending to another party any transaction or matter addressed herein + +# EXHIBIT 5 + +Front Denise George Sent Monday, February 10, 2020 4:39 PM To: Chris Kroblin Cc: Subject: RE: [EXTERNAL MAIURE:GVI v. Epstein Estate et al + +Good day Attorney Kroblin, + +Please provide us with a copy of that motion. Thank you. + +Vcn N. Gwwz, En Attorney General Virgin Islands Department of Justice Office of the Attorney General + +![](_page_16_Picture_5.jpeg) + +From: Chris Kroblin Sent: Monday, Februa To: Denise Geo Cc: 10, 2020 4:26 PM Subject: [EXTERNAL MAIL)RE: GVI v. Epstein Estate et al + +Attorney General George, + +We appreciate your recognition of the critical importance of paying the ongoing maintenance expenses of the Epstein Estate. Because the Estate cannot survive the indefinite "hold" placed on the Estate's account at FirstBank as the result of the Criminal Activity Lien Notices recently issued by your office, and because FirstBank has informed us that it will maintain that hold absent "an Order from a court of appropriate jurisdiction releasing the [Government's] lien claims," the Co-Executors have today sought an order from the Superior Court releasing all funds necessary for the routine administration of the Estate and the preservation of its assets. + +We received your communication yesterday afternoon regarding the voluntary compensation program proposed by the Co-Executors and endorsed by the Court and claimants' counsel at the hearing on February 4. We will consult with our clients and expect to respond shortly. + +From: Sent To: Cc Subject Attachments: Chris Kroblin Monday, February 10, 2020 5:45 PM Denise George [EXTERNAL MAIL]RE: [EXTERNAL MAIL]RE: GVI v. Epstein Estate et al DS Emergency M for Order Releasing Funds for Administration.pdf + +Please see the attached. + +Best regards, + +Christopher Allen Kroblin + +Member KELIERHALSEfitGLISON KAMEN Pat\_ + +Of Counsel to: H + +Notice: This communication may contain privileged or other confidential information. If you are not the intended reaPient. or believe that you have received ea communication in error, please do not print, copy. re•trxwnM, disseminat or otherwise use this information. Also, please indicate to the sender that you have received this omen In error. and delete the copy you received. Thank you. Circular 230: To ensure compliance with the requirements imposed by the RS. we Inform you that any tax advice contained In ow communication (including any attediments)wes not Intended or within to be used, and cannot be used. for the purpose of (i) avoiding any tax peaty or (II) promoting, marketing or recommittal° to another party any transaction or matter addressed hares. + +From: Denise George Sent: Monday, February 10, 2020 4:39 PM To: Chris Kroblin MAILIRE: GVI v. Epstein Estate et al + +Good day Attorney Kroblin, + +# Exhibit 6 + +From: + +Sent: + +To: + +Cc: + +Subject + +Attachments: + +Tracking: + +Monday, February 10, 202010:19 AM + +Chris roblin + +Denise George + +02-10-2020 Letter to Christopher Kroblin (Estate of Jeffrey E. Epstein) + +02-10-2020 Letter to Christopher Kroblin (Estate of Jeffrey E. Epstein).pdf + +Recipient Delivery Read + +Chris Kroblin + +Denise George + +Good Morning Attorney Kroblin: + +Delivered: 2/1012020 10:19AM Read: 2/1012020 10:21 AM + +Attached please find letter dated February 10, 2020 from Attorney General Denise George. Thank you. + +KINDEST REGARDS, + +![](_page_19_Picture_22.jpeg) + +Executive Assistant to the Attorney General + +Virgin Islands Department of Justke + +Office of the AttorneyGeneral + +Live Your Life With Purpose: Count your blessings, not your problems, and you will realize how beautiful your lift truly is. + +![](_page_20_Picture_0.jpeg) + +### THE UNITED STATES VIRGIN ISLANDS DEPARTMENT OF JUSTICE OFFICE OF THE ATTORNEY GENERAL + +February 10, 2020 + +Christopher Allen Kroblin, Esq. K elle halc Fermi nn Krohlin Pr + +![](_page_20_Picture_4.jpeg) + +RE: Estate of Jeffrey E. Epstein + +Dear Attorney Kroblin: + +It was good to meet with you on Friday as we discussed matters involving the Estate of Jeffrey Epstein ("Estate"). As we discussed briefly, Judge Carolyn Hermon-Percell requested that the Attorney General's Office and the Estate confer on the issues related to a victims' compensation fund ("Fund"). I write to begin that dialogue by laying out in detail my concerns about and recommendations for the Fund. + +Iexpect and certainly understand why some victims will want an expedited process that provides compensation — however incomplete for the harm done to them. However, to be credible and to comport with the law and policies of the Virgin Islands, that process must also be fair, just, and independent. The Fund, as proposed by the Estate, does not meet those standards. + +Among the issues raised in the Government's opposition to the Fund were four critical issues. + +Frist, the Fund must set aside sufficient funds to pay claims of victims who may come forward in the future or may proceed through civil litigation. Particularly given the nature of the trauma suffered by these victims, many of whom were children when they were trafficked, there needs to be sufficient time and alternate venues available to victims. While some victims have stepped forward now, others may require more time and support. To make the Fund truly voluntary, the Estate must preserve assets for those who choose not to participate in it. Otherwise, many victims will be coerced into the process, believing that the Fund provides the only chance to ensure that their claims are paid. To the extent that additional victims do not seek or obtain funding, those funds can support organizations that advocate for or support victims of human trafficking - a far more meaningful and appropriate use of an Estate so tied to its fundcr's criminal activities. + +Second, public policy does not permit the Estate to require broad third-party releases from victims in exchange for compensation. These releases serve no permissible purpose and will only silence victims and prevent them from seeking accountability and recovery from other individuals and + +![](_page_20_Picture_12.jpeg) + +entities that participated in, facilitated, or covered up Jeffrey Epstein's crimes. I understand that, after I raised this issue, the Epstein Fund has now offered to remove those broad releases from its protocol. That is a positive step, but the commitment must be made binding. + +Third, the Epstein Estate, whose executors arc directly associated with entities that are defendants in the Government's lawsuit and which allegedly facilitated or participated in Epstein's criminal activity, should play no role in choosing a claims administrator or in designing a compensation program. While the Estate has indicated that the program administrator will have full authority to evaluate and set claim amounts, the fact that the administrators were chosen by, advised by and would be paid handsomely by the Estate creates an unavoidable appearance of impropriety. To ensure the integrity and credibility of the process, the Estate must disavow any role in the process, and allow the victims and the Attorney Genera], with the Court's approval, to collectively select an appropriate administrator. Further, payments to the administrator, now disclosed to be up to \$200,000 per month, with \$1.7 million for just two months of work to the attorney who designed the Fund, as well as administrative staffing and other business expenses that could amount to millions, are excessive and disproportionate to the nature of the case and anticipated number of victims. The costs to run the Fund should be capped at a reasonable amount that ensures that the Estate's assets will not be unnecessarily and unreasonably dissipated. + +Fourth, the Epstein Estate must commit not only to a providing compensation, but cooperating with law enforcement. Otherwise, the Fund's primary purpose can be seen as limiting the Estate's exposure, protecting Epstein's associates, paying for victims' silence and avoiding further public exposure. That is a debt owed not only to Epstein's victims, but to all those who may avoid becoming victims of other sexual predators in the future. + +Specifically, an acceptable, fair and appropriate victims' program fund would have to be consistent with these principles and include the following commitments from the Estatc: + +- 1. The Estate must provide a complete inventory and accounting of the assets that are held by the Estate, 1953 Trust and by Jeffrey Epstein or any other entities that he owned or controlled, whether or not a part of the probate. The Estate in good faith should be open and honest with the victims, the Court and the Government regarding the assets of the estate and the value of each asset as Virgin Islands probate law requires. The victims should not be asked to evaluate appropriate compensation, nor can the Government blindly release funds from its criminal activity liens without knowing the true nature and total value of Epstein's assets. +- 2. The Estate must agree to set aside a sufficient fixed fund prior to the close of the probate proceedings to compensate victims who do not accept payment from the Fund or do not come forward within the probate claims period of the Estate. In the event that such victims do not come forward or obtain judgments, the balance of the fund would be donated, through cypres, to organizations providing support to victims of human trafficking, sexual exploitation and sexual assault. The timing for payments must be centered on victims' relief, not deadlines dictated by the probate process. + +- 3. The Estate may not transfer ownership of Great St. James and Little St. James and other instrumentalities of Epstein's crimes in the Virgin Islands and must set aside a fixed sum sufficient to satisfy any potential judgment in favor of the Government of the Virgin Islands. The Government preserves its authority to enforce its laws to curtail human trafficking, sexual assaults and criminal enterprises, to hold Epstein and other violators accountable, to protect the safety and wellbeing of the Virgin Islands, to guide how victims are cared for and to protect our children—those who live here, as well as those who are brought here—from the scourge of human trafficking and sexual exploitation, now and in the future. +- 4. The Fund administrator and the protocol and criteria for the Fund must be chosen by Epstein's victims and the Attorney General, informed by experts in human trafficking, and/or survivors of human trafficking, and approved by the Court. The Fund administrator herself must be knowledgeable and experienced in the administration and settlement of funds for victims of crimes of human trafficking and sexual exploitation/assault of women and children. +- 5. Because of the existing conflicts of interest of the Estate and executors, as laid out in the Government's opposition to the Fund, there must be an absolute firewall between the Fund and the Estate. Furthermore, because of these conflicts, the Executors of the Estate should have no role at all in the Fund, including in selecting or approving the administrator, the protocol or criteria for the fund, or oversight or approval of the Fund's administration. +- 6. The Fund must provide full reporting on its criteria, process, awards, and expenses to the Court and the public while protecting the privacy of any claimants who choose to remain anonymous. +- 7. The program administrator must, in consultation with victims and non-profit or government organizations focused on human trafficking, identify a plan to adequately publicize the existence of the Fund. +- 8. Once a claim reaches settlement, victims will not be asked or required to release any person or entity from liability other than the Estate. +- 9. The Estate will set aside funds to provide counseling to any victim who wishes to discuss coming forward to the Fund or to law enforcement. The individual or entity providing such counseling will be approved by the Attorney General, victims' counsel, and the Court. The identity of all such victims will not be disclosed to the Estate. +- 10. Claimants will be provided with the Virgin Islands Crime Victims' Bill of Rights and be provided with contact information for the Virgin Islands Office of the Attorney General should they care to cooperate with Virgin Islands law enforcement. + +*Christopher Allen Kroblin, Esq.* + +*February 10, 2020* + +*Page 4* + +1. 11. The Estate will agree that no records obtained in the claims or counseling process will be used against any victim or in defending any claim against the Estate or related entities or individuals. +2. 12. Expenses of setting up and administering the Epstein Fund will be capped at a reasonable amount. This is absolutely necessary to avoid the excessive costs proposed to run the Fund, which would deplete the funds in the Estate and place significant resources from the Fund in the pockets of the Estate's associates and hand-picked administrators and attorneys. The costs of the program should be commensurate with the nature of the claims and the number of victims addressed. +3. 13. The Estate will agree to preserve, identify, and make available to the Virgin Islands all documents (including electronically stored information and video/audio recordings) related to Epstein's criminal conduct in the Virgin Islands, and will not seek to prevent disclosure of such information, though no information that might reveal the identity of his victims will be publicly disclosed, as required by Virgin Islands law. +4. 14. The Estate will agree to cooperate to provide information against any individuals or other entities that participated in the conduct described in the Government's complaint. +5. 15. The Estate will waive any non-disclosure agreements signed by former employees of Epstein or related entities and will notify such employees that they are not bound by confidentiality and are encouraged to cooperate fully and truthfully with the Attorney General and her representatives. + +I sincerely hope that the Estate will find these commitments to be uncontroversial and consistent with its commitment to ensure swift, fair and lawful resolution for Epstein's victims, and we look forward to talking with you about these issues and any other suggestions you may have to address the Government's concerns and interests. + +Sincerely, + +![]()Denise N. George, Esq. + +Attorney General of the U.S. Virgin Islands + +![]() + +# Exhibit 7 + +From: Brittany Henderson c Sent: Monday, February 10, 2020 11:37 AM To: Denise Georoe Cc: Subject: Re: Epstein Estate + +Attorney General George, + +After our meeting, I am confident we all agree that there is nothing more powerful than the voices of the victims. As a testament, one of our clients reached out late last week and asked if she could speak with you directly or write you a letter sharing her feelings on the events that have recently transpired. The next day, another client called with similar requests. Hearing that these women welcome the opportunity to speak with you not only instills in me a great sense of pride, but it is also a reminder that we are all stronger together. Please let me know if you are interested in meeting so that we can figure out the best way to make that happen. + +Thank you for your time, + +![](_page_25_Picture_5.jpeg) + +In EDWARDS POTTING ER LLC + +Brittany N. Henderson + +Trial Attorney + +![](_page_25_Picture_9.jpeg) + +Caution: This e-mail has originated outside of GVI network. Do not click on links or open any attachment (s) that might look suspicious unless you have knowledge of who the sender is. + +From: Denise George Sent: Monday, February 10, 2020 12:46 PM To: Brittany Henderson Cc: Subject: RE: Epstein Estate Attachments: Brad Edwards 02-10-2020 AG Letter to Christopher Kroblin (Estate of Jeffrey E. Epstein).pdf + +Good day Ms. Henderson and Attorney Edwards: + +We are indeed very interested in meeting with the victims and I thank you for the productive and encouraging conversation in our February 4"1meeting. I agree that this is so important to ensure that we maintain an open dialogue with a goal of reaching a resolution that best serves all of the victims of Jeffrey Epstein's conduct and provides a model for how cases and conduct like this may be resolved in the future. + +To that end, I have attached a letter that I want to share with you which I sent to Epstein's Estate to establish the kind of specific commitments that would be required of the Estate to address the Government's concerns regarding their program as proposed. I welcome your thoughts and feedback. I also welcome you to contact my Executive Assistant Jennifer Springette to coordinate a meeting with the victims as soon as possible. + +I look forward to meeting with you again on this very important matter. + +Sincerely, + +DINISE N. GEORGE, ESQ. Attorney General Virgin Islands Department of Justice Office of the Attorney General + +![](_page_26_Picture_8.jpeg) + +From: Brittany Henderson Sent: Monday, Febr • To: Denise Geor e Cc: Su ject: Re: Epstein Estate + +From: Brittany Henderson Sent Monday, February 10, 2020 2:13 PM To: Denise Gear. e Cc: Subject: Re: Epstein Estate + +Attorney General George, + +Thank you very much for the quick reply. It is evident in reading your correspondence to the Estate that you and your team have put a significant amount of time Into reviewing the proposed claims fund in its current form. Your suggestions and requested commitments, as outlined, demonstrate that the best interests of the victims are at the forefront of your mission. That alone is comforting to us as we wade through conversations with our clients regarding the current status of affairs. + +That being said, I reached out to both of our clients immediately, who appreciate tremendously your willingness to meet with them. We look forward to facilitating an even more expansive free flow of ideas in an effort to reach a resolution that is most advantageous to the survivors. At your direction, we will contact Ms. Springette today to coordinate a time that works best for you and your office. + +In the meantime, please let us know if you are available this afternoon for a short call to discuss which portions of your letter, if any, you would feel comfortable with us sharing with the court tomorrow during the status conference for all currently pending cases being litigated in the Southern District of New York. Alternatively, we can speak in the morning prior to the conference which is set to begin at 10am EST. + +We look forward to speaking and continuing to work with you. + +Brittany Henderson, Esq. Edwards Pottinger LLC + +On Feb 10, 2020, at 11:45 AM, Denise George wrote: + +Good day Ms. Henderson and Attorney Edwards: + +We are indeed very interested in meeting with the victims and I thank you for the productive and encouraging conversation in our February 4'h meeting. I agree that this is so important to ensure that we maintain an open dialogue with a goal of reaching a resolution that best serves all of the victims of Jeffrey Epstein's conduct and provides a model for how cases and conduct like this may be resolved in the future. + +To that end, I have attached a letter that I want to share with you which I sent to Epstein's Estate to establish the kind of specific commitments that would be required of the Estate to address the Government's concerns regarding their program as proposed. I welcome your thoughts and feedback. 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b/marker2/ds9/EFTA00087372/_page_7_Picture_34.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:adf22fc064057fe4a974d7956219fac6e5fe98c862c470b03937614367cf7f72 +size 3728 diff --git a/marker2/ds9/EFTA00087400/EFTA00087400.md b/marker2/ds9/EFTA00087400/EFTA00087400.md new file mode 100644 index 0000000000000000000000000000000000000000..d426e851301c086a8c34ef505b5288944cfce45c --- /dev/null +++ b/marker2/ds9/EFTA00087400/EFTA00087400.md @@ -0,0 +1,5633 @@ +To: + +Subject: Fw: Formal appeal for covered action 2015-016/ Knight Capital TCR & Appendix + +Date: Tue, 17 Aug 2021 11:54:22 +0000 + +Attachments: KCG\_Appendix\_3-20\_13\_penultimate.docx; KCG\_TCR\_3-20-13-penultimate\_draft.pdf; + +KCG\_TCR\_3-20-13-penultimate\_draft.docx; KCG\_Appendix\_3-20\_13\_penultimate.pdf; + +kcglq2015.pdf; IMDS2012shareincrease.pdf; IMDS2013authshareinc.pdf; + +IMDS2014offering.pdf; IMDSShareincrease2017.pdf; IMDSshareincJune282018.pdf; + +IMDSdecauthorizedJuly122018.pdf + +No doubt Mr Hoecker ANOTHER in depth and thorough "investigation" by your office coming. Say it with me: The SEC is a grossly corrupt, criminal organization ACTIVELY facilitating multiple, ongoing, massive frauds on the public it is mandated to protect to the benefit of the criminals who own them while screwing the whistleblower + +who caught them: ME: Christopher J Dilorio + +Whistleblower Extraordinairel + +Cheers! Chris + +From: Chris Dilorio c > Sent: Monday, August 16, 2021 8:55 PM + +Subject: Fw: Formal appeal for covered action 2015-016/ Knight Capital TCR & Appendix + +SDNY,NY Supreme Court, NJ Judges et al + +IRREFUTABLE proof of SEC criminal Obstruction and corruption + +IMDS Florida SoS page + +ALL of the links have been expunged Detail by Entity Name (sunbiz.org) + +Good thing I have electronic versions: see attached + +2012 share increase from 4,000,000,000 to 10,000,000,000 2013 share increase from 10,000,000,000 to 20,000,000,000 + +2014 Series M with Viable + +2017 share increase from 20,000,000,000 to 30,000,000,000 June 2018 share increase 30,000,000,000 to 40,000,000,000 + +weeks later: + +July 2018 reverse split to 502,000,000 + +Mr Bustilloe et al at the grossly corrupt SEC: + +FUCK YOU! + +You corrupt pieces of SHIT! + +Cheers! + +Christopher J Dilorio + +Whistleblower Ext raordi na ire + +Subject: Fw: Formal appeal for covered action 2015-016/ Knight Capital TCR & Appendix + +Irrefutable proof of SEC facilitated fraud. + +My 2013 Knight/UBS TCR filed with Berger Montague in March 2013. Highlighted trading activity in Imaging Diagnostic Systems: IMDS. Despite glaring AML Red Flags involving entities subsequently cited by the SEC as Securities law violators, NITE and UBSS traded billions of shares. The SEC: Boston Director Levenson et al brought a complaint against IMDS, CEO Linda Grable, and CFO Alan Schwartz for among other things: making false and misleading statements. The complaint also calls IMDS a fraud. In an effort to cover up this massive + +illegal activity by NITE and UBSS, the SEC chose to cover up instead. + +The SEC was in the process of revoking the IMDS registration when it allowed barred Linda Grable and Alan Schwartz along with Grable II to execute a SPA with a Chinese National entity called Viable International. The 2014 13D filed by Viable shows them owning 37 BILLION shares of IMDS when the SEC was in the process of revoking the registration and with the stock at .0001. Yet, the SPA with Viable was for a Series M preferred and + +the 6 tranch conversion was nowhere near 37 billion shares. In fact, Viable filed an "amended" 13d in March 2019 showing owning 87.1 million shares. Adjusted for reverse splits this amt approimates the Series M + +conversion formula in the SPA and filed with the Florida SoS. + +The 37 BILLION shares were used to close out open naked short fails. The SEC/Levenson orchestrated ANOTHER + +"glitch" to AGAIN bail out the criminal entity NITE. The ink wasn't even dry on the August 2012 "glitch". In facilitating this corrupt and criminal scheme the SEC allowed NITE/UBSS and others to close out a massive naked short position at a profit rather than forcing NITE/UBSS to cover/buy in the open market as is required under Rule 204 and incur massive losses. Proving AGAIN that the SEC bailed out a KNOWN criminal entity: NITE + +in August 2012. Simple fact of the matter: According to the Florida SoS page + +Detail by Entity Name (sunbiz.org) + +IMDS did not have 37 billion or more shares authorized under its articles of Incorporation + +In 2012, IMDS increased authorized to 10 billion from 4 billion shares + +ConvertTiffToPDF (sunbiz.org) + +in 2013, IMDS increased authorized shares from 10 billion to 20 billion + +ConvertTiffToPDF (sunbiz.org) + +Per my e mail below, + +IMDS didn't increase share authorization to the 40 billion required to account for the 37 billion share Viable + +"owned" until 2018. Yet the 13D and the SPA were done in 2014. + +The 37 billion shares were not authorized in 2014. + +The crux of illegal naked shorting. + +My information. This is EXACTLY what Congress intended when it enacted the Whistleblower statutes of Dodd Frank. Egregious illegal activity brought to the attention of the SEC by a whistleblower: ME. My information should have resulted in a very big award. Rather, Levenson/the SEC screwed me by covering up this massive fraud on the investing public. What has been the result of this criminal and corrupt scheme? The SEC OWB has denied my rightful award applications TWICE since. AND, the SEC gave these same criminals and others their own exchange in 2020: MEMX despite my pleading with the SEC not to allow it. The result: in 1Q2021 OTCM share volumes in hundreds of money laundering shells like IMDS hit 4+ TRILLION. Absolutely STAGGERING. + +The SEC is a grossly corrupt, criminal organization ACTIVELY facilitating multiple, ongoing, MASSIVE frauds on the public it is mandated to protect to the benefit of criminals who own them while screwing the whistleblower + +who caught them: ME. + +Mr Levenson/the SEC Boston has jurisdiction over AQR: Greenwich. + +Mr Peavler et al in Ft Worth brought a complaint against the massive fraud Nikola/Trevor Milton just last week + +for False and misleading statements. NKLA SPAC sponsors: VectolQ: AQR and Steve Girsky: Brookfield. + +ANOTHER fraud on the SDNY Courts + +Cheers! Chris + +From: Chris Dilorio + +Sent: Saturday, July 31, 2021 1:02 PM + +Subject: Fw: Formal appeal for covered action 2015-016/ Knight Capital TCR & Appendix + +SONY, NY Supreme Court, NJ Judges, NY AG/DFS et al, The interconnectedness of my claims on display AGAIN. + +I don't "hop" from 1 TCR to another by accident. Levenson: IMDS. Levenson:AQR + +Obstruction in both cases. + +So, + +Back to my Knight Capital/UBS et al TCR. + +IMDS: NITE/UBSS trading activity. Fraud SEC denials of awards. 2014: 2 years after the so called August 1 2012 "trading glitch" + +The IMDS "glitch". The naked short trading activity in IMDS by NITE and UBSS was massive. See my Knight/UBS + +TCR + +I caught them. + +Here's still MORE irrefutable proof of the veracity of my claims: + +SEC allowed 2 barred individuals: Schwartz/Linda Grable to execute the SPA with the Chinese National entity Viable which created 37 billion shares at .0001. Viable agreed to purchase these 37 billion shares knowing full well the SEC/Levenson were in the process of revoking the IMDS registration. Of course! Who wouldn't jump at + +the opportunity to own 37 billion shares of a revoked company? Grable II in SWORN affidavit says he alone executed the Viable SPA. LIE. The exhibit linked AGAIN below by me shows BARRED Schwartz/Linda Grable as + +representatives of IMDS along with Grable II. + +Again: the August 19 2014 Viable 13D showing ownership of the 37 billion shares + +EDGAR Filing Documents for 0001213900-14-006130 (sec.gov) + +EDGAR Filing Documents for 0001213900-14-006130 + +Viable International Investments, LLC (Filed by) CIK: 0001617230 (see all company filings) IRS No.: + +464891086 I State of Incorp.:FL I Fiscal Year End: 1231 Type: SC 13DSC 13D + +www sec g ov + +that was 2014: TWO THOUSAND FOURTEEN + +Just 1 problem: + +The IMDS articles of incorporation with the Florida SOS show the authorized increased in shares from 30 billion + +to 40 billion common and 2 million pref took place in June 2018 + +June 29, 2018 to be exact ConvertTiffToPDF (sunbiz.org) + +Here's the Grable II amended corp details with The Florida SOS filed in conjunction with the Viable SPA + +ConvertTiffToPDF (sunbiz.org) + +600 shares of Series M + +conversion rate: 147,282,723.12 shares of common per 1 share of Series M + +Do the math: IMDS did not have these common shares authorized when the Viable SPA was executed. + +the 37 billion shares of common were not authorized. + +According to Florida SOS articled of incorporation On June 28,2018: TWO THOUSAND EIGHTEEN Authorized + +shares were increased from 30 billion to 40 billion common and 2 million pref + +ConvertTiffToPDF (sunbiz.org) + +Then came the SEC reviewed Dec 31 2018 10O filed by IMDS + +https://www.sec.gov/Archivegedgar/data/790652/000121390019002531/f10q1218 imagingdiagnos.htm + +Filed on February 14,2019 + +EDGAR Filing Documents for 0001213900-19-002531 (sec.gov) + +EDGAR Filing Documents for 0001213900-19-002531 + +IMAGING DIAGNOSTIC SYSTEMS INC /FL/ (Filer) CIK: 0000790652 (see all company filings) IRS No.: + +222671269 I State of Incorp.:FL I Fiscal Year End: 0630 Type: 10-Q I Act: 34 I File No.: 000-26028 I Film No.: + +19605508 SIC: 3845 Electromedical & Electrotherapeutic Apparatus Office of Life Sciences + +written request to effect a 1:1000 reverse stock split in the form of a written consent of the majority + +shareholder of Imaging Diagnostics Systems Inc. The BoD of the corporation believed it to be in the best interest + +of the corporation and recommended that the stockholders approve a 1:1000 reverse stock split of the corporations issued and outstanding shares of common stock and a decrease in the amount of shares of common stock authorized to be issued from 40,000,000,000 shares to 500,000,000 shares" full stop. Please + +help me with this math as I'm not a corrupt SEC attorney. + +further: + +" After receiving stockholder approval by majority written consent the company filed amended and restated Articles of Incorporation with the Florida SoS on July 12 2018 to record this action. The reverse split became + +effective July 27, 2018" + +Here is the Florida SoS amended articles showing the decrease in Auth Shares to 500,000,000 common and 2 + +million pref + +ConvertTiffToPDF (sunbiz.org) + +NEVER was authorized increased to 50 Billion as the reverse math would suggest + +Further, + +IMDS filed amended Articles in 2017 increasing the authorized share count from 20,000,000,00 to + +30,000,000,000 common and 2 mil pref + +ConvertTiffToPDF (sunbiz.org) + +Meaning: IMDS did not have the 37 billion shares authorized to sell to Viable in 2014. + +What was going on here? + +June 29, 2018: increase authorized from 30 billion to 40 billion + +2 weeks later: July 12, 2018: 1:1000 reverse split from 40 billion to 500 million (math???) + +But here's the kicker/smoking gun: + +Amended 13D filed by Viable on May 3 2019 + +EDGAR Filing Documents for 0001213900-19-003579 (sec.gov) + +showing Viable owning 87,104,691 shares of common + +If you do the math based on the Series M conversion and adjust for 1:1000 that gets you to the 87+ million + +shares. + +AGAIN: The Viable SPA with barred Schwartz, Linda Grable and Grable II + +f8k062714ex10i imagingdiag.htm (sec.gov) + +f8k062714ex10i\_imagingdiag.htm - SEC + +WHEREAS, subject to the terms and conditions set forth in this Agreement and pursuant to Section 4(2) of the Securities Act of 1933, as amended (the "Securities Act"), and Rule 506 promulgated thereunder, the Company desires to issue and sell to Purchaser, and Purchaser desires to purchase from the Company, + +securities of the Company as more fully described in this Agreement. + +www.sec.gov + +The SPA was in the form of the Series M pref with conversion schedule above AGAIN: that would translate post reverse to the 13Da: 87,104,691 shares + +The crux of illegal naked shorting: shares created but not authorized by the issuer and its shareholders. This was the case in IMDS: my Knight/UBS TCR. To the tune of 37 BILLION shares. Covered up by the SEC/Levenson et al rather than prosecuting NITE for this illegal activity and paying me a rightful award for bringing these egregious Securities law violations to the SEC attention: EXACTLY what the SEC Whistleblower statues were intended by + +Congress to do. + +Rather, the SEC/Levenson et al chose to criminally and corruptly cover up and screw the whistleblower who caught them: ME. THEN, the grossly corrupt SEC followed up with TWO official, corrupt: ILLEGAL award denials. IMDS is just 1 of NITE/UBS top traded OTCM money laundering shells. The level of this illegal activity in 10 2021 + +through MEMX by these KNOWN criminals is the direct result of this and other SEC corrupt criminal + +obstruction. + +Mr Levenson, what is the current itteration of Imaging Diagnostics trading symbol TODAY? + +There is none. ALL of this share increase/decrease post being revoked by the SEC has taken place in a NON + +trading BUT FULLY reporting SEC company. + +The latest SEC reviewed filing came in May 2021. + +EDGAR Search Results (sec.gov) + +In furtherance of the conspiracy + +Cheers! + +Christopher.' Dilorio + +Whistleblower Extraordinaire + +From: Chris Dilorio + +Sent: Friday, July 23, 2021 6:45 AM + +Subject: Fw: Formal appeal for covered action 2015-016/ Knight Capital TCR & Appendix + +SONY, NY Supreme Court, NJ Judges et al + +still MORE examples of SEC criminal obstruction and corruption. Carefully designed "complaints" that tell only part of the story INTENTIONALLY guaranteeing the illegal activity continues. Also designed to cover up SEC + +corruption while screwing the whistleblower who caught them: ME. + +Recall: the above referenced Oppenheimer AML preliminary Denial of award by Norberg et al: "SEC Staff never saw Mr Dilorio's information" only AFTER using my information for 5 (FIVE) years. Not just impossible but + +criminal as well. + +More + +Dick Best, Ms Mehtaban: SEC New York bullshit Cemtrex/Govil et al complaint ripped to shreds by yours truly: \$7 million in "mis appropriated funds yet just \$670k disgorgement: Money laundering acknowledged. Of + +course: no mention of money laundering in the complaint. + +No mention of the Cemtrex PUBLIC announcement with SEC filings unsolicited "take over" of contract + +manufacturer Key Tronic in September 2017. AND, Key Tronic public announcement with SEC filings response. + +Where Key Tronic details Cemtrex as an out right fraud. + +Related party transactions with NY based Vicon Industries: buying a position already sold in another SEC + +reviewed offering. ALSO Money laundering + +Prolific Bag Man Fife and Bag Man Ayrton: MY INFORMATION "investing" in Cemtrex in 2019: They BOTH knew Cemtrex was a money laundering shell. As did the other sophisticated "investors" like Cerberus and several + +others I detailed below: money laundering + +SEC + +Cemtrex Announces Pricing of Public Offering of Common Stock . Farmingdale, NY (August 22, 2018) — Cemtrex, Inc. (NASDAQ: CETX, CETXP, CETXW), a leading technology and manufacturing company, + +announced today the pricing of its previously announced underwritten public offering of 1,000,000 shares of common stock at a public offering price of \$1.65 per share for total gross proceeds of \$1,650,000. + +; -;.sec goy + +This offering was the result of a shelf Cemtrex filed and the SEC approved on June 5 2017 + +EDGAR Filing Documents for 0001493152-17-006182 (sec.gov) + +This shelf like hundreds others I have detailed should have been pulled by the SEC given the Key Tronic public response to Cemtrex in September 2017. IF the SEC was actually interested in protecting the public as it is + +mandated to do. + +NOPE + +WHO underwrote the August 2018 Cemtrex public offering? + +Aegis + +SEC.gov I Broker-Dealer Admits It Failed to File SARs + +SEC.gov I Broker-Dealer Admits It Failed to File SARs + +Broker-Dealer Admits It Failed to File SARs. FOR IMMEDIATE RELEASE 2018-50 Washington D.C., March 28, + +2018 — + +i VA'AV.SeCgOV + +In march 2018, Aegis ADMITTED to facilitating money laundering in publicly traded shells. + +5 months later, they do an offering in Cemtrex. 1 year later, Fife, Ayrton, Cerberus et al do more "investing" in Cemtrex. How many AML red flags were ignored by Fife et al when they "invested" in Cemtrex? How many AML + +red flags did Best,Mehraban et al intentionally omit from their Cemtrex/Govil "complaint"? + +WHO executed the Aegis and other trades in Cemtrex,Vicon etc ? + +From the carefully constructed Best,Mehrban, SEC NY complaint the track record clearly points to Mehraban + +Paul Weiss mentor Dougie Large and Knight/KCG/VIRT: NITE. + +and NOT the "penny stock trading fairies". A page out of the BBH AML complaint as well as the UBS and Opco corrupt SEC playbook. Because as my irrefutable evidence: the record clearly shows: the core business at + +Knight/KCG/VIRT:NITE is and always has been: illegal naked shorting OTCM (and other) publicly traded shells to + +facilitate money laundering and tax evasion. + +As I have also detailed at great length in my correspondence with the SEC: NITE can NOT rely on third parties like Aegis as a substitution for its own compliance due diligence. What does NITE compliance do exactly except look the other way, also ignore glaring red flags, and NOT file ANY SAR's. SEC NY/Best/Mehrban have been corruptly obstructing investigations into my claims for years. These massive ongoing frauds are a direct result. The corrupt and criminal denials of my award claims with the OWB also play a key role in the SEC ACTIVELY + +The attached stated SEC procedures for handling whistleblower submissions. + +The stated testimony to Congress that the OWB is the primary point of contact between whistleblowers and the + +Commission. + +My extensive correspondence: THE RECORD. + +SEC IG Hoecker, I am STILL eagerly waiting for your office to interview me based on stated procedures you + +yourself wrote in conducting thorough investigations. The evidence is irrefutable: + +The SEC is a grossly corrupt, criminal organization ACTIVELY facilitating multiple, massive, ongoing frauds on the public it is mandated to protect to the benefit of the criminals who own them while screwing the whistleblower + +who caught them: ME. + +It has been 1 1/2 years since I filed an appeal for the Oppenheimer award denial. While I was waiting, + +Norberg/Pasquinelli et al issued a fraud denial for the FINRA/SEC/FINCEN UBS AML complaint. As I have shown, MANY within the SEC had my information. Including SEC NY. Which is why the SEC corruptly moved the handling of the complaint to the SEC LA. While never bringing ANY individual complaints against UBS San Diego brokers. + +The UBS trading activity: My information + +UBS acknowledged in the complaint by the SEC,FINRA,FINCEN as never shutting down its cross border business + +per the 2010 DoJ dropping its DPA: also my information. + +Not just impossible that "SEC staff never saw Mr Dilorio's information" + +But CRIMINAL as well. + +Cheers! + +Christopher J Dilorio + +Whistleblower Extraordinaire + +From: Chris Dilorio e > + +Sent: Tuesday, July 20, 2021 8:36 AM + +UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 . FORM 10-K (Mark One) [X] ANNUAL REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF + +sec CO': + +Cemtrex: Brooklyn based Electronics Manufacturing Services (EMS) entity + +EDGAR Search Results (sec.gov) + +Did Dick Best et al SEC NY ever actually visit Cemtrex: EMS: HQ where all that contract manufacturing takes + +place? + +Bond Collective I Greenpoint + +Bond Collective I Greenpoint + +276 Greenpoint Ave Brooklyn, NY 11222. Spanning a floor- + +through of the Leviton factory building, our Greenpoint location is spacious, sun-filled and conveniently situated one block from + +the G train and NYC Ferry. + +www.bondcollective.com + +conspicuously absent from the Dick Best, Mehraban et al SEC NY complaint as usual: Money laundering + +In September 2017, Govil/Cemtrex announced an "acquisition" of Key Tronics. Key Tronics actually IS in the EMS + +space + +SEC reviewed filings and everything + +https://www.sec.gov/Archives/edgar/data/1435064/000149315217012469/ex99-5.htm + +EDGAR Filing Documents for 0001493152-17-012469 (sec.gov) + +https://www.sec.gov/Archives/edgar/data/1435064/000149315217012469/forms4a.htm#a 014 + +What followed is absolutely astounding. Even for the grossly corrupt SEC: + +here is the Key Tronic official response to the Cemtrex/Govil "acquisition" announcement + +Keytronic Comments On Cemtrex Release — Keytronic Contract Manufacturer + +Keytronic Comments On Cemtrex Release — Keytronic Contract + +Manufacturer + +KEY TRONIC CORPORATION COMMENTS ON CEMTREX RELEASE Spokane Valley, WA — September 15, + +manufacturing services, became aware of a press release issued by Cemtrex, Inc. ("Issuer") on September 13, 2017 regarding its purported exchange offer for the outstanding shares of common stock of Key [...] + +There is a LOT the SEC had in its possession with this release. But, I would highlight the following point: "Key Tronic has never encountered Issuer (Cemtrex) in the Electronic Manufacturing Services (EMS) market space nor was Key Tronic aware of Issuer (Cemtrex) existence before Issuer (Cemtrex) filed a registration + +statement (with the SEC) regarding this purported offer" + +That was September 15, 2017. WHY isn't this little tidbit in the Dick Best/SEC NY complaint? + +OH, but there is MUCH MUCH MORE. + +Key Tronic is very much up and running as an independent company today: + +EDGAR Search Results (sec.gov) + +Then there's this: + +"Cemtrex acquires 46% of Vicon Industries" + +Vicon: Hauppauge NY + +EDGAR Search Results (sec.gov) + +This "acquisition" took place on/around March/April 2018 EDGAR Filing Documents for 0001493152-18-004566 (sec.gov) + +In January 2018 the SEC approved an offering of 9 million shares owned by an entity called NIL Funding Corp + +(too funny) in Vicon Industries + +Document (sec.gov) + +NIL is an affiliate of InterTech Group and controlled by Vicon Chairman Julian Tiederman + +InterTech Group + +EDGAR Search Results (sec.gov) + +NIL Funding/ Vicon Chairman Tiedemann supposedly loaned \$5 million+ to Vicon Industries: related party transaction: which of course was converted to worthless certs and dumped on the public in an SEC approved + +offering. + +So, HOW did Cemtrex "acquire" %46 of Vicon Industries? + +by purchasing the NIL Vicon position AFTER it was sold to the public from NIL of course + +https://www.sec.gov/Archives/edgar/data/310056/000149315218004566/ex99-1.htm + +Let's pause there to make sure EVERYONE knows what took place here: + +Fraud related party notes converted and sold to the public in Vicon:NlL Funding: January 2018 + +Cemtrex claims %46 ownership in Vicon in March/April 2018 after purchasing the SAME NIL Funding position + +sold in the January 2018 SEC approved Vicon offering + +Then, + +Cemtrex selling the same NIL Funding position in Vicon in April 2018 + +https://www.sec.gov/Archives/edgar/data/1435064/000149315218005560/forms-3.htm#a 006 + +ANOTHER sham transaction: + +aa) The entire technical and commercial know-how attributable to the Seller's business operations, all technical and commercial business and business secrets, procedures, products, product solutions and developments, the respective rights thereto and all embodiments of these rights, other technical documentation and certifications - as well as all rights to inventions (collectively referred ... + +www.sec.gov + +Vicon Industries: a money laundering shell like Cemtrex voluntarily de registered with the SEC in 2019 + +https://www.sec.gov/Archives/edgar/data/310056/000149315219000779/ex99-1.htm + +SEC.gov I HOME + +EXHIBIT 99.1 . Vicon Industries, Inc. Announces Plans to Deregister Common Stock with SEC . Hauppauge, New York, January 15, 2019 — Vicon Industries, Inc. (the "Company"), a publicly-traded producer of video + +management systems and components (OTCQB: VCON) headquartered in Hauppauge, New York, announced today that it intends to file with the Securities and Exchange Commission ("SEC ... + +www.sec.gov + +The SEC KNOWS Cemtrex to be a money laundering shell for years also. The Key Tronic letter SHOULD have + +shut down Cemtrex/Govil in 2017 + +WHY didn't it? + +Look who "invested" in Cemtrex in June 2019: Iliad: Fife: MY TCR. MY INFORMATION AGAIN + +EDGAR Filing Documents for 0001567619-19-013717 (sec.gov) + +Fife not the only Bag Men in Cemtrex + +also: CVI/Susquehana + +EDGAR Filing Documents for 0001104659-21-023193 (sec.gov) + +EDGAR Filing Documents for 0001104659-21-023193 + +CVI Investments, Inc. (Filed by) CIK: 0001649553 (see all company filings) IRS No.: 981253664 i State of + +Incorp.:E9 I Fiscal Year End: 1231 Type: SC 13G/ASC 13G/A + +sec cloy + +and Ayrton + +EDGAR Filing Documents for 0001493152-21-003859 (sec.gov) + +www sec g ov + +BOTH + +CVI/Susquehana + +in AQR/Trump/1MDB/Astra/Navios/ORIG/DRYS/Ari Glass etc money laundering shell Phunware + +EDGAR Filing Documents for 0001104659-21-027253 (sec.gov) + +EDGAR Filing Documents for 0001104659-21-027253 + +CVI Investments, Inc. (Filed by) CIK: 0001649553 (see all company filings) IRS No.: 981253664 I State of + +Incorp.:E9 I Fiscal Year End: 1231 Type: SC 13G + +vo..,rw sec goy + +EDGAR Filing Documents for 0001493152-21-004485 (sec.gov) + +EDGAR Filing Documents for 0001493152-21-004485 + +Phunware, Inc. (Subject) CIK: 0001665300 (see all company filings) IRS No.: 000000000 I State of Incorp.:DE + +Fiscal Year End: 1231 Type: SC 13G I Act: 34 I File No ... + +v(ww.sec goy + +as well as many other money laundering shells. + +To sum up: the SEC NY: Best/Mehraban et al Govil/Telidyne/Cemtrex complaint omits more than it SUBMITS. Intentionally. No mention of money laundering: also intentionally. The scope of the "investigation": also INTENTIONALLY limited. This was yet another attempt to cover up a massive SEC failure made possible by + +criminal obstruction and corruption related to my claims. + +Like ALL other money laundering shells: Fife, Ayrton etc etc know EXACTLY what these shells are: money + +laundering vehicles. The executing BD/MM's like NITE,CDEL etc know also. + +MORE irrefutable evidence that the SEC ACTIVELY facilitates massive, ongoing, multiple frauds on the public it is mandated to protect to the benefit of the criminals who own them at the expense of the public it is mandated + +to protect while screwing the whistleblower who caught them: ME. + +BTW Dick Best and Ms Mehraban et al: "Govil misappropriated more than \$7 million" + +yet, disgorgement of \$670O72227 + +AGAIN: money laundering explained and acknowledged. + +More fraud on the SDNY courts. Quickly settled by SEC in cover up. + +Cheers! + +Christopher Dilorio + +Whistleblower Extraordinaire + +From: Chris Dilorio + +Sent: Sunday July 18, 2021 10:24 AM + +ci• • PP / isnignc t.ap PP + +SONY Judges et al, + +I made a few corrections to typos below. I also linked the actual 2017 10K. Prior I linked the 2017 10Ka. My + +apologies. + +As previously stated below: FTE "acquired" US Home Rentals: Alex and Antoni Szkaradek: Vision etc etc in December 2019. The corresponding revenue associated with this "acquisition" must be significant. But, how would the investing public conduct their due diligence when FTE hasn't filed a 2020 SEC reviewed/audited 10K? + +AND + +FTE hasn't filed a 100 with the SEC since 3Q2018? + +SEC cover up coming as is standard MO: revoke the FTE/Benchmark/US Home Rental registration AGAIN. + +How is it even remotely plausible there wouldn't be ANY mention of money laundering in ANY of these actions? + +Indicate by check mark whether the registrant is an emerging growth company as defined in Rule 405 of the Securities Act of 1933 (§230.405 of this chapter) or Rule 12b-2 of the Securities Exchange Act of 1934 + +(§240.12b-2 of this chapter). + +www.sec.gov + +from 2018 into 2019 massive money laundering + +Start with Auctus + +https://www.sec.gov/Archives/edgar/data/1122063/000149315219003102/ex10-6.htm + +SBI Investments + +https://www.sec.gov/Archives/edgar/data/1122063/000149315219003102/ex10-4.htm + +Momingview Financial + +https://www.sec.gov/Archives/edgar/data/1122063/000149315219003102/ex10-7.htm + +One44 Capital + +https://www.sec.gov/Archives/edgar/data/1122063/000149315219003102/ex10-8.htm + +CrossOver Capital + +https://www.sec.gov/Archives/edgar/data/1122063/000149315219003102/ex10-9.htm + +Crown Bridge Capital + +https://www.sec.gov/Archives/edgar/data/1122063/000149315219003102/ex10-10.htm + +www.sec.gov + +SECURITIES PURCHASE AGREEMENT . This SECURITIES PURCHASE AGREEMENT (the "Agreement"), dated as + +of October 25, 2018, by and between FTE NETWORKS, INC., a Nevada corporation, with headquarters located at 999 Vanderbilt Beach Rd., Suite 601, Naples, FL 34108 (the "Company"), and CROWN BRIDGE PARTNERS, LLC, a New York limited liability company, with its address at 1173a 2nd Avenue, Suite ... + +www.sec.gov + +Eagle Equities + +https://www.sec.gov/Archives/edgar/data/1122063/000149315219003102/ex10-11.htm + +Qarum Holdings + +https://www.sec.gov/Archives/edgar/data/1122063/000149315219003102/ex10-14.htm + +JEM Debt Fund + +https://www.sec.gov/Archives/edgar/data/1122063/000149315219003102/ex10-18.htm + +Labrys Fund + +Adar: prolific Bag men + +EDGAR Search Results (sec.gov) + +LG Capital Funding "L": Joseph Lerman "G": Nochum Greenberg + +detailed extensively by me in related correspondence with the SEC/IRS/DoJ et al + +Also prolific Bag Men + +https://www.sec.gov/Archives/edgar/data/1122063/000149315219003102/ex4-20.htm + +EDGAR Search Results (sec.gov) LG overlap with NITE top traded shells + +Also: + +Baruch Greenberg (Nochum father) and Benny Silberstein: "payment processor" Payrix + +SAME address as LG: VERY symbiotic relationship + +Brooklyn NY 11225 SEC FORM D + +SEC FORM D + +In submitting this notice, each issuer named above is: Notifying the SEC and/or each State in which this notice is filed of the offering of securities described and undertaking to furnish them, upon written request, + +in the accordance with applicable law, the information furnished to offerees.\* + +www.sec gov + +AND: Cited in my claims and why IRS CI Agents flew to Denver from Chicago to meet with me in April 2016: My IRS TCR was based on the SEC TCR also filed with Berger Montague: John Fife: St George Investments, + +Typanex,Iliad, Tonaquint + +https://www.sec.gov/Archives/edgar/data/1122063/000149315219003102/ex4-1.htm + +EDGAR Search Results (sec.gov) + +EDGAR Search Results (sec.gov) + +EDGAR Search Results (sec.gov) + +EDGAR Search Results (sec.gov) + +EDGAR Search Results (sec.gov) + +The St George/Fife FTE Note was dated March 2018. FIVE F'N YEARS AFTER SUBMITTING MY SEC TCR + +John M. Fife, Chicago Venture Partners, L.P., Iliad Research and Trading, St. George Investments LLC, Tonaquint, Inc., and Typenex Co-Investment, LLC (Release No. LR-24886;3sp. 3, 2020) fsec.ggi) + +John M. Fife, Chicago Venture Partners, L.P., Iliad Research and Trading, St. + +George Investments LLC, Tonaquint, Inc., and Typenex Co-Investment, LLC + +(Release No. LR-24886; Sep. 3, 2020) - SEC.gov + +The Securities and Exchange Commission today filed charges against John M. Fife of Chicago and companies he controls for acquiring and selling more than 21 billion shares of penny stock without + +registering as a securities dealer with the SEC. + +www.sec.gov + +The Corrupt SEC OWB has yet to post this action to its website for award eligibility. WHY? + +Because it's MY INFORMATION + +Fife/FTE never should have happened + +Also laundering in FTE etc: + +Cerberus + +https://www.sec.gov/Archives/edgar/data/1122063/000149315219003102/ex10-15.htm + +Cerberus: Feinberg: Gruntal with SAC,Sater etc: Milken + +Cerberus: post NITE "glitch" bid with Virtu for OTCM Money laundering shell trader NITE. Virtu eventually + +did aquire NITE in SEC facilitated fraud transaction July 2017. + +Lastly: In the NYAG/NYDFS complaint against Vision in the SDNY: Atalaya + +Atalaya ALSO prolific money laundering Bag Men as well + +EDGAR Search Results (sec.ggs) + +So again: + +"SEC charges Executives of Network Infrastructure Company with accounting fraud" + +AND + +"Former CEO and CFO of Public Telecommunications Company charged in Manhaattan Federal Court with + +scheme to defraud investors" + +Doesn't even come close to describing the money laundering shell FTE. + +Which is why there is no mention of money laundering in ANY of these complaints. Guaranteeing it will + +continue. + +Cheers! + +Christopher J Dilorio + +Whistleblower Extraordinaire + +From: Chris Dilorio + +Sent: Saturday, July 17, 2021 1:12 PM + +Subject: Fw: Formal appeal for covered action 2015-016/ Knight Capital TCR & Appendix + +ABSOLUTELY ASTONNISHING! + +STIPULATED ORDER AND FINAL JUDGMENT: Defendants shall not engage in acts practices or conduct that + +violates the following laws and regulations: the Consumer Financial Protection Act 12 U.S.C. § 1601 et seq• New York Executive Law § 63(12)• New York General Business Law ("GBL") § 349; New York Banking Law Article 12-D• New York Banking Law §§ 6-1 and 6-m; 3 CRR-NY §§ 41.3(a) and 41.4(a); 3 CRR-NY § 420.18• New York Financial Services Law § 4 08; Truth in LendingAct, 15 U.S.C. § 1601 et seq and Regulation Z, 12 C.F.R. § 1026 et seq; and New York Real Property Law § 235-b. Defendants are permanently restrained and enjoined from engaging in the following activities in New Yo rk: a. Purchasing, selling, managing or leasing any Residential Real Property except as expressly provided for in this Final Judgment or for their own personal use and enjoyment, and as further set forth in this judgment. By reason of the violations of law alleged in the Complaint, judgment for restitution in the amount of \$600 000 is hereby entered in favor of the Plaintiffs against Defendants. The NYAG will pay each Consumer who entered into a Residential Property Agreement with Defendant son or after December 12, 2011, who did not receive any compensation under the settlement obtained by the Plaintiffs from Atalaya Capital Management (Assurance No. 19-104 attached as Exhibit A to this Consent Judgment) and who will not receive rest itution pursuant to paragraphs 26-27 below the amount of \$22,641.50 each from the Vision Escrow Account. Plaintiffs represent that to the best of their knowledge, based in part on the information provided by Defendants, these Consumers are those listed in Confidential Appendix I. To the extent multiple Consumers listed in Appendix I jointly signed a Residential Property Agreement, the \$22 641.50 shall be divided equally between or among them, jointly and severally. By reason of the vio lations of law alleged in the Complaint, judgment for non-monetary restitution in the amount of \$3,161,805 is hereby entered in favor of the Plaintiffs against Defendants jointly and severally, and as further set forth in this judgment. Plainti ffs hereby release Defendants from all civil claims and causes of action brought by Plaintiffs arising from the subject matter of the Complaint, including any civil claims or causes of action that could be raised by Plaintiffs related to any Resident + +ial Property Agreement. For purposes of Federal Rule 54(b) this Final Judgment is as to all parties and all claims in this Action. This Final Judgment becomes effective upon entry by the Court. The Court will retain jurisdiction of this matter solely for the purpose of enforcing this Order and Final Judgment. (Signed by Judge Jed S. Rakoff + +on 1/10/2020) (jwh) (justia.com) + +Does Judge Rakoff know about the massive fraud the SEC and SDNY DoJ are CURRENTLY perpetrating on the + +SONY and NY AG/DFS? + +I will re post the FTE 2019 SEC reviewed 10K + +https://www.sec.gov/Archives/edgar/data/1122063/000149315220020612/form10-k.htm + +It really is that astonnishing! + +pg 9 and following + +The pre meditated fraud transition from "telecom infrastructure" to "commercial rennovation" to "Single family + +home rentals" explained + +FTE acquires US Home Rentals: Vision Property Management for total consideration of \$350 million: that's \$350,000,000 from Alex and Antoni Szkaradek for common stock, promissory notes, and Series I pref in + +December 2019. + +Further, an entity called Inmost Partners LLc run by Tiger Cub Eliot Kang Eliot Kang - CEO/Managing Partner - Inmost Partners LLC I Linkedln + +Eliot Kang - CEO/Managing Partner - Inmost Partners LLC I LinkedIn + +Eliot Kang Founder & CEO at Inmost Partners LLC New York, New York, United States 500+ connections + +www.linkedin.com + +"acquired" through various assignments more than \$50 mil in prior issued notes: pass the notes around + +Per my analysis below: + +the last 100 filed by FTE was 3Q2018 + +EDGAR Search Results (sec.gov) + +AND + +FTE has yet to file a 10K for 2020 HOW IS THIS REMOTELY PLAUSIBLE? + +Bustilloe, Hodgman/Strzok,Gibson, Mrs Rusty Wing et al brought these frauds to the SDNY KNOWINGLY + +These "comlaints" don't accurately portray what the true nature of FTE really is. Not even close. + +The SEC KNEW FTE was a money laundering shell when it revoked: kinda/sorta: the FTE registration. ALL + +involved in FTE AFTE 2014 knew it was a money laundering shell. Then, in a very well orchestrated + +"transformation", FTE was used to launder HUNDREDS OF MILLIONS OF DOLLARS by known to the SDNY Courts, NY AG, and NYDFS felons. The vehicle: fraud note/fraud acquisitions, worthless certs dumped on the public. No doubt the SEC cover up MO will go into action and the SEC will AGAIN revoke the FTE registration. AGAIN: after + +Cheers! Chris + +From: Chris Dilorio + +Sent: Saturday July 17, 2021 8:19 AM + +Subject: Fw: Formal appeal for covered action 2015-016/ Knight Capital TCR & Appendix + +SDNY Judges et al, + +You were played for fools by the SEC. + +Irrefutable. + +OPINION AND ORDER GRANTING MOTIONS TO DISMISS re: 66 MOTION to Dismiss the Amended Complaint and Partial Joinder in Motion by Defendants Fred Sacramone, James Shiah, Jeanne Kingsley, and Stephen Berini to Dismiss the Amended Complain t filed by Brad Mitchell, Christopher Ferguson, Luisa Ingargiola, Patrick O'Hare, 63 MOTION to Dismiss the Amended Complaint filed by Lynn Martin, 99 MOTION to Take Judicial Notice filed by + +Efraim Bare nbaum, IRA, 59 MOTION to Dismiss Amended Complaint filed by James Shiah, Jeanne Kingsley Stephen Berini, Fred Sacramone. After a series of revelations of corporate misconduct by executives at FTE Networks, Inc., Plaintiff Ephraim Barenbaum, IRA, brought this action derivatively to recover on behalf of the company for that wrongdoing. In addition to the responsible actors Barenbaum sued certain members of the FTE Board. However, Barenbaum's Amended Complai nt fails to allege that demand on the now-existing FTE Board of Directors would have been futile, as he must, to have standing to bring a derivative case. As a result, the Amended Complaint is dismissed with prejudice. Alternatively, all claims against Defendants Sacramone, Shiah, Ferguson, Ingargiola, Mitchell, O'Hare, Martin, Kingsley, and Berini are dismissed pursuant to Federal Rule of Civil Procedure 12(b)(6) for failure to state a claim. The Court also grants Pla intiffs motion for judicial notice as set forth herein. In summary, the Court grants the motions to dismiss at ECF #59, 63, and 66 with prejudice and grants the motion for judicial notice at ECF #99. The Clerk of Court respectfully is requested to close the case. (Signed by Judge Mary Kay Vyskocil on 9/30/2020) (mro) Transmission to Orders and Judgments + +Clerk for processing. (justia.com) + +It ALL continues under new "management". Fraud notes with new management will lead to further dilution and + +4.4 Enforceability.The Note is a valid, legal and binding obligation of Borrower, enforceable against Borrower in accordance with its terms except as enforceability may be limited by applicable bankruptcy, insolvency, reorganization, moratorium or similar laws affecting the enforcement of creditors' rights + +generally and by general equitable principles (whether enforcement is sought by ... + +www.sec.gov + +pg 52 of the 2019 SEC reviewed 10K below + +Cobblestone Ventures LLc is controlled by current CEO Michael Beys + +ANOTHER fraud note from convicted NY Felon + +Alexander Szkaradek + +also pg 52 of the SEC reviewed 2019 10K + +New York Sues S.C.-Based Lender Over Predatory Practices (nationalmortgageprofessional.com) + +New York Sues S.C.-Based Lender Over + +Predatory Practices + +New York Attorney General Letitia James and New York + +Superintendent of Financial Services Linda A. Lacewell have filed a lawsuit in federal court against Columbia, S.C.-headquartered Vision Property Management LLC, its CEO Alex Szkaradek and + +affiliated companies for allegedly running an illegal and + +nationalmortgageprofessional.com + +Then, there's Lateral + +More to follow + +Cheers! Chris + +From: Chris Dilorio + +Sent: Friday, July 16, 2021 3:37 PM + +Subject: Fw: Formal appeal for covered action 2015-016/ Knight Capital TCR & Appendix + +SONY, NY Supreme Court, NJ Judges et al. + +It truly takes a corrupt village. Mr Bustilloe/Miami SEC + +"SEC charges Executives of Network Infrastructure company with Accounting Fraud" + +SEC.gov i SEC Charges Executives of Network Infrastructure Company With Accounting Fraud + +SEC.gov I SEC Charges Executives of Network Infrastructure Company With + +Accounting Fraud + +The Securities and Exchange Commission today charged the former CEO and CFO of FTE Networks Inc., a network infrastructure company formerly based in Naples, Florida, with conducting a multi-year accounting + +Mrs John "Rusty" Wing aka piled on to bring yet ANOHER fraud to the SDNY Courts + +Former CEO And CFO Of Public Telecommunications Company Charged In Manhattan Federal Court With + +Scheme To Defraud Investors I USAO-SDNY I Department of Justice + +"Former CEO and CFO of Public Telecommunications Company Charged in Manhattan Federal Court with + +scheme to defraud investors" + +let's take a deeper dive into the money laundering shell FTE Networks + +fka Beacon Enterprise Solutions, Galaxy Specialities Inc, Suncrest Global Energy + +EDGAR Search Results (sec.gov) + +The FTE/Beacon 2016 SEC reviewed 10K + +https://www.sec.gov/Archives/edgar/data/1122063/000149315217005044/form10-k.htm + +2015 Revenue 14,388,682 2016 Revenue 12,269,079 + +BUT + +largest customer "M" was 52% of total revenue at 6,332,966 in 2016 WHILE customer "M" was 66% of Account receivable at 4,624,600 + +Revenue recognition???? + +Businesses included Focus Fiber, Focus Wireless, Jus-Com, and CrossLayer Inc. + +the 2017 10k + +https://www.sec.gov/Archives/edgar/data/1122063/000149315218005377/form10-k.htm + +2017 Revenue \$243,409,000 + +On April 20, 2017 FTE bought Benchmark Construction with "historical revenue in the \$300 mil-\$400 mil range. Benchmark's business model focuses on the buildout of Interior commercial space for a client base that consists + +of the worlds most distinguished companies" + +"we completed the acquisition of Benchmark, a leading provider of construction management services based in + +New York for \$74,245,000." + +Quite the deal for an entity generating \$300-400 million in annual revenue. + +The FTE SEC reviewed 2018 10K 2018 revenue \$384,755,000 + +https://www.sec.gov/Archives/edgar/data/1122063/000149315220008176/form10-k.htm + +The 2019 SEC reviewed 10K + +https://www.sec.gov/Archives/edgar/data/1122063/000149315220020612/form10-k.htm + +2019 revenue 7,518,000 2018 revenue 15,103,000 + +So, Benchmark Construction purchased in April 2017 for \$74 mil with annual revenue of \$300-400 mil contributed to the FTE \$ 243,409,000 mil in revenue in 2017 and \$384,755,000 in 2018 revenue then + +Read my TCR's and correspondence: sham transactions. A vehicle used to create billions of worthless certs. Usually through fraud convertible notes. Often assigned. Converted, dumped on the public by executing BD/MM who profit via illegal naked shorting. EXACTLY what happened here. But, wait there's more! + +F7 + +"Description of Business" + +"FTE Networks Inc (collectively with its subsidiaries, "FTE" or the "company") by and through its wholly owned subsidiary, US Home Rentals LLC is a MAJOR owner and operator of single family rental homes in Tier 3 and Tier + +4 markets with 3200 rental home properties across the US...." + +So, + +"Telecom infrastructure" to "Commercial renovations" to "Major owner and operator of single family rental homes" in just 3 years. WOW!! What a "tranformation". IF the ownership of 3200 rental homes is legit, HOW + +did they finance their purchase??? + +FBI Agent Sweeney, did they stop teaching money laundering at the FBI? + +It's obviously not taught in the SONY OR SEC either. + +Here's a little pointer: + +In 2009, Beacon did an SEC approved D offering for \$1 million through Garden State Securities NJ and affiliates + +SEC FORM D + +Interesting firm ala NETE/Mullen/AQR et al: Alexander Capital + +GSS: Red Bank NJ. Bada Bing + +GARDEN STATE SECURITIES INC. - BrokerCheck (finra.org) + +BrokerCheck - Find a broker, investment or financial advisor + +BrokerCheck is a trusted tool that shows you employment history, certifications, licenses, and any violations + +for brokers and investment advisors. + +brokercheck.finra.org + +According to the GSS/affiliates web page: they sell their orderflow to "wholesalers" like NITE + +GSS/affiliates clear through Axos + +Axos Bought COR Clearing + +Axos Financial Inc. Closes COR Clearing LLC Acquisition (tradersmagazine.com) + +Axos Financial, Inc. Closes COR Clearing LLC Acquisition + +Axos Financial, Inc. (NYSE: AX) (Axos or the Company) announced that its subsidiary, Axos Clearing, LLC, has completed the acquisition of the parent company of COR Clearing LLC (COR Clearing) after receiving all + +required regulatory approvals. + +www.tradersmagazine.com + +COR Clearing LLC (sec.gov) + +UNITED STATES OF AMERICA SECURITIES AND EXCHANGE COMMISSION + +SECURITIES EXCHANGE ACT OF 1934 ORDER INSTITUTING + +ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS, PURSUANT TO + +SECTIONS 15(b) AND 21C 1934, MAKING FINDINGS, AND IMPOSING - + +SEC.gov I HOME + +4 selling the shares and then wiring out the proceeds of the resale."3 COR's AML policies recognized since + +at least early 2013 that the foregoing DSW activity indicated a red flag. + +Remember: the SEC revoked the FTE registration in 2014. + +Kinda/sorta: a shell + +UNITED STATES OF AMERICA (sec.gov) + +the fraud Benchmark acquisition "revenue" used to "uplist" to the NYSE + +you can take the money laundering shell out of the OTCM but you can't take the OTCM out of the money + +laundering shell. Interim CEO of FTE: House rental company TODAY is a former EDNY "prosecutor": Michael Beys + +Agent Sweeney, Mrs Rusty Wing, Mr Bustilloe et al + +\$23 million is just the beginning of this fraud. A KNOWN money laundering fraud kept up and running by the + +SEC for 21 years and counting. AND after being revoked in 2014 kinda/sorta + +Speaking of money laundering shells kept up and running by the SEC: + +AQR CIS,Delta,Urban Tea,Bit Brothers money laundering shell. Filed a \$200 mil shelf in June 2021. Did a \$22.5 + +mil direct offering last night. Stock down 47% today. Must be a WHOPPER of an "investigation". + +Cheers! + +Christopher J Dilorio + +Whistleblower Extraordinaire + +From: Chris Dilorio ‹ > + +Sent: Saturday, July 10, 2021 8:08 AM + +Subject: Fw: Formal appeal for covered action 2015-016/ Knight Capital TCR & Appendix + +Judge Oetken et al, + +No wonder why the SEC settled so quickly with Arena and Bradley: Parallax. + +I left out 1 selling shareholder from the thoroughly reviewed Parallax June 2019 51 + +Lincoln I Pace Arizona Dentist + +Lincoln I Pace DDS - Book Appointment Online, View Reviews, Timings I Dentallnsider.com + +Rated Dentist on Dental Insider + +Each day, thousands of patients rely on our comprehensive + +dentist profiles and reviews to find dental professionals providing + +the highest level of care. + +www.dentalinsider.com + +Judge Oetken, + +I have attached my IRS TCR filed with Berger Montague. The IRS TCR was based on the SEC TCR. It was WHY IRS CI agents Vikas Arora and Nate Sarnacki flew to Denver from Chicago in April 2016 to meet with me. Berger submitted my IRS TCR shortly after submitting my SEC TCR in March 2013. As you can clearly see and as the record of extensive correspondence (including IG Hoecker) clearly shows: the SEC/FINRA/FINCEN UBS AML complaint for which Norberg,Pasquinelli,Knowles,Wardlay issued their fraud denial WHILE I was still waiting for + +my Opco Denial appeal: The Opco trading data ALSO implicates UBS as well as NITE: SEC OWB/IG Hoecker FRAUD: "Enforcement staff never saw Mr Dilorio's information" + +FinCEN Assesses \$14.5 Million Penalty against UBS Financial Services for Anti-Money Laundering Failures + +FinCEN.gov + +FinCEN Assesses \$14.5 Million Penalty against UBS Financial Services for + +Anti-Money Laundering Failures I FinCEN.gov + +WASHINGTON—The Financial Crimes Enforcement Network (FinCEN) today announced an assessment against UBS Financial Services, Inc. (UBSFS) for willful violations of the Bank Secrecy Act (BSA).. FinCEN assessed a \$14.5 million civil money penalty, of which \$5 million will be paid to the U.S. Department of the + +Treasury and the remainder will be concurrent with penalties for similar or related ... + +www.fincen.gov + +The blatant, and egregious disregard by NITE/UBSS at al in trading billions of shares of sham companies with no products, nothing but losses, reverse merger,repeat explained: illegal naked shorting facilitates ALL of it. Very profitable. Virtually riskless. Further, as I ask in my information: WHEN would NITE,UBSS, CDEL etc file a SAR? BEFORE or AFTER trading billions of shares???? There ARE NO SAR's. This also would fall under the jurisdiction of Kevin Goodman. This is the IRS TCR: money laundering/tax evasion related to this illegal naked shorting. In it, + +I discuss the Economic Substance Theory. WHY do sophisticated investors like the ones I have detailed + +extensively bother "investing" in these sham companies?? Take Mr Goodman's et al Parallax "Covid complaint" and the OTHER sham shells I detail below. In fact, take the SEC OWN WORDS in the Parallax complaint: Parallax had no products AND no money in Early 2020 when Arena/Bradly made their bogus claims. What did they have? The same thing I detail in my extensive correspondence: ALL of these money laundering shells have + +worthless certificates. Usually converted from bogus, fictitious promissory notes. Then dumped on the public by + +a WILLING executing BD/MM like NITE,UBSS,CDEL etc. AND, converted into real money. The BD/MM are + +compensated in the form of illegal naked shorting trading profits. This is and always has been the core business + +This is why my claims have been criminally obstructed by the SEC. The SEC has REPEATEDLY bailed out a known criminal enterprise. This is why Goodman produced the bullshit "order handling" complaint almost 6 months + +after I sent him my TCR in July 2015. This is why ALL of the related entities are omitted in his Parallax complaint. The SEC admits also repeatedly admits that shams like Parallax are money laundering shells. WHY? Just ask who + +trades them. + +In Parallax Goodman, the SEC et al acknowledge Parallax as a money laundering shell. Yet no AML complaint. + +NITE top trader? + +To further prove my point: The SEC approved Parallax 51: June 2019 with sellers I detailed below. Yet, in early 2020, the SEC acknowledges Parallax had no money to support their "new product" claims. HOW CAN THIS BE? As with hundreds of money laundering shells/NITE/UBSS et al top traded: These sophisticated investors are NOT + +"investing". They are LAUNDERING. + +And with bullshit "order handling", "front running", stand alone "P&D" (per my TCR: just a tool used to facilitate the laundering/naked shorting), "market access", "Covid disclosures", etc etc complaints, the SEC guarantees + +the activity will continue. + +It does in July 2021. + +Cheers! Chris + +From: Chris Dilorio ‹ > + +Sent: Friday, July 9, 2021 5:50 AM + +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix + +Judge Oetken, + +I am EAGERLY awaiting to see which SDNY Judge is the victim of the latest SEC fraud on the Courts and the + +investing public it is mandated to protect. + +"SEC charges Company and Two Executives for Misleading COVID-19 Disclosures" + +Let that sink in for a minute + +Parallax Health Sciences, Inc., Paul Arena and Nathaniel Bradley (sec.gov) + +UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +S . FACTUAL BACKGROUND 13. At all times relevant to this Complaint Defendant Parallax was a publicly + +traded company with the ticker symbol PRLX and was required to file periodic reports with the + +www.sec gov + +Parallax + +fka Endeavor Power/EndeavorUranium/VB Trade + +a money laundering shell kept up and running for more than a decade + +EDGAR Search Results (sec.gov) + +A June 2019 approved offering is chock full of info. Pre COVID of course + +Form S-1 Registration (sec.gov) + +Selling shareholders include: + +EMA: detailed by me as a prolific Bag Men/women in extensive correspondence with the SEC: the record + +EMA: 40 Wall Street: Trump EDGAR Search Results (sec.gov) + +Ionic Ventures + +EDGAR Search Results (sec.gov) + +Ionic is Keith Coulston. Formerly Ironridge + +SECURITIES EXCHANGE ACT OF 1934 ADMINISTRATIVE PROCEEDING + +ORDER INSTITUTING ADMINISTRATIVE AND CEASE -AND - DESIST + +PROCEEDINGS PURSUANT TO SECTIONS 15(b) AND 21C OF THE + +SECURITIES EXCHANGE ACT OF I. ,URQULGJH\*OREDO3 DUWQHUV //& + +,URQULGJH " II. - SEC.gov + +3 Ironridge Develops a Finance Model Based on the Registration Exemption Contained in Section 3(a)(10) + +of the Securities Act 7. In relevant part, Section 3(a)(10) of the Securities Act provides an + +Ironridge: like Ionic: Prolific Bag Men EDGAR Search Results (sec.gov) + +Ionic also in the AQR money laundering shell CIS/Delta/Urban Tea/Bit Bros + +EDGAR Filing Documents for 0001753926-20-000178 (sec.gov) + +EDGAR Filing Documents for 0001753926-20-000178 + +business address huakun times plaza, room 1118, floor 11 no. 200, erduan, east xiang fu road yuhua + +district, changsha city f4 410014 86 511-8673-3102 + +www.sec gov + +Central to my AQR TCR: Russian spies and Chinese Nationals. Up and running TODAY + +Ironridge was involved in ANOTHER AQR money laundering blank check shell in my TCR: Cereplast + +EDGAR Filing Documents for 0001144204-12-040024 (sec.gov) + +Cereplast has also been kept up and running and has been reincarnated after bankruptcy as ANOTHER Chinese + +money laundering shell + +Ironridge also NITE top traded fraud VelaTel + +EDGAR Filing Documents for 0001144204-15-009142 (sec.gov) + +AND ANOTHER SEC fraud on the SONY: NewLead Holdings for which I filed a separate but related TCR + +EDGAR Filing Documents for 0001144204-14-014312 (sec.gov) + +Other selling shareholders: Harbor Gates Capital LLc + +Michael Sobeck and Christina Avila: Puerto Rico Sobeck is a Prolific Bag Men formerly Tangiers + +Highlighted by me with a few NITE top traded shells like NYXIO + +EDGAR Search Results (sec.gov) + +Stefansky also in money laundering shell Aquamed Technologies now Nexgel + +EDGAR Search Results (sec.gov) + +Stefansky controlled Aquamed/Nexgel with Nachum Stein Stein is CEO/Chairman of American European Insurance + +About I American European Insurance Group (aeiginsurance.com) + +Aquamed/Nexgel77777 + +For his part Rosenblum is involved in OTC bb shell Innovative Payment Solutions: IPSI + +fka Asiya Pearls Inc, fka QPAGOS EDGAR Search Results (sec.gov) + +IPSI CTO is formerly CTO at Cyprus based/NASDAQ listed QIWI: related to my NetElement TCR. + +An "Investor" in IPSI is Robert Klimov/Bellridge Capital + +Klimov/Bellridge also in the money laundering shell Black Cactus Global Inc + +FKA Envoy Group Now BLGI Inc + +EDGAR Search Results (sec.gov) + +Klimov/Bellridge/Black Cactus involved in some Paid P&D + +https://www.sec.gov/Archives/edgar/data/1575345/000116169718000269/exhibit 99-1.htm + +Another seller in Parallax: Digital Power Lending LLc + +Contact — Digital Power Lending + +VJ Contact — Digital Power Lending + +Get in Touch with Us. Fill out the contact form below and one of our courteous professionals will get back to you as soon as + +possible. + +digitalpowerlending.com + +DPL is a subsidiary of DPW Holdings now Ault Group + +Controlled by Milton Ault + +EDGAR Search Results (sec.gov) + +"investor" in DPW: + +EDGAR Filing Documents for 0001104659-20-087614 + +DPW Holdings, Inc. (Subject) CIK: 0000896493 (see all company filings) IRS No.: 941721931 I State of + +Incorp.:DE I Fiscal Year End: 1231 Type: SC 13G I Act: 34 I File ... + +www.sec.gov + +Digital Power Lending: Newport Beach CA. + +Oh, did I forget to mention Parallax CEO Paul Arena is well known to the SEC as well as the New Mexico + +Securities regulator? + +augmecorresp041911.htm (sec.gov) + +OTHER Paul Arena money laundering shells: + +Augme + +fka HipCricket,Innerspace,Modavox,Surfnet Now: EPMLive. Kept up and running by the SEC + +EDGAR Search Results (sec.gov) + +Geos Communications: fka Digital Data Networks, 12 Telecom International + +EDGAR Search Results (sec.gov) + +Revoked by the SEC as a shell + +and + +Cerus Technology Partners fka AIM Group Inc + +EDGAR Search Results (sec.gov) + +But But But But "COVID Disclosures" + +ALL of the activity detailed in my claims is very much on going in July 2021 thanks to SEC criminal + +obstruction/corruption on display once again in the SDNY with this complaint. This complaint is yet ANOTHER + +fraud on the SONY Courts and is irrefutable evidence of my serious allegations: + +The SEC is a grossly corrupt, criminal organization ACTIVELY facilitating multiple, massive,ongoing frauds on the public it is mandated to protect to the benefit of the criminals who own them while screwing the whistleblower + +who caught them: ME + +Per the PR announcing the Parallax COVID disclosure complaint: + +"The Commission appreciates the assistance provided by the Financial Industry Regulatory Authority" + +Kevin Goodman: SEC OCIE BD's was made Chief Overlord of FINRA: Goodman new title: + +OCIE FINRA and Securities Industry Oversight (FSIO) group + +Report from FINRA Board of Governors Meeting — September 2019 I FINRA.org + +Report from FINRA Board of Governors Meeting - September 2019 + +WASHINGTON - FINRAs Board of Governors met on Sept. 24-26 at FIN RA's offices in New York, where it approved six rule proposals and received several operational updates from FINRA staff.. The Board continued its engagement with key stakeholders by meeting with two officials from the Securities and + +Exchange Commission (SEC): Pete Driscoll, Director of the SEC's Office of Compliance ... + +www.finra.org + +FINRA/Goodman put out this friendly reminder just yesterday for Criminal BD's like NITE/CDEL who own the + +SEC/FINRA and their PFOF/Best execution "requirements" + +Regulatory Notice 21-23 I FINRA.org + +Regulatory Notice 21-23 I FINRA.org + +Summary FINRA is issuing this Notice to remind member firms of longstanding Securities and Exchange Commission (SEC) and FINRA rules and guidance concerning best execution and payment for order flow, which the SEC has defined very broadly to refer to a wide range of practices including monetary payments + +and discounts, rebates, or other fee reductions or credits. + +www.finra.org + +No doubt a deterrent from the BD SRO FINRA where the salaries of employees are paid by the criminals they + +"oversee". + +What an absolute farce of an enforcement deterrent the BD SRO FINRA is. Goodman is the PERFECT fit as the FINRA Overlord at the SEC. This bullshit "COVID 19 disclosure" complaint brought by the SEC/FINRA/Goodman et al is yet another example of SEC obstruction and corruption. Like "front running", "order handling", "market access", "stand alone P&D", etc etc etc. NOT a deterrent. Intentionally. So the criminal activity can continue. Because the criminals OWN the SEC/FINRA. This is why the SEC has outsourced the entire OTCM to FINRA. Including short interest reporting, issuer corporate actions: reverse splits, and compliance with the BSA. + +Judge Oetken et al: The reason SEC IG Hoecker and his "bosses" at the SEC don't want to meet with me despite + +my many offers to do so (same goes for Dal/FBI): I would absolutely HUMILIATE them. + +Cheers! + +Christopher J Dilorio + +Whistleblower Extraordinaire + +From: Chris Dilorio + +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix + +SDNY Judges: which one of you will be the lucky recipient of still MORE SEC fraud on your courts? + +Complaint - OFER ABARBANEL (sec.gov) + +As is SOP for the SEC + +More OMMISSIONS than submissions + +Are we clear? Further: + +"From March 2019 through November 2020, Abarbanel and the ( FULLY SEC REPORTING SHELL) Fund transferred approximately \$102,000,000 of the funds invested by investor Group A into NARL ACCOUNTS" + +the COO of State Funds/New York Alaska is Nicholas Abbate A former "independent" Market Maker at Knight Capital + +UNITED STATES (sec.gov) + +Guess who controlled (for others) 40% of the State Fund receiving the \$102,000,000 investor Funds? + +"Note 9. Control and Ownership" + +Brown Brothers Harriman + +The penny stock money launderer FINRA/Dick Best all entities un named + +Guess who controlled (for others) 57% of the State Fund/NARL receiving the \$102,000,000 investor funds? + +Bahamas/Toronto based Old Fort/Mosaic Ltd + +Mosaic Financial (mosaic-financial.com) + +Mosaic Financial + +For more than 50 years, our team has built on expertise in private banking for UHNW individuals and families to serve larger and more complex accounts in financial technology. To serve our clients better, we provide a turnkey asset management platform that simplifies custody, execution, accounting, reporting, research, + +mosaic-financial.com + +Yet, somehow/ some way: no mention of COO Abbate, BBH, OR Mosaic/Old Fort + +AND + +Of course: absolutely ZERO reference to AML. + +ANOTHER fraud SEC complaint coming to the SDNY Courts + +The SEC is a grossly corrupt, criminal organization bought and paid for by criminals ACTIVELY facilitating multiple, massive, ongoing frauds on the public while screwing the whistleblower who caught them: ME + +Cheers! Chris + +From: Chris Dilorio + +Sent: Friday, June 11, 2021 5:59 AM + +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix + +SDNY,NY Supreme Court, NJ Judges et al + +to say the SEC is a grossly corrupt ,criminal enterprise ACTIVELY facilitating multiple, massive, ongoing frauds on the public to the benefit of the criminals who own them while screwing the whistleblower who caught them: me. The real world implications of this irrefutable FACT are staggering. REAL lives changed/ruined. Staggering losses for "main street investors" as Clayton referred to them. Because, for ANYONE spending more than an hour or 2 on a trading desk: Gordon Gekko was right: "It's a zero sum game. Somebody wins, somebody loses". The Grossly corrupt SEC has rigged the game in favor of the criminals over the public it is mandated to protect. + +Mr Paley, did your Micro Cap Fraud Task Force actually accomplish ANYTHING? How did 4+ + +TRILLION shares of OTCM money laundering shells trade in 10 2021? Are prolific Bag Men like Kramer and + +Honig etc etc etc actually "out of business"? + +Mr Gensler, Chair Waters/Congress made repealing the grossly corrupt Clayton, Peirce, Roisman Rule in the summer of 2020 that exempts 90% of current 13 F filers a priority. Will you execute the stated will of Congress? + +SEC.gov I SEC Proposes Amendments to Update Form 13F for Institutional Investment Managers: Amend + +Reporting Threshold to Reflect Today's Equities Markets + +SEC.gov I SEC Proposes Amendments to Update Form 13F for Institutional + +Investment Managers; Amend Reporting Threshold to Reflect Today's + +Equities Markets + +The Securities and Exchange Commission today announced that it has proposed to amend Form 13F to update the reporting threshold for institutional investment managers and make other targeted changes. + +www.sec.gov + +Speaking of Prolific Bag Man Honig: As you are all aware, I made the connection between Honig, Russian entities,Signature Bank: SBNY, and the criminal law firm of Sichenzia Ross. Mr Gottschall: Have you been able + +to locate Castle Rock on a map yet? + +Here are just a few of the recently filed RIOT Blockchain filings with the SEC + +Detailing a few "transactions" + +With the likes of The Bejing China Bitcoin mining company Bitmain where RIOT bought the "mining machines" at the Rockdale Texas I gig-F "HPC" data center. It doesn't look like Bitmain has much of a future in China. But + +Rockdale Texas is a growth market for sure. + +https://www.sec.gov/Archives/edgar/data/ 1 I 674 I 9/000107997321000272/ex99x I .htm + +SEC.gov I HOME + +Hash Rate Growth . By Q4 2022, Riot expects a total hash rate capacity of 7.7 EH/s with a fleet of approximately 81,146 Antminers, 95% of which will be the latest generation S19 series model. + +www.sec.gov + +Another "transaction" involves the RIOT acquisition of a Data Center in Rockdale Texas owned by a German + +entity called Northern Data/Northern Bitcoin/Whinstone + +Northern Data AG successfully closed the sale of its Texas data center to Riot Blockchain, Inc. - Northern Data + +AG + +infrastructure supplier for Bitcoin mining and other HPC infrastructure solutions, successfully completed the sale of its U.S. subsidiary Whinstone US, Inc., which operates a high-performance data center facility based + +in Rockdale, Texas, to Riot Blockchain, Inc. (NASDAQ: "RIOT"). The ... + +northerndata.de + +Northern Data is a publicly traded company with ADR's trading OTCM Pinks. + +US Jurisdiction established + +Half-Year-Report 2019.pdf (northerndata.de) + +HALF-YEAR REPORT 2019 - Northern Data + +PAGE 4 NORTHERN BITCOIN AG I HALF YEAR REPORT 2019 BITCOIN IS CHANGING THE WORLD Bitcoin is a + +digital finance system that cannot be manipulated. + +northerndata.de + +Investor Relations - Northern Data AG + +Investor Relations - Northern Data AG + +Northern Data AG develops and operates global infrastructure solutions in the field of High-Performance Computing (HPC). With its customer-specific solutions, the company provides the infrastructure for various HPC applications in areas such as bitcoin mining, blockchain, artificial intelligence, big data analytics, IoT or + +northerndata.de + +OTC Markets I NDTAF I Company Profile I OTC Markets + +Northern Data is now a 12% holder of RIOT + +Inline XBRL Viewer (sec.gov) + +EDGAR Filing Documents for 0001140361-21-019019 (sec.gov) + +Northern Data/Bitcoin Frankfurt came into existence in 2015. + +The founder is a guy named Mathis Schultz. Mr Schultz previously was a Private Banker at Julius Baer, LGT, + +and Elan Capital Management + +Mining Like a Viking: How the Fjords of Norway Offer a Greener Alternative - Bitcoin Magazine: Bitcoin + +News Articles, Charts, and Guides + +Norway Offer a Greener Alternative - Bitcoin + +Magazine: Bitcoin News, Articles, Charts, and + +Guides + +Northern Bitcoin's energy costs are lowered still by the climate control measures Lefdal mine features by design. As if the Norwegian climate wasn't cool enough, the data center is + +situated some 656 feet below ground, so it maintains a constant temperature of 55 degrees Fahrenheit (-12.5 degrees Celsius). + +bitcoinmagazine.com + +Schultz picked a very interesting nobody from New Orleans to build his 1Gig+ "I-IPC" data center in Rockdale + +Texas: Chad Everett Harris + +qualifications? + +The Year of Chad Everett Harris - Chad Everett Harris + +The Year of Chad Everett Harris - Chad Everett + +Harris + +2020 will be the Year of Chad Everett Harris. This will be the year that the last 1642 days of work pays off and things get back to my normal chaotic life that I love. This year will be filled with achievement, challenges, and excitement. It will also be a year of + +living in the LI + +www.chadeverettharris.com + +Chad Everett Harris I Meet New Orleans Entrepreneur + +Chad Everett Harris I Meet New Orleans + +Entrepreneur + +Chad Everett Harris realized his passion for entrepreneurship very early on in his childhood. Born in Palos Verdes, California in 1969, he spent much of his young life moving between cities across the US.In his early years alone, he spent considerable time in Georgia, + +Michigan, and Louisiana. + +www.chadeverettharris.com + +lea: • rormai app / icmgnr uapirai iun & Hpp + +SONY, NY Supreme Courts/NJ Courts grossly corrupt SEC et al, + +Let's break down VIRT CEO Dougie "Mr Transparency" Cifu comments to Sell Side analists on the NITE/VIRT 10 + +2021 earnings call in May 2021: + +Per below: + +"Yes, Dan, obviously you look at the same metrics I do, just to give you a little commentary on them,' mean + +April volumes were a hair under 10 billion shares per day which is down 32 odd percent from the first + +quarter " + +Meaning: 10 2021 equity market making volumes at NITE were roughly 13 billion shares per day. + +Let's compare the last KCG stand alone quarter: 1Q2017 (below) where total equity market making share + +volumes were "a hair OVER 10 billion shares per day": 10.082 billion shares per day to be exact. + +KCG 1Q2017: 154 mil trading revenue + +93.589 mil commissions/fees eps .05/ 67 mil shares outstanding + +Since Dougie "Mr Transparency" Cifu won't actually disclose 1Q2021 metrics, let's do some simple math and + +solve for "X" shall we? + +NITE/VIRT COMBINED 1Q2021 + +Remember: "April volumes were down approximately 32% from 10 2021 volumes " + +April volumes were a "Hair under 10 billion shares pe day" + +Therefore: Cifu says to Sell Side analysts on May4 2021 earnings call: 1Q2021 share volumes were roughly 13 + +billion shares per day + +The 1q2021 NITE/VIRT combined SEC reviewed 100 + +Again: 10 2017 OTCM Pink money laundering shell volumes: 90%+ of total equity MM volumes + +OVERALL OTCM Volumes: 100-300 billion shares/month + +in 1O2021 OVERALL OTCM Money laundering share volumes were 4+ TRILLION shares + +a 10-30x+ INCREASE 2021 vs 2017 in OTCM Money laundering shell volumes + +YET TOTAL equity market making share volumes were up just 30+% 1O2021 vs KCG stand alone 1O2017???? + +How much market share did NITE/VIRT LOSE since 2017: 90+%???? + +NITE/VIRT 1O2021 share volumes were MULTIPLES of 13 billion shares/day. Cifu is KNOWINGLY LYING + +Further: + +Recall: ANOTHER example of SEC corruption: the KCG 1O2014 "astronomical" OTCM share volume metrics + +expunged by McKessy, Norberg, Pasquinelli, et al from the 1O2014 10O: + +The KCG stand alone 1O2014 10O: the basis of my March 2014 letter to McKessy with Berger Montague : I have + +attached the KCG 1O2015 SEC reviewed 10O above + +Year over year numbers: The corrupt SEC failed to expunge + +pg 53 + +1O2014 KCG STAND ALONE OTCM share volumes 14.045 BILLION shares/day (My Letter to McKessy) NYSE/NASDAQ volumes: 862 MILLION shares/day So according to Dougie "Mr Transparency" Cifu" + +1O2021 average daily share volumes were roughly 13 billion shares per day: This number is LESS than KCG stand + +alone 1O2014 share volumes of almost 15 billion shares/day: 7 FUCKING YEARS AGO + +In 1O2014 KCG trading revenue was 254.6 million and eps was .30/share + +This is blatant, egregious Cifu/SEC facilitated fraud on the public the SEC is mandated to protect. + +WHY is Cifu hiding this from the investing public and as important: WHY is the grossly corrupt SEC letting him? Read my TCR. In furtherance of the conspiracy: the CORE business at Knight/KCG/VIRT: NITE is and always has + +been Illegal naked shorting OTCM shells to facilitate money laundering. + +Further: Clayton et all CORRUPTLY gave NITE and CDEL their own exchange: MEMX: in 2020 for this EXACT + +reason + +The FINRA OTCM share volume discrepancies explained: NITE/VIRT is NOT reporting the vast amount of illegal naked shorting OTCM share volumes. Recall my correspondence to the grossly corrupt SEC when MEMX was + +announced: "Just between us criminals" + +Once again, my allegations are irrefutably accurate. The SEC has AGAIN doubled down and taken the side of the + +criminal entity NITE. As a result: the SEC ACTIVELY facilitates multiple, ongoing frauds on the public to the + +benefit of the criminals who own them while screwing the whistleblower who caught them: ME. + +Cheers! + +Whistleblower extraordinaire + +Christopher J Dilorio + +From: Chris Dilorio ‹ > + +Sent: Friday, May 28, 2021 8:58 AM + +u•ject: w: orma appea or •en a co g t apita • : • pp + +SDNY/NY Supreme Court/NJ judges: My apologies. I think I typed too fast for many on this email. Let me state plainly what I allege: For that, I turn directly to UBS Sell Side Analyst Alex Kramm who had quite the exchange + +10 2021 OTCM total reported share volumes: 4+ TRILLION Cifu on the call(' have electronic version should you prefer) + +"Yes Dan (Jefferies analyst Fannon), obviously, you look at the same metrics I do, just to give you a little commentary on them (without actually disclosing them), I mean April volumes were a hair under 10 billion + +shares per day " + +Mr Kramm: this is a knowingly, blatantly false and misleading statement. Accurately: a bald face lie. This is why + +Cifu won't disclose the actual share volumes. + +Per below: in 10 2017: the last stand alone KCG quarter: OTCM share volumes were reported in SEC reviewed 10O at 9+ billion shares/day. Back when OTCM TOTAL SHARE VOLUMES were reported in the 100-300 billion + +shares per month. + +Yet, in 10 2021 when total reported OTCM share volumes were more than 1 TRILLION shares per month, hitting almost 2 TRILLION shares in Feb 2021, Cifu would have us believe NITE Equity market making share volumes + +were a "hair under 10 billion shares per day". + +A blatant LIE. The SEC knows EXACTLY what the NITE equity share volumes were in 1Q2021. And it was a LOT MORE than "a hair under 10 billion shares/day". Driven of course by OTCM Money laundering shells.Trading + +profits: illegal naked shorting. Exploding balance sheet. Insolvent still/again. + +Once again, the SEC facilitating/covering up a MASSIVE ongoing fraud on the public to the benefit of the + +criminals who own them while screwing the whistleblower who caught them: ME + +Have a GREAT long weekend! + +Christopher J Dilorio + +Whistleblower Extraordinaire + +From: Chris Dilorio + +Sent: Friday, May 28, 2021 7:25 AM + +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix + +Ms Pasqinelli, + +There have been 3 (THREE) SEC actions CLEARLY based on my information that also CLEARLY qualify for OWB + +Award eligibility. + +Sason/Keener/Salviola et al: NewLead + +Joshua Sason, et al. (Release No. LR-24403; Feb. 15, 2019) (sec.gov) + +Joshua Sason, et al. (Release No. LR-24403; Feb. 15, 2019) + +SEC Files Charges in Elaborate Microcap Stock Fraud Litigation Release No. 24403 / February 15, 2019 + +Securities and Exchange Commission v. Joshua Sason, et al. + +www.sec.gov + +John Fife + +John M. Fife, Chicago Venture Partners, L.P., Iliad Research and Trading, St. George Investments LLC, Tonaquint, + +Inc. and Typenex Co-Investment LLC (Release No. LR-24886• Sep. 3 2020) (sec.gov) + +John M. Fife, Chicago Venture Partners, L.P., Iliad Research and Trading, St. + +George Investments LLC, Tonaquint, Inc., and Typenex Co-Investment, LLC + +(Release No. LR-24886; Sep. 3, 2020) - SEC.gov + +The Securities and Exchange Commission today filed charges against John M. Fife of Chicago and companies he controls for acquiring and selling more than 21 billion shares of penny stock without + +registering as a securities dealer with the SEC. + +Justin W. Keener d/b/a JMJ Financial (Release No. LR-24779; Mar. 24, 2020) + +- SEC.gov I HOME + +SEC Charges Unregistered Penny Stock Dealer Litigation Release No. 24779 / March 24, 2020 Securities and Exchange Commission v. Justin W. Keener d/b/a JMJ Financial, No. 20-cv-21254 (S.D. Fla. March 24, 2020) + +viww sec g ov + +ALL: My information. + +Yet NONE of these actions have been posted to the OWB Award Eligible website + +SEC.gov I Office of the Whistleblower + +SEC.gov I Office of the Whistleblower + +NOTICE: Until further notice, any Whistleblower Award Applications submitted by mail should be sent to the following address due to the mandatory telework posture at the SEC's Washington, DC headquarters: + +14420 Albemarle Point Place, Suite 102, Chantilly, VA 20151-1750. + +vomv sec g ov + +SEC IG Hoecker: HOW IS THIS REMOTELY PLAUSIBLE?? + +There is only 1 explanation: SEC criminal obstruction and corruption. + +Like the Dick Best/FINRA BBH complaint: also my information. No mention of executing broker dealers/MM's. + +OR as the SEC would like us to believe: "Penny stock trading fairies" + +NO! + +The SEC in ALL of these actions is protecting the criminal enterprise which has been bailed out on multiple + +ocassions: Knight/KCG/VIRT:NITE + +Automatically placing this criminal enterprise on the SEC "Do not investigate list". + +As a result, the SEC has KNOWINGLY, ACTIVELY facilitated countless, ongoing frauds on the public it is mandated to protect. ALL of the ilegal activity I have detailed is ongoing in May 2021. NITE is again/still insolvent. Cifu in the latest attempt to conceal this massive ilegal activity has once again limited transparency for the investing + +public. The NITE CI1 earnings call: May 4, 2021 + +Virtu Financial Inc (VIRT) O1 2021 Earnings Call Transcript i The Motley Fool + +Virtu Financial Inc (VIRT) Q1 2021 Earnings + +Call Transcript I The Motley Fool + +Virtu Financial Inc (NASDAQ:VIRT) Q1 2021 Earnings Call May 4, 2021, 8:30 a.m. ET. Contents: Prepared Remarks; Questions and Answers; Call Participants; Prepared Remarks: Operator. Good day, + +Cifu: "April volumes were a hair under 10 billion shares per day + +So, the last 10O filed by KCG/Knight as a stand alone company was 10 2017. The VIRT acquisition closed on July 31, 2017. Cifu won't disclose and the SEC let him KCG 2Q2017 financials. BLATANT fraud. Cifu/ the SEC wrote + +down more than \$4 billion in fails. + +EDGAR Search Results (sec.gov) + +The 1Q2017 KCG 10O Document (sec.gov) + +pg 49 + +Market Making stats. Cifu no longer discloses in SEC reviewed filings Avg daily OTC BB and OTC Market shares traded (millions) 9,096 + +Avg daily NYSE AND NASDAQ shares traded (millions) 986 + +Per my consistent correspondence with the SEC: Knight/KCG:NITE derived 80-90%+ of their equity Market making share volumes from OTCM . This is why VIRT acquired KCG/Knight. This is and always has been the core + +business at NITE. This is what Cifu conceals from the investing public. In May 2021. + +As I have also detailed over the last several years: FINRA share stats data is complete fraud. This ALSO continues + +in May 2021 + +Market Statistics - Equity Trading Data Monthly (finra.org) + +At the top of the page: "Last month statistics: April-2021 Share volume 44+BILLION shares" + +Yet below that under April share volumes:TOTAL SHARES: 928+BILLION + +The Knight/KCG/VIRT: NITE balance sheet in 10 2021 filed with the SEC in May 2021 + +The balance sheet is AGAIN exploding + +Inline XBRL Viewer (sec.gov) + +NOT HFT related where holding time is seconds + +Tangible book after properly classifying naked short fails: booked as an asset: receivable due to self clearing: + +insolvent. By a VERY wide margin. + +ALL as a direct result of ONGOING SEC criminal obstruction and corruption. + +So, Ms Pasquinelli: who was the executing BD/MM converting all of these fraud notes into worthless certs and dumped on the investing public where they are converted to real money? WHY would ANY BD/MM execute these trades? HOW do OTCM money laundering shells trade to trip zeroes? More buyers than sellers? NOPE: ilegal naked shorting to facilitate money laundering. That is why none of these actions have been posted to the + +OWB website. Even though they CLEARLY are eligible actions: My information. + +Cheers! Chris + +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix + +More Honig/Stetson et al SEC facilitated ONGOING fraud on the public + +David Urban: Trump PA Campaign Manager and NITE Not So Independent Board Member and his own money + +laundering shell: FSD Pharma: HUGE with Pakistani's + +Had a BINDING LOI to acquire Israeli Therapix. + +FSD Pharma Responds to Therapix Termination of Binding LOI I Business Wire + +Not so binding. I caught them. Plan B + +and never shut down by the SEC as is typical of many Honig money laundering shells + +EDGAR Search Results (sec.gov) + +Today, Therapix is now Sci Sparc Ltd SEC approved offerings done By Aegis + +SEC FORM D + +Yes: that Aegis: also very much up and running in May 2021. New York: SDNY jurisdiction We don't need no stinkin' SAR's. Aegis prolific OTCM/NASDAQ shell money launderer + +Aegis Capital Corporation (sec.gov) + +UNITED STATES OF AMERICA Before the SECURITIES AND EXCHANGE + +COMMISSION ADMINISTRATIVE PROCEEDING File No. 3-18412 ORDER + +INSTITUTING ADMINISTRATIVE PURSUANT TO SECTIONS 15(b) AND 21C + +OF THE SECURITIES EXCHANGE ACT OF 1934 AND SECTION 203(e) OF + +THE INVESTMENT ADVISERS ACT OF 1940, - SEC.gov I HOME + +3 As a result of the foregoing, Aegis willfully 2 violated Exchange Act Section 17(a) and Rule 17a-8 + +thereunder. RESPONDENT Aegis is a dually-registered investment adviser and broker-dealer with multiple + +branches + +www.sec.gov + +Well known to the SEC/FINRA: WHO were the customers? + +Who were the executing BD/MM's? MORE SEC "penny stock trading fairies" of course. NOPE: NITE. + +WHY are all entities once again UN Named? + +Robert Eide.pdf (finra.org) + +FINANCIAL INDUSTRY REGULATORY AUTHORITY OFFICE OF HEARING + +OFFICERS - FINRA.org + +FINANCIAL INDUSTRY REGULATORY AUTHORITY OFFICE OF HEARING OFFICERS DISCIPLINARY + +PROCEEDING NO. 2011026386002 HEARING OFFICER: MID ORDER ACCEPTING OFFER OF SETTLEMENT August 3, 2015 INTRODUCTION Disciplinary Proceeding No. 2011026386002 was filed on October 21, + +2014, by the + +www.finra.org + +Orders Accepting Offers of Settlement - Aegis Capital Corp. Charles Smulevitz, Kevin McKenna (finra.org) + +Disciplinary Proceeding ORDER ACCEPTING OFFER OF OFFICE OF + +HEARING OFFICERS INDUSTRY REGULATORY AUTHORITY FINANCIAL + +Aegis Capital Corp. SETTLEMENT Date: August 3, 2015 Respondents. + +INTRODUCTION - FINRA.org + +another F11"4RA member and registered with FINRA, through the firm, in several capacities, including as a + +GSR and GSP. Under Article V ofthe FINRA By-Laws,FINRA possesses + +www.finra.org + +Kevin Mckenna and Robert Eide (sec.gov) + +Kevin Mckenna and Robert Eide - SEC.gov I HOME + +3 As a result of the foregoing, McKenna willfully 2 aided and abetted and caused Aegis' violations of Exchange Act Section 17(a) and Rule 17a-8 thereunder and Eide was a cause of Aegis' violations. + +gov + +Stetson: Honig side kick. Therapix now SciSparc. Still Israel + +Beginning on pg 10 of the SciSparc SEC approved and reviewed registration + +https://www.sec.gov/Archivesiedgaridata/1611746/000121390021022427/ea139707- + +fl scisparcltd.htm#a 009 + +www.sec.gov + +20 Raul Wallenberg Street, Tower A, Tel Aviv 6971916, Israel. Tel: (+972) (3) 610-3100 : Puglisi & Associates. + +850 Library Ave., Suite 204. Newark, DE 19711 + +vAvw.sec.gov + +Sellers include: + +Aegis CEO Robert Eide Pension Plan: NOW that is f'n funny + +Hoboken restraunteur Rohit Bawa + +NYC Restaurateur Revamping Former Liberty Bar Site I Jersey Digs + +Bar Site I Jersey Digs + +The building itself was designed by Minervini Vandermark and will be four stories of concrete construction. The residential + +component will consist of three separate 3-bedroom, 2-bathroom + +units, each occupying one floor. + +jerseydigs.com + +Connecticuit distributor Michael Bozzuto + +Contact I Bozzutos.com + +Contact I Bozzutos.com + +Connect With One of Our Teams. We value your feedback. Let us know what's on your mind and how we can serve you better. Please select a department on the left to send a message directly to the team you + +would like to reach. + +www.bozzutos.com + +and, prolific Bag Man Michael Bigger + +Bigger Capital + +EDGAR Search Results (sec.gov) + +AND many more + +More on New York based Bigger Capital coming + +Of course, Aegis has a BOOMING wealth Management business + +How many related party transactions in this SEC reviewed Therapix Fl? + +https://www.sec.gov/Archives/edgar/data/1611746/000121390016017994/ff12016 therapixbio.htm#a 017 + +Next up: SciSparc + +Aegis "Investment banking" has ties to Israeli military + +Isaac Livni-EIDE: related? + +Investment Banking Team - Aegis Capital Corp. (aegiscapcorp.com) + +Aegis just did an SEC approved offering for Meten EdtechX Education Group + +China + +EDGAR Search Results (sec.gov) + +Brought to the US public/NASDAQ by the same Bag Man who brought Hwang/Archegos money laundering shell + +GSX to the US/NASDAQ + +Puglisi and Associates:Delaware + +Some reports I've read suggest the SEC won't investigate Archegos/Hwang because it lacks "jurisdiction". + +Perhaps Ms Hodgman/Strzok can clarify for us. + +Recall: Honig,Stetson/Frost/Alpha Cap (my TCR). As I REPEATEDLY told the SEC: multi BILLIONAIRE Frost didn't + +risk it all to make a few million. He/they were laundering + +8 (EIGHT) YEARS after submitting my NITE/UBS TCR with the SEC, Alpha Capital Anstalt is very much up and + +running in 2021 + +EDGAR Search Results (sec.gov) + +For His part: Frost bought Ladenberg from lcahn/Lorber/ et al: Vector/New Valley AFTER Ladenberg had bought + +Icahn's former firm Gruntal. Gruntal: SAC,Sater,Feinberg, Icahn: MILKEN + +Archegos and Greensill: Credit Suisse. + +Credit Suisse is controlled by Milken flunkies. Including the Risk Officer who quietly stepped down. + +Greensill: Jim Justice: Magna/Sason/Saviola/Sichenzia: SDNY/NY Supreme Court + +I suspect there will be no SEC investigation of Credit Suisse. Ms Hodgman Strzok is an expert at criminal + +obstruction. Pretty good, eh? It's a gift really + +Cheers! + +Christopher J Dilorio + +Whistleblower Extraordinaire + +From: Chris Dilorio + +Sent: Monday, May 24, 2021 5:47 AM + +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix + +Judge Engelmayer: + +Simply put: RIOT exists in SEC filings only. Multiple Honig money laundering shells: Aspenbio/Venaxis/Bioptix + +involving Russian Government entity: Rusnano + +RIOT world HQ in Castle Rock is 15 minutes from my home. Apparently Mr Gottschall can't seem to find Castle + +Rock on a map. There is no RIOT at SEC filing address. + +An ISP: Clear Connect and a Pakistani BPO entity: NASDAQ traded IBEX. + +Who did Mr Gottschall deliver his "no further investigation" letter to exactly? It sure as hell wasn't RIOT. + +BTW: as a result of said Gottschall letter/determination as result of his incredibly THOROUGH investigation, the + +SEC chose not to review a RIOT offering in December 2020 + +Riot Blockchain Inc. 5-3 Letter.pdf (sec.gov) + +UNITED STATES SECURITIES AND EXCHANGE COMMISSION + +WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE - + +SEC.gov + +United States securities and exchange commission logo December 11, 2020 Jeffrey McGonegal Chief + +Executive Officer Riot Blockchain, Inc. 202 6th Street, Suite 401 + +www.sec gov + +and resulted in Susquehanna/CVI pump and dump + +EDGAR Filing Documents for 0001104659-21-023563 (sec.gov) + +EDGAR Filing Documents for 0001104659-21-023563 + +Riot Blockchain, Inc. (Subject) CIK: 0001167419 (see all company filings) IRS No.: 841553387 I State of + +Incorp.:NV I Fiscal Year End: 1231 Type: SC 13G I Act: 34 ... + +www.sec.gov + +Judge Engelmayer, other SDNY/NY Supreme Court Judges: I implore you to send me a subpoena + +Cheers! Chris + +From: Chris Dilorio + +Sent: Tuesday, May 18, 2021 6:07 AM + +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix + +Well well well. Mr Gottschall ended his "thorough investigation" into RIOT/Honig et al on 1/29/2020 + +Riot Blockchain SEC Ends Investigation Letter 1.29.20 I U.S. Securities And Exchange Commission I Common + +Law (scribd.com) + +Riot Blockchain SEC Ends Investigation Letter + +1.29.20 I U.S. Securities And Exchange + +Commission I Common Law I Free 30-day + +Trial I Scribd + +Riot Blockchain SEC Ends Investigation Letter 1.29.20 - Free download as PDF File (.pdf), Text File (.txt) or read online for free. Included a letter from the Denver office of the SEC telling Riot Blockchain that the investigation by the securities regulator is over and at this time no enforcement action is recommended. + +without EVER visiting the RIOT world HQ in Castle Rock. SHOCKING! + +Curious Mr Gottschall: who recieved/signed for your "termination of investigation" into RIOT: The ISP + +ClearConnect or the Pakistani BPO entity IBEX? + +Judge Ramos, other SDNY judges, NY Supreme Court, and NJ Judge Quraishi: you have been played for fools + +once again by the grossly corrupt SEC. ALL of your courts have jurisdiction over the SEC NY. + +Let's give NJ Judge Quraishi a primer on prolific Bag Man Barry Honig shall we? + +As detailed by me in my extensive correspondence: the record. + +ANOTHER Honig money laundering shell: Inergetics fka Millenium Biotech + +EDGAR Search Results (sec.gov) + +Based in Newark NJ + +Is everyone familiar with Healthcare fraud felon Brian Colleran? + +Three Companies and Their Executives Pay \$19.5 Million to Resolve False Claims Act Allegations Pertaining to + +Rehabilitation Therapy and Hospice Services I OPA I Department of Justice + +Three Companies and Their Executives Pay \$19.5 + +Million to Resolve False Claims Act Allegations + +Pertaining to Rehabilitation Therapy and Hospice + +Services I OPA I Department of Justice + +Ohio based Foundations Health Solutions Inc. (FHS), Olympia Therapy Inc. (Olympia), and Tridia Hospice Care Inc. (Tridia), and their executives, Brian + +Colleran (Colleran) and Daniel Parker (Parker), have agreed to pay + +approximately \$19.5 million to resolve allegations pertaining to the submission of false claims for medically unnecessary rehabilitation therapy and hospice + +v.n.vw.justice.gov + +Somehow, the DoJ didn't believe this was a criminal case. The "prosecutor" on the case was Chad Readier. Now: + +JUDGE Chad Readier. Made so by Trump. + +Colleran entered into a fraud \$20 million purchase order with Millenium Biotech in 2007 + +Millennium Biotechnologies Inc. Signs Five Year \$20 000 000 Purchase Agreement with Provider Services Inc. I + +BioSpace + +Millennium Biotechnologies, Inc. Signs Five Year \$20,000,000 Purchase + +Agreement with Provider Services Inc. - BioSpace + +Millennium Biotechnologies, Inc. Signs Five Year \$20,000,000 Purchase Agreement with Provider Services + +Guess who controlled the money laundering shell Millenium/Inergetics? + +Prolific Bag Man Barry Honig + +EDGAR Filing Documents for 0001144204-10-011488 (sec.gov) + +But, it gets better still: Somehow, some way Prolific Bag Man Josh Sason/Hanover/Magna: MULTIPLE TCR's filed by me and a massive SEC fraud on the SDNY and NY Supreme Courts: NewLead/FreeSeas et al: showed up as a + +very large holder of Millenium successor Inergetics + +EDGAR Filing Documents for 0001144204-15-034843 (sec.gov) + +https://www.sec.gov/Archives/edgar/data/72170/000114420414046310/v385056 sl.htm#s1 007 + +The SEC revoked the Inergetics/Millenium registration only AFTER this massive fraud on the public was + +committed + +I can't seem to find any reference to this money laundering shell in the Dal/Readier CIVIL not criminal + +complaint. You won't find any SEC complaint implicating Colleran/ Honig /Sason either + +Millenium/Inergetics: New Jersey: SEC NY + +OTHER Sason entities list offices at 40 Wall Street: Trump + +So, Judge Ramos: HOW did prolific Bag Man Honig become involved in the Honig money laundering shell MGT + +Capital which ALSO did a "pivot" to crypto mining? + +EDGAR Search Results (sec.gov) + +Venaxis/Aspenbio/Bioptix: now RIOT. Which only exists in SEC filings. Thanks in large part to the well + +orchestrated SEC NY/ SEC Denver criminal obstruction/corruption. + +EDGAR Filing Documents for 0001493152-16-013083 (sec.gov) + +That was 1 thorough "investigation Mr Gottschall. I see great things at the SEC for you + +AND guess who ELSE was involved in MGT in 2019 just before the SEC revoked the registration: + +Chicago Bag Man Fife/Iliad + +6 years after I filed my TCR with the grossly corrupt SEC + +EDGAR Filing Documents for 0001567619-19-008772 (sec.gov) + +AND the Scumbags at Sichenzia Ross:MULTIPLE frauds on SDNY/NY Supreme Courts with Sason et al + +https://www.sec.gov/Archives/edgar/data/1001601/000114420415063432/v423506 s-1.htm + +The interconnectedness of my claims on display yet again. OR: The record + +From: Chris Dilorio + +Sent: Monday, May 17, 2021 5:28 AM + +subject: Fw: Formal appeal tor denial covered action ZU15-Ulb/ knignt (Awe' ILK & Appendix + +Oh, + +But it gets MUCH better Mr Gottschall et al: + +Ibex Digital + +Bermuda based/Pakistani controlled Ibex Ltd + +NASDAQ: IBEX + +BPO takes on a WHOLE different meaning. + +Which explains the co location with Local ISP ClearConnect. + +Riot Blockchain is just a front. + +RIOT crypto mining contract with Massena NY Coinmint + +New York Crypto Mining Farm Coinmint Set to Dissolve? - MinerUpdate + +Ir New York Crypto Mining Farm Coinmint Set to + +Dissolve? - MinerUpdate + +An ongoing dispute between the two partners who hold equal shares in multi-cryptocurrency mining company Coinmint has resulted in one of the partners filing to dissolve the company. + +www.minerupdate.com + +is on verge of dissolution + +RIOT/Aspenbio/Bioptix/Venaxis is and always has been a Prolific Bag Man Honig money laundering shell. Because: say it with me: the only difference between a NASDAQ money laundering shell and an OTCM money + +laundering shell is the amount being laundered. + +I've read that somewhere before. Hey, Pm the 1 who said it. + +Give me a call Mr Gottschall. After I help you find Castle Rock on a map, I'll walk you through it. I'll type/talk slowly for you. Because, if you can't find Castle Rock on a map you don't have a chance in hell of finding + +Pakistan on a ma . And, after ou're able to find Castle Rock on a map, I'll take you to Vista Gold :VGZ "world + +HQ" at Littleton CO + +The moneylaundering s to cite in my TCR and kept up and running by the grossly corrupt SEC for the last 8+ + +years and with SEC approved offering after offering. + +Cheers! Chris + +From: Chris Dilorio + +Sent: Friday, May 14, 2021 6:34 AM + +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix + +In addition to NeoPhotonix and Bioptix + +BiOptix Diagnostics Inc. - Portfolio company - RUSNANO Group + +BiOptix Diagnostics, Inc. - Portfolio company - + +RUSNANO Group + +RUSNANO was founded in March 2011 as an open joint stock company through reorganization of state corporation Russian Corporation of Nanotechnologies. RUSNANO's mission is to develop the Russian nanotechnology industry through co- + +investment in nanotechnology projects with substantial economic + +en.rusnano.com + +Rusanano/Akhanov invested in Quantenna + +Now On Semiconductor which supplies chips to Apple + +EDGAR Filing Documents for 0001628280-17-001249 (sec.gov) + +as well as chip company Aquantia + +EDGAR Filing Documents for 0001387131-18-000659 (sec.gov) + +Acquisition of Aquantia - Marvell + +Marvell Completes Acquisition of Aquantia Accelerating Multi-Gig Ethernet Technology Leadership. Santa Clara, California (September 19, 2019) — Marvell (NASDAQ: MRVL) today announced that it has completed its acquisition of Aquantia, Corp. (NYSE: AQ).. Aquantia pioneered Multi-Gig technology — + +www.marvell.com + +The SEC massive frauds on the SDNY and NY Supreme Courts continues Sichenzia Ross: Sason/Crede/ Jim Justice et al NewLead and FreaSeas + +As well as WNW and others. + +Now RiotBlockchain. + +So, Sichenzia facilitated a fraud "acquisition" of certain Futures Commission Broker now Introducing Broker + +trading platform from Mark B Fisher of "Miami" + +https://www.sec.gov/Archives/edgar/data/1167419/000107997318000207/riot 8k-03272018.htm + +SEC.gov I HOME + +Check the appropriate box below if the Form 8-K filing is intended to simultaneously satisfy the filing obligation of the registrant under any of the following provisions (see General Instruction A.2. below): + +vomv.sec goy + +Mark B Fisher has owned MBF Clearing + +MBF Clearing Corp (mbfcc.com) + +MBF Clearing Corp. + +Welcome to MBF Clearing Corp website About MBF Clearing Corp Founded in 1987, MBF Clearing Corp. is + +widely-recognized for our preeminent role within the global futures markets. + +www.mbfcc.com + +As well as MBF Capital + +mbf online I management (mbfcapital.com) + +mbf online I management + +Mark Fisher is the President of MBF Capital Corporation, Inc. He is a founder of Vela Pharmaceuticals, Inc., ExSAR Corporation, and Kimeragen, Inc., which merged into Valigen, Inc. Prior to the formation of + +for quite some time. BOTH New York based. + +Not even sure if there is a Miami Office for eithe Fisher entities. So WHY "Miami"? + +Part of that question can be answered by ANYONE receiving my extensive and irrefutable evidence of SEC + +criminal obstruction and corruption: + +Miami SEC Director Eric Bustilloe. A grossly corrupt Piece of Shit on par with Gottschall and Best. Did Fisher + +have outside investors in his firmS based in Miami? + +MBF /Fisher CLEARLY fall under SDNY/NY Supreme Courts jurisdiction. As does Sichenzia Ross + +As I have said repeatedly: the national security implications of these massive, multiple SEC facilitated frauds are + +staggering. + +Cheers! Chris + +From: Chris Dilorio + +Sent: Thursday, May 13, 2021 9:49 AM + +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix + +"Mr Dilorio, do you have any MORE irrefutable evidence of SEC gross criminal obstruction and corruption while + +screwing you the whistleblower who caught them?" + +Yes SDNY/NY Supreme Courts, SEC IG Hoecker, FBI, IRS CI etc etc etc: It just so happens I took a + +field trip to try and find the longstanding address of the Castle Rock CO money laundering shell + +Riot Blockchain fka Aspen Bio, Venaxis, Bioptix + +EDGAR Search Results (sec.gov) + +Enlightening! Kept up and running by the grossly corrupt SEC and pumped by Najarian(NetElement) on CNBC, Riot Blockchain is a Honig/Grousman/Stetson/GRQ et al money laundering shell which somehow escaped (along with many others) the SEC scrutiny in its Honig/Stetson/Frost/Jaclin/Alpha Cap et al complaint + +https://www.sec.gov/Archives/edgar/data/1167419/000107997317000238/bioptix s3.htm + +But WAIT. There's MORE! + +The Honig/Stetson Bioptix money laundering shell is ALSO a Colorado entity: Boulder + +EDGAR Search Results (sec.gov) + +Bioptix was just a vehicle to get Honig/Stetson et al into RIOT. Gee, I wonder what they saw in Bioptix that caused them to "invest" when it was around less than 2 years before "pivoting" to blockchain/crypto???? + +I have an idea! + +let's ask the scumbags at Sichenzia Ross who advised on the Bioptix money laundering offering which gave + +Honig et al ownership in RIOT + +https://www.sec.gov/Archives/edgar/data/1167419/000107997317000154/exl0x5.htm + +SEC + +WHEREAS, subject to the terms and conditions set forth in this Agreement and pursuant to Section 4(a)(2) of the Securities Act of 1933, as amended (the "Securities Act"), and Rule 506 promulgated thereunder, the Company desires to issue and sell to each Purchaser, and each Purchaser, severally and not jointly, desires + +to purchase from the Company, securities of the Company as more fully ... + +Then, we can ask the Bioptix offering Escrow agent: New York licensed Signature Bank:SBNY. You know the 1: the once and always Private Banking arm of Hapoalim where /Berman criminally obstructed a thorough investigation of Hapoalim tax evasion and money laundering. The same SBNY which boasted Ivanka Trump as a Board memberand was a "go to lender" for Trump/Kushner and where ALL SEC filings have disappeared. AND where Chairman Scott Shay is on BoD of CardWorks (Berman) which was go to processor for Net Element: + +Merrick Bank UT. Etc etc etc. YES, that SBNY + +https://www.sec.gov/Archives/edgar/data/1167419/000107997317000154/exl0x3.htm + +WHEREAS, pursuant to the terms of the Purchase Agreement the Company desires to sell (the "Offering") a minimum of \$2,000,000 (the "Minimum Amount") and a maximum of \$2,250,000 (the "Maximum Amount') + +of units of its securities (the "Units")."). Each Unit is being sold at a price of \$2.50 per Unit. Each Unit + +consists of one (1) share of the Company's common stock, no par value per share (the ... + +vAyw.secgov + +How much SEC et al criminal obstruction and corruption are we up to so far Mr Gottschall et al? + +Wait, there's more! + +In 2015, just prior to Honig/Stetson/SBNY/Sichenzia et al fraud offering, Boulder Based Bioptix FKA Alphasniffer + +did an SEC approved D offering + +SEC FORM D/A + +SEC FORM D/A + +In submitting this notice, each issuer named above is: Notifying the SEC and/or each State in which this notice is filed of the offering of securities described and undertaking to furnish them, upon written request, + +in the accordance with applicable law, the information furnished to offerees.\* + +www.sec.gov + +Guess who shows up as A Bioptix/Alphasniffer insider? + +Dimitry Akhanov + +WTAF is Rusnano USAmy) AND head of the Russian Federal Energy Agency???? + +WHY is he involved in Bioptix now RIOT??? + +Dmitry Akhanov CEO of Rusnano USA Inc. RUSNANO (topionetworks.com) + +Dmitry Akhanov, CEO of Rusnano USA, Inc., RUSNANO + +Curated profile of Dmitry Akhanov, CEO of Rusnano USA, Inc., RUSNANO + +www.topionetworks.com + +Akhanov is also involved in NYSE listed Neophotonics + +NeoPhotonics Names Dmitry Akhanov to Board of Directors President and CEO of Rusnano USA Joins + +NeoPhotonics Board i NeoPhotonics Corporation + +EDGAR Search Results (sec.gov) + +Neophotonics supplies optical chips to some of the biggest optical switching companies in the world like US + +based Cisco and Ciena + +Recall: Honeg/Stetson/Frost/Alpha Cap + +SEC left dozens of Jaclin money laundering shells up and running. Including Blink/New Image Concepts, + +Intercloud with Sason etc. As well as OZ/Maso/Sculptor NJ deli Hometown International: HWIN. NONE of this is + +by accident. SEC gross criminal obstruction and corruption. + +Now Honig/Stetson: Bioptix now crypto RIOT. + +Right here. 15 minutes from my home. Like CGFIA and VGZ. As well as prolific shell CPA firm BF Borgers. Give me a call Mr Gottschall. I'll point out Castle Rock to you on a map you grossly corrupt piece of shit! + +Cheers! Chris + +From: Chris Dilorio ‹ > + +Sent: Sunday, May 9, 2021 5:06 PM + +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix + +Per below: + +Judge Cote's sentencing of Dan Kamensky is a gross miscarriage of justice. The SDNY, NY Supreme Court, + +Mr Kamensky's counsel, FBI, other DoJ attorneys are in possession of information which clearly indicates a long standing and grossly corrupt relationship between the SEC and Handler/Jefferies. Further, as is material in the "ongoing" Joshua Sason investigations of massive fraud committed on the SDNY/NY Supreme Courts and directly related to my multiple claims: AQR and Sason: MI Acquisition with known felon Tom Priore: ICP: also SDNY and now a direct lending client of Ares Management: Ressler: Drexel with Handler: also Neiman Marcus. In short: Handler/Ressler set up Mr Kamensky for fucking with their deal. Had Kamensky won his bid, + +Ares/Ressler would have been left with a much less valuable asset. AND put them further under water. + +AresNeiman.pdf (pecloserlook.org) + +Sticker Shock: Can Ares Management Sell Neiman Marcus? + +2 Ares' Neiman Marcus Gamble In September 2013, Ares Management purchased luxury retailer Neiman Marcus in a joint venture of Ares Corporate Opportunities Funds IQ and IV and the Canadian Pension Plan + +Investment + +www.pecloserlook.org + +The SDNY Courts had this information. Kamensky's counsel had this information. Judge Cote should have + +declared a mistrial rather than sentence Kamensky. A gross miscarriage of justice. + +Now, let's turn to another example where the grossly corrupt SEC is ACTIVELY facilitating multiple frauds on the + +investing public while screwing the whistleblower who caught them: ME. + +Recall ANOTHER completely fraudulent denial of award : UBS AML. Where Norberg/OWB invoked the ILLEGALLY + +enacted Summary Disposition Rule aka Christopher J Dilorio rule. Where the SEC own SEC website clearly states: ALL tips received are THOROUGHLY reviewed by Enforcement Staff. Meaning: The Summary Disposition + +Rule: SEC Staff never saw the information: is a KNOWN fraud. + +Follow up for Mr Searles/Banerjee et al: SEC LA where multiple frauds left up and running. Ares also LA and NY. + +Milken: Beverly Hills + +Recall: UBS San Diego: K2. Where FINRA,FINCEN, and the SEC all confirmed UBS cross border business was never shut down per the terms of the DoJ dropping it's DPA in 2010. Further, clearly obstructed by SEC IG + +Hoecker when I filed a complaint with his office in 2015 after receiving another denial for Award related to the UBS Reg Sho complaint. ALSO according to the SEC OWB FAQ: Enforcement staff notifies investigating staff of related tips received AND Whistleblowers are ALSO entitled to awards based on new lines of inquiry. The Mckessy/Norberg/Hoecker criminal obstruction led to the UBS cross border business never being shut down. + +The UBS AML complaint acknowledges this irrefutable fact. + +UBS K2: NO individuals were censured/fined by SEC/FINRA. ALL correspondence to UBS Weehawken. SEC + +It is no coincidence the SEC LA/ UBS San Diego multiple money laundering frauds. Searles et al are PROTECTING UBS San Diego. That's why none of these frauds have been shut down. The UBS cross border business is very + +much up and running TODAY + +MORE.... + +Who is San Diego resident Jason Sunstein? CFO of several Once/still SEC reporting money laundering shells + +trading OTCM Pinks and no doubt well known to Searles,Banerjee et al in SEC LA. + +Viper Networks fka Tinglefoot Mining + +Baja Pacific International + +Taig Ventures + +EDGAR Search Results (sec.gov) + +Microsoft Word - VPER - OTC PlnkGuidelines Annual 12.31.20(Feb21 vers)v.3 nowcfo changes - Apollo Smart + +Lights-3.docx (otcmarkets.com) + +VPER - OTC PlnkGuidelines Annual 12.31.20(Feb21 vers)v.3 nowcfo changes + +- Apollo Smart Lights-3 + +27& Odunhwv \*urxs ,qf 27& 3lqn %dvlf 'Ivforvxuh\*xIgholqhv y )heuxdu\ 3djh ri wklv lvvxhu ru dq\ ri lwv suhghfhwruv kdyh ehhq wkh vxemhfw ri vxfk surfhhglqjv sohdvh surylgh dgglwIrqdo ghwdlov lq wkh + +backend.otcmarkets.com + +Santeon Group + +fka Air-Q Air Rover + +Covenant Financial Homegate Corp Spartan Oil ubroadcast + +EDGAR Search Results (sec.gov) + +Santeon and Viper: African/Egyptian entities/Individuals + +Santeon CEO : Ashraf Rofail + +International Land Alliance EDGAR Search Results (sec.gov) + +A San Diego virtual office well known to the SEC in its correspondence + +Virtual Office in DiamondView Tower I Regus RU + +Virtual Office in DiamondView Tower I Regus RU + +tf n 1 .pcMoggA/1 + +filenametpdf (sec.gov). + +International Land Alliance EDGAR Search Results (sec.gov) + +A little California pot + +a little "Mexico vacation properties" + +Mexico Vacation Property Investment I Baja Mexico Real Estate Investment I International Land Alliance + +(ila.company.) + +Mexico Vacation Property Investment I Baja + +Mexico Real Estate Investment - Baja Mexico + +Real Estate Investment I International Land + +Alliance + +International Land Alliance is a Mexico vacation property + +investment firm based in San Diego, California. The company was formed for the purpose of developing and selling residential communities for home buyers, vacation/second home, + +retirement, and investors. + +ila.company + +As of 2017, ILA is a Wyoming LLc + +SEC FORM D + +SEC FORM D + +In submitting this notice, each issuer named above is: Notifying the SEC and/or each State in which this notice is filed of the offering of securities described and undertaking to furnish them, upon written request, + +in the accordance with applicable law, the information furnished to offerees.\* + +www.sec.gov + +Of course: as has been well documented by ME: ILA currency of choice for these "beautiful Mexico land + +ventures" is common stock. + +In April 2021 + +International Land Alliance Inc. (Form: 8-K Received: 04/05/2021 14:00:05) (otcmarkets.com) + +OTC Markets Group + +OTC Markets Group Inc. OTC Pink Basic Disclosure Guidelines (v2.1 December 2019) Page 1 of 23 . + +Disclosure Statement Pursuant to the Pink Basic Disclosure Guidelines + +backend.otcmarkets.com + +Back in 2010, AV1 Group New York was controlled by a Moussa Traore + +SEC FORM D + +Who happens to have the same name as former Mali Dictator. + +Of Course, Jason Sunstein ONLY experience on Linked In is his ILA tenure. ALL of these other ventures have been + +ommitted. Gee, I wonder why. + +Jason Sunstein - Co-Founder and Vice President - International Land Alliance Inc. (OTCQB: ILAL) i LinkedIn + +Jason Sunstein - Co-Founder and Vice President - + +International Land Alliance, Inc. (OTCQB: ILAL) + +Linkedln + +Jason Sunstein Co-Founder and Vice President at International Land Alliance, + +Inc. San Diego, California 500+ connections + +www.linkedin.com + +Mr Searles,Banerjee, SEC LA have been criminally obstructing a REAL investigation into Sunstein et al. Right there in San Diego/UBS K2 back yard. So: No individual UBS San Diego K2 complaints, multiple money + +laundering shells up and running. + +For MANY reasons IG Hoecker: ALL SEC OWB Denials of my award applications are complete fraud. ALL of the + +activity continues TODAY as a direct result of your criminal obstruction and corruption. + +AND: NITE and CDEL trading all of them. + +In furtherance of the conspiracy + +Cheers! Chris + +From: Chris Dilorio + +Judge Cote, + +Your 6 month prison sentence for Dan Kamensky is a gross miscarriage of justice. Your Courts, Ms a and Mr Kamensky's counsel are in posession of information that clearly indicates a long standing and corrupt relationship between the SEC and Handler/Jefferies. Kamensky was set up. I will be contacting Mr Kamensky + +directly as his counsel has committed gross negligence in his representation. + +Chris + +From: Chris Dilorio •c > + +Sent: Friday, May 7, 2021 6:28 AM + +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix + +SDNY/NY Supreme Court Judges et al: + +The interconnectedness of my claims on display AGAIN + +Per my 2013 TCR criminally obstructed by McKessy/Norberg et al: WHY do \$50 billion Swiss banks trade OTCM Pink penny and fractional penny stocks? The record is irrefutable: FINRA/SEC/FINCEN using my information: these publicly traded shells are the perfect money laundering vehicle. Absolutely IRREFUTABLE. WHY do firms like NITE and CDEL trade the same OTCM Pink shells? Abusive, illegal naked shorting to facilitate this illegal activity. Virtually riskless. VERY profitable. NONE of this happens without a willing executing criminal BD like NITE converting worthless certs to real money and dumped on the investing public the SEC is MANDATED to protect. ACTIVELY facilitated and perpetuated by the grossly corrupt SEC: reverse splits, no CAT, Obligation + +Warehouse: circumvent close outs of Rule 204, rarely revoked registrations, outsourcing the entire OTCM to the + +BD SRO FINRA, etc etc etc. I made the link between the money laundering and the illegal, abusive naked + +shorting. This is and always has been the core business at Knight/KCG/VIRT:NITE. ALL money laundering can be + +reverse engineered from the executing BD/MM level. The cash register. + +What we are seeing in GME is a rounding error compared to the fails and illegal naked shorting in the OTCM. As I have also repeatedly said: the only difference between a money laundering OTCM Pink shell and a NASDAQ SPAC is the amount of money being laundered. Also on display real time as I have detailed. As with Swiss banks and penny/fractional penny stocks: WHY do giant Quant Hedge Funds like AQR facilitate so many fraud blank + +check shell transactions? CERTAINLY does not fit the investment thesis of a firm run by Phd's. + +WHY does giant PE/Real Estate firm Apollo play Fisker SPAC? WHY did Goldman,JPM,Jefferies et al bail out NITE + +more than once? WHY has the SEC repeatedly bailed out criminal NITE? + +The most recent Earnings call for NITE was remarkable: SELL SIDE is actually doing what it's supposed to do and questioning NITE/Cifu lack of transparency particularly in the last few years. This has been going on for some time detailed by me and blessed by the SEC. This lack of transparency is designed to conceal from the public the true nature of the core NITE business: illegal, abusive naked shorting OTCM publicly traded shells to facilitate money laundering. Until now, the Sell Side turned a blind eye/ also intentionally misled the public by omitting + +these share volumes from their models. These share volumes have been the subject of other SEC/FINRA + +actions. But, somehow NITE has avoided such actions. INEXPLICABLE. The SEC/FINRA have done everything in their power to protect NITE. WHY? Because they bailed out a known criminal entity in 2012 and have been criminally and corruptly covering up this irrefutable fact ever since. As a result: The illegal activity has continued + +un abated. Then in 1Q2021, the activity hit a level not even dreamt of. It has been a well orchestrated and massive SEC facilitated fraud on the public the SEC is mandated to protect. A key player in this massive fraud is the corrupt SEC IG Carl Hoecker who not only has criminally and corruptly obstrructed an investigation of my extremely serious allegations, Hoecker has also criminally obstructed Congress from executing its oversight of + +the SEC. + +These corrupt, criminal, ongoing frauds have also found their way into the SONY and NY Supreme Courts as I have detailed. Mr Kamensky is most definitely NOT on the SEC/DoJ "Do not investigate list". This can also be observed in real time. Per my correspondence: MI Acquisition: Magna/Sason: 40 Wall St with AQR/"payment + +processing" and felon Tommy Priore: ICP:SDNY. + +There is a straight and direct line between ICP/Priore and the Degenerate Milken as well as the corrupt SEC/SDNY Kamensky "sting" that goes beyond the degenerate Milken flunkie Handler/Jefferies. Where + +Praised the work of the SEC. As I have previously detailed: Ares Management: Neiman Marcus: Tony + +Massive CLO manager/originator. 1 stop shop. Because as I detailed previously: now a direct lender to fraud + +money laundering entities like Priore/Sason/AQR et al: PRTH. + +Because securitization drives the lending and is not a biproduct of sound credit analysis: Junk is junk REAL + +TIME. + +I applaud Chair Waters and her efforts to reign in illegal trading practices detailed in my extensive record. However: non bank lenders like the massive Ares pose a systemic risk to the US financial system. CLO's are a massive fraud on the public developed by the Milken degenerates like the sub prime and S&L's. The SEC actually brought a complaint recently: IIG which described using CLO's as a money laundering vehicle. The Caymans have recently cracked down also. Greensill: Credit Suisse: Milken: is another example of securitization as money + +laundering vehicle in sub prime factoring: Jim Justice. SBNY is also a securitization fraud: SBA. Chair Waters and her Committees see the Credit Ratings Agency/SEC fraud I have also detailed. + +My Coronavirus/repo virus: CLO correspondence: The SEC corruptly didn't downgrade massive CLO debt in 2020. The result: issuance exploded in 2021. Non bank lenders like Ares as well as Apollo,Jefferies, Ted Virtue etc etc have reaped tens of millions in management fees. Who told the SEC to obstruct the proper role of the Credit Agencies to downgrade massive CLO's in 2020? Mr Clements knows. His garbage CLO "report" late in + +2020 set the stage for the "all clear" to the SEC. + +Oh Mr Kamensky! I only hope you sue these corrupt scumbags who ruined your life while they are treated with + +ZERO implications for their illegal activity by the grossly corrupt SEC/DoJ. + +Cheers! Chris + +From: Chris Dilorio + +Sent: Tuesday, May 4, 2021 7:15 PM + +1 • rw: rormai app / nmgnc Lapicai PP + +Mr "Not so Transparent" Dougie Cifu got a little testy on the 1Q2021 earnings call and it abruptly ended. + +2 Sell Side Analists: Fannon/Jefferies and Kramm/UBS pressed @dougielarge on his lack of transparency. What is Dougie Cifu hiding? Something about "what percentage of those 4+ trillion shares of OTCM money laundering + +shells did NITE trade?" made Dougie squirm like the snake most already know he is. + +Love the parting shot to Kramm/UBS: + +"your firm would love to have our business" + +Virtu Financial Inc (VIRT) Q1 2021 Earnings Call Transcript i The Motley Fool + +Virtu Financial Inc (VIRT) Q1 2021 Earnings + +Call Transcript I The Motley Fool + +Virtu Financial Inc (NASDAQ:VIRT) Q1 2021 Earnings Call May 4, 2021, 8:30 a.m. ET. Contents: Prepared Remarks; Questions and Answers; Call Participants; Prepared Remarks: Operator. Good day, + +and ... + +www.fool.com + +Mr Gensler: in case you missed it: Dougie sends his best + +Cheers! Chris + +From: Chris Dilorio e > + +Sent: Monday, May 3, 2021 2:03 PM + +SONY/NY Supreme Court Judges. + +I once challenge the best and brightest the SEC/DoJ/FBI/IRS Cl/FINCEN have to offer. Tear me to shreds. Make + +an example. I haven't been wrong about 1 single thing. NOT EVEN 1. + +The record is simply irrefutable: + +The latest edition of "The SEC is a grossly corrupt, criminal organization actively facilitating + +multiple,massive,ongoing frauds on the public it is mandated to protect to the benefit of the criminals who own + +them while screwing the whistleblower who caught them:ME" + +I refer you to the SEC Office of the Whistleblower FAQ Of course, I have multiple forms copied should you prefer + +SEC.gov i Office of the Whistleblower + +SEC.gov j Office of the Whistleblower + +3. What information can I submit to the SEC? The SEC conducts investigations into possible violations of the federal securities laws. In general, the more specific, credible, and timely a whistleblower tip, the more + +likely it is that the tip will be forwarded to investigative staff for further follow-up or investigation. + +www.sec.gov + +AGAIN AGAIN AGAIN IG Hoecker et al: the "summary disposition" aka Christopher J Dilorio rule corruptly + +enacted by Norberg/Clayton et al was/is COMPLETE FRAUD per FAQ #12 from the grossly corrupt SEC/OWB website: + +"ALL TIPS, complaints, and referrals received by the SEC are FULLY REVIEWED BY OUR ENFORCEMENT + +STAFF " FURTHER + +"Complaints that relate to an EXISTING INVESTIGATION are FORWARDED TO the STAFF WORKING ON THE + +MATTER." + +New line of inquiry. + +I don't see how it could be ANY MORE CLEAR IG Hoecker et al. + +In addition to annual reports to Congress ACKNOWLEDGING the OWB as the primary contact for whistleblowers to the Commission at large, this is damning. The summary disposition rule aka Christopher J Dilorio Rule: "SEC staff never saw Mr Dilorio's information" is complete and total FRAUD. Designed to use my information to both + +bring and obstruct thorough investigations while screwing me out of rightfull compensation. + +IG Hoecker, I'm still looking forward to our first interview given the 3 (THREE) complaints I have filed with your office. The UBS Reg SHO Denial was complete fraud. The UBS FINRA/FINCEN, SEC AML Denial was complete fraud. The Opco Denial was complete fraud. ALL must be reversed. The Summary Disposition Rule/aka + +Christopher J Dilorio rule must be nullified RETROACTIVE to its passage as it is clearly contrary to the SEC Rules + +ITSELF. + +I look forward to speaking with you Carl + +From: Chris Dilorio + +Sent: Thursday, April 22, 2021 5:57 AM + +To: + +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix + +so sorry for incorrect e mail + +From: Chris Dilorio + +Sent: Thursday, April 22, 2021 5:44 AM + +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix + +Judge Buchwald, + +I hope your colleagues in the SDNY and NY Supreme Court have forwarded my information. Like your colleagues, you are the victim of another SEC fraud on the SDNY court. I am an irrefutable expert on SEC criminal obstruction and corruption. Jay Clayton was NEVER "shocked" by the widespread fraud in the OTCM + +and crypto markets. + +Widespread Fraud in ICOs and Penny Stocks Shocked SEC's Jay Clayton - Bloomberg + +Gbi Widespread Fraud in ICOs and Penny Stocks + +Shocked SEC's Jay Clayton - Bloomberg + +The former Wall Street deals lawyer who leads the U.S. Securities and Exchange Commission said one of the biggest surprises of his first year heading the agency has been learning about the + +levels ... + +www.bloomberg.com + +Clayton's firm Sullivan Cromwell/Jared Fishman/Rodgin Cohen et al are EXPERTS on penny stock fraud having bailed out the criminal enterprise Knight/KCG/VIRT:NITE on more than 1 occassion. OTCM shells and crypto are + +Clayton and the SEC have obstructed a thorough investigation of my very serious allegations for years. Including the 2017 merger of Virtu and KCG: NITS. As a direct result multiple, massive SEC facilitated frauds on the public + +the SEC is mandated to protect are very much ongoing. In 1Q 2021, more than 4 TRILION shares of OTCM money laundering shells were traded. Money laundering shells like SEC reporting HWIN and hundreds just like it. Bitcoin continues to be mined in China, Russia, and Belarus. Bitcoin claims to have a limited supply. But, can + +that actually be verified? On his way out the door, Clayton bought the Ripple action. As you have stated: + +extremely flawed SEC argument that Ripple IS a security but somehow Bitcoin ISN'T. + +In fact: either ALL crypto are securities OR NONE are. The IRS for its part treats cryptos as a capital asset. + +Subject to capital gains and losses for tax purposes. As your colleagues can attest, the interconnectedness of my + +information is irrefutable. Several entities including Signature Bank/Greenbox are just 1 example of my + +"Derivative" information. + +Seems to me that Clayton,Hinman, crypto pumper Peirce ALL had KNOWN settled precedent to regulate Bitcoin and ALL crypto as securities: SEC V SG Ltd. Where appeals Court got it right and where Howey was applied: + +Securities & Exchange Commission v. SG Ltd. 265 F.3d 42 I Casetext Search + Citator + +Securities & Exchange Commission v. SG Ltd., 265 F.3d 42 I Casetext Search + ++ Citator + +Read Securities & Exchange Commission v. SG Ltd., 265 F.3d 42, see flags on bad law, and search Casetext's + +comprehensive legal database + +casetext.com + +The inconsistency in the SEC approach to regulating ALL crypto as securities has caused great confusion in the + +marketplace and has opened the door wide to fraud. + +This is just another example of SEC corruption. + +Now, the SEC corruption has reached your Courtroom as well + +Cheers! + +Christopher J Dilorio + +From: Chris Dilorio + +Sent: Tuesday, April 20, 2021 11:39 AM + +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix + +Several typos omissions corrected below + +Judge Ramos: SEC 1 Off's + +Sec. & Exch. Comm'n v. Honig 18 Civ. 8175 (ER) i Casetext Search + Citator + +Sec. & Exch. Comm'n v. Honig, 18 Civ. 8175 (ER) I Casetext Search + Citator + +Read Sec. & Exch. Comm'n v. Honig, 18 Civ. 8175 (ER), see flags on bad law, and search Casetext's + +comprehensive legal database + +casetext.com + +SEC settled quickly with Honig et al. Also Alpha Capital Anstalt: Liechtenstein: IMDS: Bag Man Schlaff: Bawag: Refco:Rhino: Sedona: Scan Graphics: Shaye Hirsch: Karfunkel: Kushners: Nordlicht: Englander: et al: Judge Swain + +Derivatives. + +These SEC 1 off's guarantee the activity continues. It does. + +Below: Tri-Mark: Sytner + +When did the SEC waive 13D/G filings simply because it was disclosed in an audited/SEC reviewed 10K? + +Not 1 off's: guarantee activity continues Judge Ramos, did you put an end to Honig? + +NOPE + +Barry C. Honig et al. (Release No. LR-24262• Sep. 7 2018) (sec.gov) + +Barry C. Honig, et al. (Release No. LR-24262; Sep. 7, 2018) + +The Securities and Exchange Commission today charged a group of ten individuals and ten associated entities for their participation in long-running fraudulent schemes that generated over \$27 million from unlawful stock sales and caused significant harm to retail investors who were left holding virtually worthless + +stock. + +...1W Sec Co + +And, as I proved below: Jaclin/Honig STILL up and running in April 2021 + +SONY Judges/NY Supreme Court: The SEC CONTINUES to play you for fools while ACTIVELY facilitating massive, ongoing frauds on the public it is mandated to protect while screwing the whistleblower who caught them: ME + +As I have stated repeatedly in my correspondence: the record + +Multi billionaire Frost wasn't trying to MAKE a few million. Frost et al were LAUNDERING. + +Frost: bought Ladenburg from Icahn/LeBow/Lorber: Vector /New Valley. AFTER Icahn rolled his former + +employer: Gruntal: Sater,Feinberg,SAC et al: MILKEN: into Ladenburg. As MY record also clearly shows: Honig + +also Colleran: Trump felon fundraiser. AND: Vector/New Valley also Trump/Russia. + +"1 off's"! Too f'n funny + +Cheers! Chris + +From: Chris Dilorio + +Sent: Monday, April 19, 2021 4:10 PM + +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix + +Welcome to Episode number: I lost track: of SEC criminal obstruction/corruption while screwing the public it is + +mandated to protect and screwing the whistleblower who caught them: ME. + +Give me a call Mr Gensler. Love to catch up. Saw where you did a OTCM esque reverse split in the massive USO + +fraud on the public. + +SONY Judges et al, when you read about something as absurd and ridiculous as Hometown International with a Deli front and New Jersey and entities in Hong Kong and Macau, you're probably thinking what I was thinking 10 years ago when I began researching NITE and the OTCM shells they traded. But, these are NOT 1 offs. This is WHY the OTCM exists: abusive naked shorting OTCM shells to facilitate money laundering is and always has been the core business at NITE et al. This is WHY NITE has been bailed out multiple times by other criminal entities. There is no such thing as just 1 cock roach. HWIN is no different. It is part of a MUCH MUCH bigger and + +well orchestrated scheme. + +More on Hometown International: + +Hey look, there's a Senegal/Ivory Coast individual named Ibrahima Thiam with a Macau address + +OTCQB-Certification.pdf (sec.report) + +;2, Ibrahima Thiam - Wetlands International + +P.O. Box 471 6700 AL Wageningen The Netherlands. Tel. +31 (0) 318 660 910 E-mail: [email protected] RSIN Number: 806703726 + +Reg No: 09099028 + +www.wetlands.org + +You know the 1 I'm talking about Judge Silver: NITE top traded/multiple SEC/FINRA reverse splits/Jim Justice: 5 Mile: Perian Salviola/Josh Sason/Sichenzia : NewLead fame? AND sister fraud "Greek Shipper" FreeSeas: also NY Supreme Court. Also Sason/Sichenzia. But with other Milken flunkie Terren Peizer. Crede. Along with Deutsche Bank and Credit Suisse. Peizer/Crede also Net Element. Net Element former CFO New: also Blink Charging: with + +JMJ/Keener AND Prolific Bag Man Michael Farkas. MORE derivatives + +More on Farkas later in the e mail. Read on + +And, not to get too graphic + +But another Hong Kong/Macau HWIN "investor" is Swiss "model" Nathalie Pasyawon + +Nathalie Pasyawon - Boobpedia - Encyclopedia of big boobs + +Interconnectedness defined. OR as I like to say MORE DERIVATIVES + +The 2020 SEC reviewed HWIN 10K filed March 26, 2021 + +https://www.sec.gov/Archives/edgar/data/1632081/000121390021018020/f10k2020 hometowninter.htm + +www.sec.gov + +UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 . FORM 10-K (Mark One) ID ANNUAL REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934 For the fiscal year ended: December 31, 2020 or O TRANSITION REPORT PURSUANT TO SECTION 13 + +OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934 For the transition period from to + +vo.vw.sec.gov + +Guess who has been the HWIN auditor since 2015? + +Fined/censured by PCAOB Liggett and Webb + +James Liggett/Martin Webb + +Microsoft Word - 105-2020-010-LW.docx (azureedge.net) + +Get Stock & Bond Quotes, Trade Prices, Charts, Financials and Company News & Information for OTCQX, + +OTCQB and Pink Securities. + +www.otcmarkets.com + +Several SEC reporting + +AND a few more with up and running TODAY NASDAQ listed Orbital Energy Group OEG + +EDGAR Search Results (sec.gov) + +Aqua Power Systems APSI. That's Aqa Power systems fka NC Solar: a Jaclin money laundering shell + +EDGAR Search Results (sec.gov) + +https://www.sec.gov/Archivegedgar/data/1553264/000114420412044855/v321146 sl.htm + +Bang Holdings Corp BXNG: VERY appropriate Name. Read on. Also Jaclin. Also Zenith. AND Platinum + +EDGAR Search Results (sec.gov) + +Brownies Marine Group BWMG EDGAR Search Results (sec.gov) + +C2E Energy Inc OOGI FKA Odyssey Oil and Gas: through 2020: a NY HQ company + +https://www.sec.gov/Archivegedgar/data/1160798/000121390021020286/fl0k2020 c2eenergyinc.htm + +www.sec.gov + +The Company intended to expand the making of bio fuels from algae to other large mining Companies in South Africa. On May 26, 2009, the Company acquired 51% of H-Power (Pty) Ltd. H-Power (Pty) Limited, a South African registered company, which owns an exclusive license to develop and market batteries based + +on patented Hybrid Battery Technology worldwide. However, on August 27, 2009, the ... + +www.sec.gov + +Enviro Technologies US Inc EVTN EDGAR Search Results (sec.gov) + +Hometown International HWIN + +See Below + +Ocean Thermal Energy Corp CPWR EDGAR Search Results (sec.gov) + +EDGAR Search Results (sec.gov) + +Second Street Capital CTON content (otcmarkets.com) + +Vynleads Inc VYND + +EDGAR Search Results (sec.gov) + +PuraDyn Filter Technologies PFTI EDGAR Search Results (sec.gov) + +A New York Liggett/Webb money laundering shell is C2E Energy Inc + +Began as an "exercise equipment " shell controlled by Curtis Olschansky + +Everyone remember the Better Buns machine? + +https://www.sec.gov/Archives/edgar/data/1160798/000114420407015535/v069715 l0ksb.htm + +SEC + +Indicate by check mark whether the registrant (1) has filed all reports required to be filed by Section 13 or 15 (d) of the Securities Exchange Act of 1934 during the preceding 12 months (or for such shorter period that the registrant was required to file such reports), and (2) has been subject to such filing requirements + +for the past 90 days. + +www.sec.gov + +Here's ANOTHER lesson in derivatives for the slow on the uptake + +New York C2E Energy Inc is now controlled by PROLIFIC Bag Man David Lazar/Zenith Partners/International + +/Equity Holdings LLc's and Custodian Ventures. + +https://www.sec.gov/Archives/edgar/data/1160798/000121390021020286/f10k2020 c2eenergyinc.htm + +www.sec.gov + +The Company intended to expand the making of bio fuels from algae to other large mining Companies in South Africa. On May 26, 2009, the Company acquired 51% of H-Power (Pty) Ltd. H-Power (Pty) Limited, a South African registered company, which owns an exclusive license to develop and market batteries based + +on patented Hybrid Battery Technology worldwide. However, on August 27, 2009, the ... + +www.sec gov + +Mediashift MSHF Melt Inc MELT XXStream XMET FinotecGroup FTGI Enabling Asia Inc EAIN + +Goff Corp GOFF + +NYSE listed SyntheticBiologics SYN + +Exobox EXBX just to name a few + +Lazar NY address: 3445 Lawrence Ave + +Oceanside, NY Also SEC NY + +Lazar partner in Zenith is Los Angeles/Beverly Hills/Santa Monica based Barry Sytner + +also home to Mogilevich Bag Man Milken/Dexel/Boyd Jefferies et al + +Sytner was himself in control of Tri - Mark Mfg Inc with guess who? Barry Honig + +EDGAR Search Results (sec.gov) + +and another money laundering shell up and running today: Chinese \$5 laundering shell Worry Free Holdings + +Teed up and ready to go with Rent A CFO: CFO NOW Worry Free is FKA SEC reporting iVoiceldeas Inc + +EDGAR Search Results (sec.gov) + +Microsoft Word - WYCC 30 SEPT 2018 OTC FILING.FILED VERSION (otcmarkets.com) + +Worry Free not the only Lazar China 5\$ laundering shell + +Hong Kong Winalite Group EDGAR Search Results (sec.gov) + +Not revoked by the grossly corrupt SEC after 10 years of no financial disclosures. Rather: voluntarily suspended by Lazar to be re used at a later date. Per my record with the SEC et al: money laundering shells go dark AFTER + +the fraud is committed. SEC does nothing to PREVENT the fraud from happening in the first place + +https://www.sec.gov/Archives/edgar/data/1059885/000121390020001328/f1515d0120 hongkongwinalite.ht + +m + +Anyone keeping track of the Jaclin/Honig related money laundering shells we're up to so far? + +Again: the Lazar/Sytner/Zenith/Custodian Ventures/Liggett/Webb list is not exhaustive + +But in excess of 20 money laundering shells up and running today should be a good start. Don't you think Mr + +Gensler? + +Of course, the money laundering shell that ties all of these ongoing frauds together is Bang Holdings: BXNG https://www.sec.gov/Archives/edgar/data/1632323/000161577415000921/s101040 sl.htm#INTEREST + +(1) This Registration Statement covers the resale by our selling shareholders up to (1) 1,857,050 shares of common stock previously issued to such selling shareholders and (2) 1,500,000 shares of common stock issuable upon exercise of outstanding warrants ("Warrants") at an exercise price of 50.35 per share, that + +were issued in connection with a Securities Purchase Agreement by and between ... + +voNw.sec gov + +A Colorado incorporated/Miami based/Jaclin money laundering shell where Liggett/Webb are auditor with + +Farkas/Platinum/Zenith Equity Holdings/Michael Bernstein et al + +EDGAR Search Results (sec.gov) + +Vast majority: SEC reporting. Several Jaclin. BXNG: Farkas/Jaclin. Several with Chinese Nationals. + +Zenith/Lazar/Sytner: Jaclin 2.0 like Honig. ABSOLUTELY NOTHING random about this as I have stated repeatedly: MASSIVE in scope/Brazen/Egregious/ongoing/SEC facilitated/SEC IG complicit frauds on the public the grossly corrupt SEC is mandated to protect while screwing the whistleblower who caught them: ME. AND NONE OF IT HAPPENS without well known criminal entities like executing BD/MM's NITE et al. NOT the "penny stock trading + +fairies" + +No, SDNY/NY Supreme Court Judges: Hometown International is NOT a 1 off that slipped through the cracks. At ALL times Jaclin has been under the jurisdiction of the SEC NY. At ALL times SEC NY ALSO under the jurisdiction + +of the SDNY. + +Cheers! Chris + +From: Chris Dilorio + +Sent: Saturday, April 17, 2021 10:31 AM + +Subject: Fw: Formal appeal for denial covered action 201S-016/ Knight Capital TCR & Appendix + +SDNY Judges and SEC IG, + +I would like to Re admit the following which is part of my extensive record with the grossly corrupt SEC: Jaclin + +Money laundering shells: Honig et al. AND prolific Bag Man Michael Farkas: BLNK,ICLD etc etc + +Have you been watching the story about this Deli in New Jersey with a \$100 million dollar market cap? + +US Financial Markets Have Become A Giant Mirage Built On A Foundation Of Fraud I ZeroHedge + +US Financial Markets Have Become A Giant + +Mirage Built On A Foundation Of Fraud + +ZeroHedge - On a long enough timeline, the survival rate for + +everyone drops to zero + +www.zerohedge.com + +SDNY judges/ SEC IG: This is what I have been telling the grossly corrupt SEC for more than 8 fn years now. ALL of this activity is up and running TODAY: April 2021 thanks to SEC criminal obstruction and corruption. The SEC is a criminal enterprise ACTIVELY facilitating multiple, ongoing frauds on the public it is mandated to protect to the benefit of the criminals who own them while screwing the whistleblower who caught them: ME + +Say Hi to the OTCM Pink money laundering shell Hometown International + +EDGAR Search Results (sec.gov) + +pg 22 and following of Selling Shareholders in this 2020 SEC approved Si + +https://www.sec.gov/Archives/edgar/data/1632081/000121390020014269/ea122720-sl\_hometown.htm4j 015 + +(1) Pursuant to Rule 416(a) under the Securities Act of 1933, as amended (the "Securities Act"), there are also being registered hereby an additional indeterminate number of shares of the Registrant's Common Stock, \$0.0001 par value (the "Common Stock") as may become issuable to the selling stockholders as a + +result of stock splits, stock dividends and similar transactions, and, in ... + +www.sec.gov + +New Jersey Deli with "investors" in Macau, Hong Kong etc Welcome to my world in dealing with the grossly corrupt SEC + +Of course, Hometown International was ANOTHER Jaclin money laundering shell kept up and running by the + +grossly corrupt SEC + +hftps://vvvvvv.sec.gov/Archives/edgar/data/1632081/000114420415059929/v422176\_sl.htm + +SEC.gov I HOME + +25 E. Grant Street . Woodstown, NJ 08098 (856)759-9034 (Address, including zip code, and telephone + +number, Including area code, of registrant's principal executive offices) + +www.sec.gov + +What I have been telling the grossly corrupt SEC for YEARS: This is WHY the OTCM exists. AND, in Q1 2021, more than 4 TRILLION shares of money laundering shells like Hometown International were traded by NITE, CDEL et + +al. + +Market Statistics - Equity Trading Data Monthly (finra.org) + +ABSOLUTELY nothing has changed in the last 8 years. Infact, as the grossly corrupt SEC,DoJ et al have been in + +possession of my information, this illegal activity has EXPLODED. + +SEC IG: DO YOUR FUCKING JOB!! I I + +Hometown International: Woodstown NJ: SEC NY: SDNY jurisdiction + +Cheers! Chris + +From: Chris Dilorio + +Sent: Monday, April 5, 20215:29 AM + +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix + +Judge Swain: still ANOTHER version of A Stroll Down the ABSOLUTELY NOTHING HAS CHANGED Avenue. This is another version of my extensive correspondence as I wait on the SEC Final Determination. Below, I + +detailed the \$765 million fraud DFC/taxpayer loan to almost insolvent Kodak to transition from + +film/cameras(buggy whips) to hydroxychloriquine. The DFC was run by Jared Kushner's college roommate. Massive fraud from the outset. The SEC of course never investigated the massive pump and dump related to this fraud. AND, thanks to the SEC egregious obstruction of Congress: there is STILL no CAT. Of Course the DFC first appointed IG Zakel (Sep 6 2020) concluded 2 months later that Jared's roommate didn't break any laws. Further: The Akin Gump internal investigation is ripped to shreds by yours truly below. AGAIN:There was no Clayton et al/SEC OR DoJ investigation into the egregious Insider Pump and Dump that took place in KODK + +related to the fraud DFC taxpayer loan. + +The interconnectdness of my claims on display yet again. + +Some Interesting entities involved with Blackstone/Schwarzman/New in the almost insolvent at the time/still: + +KODK. + +Recall from a version I sent last week Judge Swain: + +Sedona/Scan Graphics: 1998 + +Kushners/Nordlicht/Englander AND + +https://www.sec.gov/Archives/edgar/data/31235/000121390020020114/ea124950scl3da2karfunkel eas.htm + +SEC.gov I HOME + +This Amendment No. 2 to Schedule 13D ("Amendment No. 2") relates to the common stock, \$0.01 par value per share (the "Common Stock"), of Eastman Kodak Company, a New Jersey corporation (the "Issuer"), and amends and supplements the initial statement on Schedule 13D filed on May 18, 2017, as + +amended and supplemented by the Schedule 13D/A filed on December 6, 2019 (the "Schedule ... + +VONW.sec.gov + +Chemdas Yisroel address: + +This EXACT address is the home of Roth CPA's etc + +Which also has offices in Israel + +Roth&Co — We understand that your business is your life's work (rothcocpa.com) + +Roth&Co - We understand that your business is your life's work + +NEW YORK. 1428 36th Street, Suite 200 Brooklyn, NY 11218 Phone: 718-236-1600 Fax: 718-236-4849 + +rothcocpa.com + +mportant to note here that George Karfunkel founded 1 of the largest Stock transfer companies: American Stock Transfer. Did I mention there was no Jay Clayton et al/SEC/DoJ Insider trading/P&D investigation into + +KOOK? I digress. + +See, back in 2004, Barry F'n Honig had a shop called GRQ Consultants + +GRQ was involved in 2 money laundering Shells: + +Amplidyne yada yada + +EDGAR Filing Documents for 0001170022-05-000036 (sec.gov) + +AND + +Cell Power Technologies + +EDGAR Filing Documents for 0001144204-04-007936 (sec.gov) + +Everyone catch the address of this Cell Boost "technology" Cell Power? + +The SAME address as Chemdas Yisroel and Roth CPA's + +but just down the hall: Suite 205 + +This is priceless. + +SONY Courts as well as NY Supreme Court. Brought to you by the grossly corrupt SEC. + +Gets better still.... + +The SEC revoked Cell Power Technologies in 2010 + +EDGAR Search Results (sec.gov) + +Barry Honig/Jaclin: also Blink Charging with prolific Bag Man Michael Farkas, JMJ, Drexel Alum Director, + +Jonathan New: NETE CFO up and running in 2021. + +And Barry Honig: Frost/Stetson/Colleran/ Alpha Capital et al + +Recall the record Laney: "multi billionaire Frost wasn't trying to MAKE a few million. Frost was laundering" Frost: bought Ladenburg from Icahn/Vector after Ladenburg bought Gruntal: Milken, SAC, Feinberg et al + +Colleran: Trump felon fundraiser + +Alpha Cap: Schlaff: Bawag/Refco/Sedona/Judge Swain: also my Knight/KCG/VIRT:NITE TCR + +2020. TEN YEARS AFTER the SEC revoked the Honig/Sichenzia money laundering shell down the hall from + +Chemdas Yisroel/Roth CPA: Garfunkel: Cell Power Technologies + +Garfunkel: 1998 Sedona/Scan Graphics w/Kushners et al + +Karfunkel/Chemdas Yisroel/Roth CPA's weren't the only ones to "get the look" (for those of you with ZERO trading experience charged with enforcing Securities Laws like insider trading, this is the term used for insider + +trading) + +Moses Marx also "got the look" + +EDGAR Filing Documents for 0001104659-20-089495 (sec.gov) + +EDGAR Filing Documents for 0001104659-20-089495 + +EASTMAN KODAK CO (Subject) CIK: 0000031235 (see all company filings) IRS No.: 1604171501 State of + +Incorp.:NJ I Fiscal Year End: 1231 Type: SC 13D/AlAct: 34 I File + +vo.yw sec g ov + +Marx and Karfunkel go way back and are still in business together + +Does United Equities/Commodities ring any bells? + +How about Berkshire Bancorp? ANOTHER New York licensed Bank + +EDGAR Search Results (sec.gov) + +Karfunkel/Marx moved BERK from the NASDAQ to the OTCM Pinks around 2013 + +WHY? Less disclosure stupid. + +Microsoft Word - {D634DCBC-639A-4A58-8504-3EDC20157A89} (otcmarkets.com) + +hey look! Marx,Karfunkel:BERK has the same auditor as Trump: Mazars. Prly just ANOTHER coincidence. For those of you incapable of following along: The probability that ALL of the Karfunkel illgotten gains in the SEC/Trump/Kushner/Blackstone/DFC et al facilitated P&D/Insider trading went to Congregation Chemdas + +Yisroel is virtually ZERO. + +Have I mentioned there was NO :zero,zilch,nada Jay Clayton et al/SEC/Dal insider trading investigation into + +KODK? + +Maybe, just maybe had the grossly corrupt SEC thoroughly investigated my irrefutably accurate allegations: Blackstone/Schwarzman: NITE, the massive pump and dump fraud:Blackstone et al: KODK wouldn't have + +happened. Which is why there has NEVER been a thorough investigation of my irrefutably accurate allegations. In fact, the grossly corrupt SEC has criminally obstructed a thorough investigation of my claims SO THAT frauds like KODK can continue. The SEC is bought and paid for by criminals while actively facilitating MULTIPLE frauds on the public it is mandated to protect WHILE screwing the whistleblower who caught them:ME. the record + +Janey is IRREFUTABLE. + +Finally Ms Wing: will you be keeping your DoJ e mail address up and running months after you land a + +new gig like Geoffrey Berman has? Almost like he never left. + +So Judge Swain: What has changed since your Sedona/Badian/Hirsch/Refco/Bawag decision? + +ABSOLUTELY NOTHING! + +Yes: Blackstone/Schwarzman/Marx/Karfunkel/Kushner/Trump et al are most definitely on the SEC/DoJ "Do not + +investigate List" + +Cheers! Chris + +From: Chris Dilorio + +Sent: Wednesday, September 23, 2020 7:18 PM + +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix + +Judges Cave and Nathan, + +If there was ANY question as to the veracity of my extremely serious allegations, the SEC put it to rest today + +with its "clarification" and new rules governing the Whistleblower program: + +My preliminary denial in June for the Opco Award application which was 5 years in the waiting: "SEC staff never + +saw Mr Dilorio's information" + +I refer you to the ONLY new rule in the "clarifications" in the interest of "transparency" + +https://www.sec.gov/rules/final/2020/34-89963.pdf + +SECURITIES AND EXCHANGE COMMISSION 17 CFR Parts 240 and 249 RIN + +3235-AM11 ACTION SUMMARY + +SECURITIES AND EXCHANGE COMMISSION . 17 CFR Parts 240 and 249 [Release No. 34-89963; File No. S7- + +16-18) FUN 3235-AM11. Whistleblower Program Rules + +www.sec.gov + +AKA the Christopher 1 Dilorio Rule. Created to deny awards of rightful compensation. Per my appeal: a whistleblower CAN NOT know who at the SEC he/she should contact as investigations are done in strict confidentiality. Further, the OWB itself + +is the CENTRAL contact for whistleblowers. It is the EXPLCIT and EXCLUSIVE responsibility of the OWB to distribute whistleblower information within the SEC. This "rule" is FURTHER overwhelming evidence of SEC corruption and + +obstruction. + +Judges Cave and Nathan: ALL information presented to your Courts must be treated with extreme skepticism if not + +outright disdain. IF the SEC is willing to commit massive fraud on whistleblowers who expose their corruption and criminal activity just imagine the evidence it is willing to fabricate to bring a case like they are in Kamensky. An immediate STAY in + +Kamensky is warranted until an independent thorough investigation of my claims can be executed. ALL evidence + +presented to your courts by the SEC must be questioned in light of the overwhelming evidence I have provided. Again: this corruption goes straight to Jay Clayton himself. His former colleague Jared Fishman has played a key role in this massive + +fraud. Clayton NEVER disclosed these conflicts. In addition, your Honors are in possession of other Clayton/Sull + +Crom/AQR/Girsky facilitated fraud: Nikola. This is what it has come to when you blow the whistle on the grossly corrupt + +SEC: They create a completely arbitrary and fraudulent rule to silence you. + +Rule 204-21F summary disposition aka Screw the whistleblowers exposing SEC corruption Rule OR + +The Christopher J Dilorio Rule + +Regards, + +Christopherl Dilorio Whistleblower + +FROM:Chris Dilorio •::l l:> Sent: Wednesda Se .tember 23 2020 5:27 AM + +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix + +Judges Cave and Nathan, + +My allegations are chock full of members of the SEC "Do Not investigate Club". Per my TCR: Key to the Aug 2012 "glitch/Bailout: Blackstone/Schwarzman. Blackstone had done extensive Due Diligence on Knight prior to the "glitch" and had considered buying them north of \$14/sh. Somehow/some way Blackstone decided not to go ahead with buying Knight not too long before the "glitch" which took the stock to \$3. The ultimate bailout deal was NOT collateral based. Rather a convert with a %50 discount to \$3: \$1.50/share. "WHEW". Per my TCR: ALL 2012 "glitch" bailout participants including Blackstone knew EXACTLY the fraud on the Knight balance sheet. Because of SEC corruption/criminal obstruction, NITE is insolvent TODAY. Absolutely nothing has changed. A + +As you can clearly see from my appeal to the OWB: The SEC intended to run out the clock. 5 years in the waiting in their Preliminary Determination Opco Award Denial for " Investigators never saw my information". Yet, SEC actions based on my information include: Hanover/Magna, JMJ/Keener, Fife, Southridge/Hicks, Opco, and + +UBSS. Missing somehow: NITE, Handler/Jefferies, Blackstone/Schwarzman etc etc. + +The last overt act of this massive conspiracy has not yet occurred. + +Mr Kamensky and I are BOTH victims of a longstanding and corrupt relationship between the SEC and + +Handler/Jefferies et al. Also victim of this corruption: the investing public the SEC is mandated to protect and + +the US Taxpayer. + +Regards, + +Christopher J Dilorio + +Whistleblower + +From: Chris Dilorio + +Sent: Wednesday, September 16, 2020 6:25 AM + +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix + +Janey, + +Schwarzman must be pretty close to the top of the SEC's "do not investigate" list. + +The latest Schwarzman/Blackstone orchestrated fraud and cover up: KODK + +Today, the KODK Board Member Jason New: Blackstone "independent" outside inquiry by the law firm Akin + +Gump is in + +https://www.kodak.com/content/products-brochures/Company/Report-to-the-Special-Committee- + +09.15.2020.pdf + +"gaps" indeed + +The flowery New/BX cover up is chock FULL of gaps. + +"Introduction to Phlow" + +Phlow: the VA consortium receiving \$350 mil in Government Covid funding to provide Trump pushed Covid + +Cure: hydroxychloroquine + +https://www.prnewswire.com/news-releases/phlow-corporation-awarded-354-million-hhsasprbarda-contract- + +to-manufacture-essential-medicines-in-shortage-301061648.html + +RICHMOND, Va., May 19, 2020 /PRNewswire/ -- Phlow, a U.S.-based, public benefit drug manufacturing corporation, has received federal government funding of \$354 million for advanced manufacturing ... + +www.prnewswire.corn + +Phlow already has/had a long standing relationship with Ampac Fine Chemicals + +https://www.phlow-usa.com/about-us/ + +About Us I Phlow Corporation + +Robert Mooney is a tireless champion of creativity and business acumen. As an entrepreneur and co-founder of New Richmond + +Ventures (NRV), Bob counseled startups and early stage companies on accounting and financial reporting, capital + +strategies, equity raising, project financing, milestones, business + +www.phlow-usa.com + +In May 2020, Phlow was re starting/building a mfg facility/warehouse with partner Ampac (AFC) to fulfill its + +Government contract + +https://richmondbizsense.com/2020/05/20/new-richmond-based-pharma-startup-with-350m-in-funding-eyes- + +facility-in-petersburgi + +New Richmond-based pharma startup with + +\$350M in funding eyes facility in Petersburg - + +Richmond BizSense + +Earlier this month BizSense first reported Phlow's initial + +government contract for \$6 million, but details on the company's plans remained unclear at the time.. Gupton said in an interview Tuesday the company's plans have been in the works for about 18 + +months, well before COVID-19 hit. + +richmondbizsense.com + +Per the KODK/New/BX/Akin Gump cover up: pg 20 + +"On June 15 2020,Kodak signed a Letter of Intent with Phlow in furtherance of its application to the DFC to + +show it had a CUSTOMER for its future API's" + +Most definitely "DEFINITIVE AND MATERIAL" + +So, where is the SEC reviewed/required 8k for this agreement? + +Further: WHY would the DFC consider "loaning" \$765 million to KODK with NO EXISTING API capability when it already granted LESS money to Phlow/Ampac with proven capabilities? Answer: KODK liquidity issues are + +SEVERE + +Like Milken: Insider trading is NOT the real issue here. The latest BX orchestrated "glitch": KODK. + +I know this information may be more than the SEC/DoJ are capable of comprehending. + +Call me and I'll walk you through it SLOWLY. + +Cheers! + +Christopher J Dilorio + +Whistleblower + +From: Chris Dilorio + +Sent: Tuesday, September 1, 2020 7:40 AM + +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix + +Janey, + +MORE on the Blackstone/Trump/Kushner KODK P&D grift. + +Again, BX helped orchestrate the Knight "glitch" and bailout. No doubt, the "luckiest" f'ers on the Street. VERY + +high on the SEC do not investigate list. So, they can continue to facilitate criminal activity. + +See below: Jason New: KODK BoD: BX. In charge of the KODK "internal investigation". Now we read where D E Shaw has taken a 5% stake in KODK. guess who DE Shaw largest investor is: Blackstone. Corruption cover up. For + +the record Janey + +https://www.thetrustedinsight.com/investment-news/de-shaw-blackstone-20190325420/ + +Cheers! + +Christopher J Dilorio + +Whistleblower + +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix + +Mr Best, + +Congratulations on your new position as Director of SECNY. + +No doubt you have earned the promotion. For those of you who don't know Dick Best from his FINRA days, this + +masterpiece is what got him his job at the SEC Atlanta office + +https://www.finra.org/media-center/news-releases/2014/finra-fines-brown-brothers-harriman-record-8- + +million-substantial-anti + +The BBH AML complaint. Truly, fantastic work. + +ALL of the entities in the complaint are un named. WHY? + +This is my information. + +Swiss Banks, FFI's, and of course: penny stock trading fairies aka executing BD's/MM's that made it all possible. + +Per Dick's complaint: BBH delivered 80%+ of the trades to executing BD's/MM's. Did Dick Best criminally + +obstruct an investigation into my claims? Per my extensive correspondence with Robin Traxler at FINRA AND the + +fact that the SEC had my Knight Capital TCR in its possession for almost a year when Dick brought his BBH complaint. So, did Dick's complaint implicate entities in my TCR and that's why ALL of the entities in Dick's + +complaint are un named? Most certainly YES. + +Recall, this scheme generated \$850 MILLION in proceeds. Dick's \$8 mil fine was not a deterrent. Intentionally + +SO. + +So Congrats Dick on your new position as Director at SECNY. Janey, Hoecker, Dick, the record is extensive of my + +correspondence including Dick Best at the Atlanta Office. No doubt he will be recusing himself related to + +matters involving the un named entities in his FINRA BBH complaint. OR will he do what is expected at the SEC: + +Criminally obstruct investigations while screwing whistleblowers like me? + +From: Chris Dilorio ‹ > Sent: Wednesday, August 19, 2020 6:53 AM + +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix + +Further: + +Janey, Hoecker, Jay, Mehraban et al + +Let me help narrow down the SEC facilitated, ongoing accounting fraud at NITE as I know none of you have ever + +spent a day on a trading desk: + +IF the avg holding period for VIRT HFT is a matter of seconds AND VIRT goes home flat every night, then what is the receivable/fails related to? With the core Virtu HFT business eliminated, what that does that leave? The + +CASH OTCM business maybe? Should I draw a picture in crayon for you Ms Mehraban? + +NITE: 3 different CFO's in the last year. Ms Mehraban, How much is your former Paul Weiss colleague/boss + +Dougie Cifu paying you to criminally obstruct an investigation of my allegations? + +Janey, Hoecker, Mehraban et al: When it comes to trading fraud/accounting fraud cover ups, SEC attorneys are + +CLEARLY not qualified. + +The record there is ALSO IRREFUTABLE. + +Here glitchy glitchy. + +Cheers! + +From: Chris Dilorio + +Sent: Tuesday, August 18, 2020 6:37 PM + +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight Capital TCR & Appendix + +Janey, Hoecker, Mehraban, Jay et al, + +The massive SEC facilitated fraud on the public known as Knight/KCG/VIRT: NITE is reaching epic proportions in + +August 2020. For the new "accounting" hires at the SEC: + +In 1Q2020, the receivable at NITE was up 90% or \$1.2 BILLION from Dec 2019 to \$2.562,721 billion + +Per the extensive record Janey: fails: because of self clearing are booked as a receivable. FRAUD. no intention of delivering. More accurately a liability. AND per my 2013 TCR: a large portion: structural liability as a result of an open naked short fail position WHEN not if a reverse split is approved by the grossly corrupt SEC/FINRA. There are some new "buckets" Malusso,loffe, Dougie large have created within the Receivable as well. Creative. The + +accounting shell game: moving fraud (abusive naked shorts) from bucket to bucket. + +The 1Q2020 10O + +https://www.sec.gov/ix?doc./Archives/edgar/data/1592386/000159238620000006/virtufinancial03- + +31x20.htm + +Inline XBRL Viewer - SEC + +The Inline XBRL Viewer allows a user to quickly and easily review details of the tagged information in an Inline document by automatically placing a top and bottom highlight border around each tagged numeric + +pg 23. + +Buckets total 52.562,721 BILLION + +the 2Q2020 10O + +https://www.sec.gov/ix?doc./Archives/edgar/data/1592386/000159238620000009/virt-20200630.htm + +pg 24 + +Buckets total 52.441,283 BILLION + +The FRAUD (please see the record Janey). + +ALL of the receivable items are related to SETTLEMENT. + +Certain items within the receivable: buckets: would zero out within days IF VIRT was in compliance with the Securities LAWS: Close out requirements of Rule 204. So, isn't it beyond amazing THAT: although there was some change in certain buckets AND that the amounts were zeroed out within days of March 31, 2020 ONLY to + +end the quarter June 30, 2020 a mere 5121.438 MILLION difference from the March 31, 2020 ending + +balance777777 + +That is absolutely f'n amazing: \$2.562,721 BILLION zeroed out from March 30, 2020 THEN a \$2.441.283 balance + +at June 30,2020. Well, the SEC does believe in "penny stock trading fairies" too. + +Nope. Not penny stock trading fairies. AND VIRT didn't zero out :FAILED to SETTLE BILLIONS \$\$ in transactions. This massive fraud is due to NEVER closing/covering as is mandated by LAW. SEC, ongoing, massive fraud on the + +public. Classic bucket shell game. A la FCM and Reverse mortgages. + +NOTHING has changed thanks to SEC corruption and obstruction while screwing whistleblowers like me. + +The massive NITE accounting fraud facilitated by the SEC that facilitates the ongoing fraud on the public the SEC + +is mandated to protect. + +CLEARLY, IRREFUTABLY: NITE is and always has been a criminal entity. ILLEGAL NAKED SHORTING drives trading profits at NITE. ALWAYS has. Janey, please post Jay Clayton AND Ms Mehraban NITE conflict disclosures. No doubt, Dougie large will see this e mail the same way the grossly corrupt SEC has disclosed my information to + +NITE for the last 10 years. NITE is GROSSLY insolvent TODAY August 18,2020. + +Cheers! + +Christopher J Dilorio + +Whistleblower + +From: Chris Dilorio + +Sent: Tuesday, August 11, 2020 6:53 AM + +Subject: Fw: Formal appeal for denial covered action 2015-016/ Knight TCR & Appendix + +Janey, Hoecker et al + +SEC criminal obstruction virtually real time. + +https://www.sec.gov/news/press-release/2020-178 + +SEC.gov I SEC Charges Interactive Brokers With Repeatedly Failing to File + +Suspicious Activity Reports + +The Securities and Exchange Commission today announced that Interactive Brokers LLC will pay an \$11.5 million penalty to settle charges it repeatedly failed to file Suspicious Activity Reports (SARs) for U.S. + +microcap securities trades it executed on behalf of its customers. + +www.sec.gov + +SECNY: Lara Shalov Mehraban. Ms Mehraban, I've asked this before: Was Dougie "Large" Cifu your boss at Paul + +Weiss? The IBKR "complaint" is getting very close to your former boss/colleague isn't it? + +Questions Ms Mehraban doesn't want the public to see: + +Her former boss/colleague Dougie "Large" Cifu hired Alex loffe as VIRT CFO in 2019. From 2003-2019 loffe was + +CFO at IBKR. INCLUDING the period covered in Ms Mehraban's complaint. + +Not filing SAR's, Microcap securities, AML red flags. No kidding. WHY are the securities un named? WHO was + +ultimate executing BD/MM? + +As self clearing Ms Mehraban, isn't Knight/KCG/VIRT (Cifu): NITE the LARGEST clearing agent of microcap + +securities? How many SAR's coming out of your former boss executing BD/MM? + +Per my TCR: NONE. ZILCH. NADA. How do I know that? + +When would the criminal enterprise NITE which is run by Ms Mehraban's former Paul Weiss boss/colleague Cifu + +file a SAR: BEFORE + +or + +AFTER trading billions of shares? + +Did NITE Compliance rely on IBKR/Ioffe compliance? That would be a violation wouldn't it? + +Ms Mehraban is the poster child of SEC corruption and criminal obstruction while screwing whistleblowers like me. Virtually real time in August 2020. Very much an ONGOING and massive fraud on the investing public. + +The record is overwhelming AND irrefutable. + +Cheers! + +Christopher J Dilorio + +Whistleblower + +From: Chris Dilorio + +Sent: Monday, August 10, 2020 8:32 AM + +Subject: Fw: Formal appeal for denial covered action 201S-016/ Knight TCR & Appendix + +Janey, Hoecker et al + +speaking of NO 8K, recall the extensive record for the criminal/insolvent/fraud on the public + +Knight/KCG/VIRT:NITE + +The record Janey: Clayton/Sull Crom/Fishman "sale" of FCM business to other criminal firm Wedbush with NO + +8K + +3Q2014 10O + +https://www.sec.gov/Archives/edgar/data/1569391/000156939114000013/kcg2014093010-q.htm + +KCG then CFO Bisgay resigned with 2 weeks left in the quarter and didn't certify the financials. WHO certified + +along with Coleman? Sean P GALVIN. + +Cifu, Viola, Urban, Hutchins et al getting the fraud band back together + +https://finance.yahoo.com/news/virtu-financial-announces-changes-finance-105100941.html + +WHY would "Cutting edge technology firm" VIRT want to go with a guy who knows how to run the books at low as low tech gets OTCM cash trading firm Knight/KCG? The core business at Knight/KCG/VIRT: NITE is and always + +Cheers! + +Christopher J Dilorio + +Whistleblower + +From: Chris Dilorio ‹ > + +Sent: Friday, August 7, 2020 6:20 AM + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight TCR & Appendix + +The SEC facilitated fraud on the public continues unabated. MORE irrefutable evidence of SEC criminal + +obstruction while screwing whistleblowers like me. + +A direct result of this ongoing massive fraud on the public. + +After NITE reported its 1Q2020 results I again again, again, like the last 10 years, alerted the grossly corrupt SEC + +to the massive accounting fraud at NITE as a direct result of abusive naked shorting. + +Per my 2013 TCR Laney, Hoecker, Jay et al: + +NITE is in a constant state of insolvency as a result of illegal, criminal, abusive naked shorting OTCM money laundering shells. This illegal activity drives trading revenue at NITE. This illegal activity is and ALWAYS has been the core business at NITE. This very profitable albeit illegal activity is WHY Sull Crom client KCG was bought by + +Virtu. This illegal activity is WHY NITE has been repeatedly bailed out by GS,BX,JEF, JPM and the SEC + +The receivable is where NITE books naked short fails as a result of self clearing. NITE has no intention of closing/ can't close these naked short positions. NOT a legit asset. Further, the receivable isn't a legit asset NITE can + +SEC.gov I HOME + +Exhibit 99.1 . Virtu Announces First Quarter 2020 Results . NEW YORK, NY, May 7, 2020 - Virtu Financial, Inc. + +(NASDAQ: VIRT), a leading provider of financial services and products that leverages cutting edge technology to deliver innovative, transparent trading solutions to its clients and liquidity to the global + +markets, today reported results for the first quarter ended March 31, 2020. + +WV:W.sec .gov + +Per the SEC reviewed 8k filing this am Aug 7, 2020 NITE reported 2Q2020 earnings. showing the receivable + +roughly flat with 1Q2020 at 2.44 BILLION + +https://www.sec.gov/Archives/edgar/data/1592386/000110465920091707/tm2026789d1 ex99-1.htm + +These are NOT "assets". More accurately, these are LIABILITIES. Massive accounting fraud. After moving these fraud "assets" to the appropriate liability classification, NITE tangible book value is GROSSLY insolvent. The SEC has obstructed my allegations for several years while allowing NITE to write down this structural liability on more than 1 occasion. Further, sell side analists at the guidance of Cifu et al never question these EGREGIOUS balance sheet issues. AND, with the grossly corrupt SEC blessing, Cifu et al never disclose insolvency in any SEC + +filing OR investor presentation. + +After dismal April/May REPORTED OTCM volumes on the FINRA now controlled website, June saw a dramatic + +spike in share volumes. + +The Top 25 OTCM money laundering shells by share volume in June 2020 and share price + +PLYZ .00015 PVDG .0008 RTON .00015 GRST .001 + +RNVA .76 (rev split) + +OZSC .0049 EWLL .0002 VSYM .0012 OPTI .14755 MOM .0001 SIML .00025 IGEN .0084 XMET .0002 GTEH .0001 ABCE .0003 TSOI .007 NTRR .0014 GFTX .0005 LVXI .0003 SGMD .0024 INQD .002765 RBNW .0005 TLSS .0238 + +Combined price approximately \$1 + +How do stocks trade to trip zeroes? More buyers than sellers? + +Covering/closing out naked short fails shouldn't be an issue. ONLY explanation: abusive naked shorting: + +MANIPULATION. NOT Bona Fide market making. + +As a direct result of this massive, ongoing SEC facilitated fraud on the public, ABSOLUTELY NOTHING HAS + +CHANGED. + +The record is irrefutable: SEC criminal obstruction while screwing whistleblowers like me to facilitae a + +MASSIVE,ongoing fraud on the public. Key facilitator: Jay Clayton/Jared Fishman: Sull Crom + +Cheers! + +Christopher J Dilorio + +Whistleblower + +From: Chris Dilorio ‹ > + +Sent: Thursday, July 30, 2020 9:31 AM + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight TCR & Appendix + +MORE SEC corruption/obstruction/screwing whistleblowers like me. + +Per my 2013 TCR attached Janey, we know that Schwarzman/Blackstone has played a key role in perpetuating + +A stroll down the record Janey: Around the same time as the SEC/BX/JEF/GS et al August 1 2012 NITE "trading glitch", Schwarzy/BX were key advisers to bondholders of Eastman Kodak and to the company also. Jason New: + +Blackstone was re elected to the KODK BoD in May 2020. + +https://www.sec.gov/Archives/edgar/data/31235/000156459020027039/kodk-8k 20200520.htm + +Then the Pumper/Grifter in Chief Trump goes out wide and far with this absolutely incredible news: + +The camera/film company Eastman Kodak is now going to be the US savior in pharma ingredients supply chain. This is a page out of the penny stock grifter playbook. This is what happens when we have a WH full of money laundering shell grifters. So, what has been the result of this incredible pump/transformation? KODK has gone + +from 2 to 90 back to 40. + +As is typical Trump/grifters/ and his criminal Clayton led SEC: the public hasn't seen a 8K filed by KODK to detail this incredible "transformation". The SEC has given its blessing to yet ANOTHER Trump/Grifter/Bag Men P&D. in + +KODK, FBO Trump BFF and Sull Crom client: Knight "savior" Schwarzy/BX. Had the grossly corrupt SEC + +investigated my claims instead of obstructing them and screwing me, MAYBE Schwarzy/BX would have thought + +twice about their latest grift: KODK. We know that Schwarzy is also a prolific GOP donor. + +F'n criminals Cheers! + +Christopher J Dilorio + +Whistleblower + +From: Chris Dilorio + +Sent: Thursday, July 30, 2020 6:33 AM + +Still MORE IRREFUTABLE evidence of SEC criminal obstruction and corruption while screwing whistleblowers like me. Per the record Laney: Trump PA campaign Mgr David Urban on the BoD of #1 money laundering shell trader and Clayton/Sull Crom client NITE. Urban also on the BoD of money laundering shell: Pakastani/Canadian pot company w/ 200k in revenue FSD Pharma:HUGE. Today HUGE is up more than 100% on "news" it will pivot away from growing pot in Canada to "developing" a pot based cure for Covid. A money laundering shell. Of course, the grossly corrupt SEC has approved a \$20 million public offering for Urban/Trump: HUGE + +SEC facilitated P&D to facilitate money laundering + +https://www.sec.gov/Archives/edgar/data/1771885/000106299320003258/formsuppl.htm + +AGAIN, the SEC is a criminal organization facilitating criminal activity and protecting criminals at the expense of + +the public it is MANDATED to protect while screwing whistleblowers like me. + +The record is extensive. + +Cheers! + +Christopher.' Dilorio + +Whistleblower + +From: Chris Dilorio + +Sent: Tuesday, July 28, 2020 7:48 AM + +subject. Fw. Formai appeal tor preliminary time' covered action ZU1S-Olb/ Knignt tapitai ILK & Appenaix + +STILL MORE OVERWHELMING evidence to support my extremely serious allegations that the SEC is a criminal + +organization, run by criminals, to support cfriminal activity while screwing whistleblowers like me. + +Farkas: Michael: is a prolific Bag Man well known to the SEC. Farkas chose a Jaclin money laundering shell INTENTIONALLY. Blink Charging (BLNK) is ANOTHER SEC facilitated fraud on the public the SEC is MANDATED to + +As is SOP for the grossly corrupt SEC: Revoked AFTER this massive fraud on the public was complete + +https://www.sec.gov/litigation/admin/2009/34-60013.pdf + +ALSO SOP for the corrupt SEC: No mention of Farkas and his controlling i Incubator entities in the complaint + +https://www.sec.gov/Archives/edgar/data/1044693/000104653200000261/0001046532-00-000261-index.htm + +https://www.sec.gov/Archives/edgar/data/1044693/000104653200000265/0001046532-00-000265-index.htm + +https://www.sec.gov/Archives/edgar/data/1044693/000104653200000263/0001046532-00-000263-index.htm + +ALSO missing from the i Incubator complaint: Executing BD/MM of the worthless Farkas certs dumped on the + +public while the grossly corrupt SEC watched. Those damn "penny stock trading fairies" AGAIN! + +NOPE. + +BLNK never should have happened. Farkas, his NETE CFO, Keener, Nordlicht, etc etc should have been shut + +down LONG AGO + +Cheers! + +Christopher.' Dilorio + +Whistleblower + +From: Chris Dilorio + +Sent: Thursday, July 23, 2020 5:59 AM + +The grossly corrupt SEC response to whistleblower OVERWHELMING evidence of money laundering ,manipulation, and fraud: MY INFORMATION has been remarkably consistent over the last 9 years++: + +Obstruct, cover up, facilitate illegal activity at the expense of the investing public it is sworn to protect while + +screwing whistleblowers like me. + +BLNK: A KNOWN Jaclin money laundering shell. Rev merger with a KNOWN Bag Man: Michael Farkas who was + +the largest shareholder of ANOTHER money laundering shell: SkyWay but somehow escaped the SEC + +investigation. With Board members like Engel: Drexel, Scigliano: Acies: NETE a CFO:New from NETE. A known to the SEC Bag Man: Keener who the SEC has kept up and running for YEARS since being BARRED (Not Exactly) by + +Industry SRO FINRA. + +In addition to that name Farkas: ANDREW/Jonathan Farkas. Trump fundraiser and Epstein: Jeffrey: business partner, this fraud has an added element. So, after receiving my overwhelming evidence with AML red flags too numerous to count, what was the par for the course SEC response: Approved BLNK public offering just several days ago AND with my overwhelming evidence in hand. But, that's not where the corrupt SEC active facilitation of this massive fraud on the public ends. Yesterday, 7/22, BLNK put out a PR linking it to a few hundred charging stations in VA,MD,DC. This pr drove the stock up almost 30% at 1 point and closed 15% higher on almost 8x avg volume. A most certainly "MATERIAL" event. AND an event that required an SEC 8k filing if "DEFINITIVE" as well. No such 8K was filed by BLNK for this pr. This pr therefore must be complete FRAUD intended ONLY to facilitate + +a massive Pump and Dump on the public. It accomplished its intended fraudulent outcome. + +But, back to BLNK fka New Image Concepts: the company + +Between Blink and New Image Concepts, BLNK was known as Car Charging Inc + +https://www.sec.gov/Archives/edgar/data/1429764/000114420414059745/v390669 defl4c.htm + +This 2014 SEC approved offering also had several red flags of its own. WHOPPERS in fact. Guess who ELSE was involved in this years in the operating money laundering shell? + +Platinum Funds/Nordlicht. With links to Kushner(s) and Trump lawyer Giuliani. Other NY entities, a Columbus + +OH entity, a Chicago entity, and a Belize entity. Still counting the AML red flags? + +The icing on the top of this massive SEC facilitated fraud: ex NM Governor Bill Richardson. + +Who, is also linked to Jeff Epstein and his NM Zorro Ranch. + +BLNK: money laundering fraud on the public ACTIVELY facilitated by the SEC in July 2020 despite overwhelming + +whistleblower (me) information. Linked to Milken,Russia, Trump, and Epstein. Of course the 7/22 trading activity NEVER would have happened without willing, executing BD's and MM's like the criminal entity known + +as Knight,KCG,VIRT: NITE. Which has also been kept up and running by the grossly corrupt SEC despite overwhelming evidence of a massive, ongoing, criminal conspiracy detailed by a whistleblower: me. + +Cheers! + +Christopher J Dilorio + +Whistleblower + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +Greetings grossly corrupt SEC et al + +Still MORE SEC facilitated fraud on the public it is mandated to protect: BLNK: Farkas/JMJ/Jaclin/CFO New(NETE) money laundering fraud + +today's pr + +https://www.globenewswire.com/news-release/2020/07/22/2065815/0/en/Blink-Charging-Awarded-Grantfrom-Virginia-Clean-Cities-to-Place-200-Fast-Level-2-Charging-Stations-Across-the-Mid-Atlantic-Region.html + +Of course, BLNK didn't file an SEC reviewed 8K for this material, definitive agreement that has the stock up 27% + +on 5x normal volume at 10:30 EST + +In fact, the last filing with the SEC by BLNK was actually the SEC declaring effective a public offering of securities + +on 7/15/20. 1 week ago today. + +MORE SEC facilitated fraud on the public. + +Cheers! + +Christopher Dilorio + +Whistleblower + +Sent: Tuesday, July 14, 2020 3:31 PM + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +OH JOHNNY! + +https://www.reuters.comiarticleibc-finreg-fbi-laundering-private-equity-idUSKCN24F1TP + +FBI concerned over laundering risks in private + +equity, hedge funds - leaked document - + +Reuters + +The U.S. Federal Bureau of Investigation believes firms in the nearly \$10-trillion private investment funds industry are being used as vehicles for laundering money at scale, according to a + +leaked ... + +www.reuters.com + +Janey, + +Even though you admit not distributing my information within the SEC, I was busy distributing it myself to + +others. + +Carl baby, I'm afraid this means your first "investigation" of my complaints to you wasn't exactly "thorough" as + +I've been saying for years. + +Shall I point out the pages for you? + +Blackstone wanted to buy NITE but only AFTER theirSEC/JEF et al orchestrated August 1 2012 "glitch" + +"luckiest f'ers" on the Street + +https://www.businessinsider.com.au/blackstone-dodged-a-bullet-with-knight-capital-2012-8 + +Capital Before Its Stock Collapsed + +One company is breathing a sigh of relief after a trading glitch sent shares of Knight Capital Group from more than \$10.30 to + +nearly \$2.50 last week. + +www.businessinsider.com.au + +From my TCR you admit never distributing Janey + +https://www.reuters.com/article/us-wealth-summit-ubs-blackstone-idUSTRE6A055020101101 + +UBS brokerage's McCann sees more + +Blackstone ties - Reuters + +UBS , rebuilding a brokerage hard-hit by the financial crisis, lately has been mingling in some good company: Blackstone Group LLP. + +www.reuters.com + +The UBS award application I sent to Janey TEN TIMES from a commercial fax machine: + +ALSO MY INFORMATION + +https://www.sec.gov/enforce/34-84828-s + +SEC.gov I SEC Charges UBS Financial Services Inc. with Anti-Money + +Laundering Violations + +ADMINISTRATIVE PROCEEDING File No. 3-18931. December 17, 2018 - The Securities and Exchange Commission today announced settled charges against broker-dealer UBS Financial Services Inc. for failing to report suspicious transactions in customer accounts. UBS agreed to pay a \$5 million civil penalty to + +resolve the SEC's charges, and separately agreed to pay \$10 million to the U.S. Treasury ... + +www.sec.gov + +y'all are gonna be FAMOUS! + +From: Chris Dilorio + +Sent: Tuesday, July 14, 2020 12:34 PM + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +MORE SEC corruption/obstruction + +ANOTHER Jaclin money laundering shell: + +https://www.sec.gov/Archives/edgar/data/1449527/000121390008002174/fsl prcomplete.htm + +YESDtc Holdings fka PR Complete + +https://www.sec.gov/cgi-bin/browse-edgar?ClK=1449527 + +MORE related entities to my claims: + +Bill Scigliano: Chairman BoD + +Scigliano was also a Director at Oleg Firer's revoked but still very much up and running in MA: Acies Corp. Acies was incorporated by His Eminence with a NY address of 14 Wall Street: Rovt: Allied Wallet: WireCard. Jaclin and + +Oleg related entities/people: Money laundering shells. Is the grossly corrupt SEC regretting their Jaclin + +complaint which was a cover up for much larger criminal activity: MY CLAIMS? + +But there's more. + +The SEC also brought "more coverup than complaint" In Frost,Honig,Alpha,Stetson et al. The SEC Knows who + +else was involved in the Jaclin money laundering shell PRComplete/YESDtc: + +Barry Honig/GRQ + +Who was the executing BD/MM converting all these billions of worthless Jaclin,lronridge,JMJ,Farkas,Honig etc + +etc certs into real money? + +The SEC response: "penny stock trading fairies". NOPE: NITE + +How is it possible that there is NO reference to AML in ANY of these SEC complaints? + +Because the SEC outsourced BD compliance with the BSA to industry advocate FINRA. DUH + +Then, there's the Jaclin money laundering shell New lmage/BLNK. Gee, wonder if Farkas of money laundering shell Skyway, JMJ/Keener: money laundering shells in my claims, Engel: Drexel, Jonathan New NETE CFO, etc + +knew BLNK was/is a money laundering shell too. + +His Eminence Firer is a prolific Bag Man. I've been telling the SEC that for years. + +Janey, update my NETE and AQR TCR's. You know, for the record. Several entities in my TCR's linked to Jaclin's + +shell factory. Including NITE. + +I've asked this many times Janey,Jay,Hoecker et al: + +WHAT EXACTLY DOES THE NITE COMPLIANCE DEPARTMENT DO EXACTLY? + +Other than looking the other way while they naked short publicly traded shells to facilitate money laundering + +that is + +Cheers! + +Christopher J Dilorio + +Whistleblower + +From: Chris Dilorio ‹ > + +Sent: Monday, July 13, 2020 10:50 AM + +u ject: w: Formal appeal or preliminary denial covered action Knight Capital TCR & Appendix + +Janey, Hoecker, Jay et al + +still MORE SEC attempts to cover up illegal activity at the expense of the public it is mandated to protect. + +The SEC latest Rule change proposal + +https://www.sec.govinews/press-release/2020-152 + +SEC.gov I SEC Proposes Amendments to Update Form 13F for Institutional + +Investment Managers; Amend Reporting Threshold to Reflect Today's + +Equities Markets + +The Securities and Exchange Commission today announced that it has proposed to amend Form 13F to update the reporting threshold for institutional investment managers and make other targeted changes. + +Will exempt 90% of current 13F filers from future equity holdings disclosures. + +WHO does that benefit? Certainly not the public the SEC is mandated to protect. LESS transparency still for the + +likes of Keener,Sason,Asher/Kramer,IBC,Ironridge/Coulston,Alpha,Dutchess,Crede, etc etc etc + +Costs to file: pocket change + +https://www.netacn.com/Service.aspx?id=dLfmwmZHCkOsIL-sP3V8Dw + +Form 13F EDGAR Filing Agent Service :: Advisor Consultant Network + +ACN will compile your 13F Report and act as your Filing Agent in order to submit the report to EDGAR. Send us your Holdings List, we compile the Form 13F Report and send you a Proof for your review and approval. Upon your approval we will submit the report to EDGAR. You will receive an email notification as + +will ACN that the report has been accepted. + +www.netacn.com + +So, WHY does the SEC want LESS transparency for the investing public it is mandated to protect? + +The SEC is bought and paid for by criminals. + +Cheers! + +Christopher.' Dilorio + +Whistleblower + +From: Chris Dilorio + +Sent: Wednesday July 8 2020 9:35 AM + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +Janey, Hoecker et al, + +Is Trump prolific Bag Man Jonathan Farkas related to Bag Man Michael Farkas: Skyway largest shareholder: + +REVOKED + +https://www.hollywoodreporter.com/rambling-reporter/inside-hamptons-fundraisers-netted-trump-12m- + +election-1230690 + +Inside the Hamptons Fundraisers That Netted + +Trump \$12M for Re-election I Hollywood + +Reporter + +The numbers are in and President Donald Trump's quick trip to the Hamptons on Friday raked in \$12 million for his re-election campaign as his Republican allies were quick to declare it a win ... + +www.hollywoodreporter.com + +Now Michael Farkas is CEO of Jaclin money laundering shell New Image Concepts/Blink charging + +How did Farkas (Michael) escape the SkyWay SEC complaint? https://www.sec.gov/litigation/complaints/2009/comp20960.pdf + +Would explain the Milken/Drexel flunkie Engel on the BLNK BoD as well. + +Also explains why the grossly corrupt SEC let Bag Man JMJ/Keener up and running in 2020 and the + +Crede/Milken/Putin etc NETE CFO New now CFO at BLNK + +Some BLNK/Trump/rinsing. With help from "issuer/bag man funded research" Zacks aka Seethroughequities + +2.0. Rusian money? + +Cheers! + +Christopher J Dilorio + +Whistleblower + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +Janey, + +MORE EXTRAORDINARY SEC corruption and criminal obstruction designed to protect criminals and screw + +whistleblowers like me. Despite my very generous 4 day offer to produce the entire record which is the basis of + +my award application/denial/appeal AND REQUIRED by the statute I have referenced: + +240.21F-12 "Materials that may form the basis of an award determination and that may comprise the record on appeal", The several hundred e mails I have sent you, Hoecker et al MUST be part of this record. Janey, you failed to produce this record. As I made clear: my 6/23/2020 emails to you Hoecker, SEC commissioners were merely re re re sent previously sent e mails: the record. Further, my 6/23/2020 e mail: Formal appeal for preliminary denial covered action 2015-016 Knight Capital & Appendix was merely a summary of several hundred e mails sent to you, Hoecker et al. These e mails SHOULD be the record. You failed to produce the record. Which begs the question: WHAT "record" was used to determine the SEC preliminary denial exactly IF the SEC can't produce the record? The preliminary denial was completely fabricated and must be reversed. But, it doesn't end there: per my 6/23/2020 summary based on several hundred e mails sent to the SEC, the RECORD of EXTRAORDINARY corrupt obstruction designed to protect criminals and screw whistleblowers is not confined to Opco,NITE,UBSS,Sason,Keener etc etc etc. I have filed 2 TCR's with the OWB related to the money + +laundering/transaction + +laundering/Putin/Rakishev/Trump/Kushner/Alfa/Crede/Peizer/Milken/Hapoalim/SBNY/CardWorks/ESQ/WireCa rd/AQR etc etc etc fraud known as Net Element. For YEARS the SEC has been in possession of not just my TCR's but HUNDREDS of e mails supporting my TCR's comprising the extensive record. Here again, the SEC is covering up a MASSIVE fraud perpetrated on the public and well within even the grossly corrupt SEC ability to shut down + +the fraud IF they had used my information to execute its mandate to do so. Instead, the SEC obstructed a thorough investigation. Per my previous e mails: the record: NETE claimed to be a payment processing entity. Claiming further to process BILLIONS of dollars worth of transactions every year. Its subsidiary Pay Online is linked to the massive fraud Wire Card. How's the SEC Wire Card investigation coming along? For years, based on + +my extensive financials research and other research, I pleaded and pleaded with the SEC to shut down this + +massive fraud. They did not. email after email. Year after year I wrote the SEC "NETE is a money + +laundering/transaction laundering fraud". Rather than shut it down, the SEC with the help of NASDAQ allowed fraud public offerings by Crede/Peizer/Milken related entities: Esousa and Cobblestone and a reverse split so + +NETE could keep its NASDAQ listing. The balance sheet has been grossly insolvent for years: goodwill. + +ALL of my allegations were confirmed when NETE decided to "unlock value in its payment processing" business by doing a reverse merger with a CA EV "manufacturer" started by a musician. This fraud transaction is quite common in money laundering shell land dominated by NITE/VIRT. The SEC cover up of criminal activity while + +screwing whistleblowers:ME: The "payment processing business" is to be "sold". Related of course was the SEC cover up of criminal activity while screwing whistleblowers: ME: The Goldman/Sull Cromm advised purchase by ALLY of CardWorks: Merrick Bank: NETE and then the recent unwinding of this fraud transaction. No doubt the brain child of Chair Clayton and his Sull Cromm colleague Jared Fishman who has played a key role in keeping + +the criminal entity NITE/VIRT up and running. + +NETE/Mullen: "here glitchy glitchy" cover up. But, who the hell would EVER touch the massive fraud: NETE? + +Only another fraud: Mullen. + +Mullen doesn't "manufacture" ANYTHING. Mullen is simply a car dealership. + +The K50 EV is manufactured in China by Ctiantu a subsidiary of CH-Auto. Qiantu/CH have a production facility in + +China. There will be no Mullen "production" of EV vehicles in Washington or anywhere else in the US. + +But, the SEC facilitated fraud doesn't end at protecting criminals and screwing whistleblowers: ME. Per my TCR attached, there is a well orchestrated eco system of fraud. Including "issuer/bag man funded research" that facilitates P&D. In fact, on 11/8/2018 the SEC brought a complaint against an entity I cited in 1 of my emails to + +the SEC: the record: known as SeeThroughEquity + +https://www.sec.gov/litigation/complaints/2018/comp-pr2018-259.pdf + +Seethruequity, LLC, Ajay Tandon, and Amit Tandon + +THE DEFENDANTS 6. SeeThruEquity, LLC is a Delaware limited liability company that was co-founded in + +2011 by brothers Ajay Tandon and Amit Tandon. + +www.sec.gov + +SeeThroughEquity was engaged in a Pump and Dump promotion of NETE in April and August 2018 + +https://www.netelement.com/press-releaseskelease-content/1062906#.XwRXEOWSnIV + +SeeThruEquity Issues Update on Net Element, Inc. + +NEW YORK, NY / ACCESSWIRE / April 10, 2018 / SeeThruEquity, a leading independent equity research and corporate access firm focused on smallcap and microcap public companies, today announced that it has issued an update on Net Element, Inc. 0. The note is available here: NETE April 2018 Update Note. Net Element, Inc. (NASDAQ: NETE, "Net Element") is a global financial + +www.netelement.com + +hups://www.netelement.com/press-releases/release-content/10734671#.XwRXGuWSnIV + +SeeThruEquity Issues Update on Net Element, Inc. + +NEW YORK, NY / ACCESSWIRE / August 6, 2018 / SeeThruEquity, a leading independent equity research and corporate access firm focused on smallcap and microcap public companies, today announced that it has issued an update on Net Element, Inc. 0. The note is available here: NETE August 2018 Update Note. Net Element Inc. (Nasdaq CM: NETE, "Net Element") is a global financial + +So, the SEC SeeThroughEquity complaint acknowledges the fraud associated with NETE. Well orchestrated. This P&D campaign was part of the 2 fraud offerings : Esousa and Cobblestone: I alerted the SEC to. Who PAID for + +the SeeThrough P&D? Crede/Peizer/Esousa/Cobblestone? + +The cherry on top of the SEC corrupt obstruction: NETE was still in business in 2020 to receive taxpayer Cares + +Act money. + +A summary of the record. Janey, Hoecker et al, + +Please update my Net Element and AQR TCR's + +Cheers! + +Christopher J Dilorio + +Whistleblower + +Not just irony but a massive fraud on the + +From: Chris Dilorio + +Sent: Tuesday, June 30, 2020 1:01 PM + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +Janey, + +the purpose of your 5 years in the waiting PRELIMINARY denial of my OpCo Award application could not be any more clear: run the clock out and protect NITE,UBSS,Magna et al while denying me rightful compensation. But, As I have repeatedly told you, Hoecker, your colleagues: the last overt act of this vast conspiracy has not yet + +occurred: + +NITE/VIRT is insolvent today 6/30/2020 as a direct result of the SEC facilitated fraud on the public which is and always has been the core business at NITE/VIRT: Abusive naked shorting publicly traded shells to facilitate money laundering. The public is STILL at risk. The SEC has facilitated NITE intentionally misleading the public as to the true nature of its business. The SEC still facilitates this massive fraud on the public while it intentionally misleads the public there is no naked shorting because the SEC authorized the DTCC to create the illegal, shadow clear mechanism Obligation Warehouse (OW) so NITE's criminal activity can continue and it can + +circumvent close out REQUIREMENTS of Rule 204 of Reg SHO. ALL very much ongoing in June 2020 as a direct result of the SEC (OWB/Hoecker/Enforcement etc etc) criminal obstruction and ACTIVE facilitation of the + +criminal enterprise known as Knight/KCG/VIRT: NITE. + +Clayton never disclosed his Sull Crom/Fishman/NITE conflicts. He must step down from the SEC IMMEDIATELY + +until a criminal investigation can be concluded. NITE must be halted IMMEDIATELY as it still poses a + +monumental risk to the investing public. FINRA should go back to being a cheerleader as it is just another + +enabler of this criminal activity. It has NO business enforcing SECURITIES LAWS. It should not be overseeing the OTCM. FINRA fines are a joke and not meant to be a deterrent. INTENTIONALLY siding with criminals over the investing public the SEC is mandated to protect. The cesspool known as the OTCM MUST be shut down. It exists SOLEY for the purpose of facilitating a massive fraud on the public. The OW must be shut down IMMEDIATELY so the public can see just how pervasive naked short selling: MANIPULATION really is. EVERYONE at the SEC who has had contact with my information MUST resign/be terminated IMMEDIATELY. ALL of the AQR blank check shells must be shut down IMMEDIATELY as they pose a serious national security risk. AQR MUST be shut + +down IMMEDIATELY. + +Certainly not exhaustive BUT a good start + +Cheers! + +Christopher J Dilorio + +Whistleblower + +From: Chris Dilorio •c: > + +Sent: Tuesday, June 30, 2020 7:36 AM + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +Janey, + +please add the following info to my appeal of your preliminary denial of my Opco award. + +More evidence the SEC is using/has used my information to both bring complaints and protect/obstruct + +complaints. Again, you, McKessy, Hoecker have been in possession of my 2013 TCR filed with Berger for several years. In addition to hundreds of e mails continuing into 2020 showing irrefutable and overwhelming evidence + +to support my allegations. + +assignments: bogus notes. NO SHIT? Really? detailed by me. In addition to Bag Man Sason/Hanover/Magna, I detailed the illegal activity of Bag Man Justin Keener/JMJ in my 2013 TCR. Keener was the customer in the + +FINRA World Trade Financial complaint. + +hups://www.finra.org/media-center/news-releases/2013/finra-fines-three-firms-900000-inadequate-anti- + +money-laundering + +FINRA Fines Three Firms \$900,000 for Inadequate Anti-Money Laundering + +Programs I FINRA.org + +WASHINGTON - The Financial Industry Regulatory Authority (FINRA) announced today that it has fined three firms a total of \$900,000 for failing to establish and implement adequate anti-money laundering + +(AML) programs and other supervisory systems to detect suspicious transactions. + +www.finra.org + +Related to the billions of OTCM money laundering shells traded through World Trade, the BD SRO FINRA requested information from Keener related to his assignments and acquisition of bogus convertible notes + +including bank statements to prove the notes weren't bogus. Keener told FINRA to 'F Off" + +hups://www.finra.org/sites/default/files/OHODecision/p182993 0 0.pdf + +FINANCIAL INDUSTRY REGULATORY AUTHORITY OFFICE OF HEARING + +OFFICERS + +5 distributions of securities in violation of Section 5 of the Securities Act of 1933. Tr. 158, 179-180.6 On + +September 22, 2011, FINRA staff served a request on Keener, pursuant to FINRA + +www.finra.org + +FINRA barred Keener/JMJ in 2013 as a "Bad Actor" The SEC was certainly aware of the FINRA action + +hups://www.sec.gov/litigation/opinions/2012/34-68014.pdf + +As recently as 2019 Bag Man Keener/JMJ was involved in ANOTHER money laundering shell called Blink + +Charging fka New Image Concepts + +https://www.sec.gov/cgi-bin/browse-edgar? + +action=getcompany&CIK=0001429764&owner=exclude&count=40&hidefilings=0 + +https://www.sec.gov/Archives/edgar/data/1429764/000114420419004046/0001144204-19-004046-index.htm + +Blink Charging Co. (Subject) CIK: 0001429764 (see all company filings) IRS No.: 030608147 I State of + +Incorp.:NV I Fiscal Year End: 1231 Type: SC 13G/A I Act 34 ... + +New Image Concepts was detailed by the SEC in their Jaclin et al "Shell factory" complaint in 2016. PRIOR to + +Keener involvement. + +https://www.sec.gov/litigation/complaints/2016/comp-pr2016-86.pdf + +Case No. 2:16-cv-03250 + +1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Case 2:16-cv-03250 Document + +1 Filed 05/12/16 Page 1 of 45 Page ID #:1 AMY JANE LONGO, Cal ... + +vAvw.sec.gov + +But Keener not the only 1 involved who knew New Concept was a money laundering shell. CEO of Blink is Michael Farkas. SEC knows him well from his Skyway Communications days. + +The SEC revoked the registration of Farkas/Skyway in 2007 + +https://www.sec.gov/cgi-bin/browse-edgar? + +action=getcompany&CIK=0001128723&owner=exclude&count=40&hidefilings=0 + +The CFO of Blink is Jonathan New. Formerly CFO of the AQR/Crede: Milken money laundering/Transaction + +laundering blank check shell: Cazador/Arco: Net Element + +A director of Blink is a guy named Donald Engel who worked at Drexel with Milken. + +New Concepts was HQ'd in Santa Monica: Milken + +But it gets better + +the Jaclin shell factory also linked to Honig,Stetson,Alpha Cap, Frost as well + +http://www.teribuhl.com/2019/08/06/honigs-shell-factory-attorney-gregg-jaclin-barred-as-sec-lawyer/ + +Honig's Shell Factory Attorney Gregg Jaclin + +Barred as SEC lawyer - TERI BUHL + +Your Voice. High Times Admits SEC Filing is Wrong: Stormy Simon + +off the Board - L.A. Cannabis News on Text messages show Cannabis investors Defrancesco & Serruya allegedly Colluded with Clarus Securities' Christodoulis in Multiple Stocks; High Times Admits SEC Filing is Wrong: Stormy Simon off the Board - + +www.teribuhl.com + +Where the SEC said multi billionaire Frost risked ALL to make a few million. NO, Frost,Alpha (also in my attached TCR), Stetson, Honig were LAUNDERING. Frost bought Ladenburg from Milken flunkie Icahn AFTER Icahn rolled + +Millenium Bio/Inergetics + +linked to Trump Cleveland fundraiser and healthcare fraud felon: Brian Colleran In typical SEC "cover up", revoked the Millenium/Inergetics registration in 2019. + +https://www.sec.gov/cgi-bin/browse-edgar? + +action=getcompany&CIK=0000072170&owner=exclude&count=40&hidefilings=0 + +Finally, + +SEVEN F'n Years AFTER FINRA barred (not exactly) Keener/JMJ and my Berger TCR filed with your office Janey, + +The SEC is going after Keener/JMJ related to my information AGAIN + +17.5 BILLION shares of money laundering penny stocks. + +https://www.sec.gov/litigation/litreleases/2020/Ir24779.htm + +Justin W. Keener d/b/a JMJ Financial (Release No. LR-24779; Mar. 24, 2020) + +SEC Charges Unregistered Penny Stock Dealer Litigation Release No. 24779 / March 24, 2020 Securities and Exchange Commission v. Justin W. Keener d/b/a JMJ Financial, No. 20-cv-21254 (S.D. Fla. March 24, 2020) + +vo.yw sec gov + +WHO was/were executing BD's/MM's in these billions of shares of worthless Keener/JMJ money laundering + +shells???? + +What are odds that bogus note/worthless certs/assignments Sason/Magna would be involved with bogus notes/worthless certs/assignments Keener/JMJ in money laundering shells like IMDS and CGFIA etc) AND CGFIA was detailed by me to the SEC/FINRA AND CGFIA was 1 of the shells in the FINRA Opco AML complaint + +AND where NITE and UBSS traded billions of shares of CGFIA AND where NITE and UBSS traded billions of shares of IMDS also + +Now, what are the odds of all of that? + +All you have to do is read my attached TCR Janey. + +Cheers! + +Christopher J Dilorio + +Whistleblower + +From: Chris Dilorio + +Sent: Tuesday, June 23, 2020 4:11 PM + +Mirror trade activity peaked in 1H2014 not 2H2014 and this coincides with OTCM astronomical share volume data in 1Q2014 and 2Q2014 that were expunged from KCG 10Q SEC filings. Not 2Q2014 and 3Q2014 SEC + +reviewed 10Q's as I previously stated + +corrected below + +Chris + +From: Chris Dilorio •c: > + +Sent: Tuesday, June 23, 2020 9:48 AM + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +Ms Norberg, + +I am in receipt of the SEC OWB correspondence allowing me more time to respond to the preliminary denial of my award application for the Oppenheimer 2015 covered action. This e mail was the last 1 I sent to your office + +related to my appeal. It will serve as the basis of my appeal. Including the attachments of my 2013 TCR submitted with Berger Montague to the SEC. I will also forward correspondence from 2012 and following detailing my extensive correspondence with Robin Traxler at FINRA as well as Sean McKessy in the OWB. Even though, I have previously forwarded your office as well as the SEC IG office the exact same corroborating + +evidence. My response to you will be lengthy and detailed. However, given that it took your office FIVE YEARS to + +send me a preliminary denial notice, that is understandable and in fact a result of YOUR lengthy delay in + +notifying me. ALL of my response pertains to the denial appeal at hand. + +In 2011, I filed my first Whistleblower complaint with the SEC. Detailing a massive fraud on the public directly implicating dozens of entities. The center of my claims: Knight/KCG/VIRT: collectively NITE and the Swiss banking giant UBS:UBSS. By far, NITE was and still is today the largest MM/executing BD in the OTCM space. I was shocked to find the Swiss banking Giant UBSS was trading many of the same stocks as NITE and to the extent they were. This came on the heels of the FINRA UBSS Reg SHO complaint where the extent of the UBSS activity "threatened to undermine the integrity of our markets" while the SEC analysis of this activity was simply a case of "sloppy record keeping". My experience as an Institutional Sales trader: executing multi million share equity trades for the largest institutions in the world like Fidelity and Putnam. In addition, as a Research Sales person: analyzing financial statements and making investment recommendations formed the basis of my + +expertise. In fact, the SEC OWB has paid out awards for information just like mine. In August of 2011, I informed the SEC that NITE was insolvent having reported just \$105 mil in working capital at June 30, 2011. AND, for the + +clearing/reverse splits/cusip changes etc. The SEC had a choice: investigate these extremely serious allegations and shut down this massive fraud on the public OR cover up their failure and allow this massive fraud on the public to continue. Unfortunately for the American public the SEC is mandated to protect, the SEC chose the latter. As a direct result, ALL of the activity detailed by me in this TCR and other TCR's filed with the SEC as well as 9 years of additional correspondence with the SEC, this is very much an ongoing, massive scheme. One that the SEC actively facilitates. Countless losses have been incurred as a result. NITE as I detailed is in a constant state of insolvency. The SEC has time and again intentionally misled the investing public that there is no abusive + +naked shorting. NITE is still in business TODAY. + +The core business at NITE is and always has been: abusive naked shorting OTCM shells to facilitate money laundering. Not DMM, FCM, reverse mortgages, or even HFT. This illegal business is EXTREMELY profitable and virtually riskless. AND, both the SEC and FINRA know this. In 2016, FINRA brought a Rule 204 complaint against NITE. The fine was pathetic and not meant to be a deterrent. This is WHY the OTCM exists. But it's not JUST OTCM as my AQR TCR filed with the SEC clearly proves: NASDAQ Blank check shells as well. I have also filed + +separate TCR's related to NewLead and FreeSeas: 2 massive money laundering shells which began on NASDAQ,de listed to the OTCM. NONE of the activity detailed in the Opco/Gibraltar complaint takes place without a willing executing BD/MM who ultimately turns worthless certs into real money. That #1 trader is NITE. As you read in my Knight TCR CGFIA is at the heart and, because it was based in Colorado, became a + +template of sorts for my extensive research. See Ms Norberg, unlike the SEC "investigators" on the + +Opco/Gibraltar complaint, I've actually seen first hand the CGFIA "world HQ" as well as the rented Littleton + +home of CGFIA CEO Guyer. I've done extensive research on Properties claimed to be owned and M&A + +transactions done for the sole purpose of cert printing and distribution (Aurelio AMNP) where the ultimate acquisition amounted to a distributor of Ukrainian folk music. I've also done extensive research on domestic and foreign financial institutions claiming to "invest" in these scam companies like Josh Sason/Hanover/Magna also cited in my 2013 Berger/Knight TCR linked. So, as I detailed to Ms Traxler, I followed Guyer to Neuchatel Switzerland and his previous endeavor: Antelope Technologies also with an office in Highlands Ranch CO. + +Where I discovered a connection to Swiss/German individuals/entities that were also related to another OTCM shell in the OpCo/Gibraltar complaint as well as my Knight TCR: AppTech. Offices in the Woodlands TX and Boca Raton. AND very much up and running today. SHOCKING. The SEC OpCo/Gibraltar complaint is based on the FINRA complaint. That is absolutely irrefutable. As the Gibraltar complaint alleges just 1 OTCM shell and just a million shares while Commissioners Stein and Aguilar referenced BILLIONS of shares in their OpCo waiver dissent. Who executed those BILLIONS of shares? Was OpCo even a MM? If I ask a question it's typically a rhetorical: I know the answer. The SEC knows the answer also. The SEC OpCo complaint does not mention the executing BD/MM. The SEC complaint doesn't mention Sason/Hanover/Magna either. The SEC complaint makes no mention of illegal naked shorting which is clearly evident in the CGFIA 10Q referenced below. THIS IS MY INFORMATION. So, why aren't NITE, Hanover/Magna and UBSS implicated in the SEC OpCo/Gibraltar complaint? What my TCR clearly and irrefutably proves: NITE was engaged in illegal activity both BEFORE and AFTER the + +SEC et al orchestrated August 1 2012 "trading glitch". So, the SEC bailed out a KNOWN criminal entity. + +Unfortunately for the investing public, the SEC has doubled downed on facilitating this illegal activity into 2020. The "glitch". Knight was insolvent in August 2011. I told the SEC this. The "glitch" proved my allegations. Key point in my TCR: NITE inadvertently sent 4000 worthless securities to JPM to secure an emergency bridge financing as collateral. These were open, naked short fails that could not be covered/closed due to a cusip change (SEC/FINRA approved rev split) booked as an "asset"(receivable) due to self clearing: MASSIVE + +accounting fraud. Ironically, the "glitch" proved my allegations: despite claiming to have a "highly liquid balance sheet" NITE had to raise the entire amount of the "glitch". AND the ultimate "financing" was not collateral based. Rather a 50% discounted convert when the stock had already been crushed to \$3 OR \$1.50. ALL of the financing participants knew the NITE balance sheet was complete fraud. NITE also committed securities fraud in + +Further, I submitted my amended TCR with Berger in March 2013, In August of 2013, FINRA brought a penny stock AML complaint against OpCo. Sale of unregistered penny stocks. WHO ultimately executed the trades? 2008-2010. In July 2013, the "glitch" financing Gen Atlantic/Getco reverse merger with Knight to form KCG closed. The new CEO of KCG was Dan Coleman who ran Equities at UBSS during their Reg Sho and cross border + +activity. For UBSS, the DOJ (Acosta Downing et al) dropped their DPA in 2010. My claims: the FINRA + +OpCo/Gibraltar complaint clearly implicates UBSS criminal activity AFTER the DoJ dropped its UBSS x border DPA. This is what the SEC is protecting in the OpCo/Gibraltar complaint: NITE/UBSS/Hanover/Magna illegal + +activity. + +Also in my Knight/Berger 2013 TCR: IMDS. A multi year money laundering shell kept up and running by the SEC. + +Also NITE,UBSS, and Hanover Magna. In addition to other entities like JMJ, Southridge, and Alpha Capital Anstalt. Alpha Capital Anstalt is very much in business today as a result of SEC obstruction while the SEC recently brought a complaint against JMJ for activity like that in IMDS even AFTER he was barred by FINRA. In IMDS, the SEC allowed 2 barred individuals (CEO/CFO) to do an offering that created 37 BILLION shares of IMDS at .0001 with Chinese Nationals before revoking the IMDS registration. What do you do with 37 billion shares of IMDS at .0001 when there are no bids below that? NOTHING. The stock never traded. The SEC orchestrated a NITE/UBSS/Hanover/Magna/JMJ/Alpha etc MASSIVE naked shorting to facilitate money laundering scheme bailout so that the MASSIVE naked short position didn't need to be covered in the open market as is mandated + +by Rule 204. Thus insuring profits and not MASSIVE losses for NITE and UBSS. + +I also filed separate TCR's for NewLead and FreeSeas. 2 "Greek shipping" money laundering shells started on NASDAQ and delisted to OTCM. NITE top trader in BOTH. Hanover/Magna in both. I contacted the KY Div of Mines and notified the SEC that these "transactions" were complete fraud. The SEC Feb 2019 complaint against Hanover/Magna is my information: Bogus obligations, assigned, converted to worthless certs. Then dumped on the public and converted to REAL money by the executing BD/MM:NITE. Who generates illegal trading profits by abusive naked shorting. Very symbiotic relationship. 1 of the Hanover/Magna entities was Gibraltar/Hanover. Somehow omitted from the SEC OpCo/Gibraltar complaint. In NewLead, then SEC White and Ceresney firm Debevoise did a "fairness opinion" of a Russian Nickel wire transaction where the NewLead CEO had back dated + +documents. That has been expunged from SEC reviewed filings. FreeSeas: a structured tax evasion/money laundering shell. Also involved Credit Suisse and Deutsche Bank. Both Debevoise clients. Both involved in the tens of billions Russian Mirror trade scheme. In addition to Hanover/Magna a Milken related entity Crede: Run by Milken/Drexel/Obstruction of justice/Parking: Terren Peizer and his felon partner Michael Wachs. This led me to Net Element NETE. Peizer again. This time with more AML red flags than be counted. Well known to the SEC through TWO of my separate TCR's. CEO is Oleg Firer. Firer former money laundering shell Acies shut down by the SEC while NETE was left up and running. Acies very much up and running also in MA. In NETE: NASDAQ. AQR Blank check shell. SEC allowed 2 offerings so that NETE could keep its NASDAQ listing. 1 was with entity Esousa: felon Wachs ex wife. 2nd was with Cobblestone: felon Wachs sister. I told the SEC. They still approved + +the offerings. I discovered AQR money laundering blank check shell activity doing research on NITE and + +Hanover/Magna. A top traded NITE OTCM shell was Cereplast. Another AQR blank check shell. + +Hanover/Magna/NITE/ and Alpha Capital Anstalt. Alpha is Liechtenstein based and controlled by Martin Schlaff: Austria/Israel. AlsolMDS (w/Schlaff controlled Balmore) and the Frost/Honing/Stetson et al complaint. Schlaff also LH Financial/Wolfson/Sulphco and Bawag: Sedona/Scan Graphics: Refco: Naked shorting. NITE is Refco on + +steroids. Cereplast ended in bankruptcy. + +NETE claims to be a "payment processor". BILLIONS in transactions processed. Never break even let alone profitable. Balance sheet complete fraud. AML red Flags: Firer is Grenada Amb to Russia living in Miami, + +Apockinas/Grinshpun/Antonov/Rakishev/Trump/Kushner/SBNY/CardWorks/Merrick Bank/ESQ/Cohen etc etc etc money laundering/transaction laundering BILLIONS shell. Kept up and running for years since filing my NETE/AQR SEC TCR's. ALL of my allegations proved accurate in 2020 when NETE received Cares Act taxpayer money then announcing it was "unlocking the value in its misunderstood payment processing business" by doing a reverse merger with a CA electric car company started by a former musician. The payment processing business to be "sold" and the new company (Mullen) will own 80-90%. All made possible by SEC obstruction + +and ACTIVELY facilitating illegal activity. Another AQR blank check shell is Astra/Phunware. More Greek shippers related to massive swindler Economou originally intended to do an "energy logistics company" acquisition and somehow settled on "mobile app developer" Austin DC Phunware. PHUN CEO is well known to the SEC with shells going back 15 years. I alerted the DoJ and SEC that PHUN was a money laundering shell. In addition to the "genius quant" AQR, AIPAC: Gerber/Hudson Bay, Nordlicht: Ari Glass/Boothbay, 1MDB: Khazanah Nasional, Global Crown/Rani Jarkas/EFG/BSI/Optima/Max Fang. AG Barr 1MDB waivers: Kirkland also AQR. Broidy: + +Trump: 1MDB money laundering. PHUN also received Cares Act money. AND PHUN is Trump/Kushner/Parscale campaign mobile App. PHUN should have also been shut down long ago. AQR too. OTHER AQR blank check shells: CIS/Delta/Urban Tea, Ability/Cambridge, Hunter Maritime, and MI Acquisition/Priority Tech Holdings. + +Ability/Cambridge: Israeli cellular intercept/surveillance. Israel sent employees to jail. In the US it was + +"securities fraud". The SEC Ability/Cambridge complaint was handled by Ansu Banerjee in the SECLA office. Milken/Mogilevich/BoNY money laundering entity Sinex: Debasish Banerjee. WHY did SECLA have jurisdiction + +over ABILF/Cambridge? Result: ABILF is very much up and running today. I believe this is the + +PHUN/Trump/Kushner/Parscale mobile app technology. + +Hunter Maritime:HUNTF: Never consummated an acquisition. Just cert printing/dumping. Also involved: Milken + +family office: Silver Rock. MI/Priority:PRTH. CEO Tom Priore: well known fraudster to the SEC. Also + +transaction/money laundering like NETE. Also involved: Hanover/Magna. + +ALL AQR money laundering shells up and running today thanks to the SEC. Only recently did the SEC revoke CGFIA and NewLead. well after going dark and the massive fraud on the public had already been perpetrated. In NewLead, FreeSeas, etc etc etc a common tool used is reverse splits to perpetuate and facilitate illegal activity. SEC/FINRA approved. The result is the massive accounting fraud at NITE. WHEN not IF there is an open naked short fail when a rev split takes place, a new CUSIP/security is issued. Trades in the old cusip/security cease. This creates a structural liability. The fail/short can NOT be closed. Like covering a short in AAPL with MSFT. Because NITE is self clearing it books a prop naked short as a receivable. An asset. But, because NITE won't or CAN'T deliver, massive accounting fraud. Literally a liability booked as an asset. This is how "glitches" are born. + +But the SEC facilitated fraud doesn't end there. The definition of a failed trade: 1 that hasn't settled. The SEC/DTCC issue new securities where trades in the old haven't settled yet AND not authorized by the issuer. Settlement: buyer brings cash/seller brings securities. The DTCC simply makes journal entries. But there are still "IOU's" in the system. The SEC authorized the DTCC to create a shadow clear,non guaranteed, ILLEGAL (clearly contrary to 34' Act "prompt and accurate settlement) Obligation Warehouse so criminals like NITE et al can circumvent close out REQUIREMENS of Rule 204. The OW is just what it sounds like. Per my Knight TCR, DTCC suspends services (Chill/Lock) and trades are deemed "ex clearing". In a FOIA request made with POGO,Berger and I asked the SEC fails data on dozens of NITE/UBSS top traded stocks like CGFIA,APCX and MIDS. The SEC response: see our website. The SEC fails data is for DTCC cleared trades only. The SEC knows exactly the level of fails sitting in the OW. They don't disclose. Intentionally misleading the public there is no naked shorting. In 1Q2020, the receivable at NITE/VIRT increased \$1.2 BILLION sequentially. Up almost 90%. AND the tangible book value is grossly insolvent. When it comes down to it, there really isn't ANYTHING in the receivable that NITE can convert into cash for its own use. There are prior commitments on those "assets": SETTLEMENT of transactions. Because the SEC has never shut down this activity, NITE is in a constant state of insolvency. + +Other examples of SEC attempts to cover up NITE illegal activity so that it can continue include: + +Cerberus/Feinberg/VIRT bidding on NITE post "glitch". Wasn't their turn. First, Gen Atlantic needed to monetize its GETCO "investment". The HFT business at GETCO was in a death spiral when the rev merger took place. So what was the attraction to NITE? The business that had absolutely ZERO overlap/synergies: OTCM. As low tech as it gets. Literally a trader sitting in a chair. As I have asked the SEC on hundreds of occasions over the years: what would happen to NITE trading profits if their OTCM share volumes went to ZERO? Cerberus is Feinberg: Gruntal/Milken. Also bailed out Bawag:Refco, HSH, and Deutsche Bank (\$50 bil Bad Bank to Goldman). Another + +risked it all trying to "make" a few million when he, Honig, Stetson, Alpha et al were really LAUNDERING. Milken also Whiterock ,D H Blair (Morty Davis) and AR Baron (Bressman/D H Blair) which was the precursor to Bear Stearns collapse . So, Milken and his merry crew of flunkies are really at the nexus of JUNK. They own Trump and his White House (Trump casino junk) and they own the SEC. It was Milken, Leon Black, Handler, Moelis, Virtue: Drexel that caused the S&L taxpayer bailout stuffing them with junk like Trump's. It is no coincidence that these same flunkies are also the largest CLO originators/managers. CLO's: Junk on steroids. AGAIN Bailed + +out by taxpayers in Cares Act HY. There also connections to Epstein. Treasury Sec Mnuchin and Black: + +HY/Junk/S&L's and Epstein. Black: Money laundering shell ESWW kept up and running by the SEC was/is an + +Epstein money laundering vehicle: JUNK IS JUNK. + +THIS EXPLAINS the Handler/Jefferies/Milken repeated bailouts of NITE. It also explains the SEC criminal + +obstruction. + +SEC Chair Clayton is also directly linked to this criminal obstruction. His firm Sullivan Cromwell and Jared + +Fishman are ACTIVELY facilitating this massive fraud on the public. Clayton did not disclose these conflicts in his disclosures. Sull Crom/Fishman have advised Knight/KCG/VIRT and several transactions designed to facilitate this ongoing and ongoing fraud on the public. Many of the same players involved in the "glitch" were involved in + +the VIRT acquisition of KCG in July 2017. In addition to Sull Crom/Fishman and Handler/Jefferies: JPM and Goldman. The SEC facilitated fraud in the NITE/VIRT transaction is egregious illegal activity. The transaction NEVER should have happened. KCG was an SEC reporting company until the deal closed on July 31 2017. + +Despite this FACT, VIRT CEO Cifo refused to "publish" KCG 2Q2017 financials. I estimate + +Cifu/Coleman/Handler/GS/JPM wrote down more than \$4 billion in open naked short fails: "leverage". The SEC let him. Meaning: "assets" used to determine the take out/ tangible book of KCG was complete fraud. VIRT + +grossly OVER paid for insolvent KCG. + +Prior to the NITE/VIRT transaction closing in July 2017, NITE would report its trading stats monthly. Including OTCM share volumes. Cifu stopped this post merger. The SEC let him. In fact, you will find NO reference to NITE/VIRT OTCM share volumes in any SEC reviewed filing, sell side research or investor presentation. A well orchestrated fraud on the public. Omissions to Intentionally mislead the public as to the true representation of the NITE/VIRT business model. These share volumes are also at the center of my 2013 Berger TCR. There are no affirmative disclosures in any SEC filings to this day as to the AML risks posed in trading these OTCM and other shells. In a 2014 letter to the SEC, I detailed the first 2 months of NITE OTCM share volumes. When the 1Q2014 10O was filed, these volumes were confirmed: An ASTRONOMICAL increase sequentially as well as year over year. These share volumes/my letter/TCR SHOULD have triggered an immediate SEC investigation. It did not. This portion of the KCG 1Q2014 10O was expunged as well as 2Q2014 OTCM share volumes. I have detailed this to the SEC/OWB/Enforcement/IG. In the months leading up to the NITE/VIRT closing in July 2017, KCG put out monthly trade stat pr's showing KCG trading more volume than the overall market. Also indicative of naked shorting. Those pr's were also expunged. I also including electronic forms to the SEC OWB/Enforcement/IG. The SEC has essentially outsourced the ENTIRE OTCM market to the Broker Dealer SRO FINRA. Including: management of the OTCM share volume website fka OtcBB.com. Today, there is very little transparency into trading activity by MM as a result. Also: ISSUER corporate actions: rev splits, Short interest reporting: an + +absolute farce given there is still no CAT. AND BD compliance with the BSA. Per my TCR: WHY did NITE and UBSS trade Billions of shares of CGFIA and IMDS AFTER a Chill or Lock was placed (ex clear/OW)? CLEAR AML red flags. Because they had an open naked short position. Why not pull a market? Because they had an open naked short position. SAR's? WHEN? BEFORE OR AFTER THEY TRADED BILLIONS OF SHARES? There were no SAR's either. NITE can not outsource its compliance responsibilities to 3rd parties (like OpCo) when executing trades as MM. In 2015 at a SIFMA conference, Ceresney was "shocked" by the number of BD's under his supervision filing 1 or ZERO SAR's. NITE SHOULD have been investigated for egregious BSA violations long ago based on my + +TCR. Knight/KCG/VIRT:NITE is and always has been a criminal enterprise. Spitzer Russian/US mob bust: + +"worthless paper". Ashton Tech became VIE became Optimark became Knight/Trimark NITE literally "made by the mob". The SEC has known this for years. ALL of the "worthless paper" shells were SEC reporting companies. + +money laundering shell: Canadian/Pakastani/pot/COVID: FSD Parma: HUGE. Trump advisers/campaign staff Bannon and Parscale also involved in OTCM money laundering shells.Parscale Cloudcommerce fka Roaming + +Messenger also receiving taxpayer Cares Act money. + +Madoff: more money laundering than Ponzi. HOW THE HELL did the SEC let that scam go on for as long as it did? Criminal obstruction. The former SEC IG Kotz actually investigated his "bosses" at the SEC unlike current IG Hoecker. Years of SEC obstruction. Bullshit "investigations" into "running ahead" meant to distract. Similar to the SEC "glitch" "market access complaint" where former SEC "glitch" Enforcement Dir Khuzami/Kirkland(Barr) also rep'd NITE. Can't make this up. The center of IG Kotz scathing failure of the SEC in Madoff: SEC NY and Mr John McCarthy who ended up being Knight/KCG Chief Counsel. As I said: can't make this up. And, as we know + +Madoff started his career in NASDAQ penny stocks exactly like the l's in the Spitzer/Mob complaint. OTCM: This is WHY the OTCM exists: abusive naked shorting publicly traded shells to facilitate money + +laundering. CEO Cromwell Coulson CHAIRED the FINRA market Regulation Cmte. Say it with me: Can't make this shit up: CMTSU. A founding OTCM Board member is former NITE trader Andrew Wimpfheimer:CMTSU. This is a very well orchestrated and ongoing fraud on the public. Russian mirror trades: no SEC OR DOJ investigation HOW? According to stories: activity peaked in 1H2014. Coinciding with NITE astronomical OTCM 1O2014 share volume increase. In additional to money laundering penny stock shells, the OTCM is also home to many ADR's. Including Russian ADR's cited in the NYDFS/DBTCA/mirror trade complaint. Little/no disclosures. Also in my TCR: P&D is just a tool used to facilitate the fraud and NOT a stand alone fraud. The SEC intentionally stops short of thorough investigations into much bigger frauds. The same way it has the public believe the "penny stock trading fairies" convert worthless certs to real money. NO! willing executing BD's and MM's like NITE do that. Less than a year after filing my Knight TCR with Berger, FINRA (not the SEC) brought the BBH AML complaint. This was my information. Swiss banks, foreign/domestic institutions, executing BD's/MM's/ penny stock shells: \$850 mil in proceeds. Did BBH implicate NITE and other entities in my claims? WHY are all of the entities in the complaint UN NAMED? In the interest of transparency for the investing public? In 2019, I also filed an award application for the UBS x border/AML complaint. This is BLATANTLY my information. SEC/FINRA/ AND the SEC. I filed an IRS TCR based on my SEC TCR attached. In April 2016, 2 IRS CI Agents: VIKAS Arora and Nathan Sarnacki flew to Denver from Chicago to meet with me. I believe they were blown away. Then came the UBS complaint. As a follow up to our meeting, they wanted to know WHO at the SEC I shared my information with. I told them. + +That was the last I heard from them although I continued to send them my information. + +To the SEC IG Carl Hoecker: In 2015 I parted ways with Berger as I was convinced the SEC was using my + +information in an unethical/illegal manner to both bring and obstruct complaints. Berger was not willing to file an IG complaint. After parting ways, I almost immediately did just that. Prior to retaining Berger I had filed an + +award application for the UBS Reg Sho complaint. In my submission and my correspondence with + +Mckessy/OWB I made the claim based on OWB permissible rules to "open a new line of inquiry". One that would link the trading activity detailed in my ultimate TCR by NITE and UBSS. That link: Abusive naked shorting publicly traded shells and money laundering. My application was denied and there was no investigation into + +this link. The SEC had just bailed out a "known criminal enterprise":NITE "glitch" was not a forthcoming admission. Neither was the blatantly and knowingly false pretext for the DOJ dropping its UBSS x border DPA because "UBSS was in full compliance" in 2010. So, rather than open a new line of inquiry, the SEC chose to + +obstruct. + +I made clear to Hoecker the egregious conflicts by Khuzami,White and Ceresney with clients UBS,JPM,CS, and DB. Hoecker claims to have conducted a "thorough" investigation of my very serious allegations and found nothing. Despite MJW waivers received to "investigate" her Swiss bank client CS. Then in 2019, Hoecker arrogantly told me I could file a FOIA request on his findings. Then, came 2019 and absolutely nothing had changed. NITE was still trading billions of shares of OTCM shells like ELTZ. There were still no risk disclosures. Cifu refused to publish KCG 2O2017 financials, Hanover/Magna/AQR/Alpha/IMDS etc etc etc were still up and running . I filed ANOTHER complaint with IG Hoecker. Despite the fact that Hoecker himself wroth the IG handbook on "thorough investigations" mandating complainant interviews, I have never been interviewed by Hoecker. In addition, the IG Hoecker is mandated to inform Congress as to serious allegations like mine. He did + +not. In doing so, obstructed Congress from executing its oversight of the SEC/OWB. And despite hundreds of offers to fly to SEC HQ to have the best and brightest at the SEC rip apart my allegations 1 by 1 I have never been taken up on my offer. Why is that? The SEC OWB has gone to great lengths in other cases to explain the OWB process etc to whistleblowers. I have never been told "no thanks" for my information. In fact, McKessy has + +solicited MORE information from me after submitting my Berger TCR. In Madoff, an intern could have verified/shut down in weeks NOT years. No contra parties. Only a well orchestrated obstruction by + +SECNY/McCarthy et al kept it up and running. As I have also repeatedly told the SEC: My claims could be verified + +in weeks also. NITE has a P&L for every stock they trade. These, aggregated, are basis for quarterly trading + +profits. These P&L's, combined with OW data, and balance sheet data will validate ALL of my claims. I've offered my service to do exactly that. 2 weeks max. Afterall, proprietary trading strategies are NOT proprietary if they're illegal. For the reasons I have listed in this summary, NITE/VIRT is on the SEC "do not investigate list". And yes, there most definitely is such a thing. Especially when it comes to illegal activity facilitated by the SEC. So, the SEC denial of my OpCo award claim which was 5 years in the making is just another example of my very serious + +allegations: The SEC solicits and uses whistleblower information like mine to both bring and obstruct complaints. Unethical. Illegal. To deny my award application because the "investigators" didn't see my + +information is further affirmation of my allegations. They saw it. They used it. They denied my compensation for + +it. Again Ms Norberg, I will forward my 2012 etc emails with Robin Traxler at FINRA as well as McKessy as + +further evidence that my Award application denial should be overturned. Further affirmation from 2 dissenting SEC Commissioners and the judge in the Gibraltar case makes this denial both egregious and bizarre. Bizarre ONLY if you believe that there is no SEC obstruction that is. BTW, crazy stuff going on with the firing of Mr Berman/Clayton nomination to take his place/Rabbitt to DoJ/Carpenito replacing eTrump/Barr + +don't you think? The SEC needs some fixers. Wonder why. + +I'm cc'ing some our mutual friends on this email Jane. The last overt act of this massive ongoing, SEC facilitated + +conspiracy has not occurred yet. + +Cheers! + +Christopher J Dilorio + +Wistleblower + +From: Chris Dilorio ,c; > Sent: Wednesday, June 10, 2020 2:30 PM + +To: + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +Mr Roach, + +The SEC is irrefutably using my information in unethical and illegal manner. My information is being used to BOTH Bring complaints AND obstruct/protect investigations into entities detailed in my various TCR's. Denying + +me rightful compensation. This is the latest example + +Chris + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +As straightforward as it gets: + +The SEC OWB dragged its feet for 5 years in issuing its preliminary denial notice. + +The SEC knows this is my information. The SEC committed fraud on the court in Gibraltar. The judge corrected them. The SEC was omitting information that implicated NITE, UBSS and customers like Sason/Hanover/Magna. The SEC was obstructing a thorough investigation of my claims. The naked shorting cited in the CGFIA 10O in 2013 PROVES my allegations. The SEC's "targeted investigation" stops short of a full accounting. The SEC + +Gibraltar complaint does NOT explain the totality of the Oppenheimer complaint. The SEC Gibralter complaint cites 1 OTCM shell and less than 1 million shares traded by Opco. 2 dissenting Opco waiver SEC Commissioners proved that also citing "BILLIONS" of shares in their dissent. The SEC/Opco AML complaint was based on the FINRA complaint and my information. The SEC OWB concocted a completely fabricated reason for denying my Award: "The SEC investigators involved never saw claimants information". The responsibility to distribute + +Whistleblower information within the SEC is the exclusive and explicit responsibility of the OWB. As a result, the + +massive fraud taking place continued well into 2020. The 1Q2020 10O proves this. + +The SEC IG Hoecker is guilty of violating specific IG requirements in keeping Congress informed of serious matters like mine. The SEC IG Hoecker has never interviewed me despite my filing 2 separate complaints with his office. The SEC IG Hoecker is guilty of criminal obstruction. SEC Chair Clayton and Co Enforcement Peikin worked at Sullivan Cromwell with Jared Fishman. Fishman has played a key role in the SEC facilitated criminal obstruction. Peikin and Clayton should have recused themselves from ANY pending NITE/VIRT matter before the SEC: My information. Clayton and Peikin should have recused themselves from the SEC facilitated KCG/VIRT + +merger. My information, including the Opco AML complaint SHOULD have stopped the merger from ever happening. 2 former SEC Commissioners agree with that analysis. The SEC is actively facilitating a massive ,ongoing fraud on the American people they are mandated to protect. NITE/VIRT is a criminal entity. The SEC + +MUST invoke emergency powers and halt trading in VIRT IMMEDIATELY. + +In short Mr Arp, the criminal activity actively perpetrated by the SEC OWB/IG must be referred to law enforcement as well as Congress. Separate but related: SEC facilitated criminal activity and my claims. The criminality is a matter for law enforcement. My pending matters with the SEC have no bearing on a criminal + +investigation OR a GAO investigation. You are incorrect in your analysis. + +I Urge the IG Integrity Board to have SEC IG Hoecker refute my claims point by point. + +I will be on a plane tomorrow so he can do it in person. + +Cheers! + +Christopher J Dilorio + +Whistleblower + +From: Chris Dilorio ‹ > + +Sent: Tuesday, May 12, 2020 8:54 AM + +Almost immediately I filed a formal appeal to the SEC OWB fabricated denial of my award application. In this appeal I show irrefutable proof of my allegations: The SEC OWB used/ is using my information to both bring complaints AND obstruct complaints while denying me compensation. In short: My information exposes an ongoing, massive in scope, SEC facilitated fraud on the American people. Rather than shut it down, the SEC has + +chosen to cover up so that the illegal activity can continue. It does in 2020 + +Chris + +From: Chris Dilorio + +Sent: Monday, May 11, 2020 7:16 PM + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +From: Chris Dilorio + +Sent: Wednesday, April 29, 2020 8:03 AM + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +The SMOKING GUN in my allegations: + +Naked shorting in CGFIA (My TCR/FINRA complaint) by "un named third party BD" in 2013. Well known to the SEC. This is why there was no investigation into the ENTIRETY of the FINRA trading activity. The SEC issued + +waivers to Opco within days of its AML complaint. WHO was the SEC protecting? WHO were the customers and + +executing BD's/MM's in the Opco complaint? ALSO well known to the SEC: + +MY INFORMATION. 5 years to get a preliminary denial: statute of limitations. BUT the last overt act of this + +ongoing conspiracy has not yet occurred. + +Chris + +From: Chris Dilorio + +Sent: Wednesday, April 29, 2020 7:56 AM + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +Still more evidence of a well orchestrated scheme to cover up and obstruct a FULL SEC investigation into + +Opco/Gibraltar/NITE/UBSS trading activity in billions of shares of OTCM money laundering shells. The SEC used + +my information to bring AND obstruct complaints. + +Dissenting Statement In the Matter of Oppenheimer & Co., Inc., by Commissioner Luis A. Aguilar and + +Commissioner Kara M. Stein, February 4, 2015 + +'ArIA,W.SeC.C7C3V + +In fact, the SEC waivers came within days of their complaint. Here, these 2 Commissioners cite Oppenheimer + +trading "BILLIONS of shares of penny stocks". Clearly, they were not JUST referencing the SEC Gibraltar + +complaint. WHO was the SEC protecting with its complaint then waivers? + +The smoking gun which I have provided to the SEC on several e mails: + +Which came in an SEC reviewed CGFIA 10O + +https://www.sec.gov/Archives/edgar/data/1344394/000135448814000425/cgfi 10q.htm + +cgfi\_10q.htm - SEC + +Indicate by check mark whether the registrant (1) has filed all reports required to be filed by Section 13 or 15(d) of the Securities Exchange Act of 1934 during the preceding 12 months (or for such shorter period that the registrant was required to file such reports), and (2) has been subject to such filing requirements + +for the past 90 days. + +vAvw.sec.o,ov + +pg 27 + +"Our stock is subject to a "Global Lock" imposed by the Depository Trust and Clearing Corporation (DTCC)" "On September 24, 2013, we were notified that the DTCC would be placing a 'Global Lock" on the Company's Class A stock as a result of actions by a third-party broker dealer. On November 11 2013, DTCC imposed the "Global Lock". Since less than 0.02% of the Company's Class A common stock shares were held within DTCC, Management chose to not undertake the expense of challenging the Global Lock. Nevertheless, shares that are + +held in street name (CEDE & CO), will not be able to be withdrawn from DTCC without further action." + +Of Course, I have hard copies if you prefer. + +ex clearing: The illegal SEC/DTCC Obligation Warehouse. + +This is CLEAR,IREEFUTABLE,INCONTROVETIBLE evidence of naked shorting by executing BD's in CGFIA. This + +activity took place per my Knight/UBSS TCR submitted to the SEC. So, WHY did the SEC obstruct an + +investigation into the ENTIRETY of the trading activity in the FINRA (and FINCEN) complaints? WHO were the + +executing BD's/MM's? WHO were the customers? + +The veracity of my information is also irrefutable and incontrovertible. + +Game. Set. Match. The SEC is a grossly corrupt, criminal enterprise facilitating illegal activity detailed by me so that this activity can continue. It does in 2020. The SEC solicits then uses Whistleblower information (MINE) to bring complaints AND obstruct other illegal activity while denying proper compensation to whistleblowers (ME). The SEC KNEW who the "third party BD" was in the CGFIA filing long before it filed its Opco complaint in 2015. It + +had my TCR in its possession in March 2013. So why did it take 5 years for the SEC to issue its preliminary denial? I would remind the SEC that this is very much an ONGOING conspiracy on the part of the SEC et al. + +From: Chris Dilorio + +Sent: Tuesday, April 28, 2020 7:24 AM + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +Per my extensive SEC TCR's: Josh Sason/Emanuel/Abitebol/Hanover/Magna extensive overlap with NITE/VIRT + +(and AQR) money laundering shells. + +The SEC Sason/Magna/NewLead Feb 2019 complaint: also my information + +https://www.sec.gov/litigation/complaints/2019/comp24403.pdf + +Marc P Berger SECURITIES AND EXCHANGE COMMISSION Brookfield Place + +200 Vesey Street, Suite 400 New York, NY 10281-1022 SOUTHERN + +DISTRICT OF NEW YORK JOSHUA SASON, MARC MANUEL, + +3 5. In addition, Pallas acted as an underwriter for a primary offering of NewLead stock, which NewLead + +attempted to disguise as an asset sale transaction. + +www.sec.gov + +https://www.sec.gov/Archives/edgar/data/1322587/000114420413065095/v361773 scl3g.htm + +www.sec.gov + +(i) Sole power to vote or to direct the vote . The information required by Item 4(c)(i) is set forth in Row 5 of the cover page for each Reporting Person hereto and is incorporated by reference for each such Reporting + +Person. + +www.sec.gov + +MG Partners Ltd: Abitebol + +But not in the complaint: MAGNA GIBRALTAR INVESTMENTS LLC: also Abitebol + +As with Opco/GIBRALTAR, who is the SEC protecting? + +Cheers! + +Christopher Dilorio + +Whistleblower + +From: Chris Dilorio + +Sent: Tuesday, April 28, 2020 6:43 AM + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +More evidence of SEC fraud on the court in Gibraltar. + +It is CLEAR that the Opco AML Covered Action 2015-016 was NOT ENTIRELY based on the SEC Gibraltar Action. The SEC Gibraltar action covered trading activity in just 1 OTCM Money laundering shell: Magnum d'Or where Opco traded less than 1 million shares. CLEARLY the SEC Opco complaint was based on the trading activity in the FINRA Opco AML complaint: my information. However, the SEC Opco complaint even stops short of a thorough investigation of the ENTIRETY of the FINRA trading activity. WHY? WHY didn't the SEC Opco/Gibraltar complaint + +go into trading activity in the FINRA AML OTCM shells through 2014 as FINCEN did? WHY did the SEC omit MATERIAL information to the court in Gibraltar causing a "significant under estimating" of criminal activity? The SEC knows who the accounts were. The SEC knows who the executing BD's/MM's were. The SEC committed + +a fraud on the court in Gibraltar. + +Gibraltar was ROLLING OUT NEW OTCM services into the end of 2011. + +https://www.pr.com/press-release/355246 + +Gibraltar Global Securities Now Offering Offshore Brokerage Accounts - + +PR.com + +Nassau, Bahamas, The, September 22, 2011 --0-- Gibraltar Global Securities is now offering offshore + +brokerage accounts in addition to their broad array of financial services.Gibraltar Global ... + +www.pr.com + +https://www.pr.com/press-release/355247 + +GGSI Bahamas is Now Offering Pink Sheet Clearance + +Offshore Broker Adds to Buying and Selling Services + +www.pr.com + +and Communication + +GGSI (Gibraltar Global Securities Inc.) has just announced the release of their latest security measures designed to protect their client's personal data, and to secure electronic communication. + +www.pr.com + +The SEC KNEW the Gibraltar/Opco trading activity went well beyond 2011 YET cut off its investigation at "well + +into 2010". Thus, KNOWINGLY omitting material information in Gibraltar: FRAUD ON THE COURT. + +Confirming my allegations of SEC criminal activity in handling my information. WHY? to protect NITE and UBSS. + +2 criminal entities bailed out by the SEC. + +Now, the SEC is using the completely fabricated reason for denying my award claim for covered action 2015- + +016: "The investigators never saw the claimants information". + +WHEN the explicit and exclusive responsibility to distribute whistleblower information within the SEC falls on + +the OWB itself. + +More criminal activity. + +Criminals bailing out criminals while denying Whistleblowers due process and compensation. + +Cheers! + +Christopher.' Dilorio + +Whistleblower + +From: Chris Dilorio + +Sent: Sunday, April 26, 2020 9:36 AM + +To: + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +From: Chris Dilorio + +Sent: Friday, April 24, 2020 8:18 AM + +Subject: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +I am in receipt of the SEC preliminary denial of my award claim for the Oppenheimer AML covered action 2015- + +016 + +This is my formal appeal of the SEC preliminary determination. My award application was based on this very simple FACT: + +The SEC (and FINCEN) Oppenheimer AML actions were based on the FINRA Oppenheimer AML action + +which isFINRA a party, to the entry of findings and violations consistent with the allegations of the (asComplaint sanctions amended andby the Offer of Settlement), to the imposition of the set forth andbelow, understands fully that this Order will become part ofRespondent's permanent disciplinary + +andrecord may anybe considered in future actions brought by FINRA. BACKGROUND ... + +www.finra.org + +The SEC + +https://www.sec.gov/litigation/admin/2015/33-9711.pdf + +Before the SECURITIES AND EXCHANGE COMMISSION + +Before the . SECURITIES AND EXCHANGE COMMISSION . SECURITIES ACT OF 1933 . Release No. 9711 / + +January 27, 2015 . SECURITIES EXCHANGE ACT O F 1934 . Release No. 74141 / January 27, 2015 . + +ACCOUNTING AND AUDITING ENFORCEMENT . Release No. 3621 / January 27, 2015 . ADMINISTRATIVE + +PROCEEDING . File No. 3 -16361 . In the Matter of + +www.sec.gov + +FINCEN + +https://www.fincen.gov/news/news-releases/fincen-fines-oppenheimer-co-inc-20-million-continued-anti- + +money-laundering + +FinCEN Fines Oppenheimer & Co. Inc. \$20 Million for Continued Anti— + +Money Laundering Shortfalls I FinCEN.gov + +Washington, D.C. - The Financial Crimes Enforcement Network (FinCEN), working closely with the U.S. Securities and Exchange Commission (SEC), assessed a \$20 million civil money penalty today against Oppenheimer & Co., Inc., for willfully violating the Bank Secrecy Act (BSA). Oppenheimer, a securities + +broker-dealer in New York, admitted that it failed to establish and implement an adequate ... + +www.fincen.gov + +In the summer of 2012, I had extensive correspondence with Robin Traxler at FINRA where I also cc'd Sean + +McKessy then SEC OWB Chief. The CURRENT OWB Chief and the SEC IG are in possession of this + +correspondence. My correspondence dealt with 2 penny stock shells cited in my Knight Capital TCR submitted by Berger Montague in March 2013 attached here: Colorado Goldfields and AppTech. Both shells were NITE and + +UBSS top traded OTCM shells in 2010-2013. These 2 shells were cited by FINRA in their Oppenheimer AML complaint. Again, the SEC and FINCEN Oppenheimer AML complaints were based on this FINRA complaint. In fact, per the FINRA Opco complaint above, customer "TC" was dumping worthless AppTech (APCX) certificates well into mid 2010. DIRECTLY overlapping with the NITE/UBSS APCX trading activity cited in my Berger 2013 TCR attached and discussed by me with Robin Traxler at FINRA. HOW is it possible that the SEC OWB didn't share + +WHO ultimately executed the trades cited in the FINRA Opco complaint? + +Further, the SEC Gibraltar Securities complaint raises more questions than answers as well. + +https://www.sec.gov/litigation/complaints/2013/comp22683.pdf + +UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +SECURITIES AND EXCHANGE COMMISSION, 13 Civ. GffiRALTAR GLOBAL + +SECURITIES, COMPLAINT NATURE OF THE ACTION - SEC.gov + +12. David Della Sciucca, Jr, age 27, is a resident of Fort Lauderdale, Florida. In . the Magnum d'Or + +complaint, the Commission charged Della Sciucca with acting as a nominee + +www.sec gov + +The SEC Gibraltar Securities complaint references only 1 OTCM money laundering shell: Magnum d'Or. The complaint specifically states that Oppenheimer sold just 969,822 shares. Again, no mention of executing + +BD/MM. + +The SEC Oppenheimer AML cites Gibraltar trading activity also. + +The share amounts in the SEC complaint grossly under estimate that in the FINRA complaint. WHY? + +The judge in the Gibraltar case said "the SEC's requested amount CLEARLY UNDERESTIMATES the defendants ill- + +gotten gains...." + +http://www.tribune242.com/news/2016/jan/13/bahamian-broker-25m-sanction/ + +Bahamian broker in \$25m sanction I The Tribune + +A former Bahamian broker/dealer and its principal have been hit with a combined 524.484 million in + +financial sanctions by a US court, which found that their "ill gotten gains" were likely ... + +www.tribune242.com + +WHY didn't the SEC go after ALL of the sellers in the FINRA Opco AML complaint? WHY did the SEC "strip out" \$46 million from the Gibraltar ill gotten gains claiming the customers were "UNKNOWN"? WHO is the SEC protecting? WHO were the executing BD's/MM's in the FINRA Opco CGFIA and APCX trades? They certainly know who the customers were. Is customer "JK" Justin Keener/JMJ also in my March 2013 TCR attached? While the SEC Opco AML was based on the FINRA Opco AML, it stopped short of a thorough investigation of NITE and UBSS. In fact, the trading activity of NITE/VIRT and UBSS in the FINRA complaint: my information SHOULD have triggered an immediate investigation of NITE and UBSS. It did not. Did the SEC commit fraud on the court in its + +OMISSION of material information? + +The timing of the SEC's preliminary determination and the reasoning for the denial ALSO raises more questions + +"Investigative staff responsible for the covered action NEVER RECEIVED ANY INFORMATION FROM THE + +CLAIMANT OR had any communication with the claimant" + +Let's take this whopper in 2 parts: + +First, the SEC OWB denied my Award application because The investigators in the complaint never received my + +information. Has the SEC OWB re written the investigative protocol in this denial? How am I or ANY + +whistleblower supposed to know WHO the investigators are in a particular case WHEN according to the SEC: + +ALL investigations are done in a confidential manner???? + +WHAT DOES THE SEC DO WITH WHISTLEBLOWER TIPS EXACTLY? Do they share whistleblower information with ENFORCEMENT as is mandated? HOW would ANY whistleblower know WHO to share information with at the + +SEC? Isn't that the job of the SEC OWB? + +Second, the fact that no one at the SEC contacted me DOES NOT mean the SEC didn't use my information. This is a completely bogus argument. It certainly would NOT be the first time the SEC used my information now + +would it Jane? + +In fact, it is NOT the responsibility of the whistleblower to get his/her information to the right Enforcement personnel. That responsibility EXPLICITLY falls on the SEC OWB. So, is the SEC OWB admitting gross negligence + +in handling my information? After the monumental failure in the Madoff Ponzi/ money laundering SEC + +facilitated scam on the public the then SEC IG made specific recommendations to the SEC with regards to the + +proper handling/vetting of Tips and Complaints. + +https://www.sec.gov/files/468.pdf + +Review and Analysis of OCIE Examinations of Bernard L. Madoff Investment + +Securities, LLC + +Review and Analysis of ODE Examinations of Bernard L. Madoff Investment Securities, LLC Executive + +Summary Background. On June 25, 2009, the Securities and Exchange Commission's + +voNw.sec gov + +AGAIN: The responsibility to properly vet Whistleblower information and get the information into the right hands at the SEC falls EXPLICITLY and EXCLUSIVELY with the SEC OWB itself and is NOT the responsibility of the whistleblower. Further, according to the previous SEC IG in the monumental Madoff failure: the responsibility to contact those supplying Tips and Complaints ALSO falls explicitly and exclusively with the SEC OWB and not + +the whistleblower. Using these excuses as the basis of denial of Award is completely contrary to SEC + +MANDATED protocols and procedures. + +Is the SEC OWB admitting it doesn't comply with those recommendations? Recall: the monumental SEC Madoff failure was NOT the fault of Whistleblowers either. OR is the SEC OWB scrambling for a 5 years in the waiting + +preliminary determination? + +So, after 5 years of waiting for a preliminary determination for my award claim, this is what the SEC best and + +brightest come up with? + +My Denial of Award for covered action 2015-016 was completely made up on the fly. + +The SEC OWB has applied completely fabricated "rules" to issue this denial. Further affirmation of ALL of my + +allegations. + +Also by SEC admission, the SEC allowed these 2 penny stock shells to remain a clear and present risk to the investing public. Were CGFIA and APCX ONLY money laundering shells for Oppenheimer in 2008-2010 and then + +WHY did it take until September 2018 before the SEC finally revoked the CGFIA registration? + +https://www.sec.gov/cgi-bin/browse-edgar?company=Garpa&owner=exclude&action=getcompany + +So, WHY was there no SEC investigation of NITE and UBSS trading activity in money laundering shells APCX and CGFIA? The SEC et al facilitated NITE "glitch" took place in August 2012. This SEC/Jefferies/JPM/BX/GS/SEC Chair Clayton Sullivan Cromwell colleague Jared Fishman et al bailout coincides directly with NITE trading activity in 2 + +SEC/FINRA/FINCEN acknowledged money laundering shells. AND the "bailout" penny stock esque reverse merger between Getco and Knight didn't close until July 2013. HOW could the SEC conduct a COMPLETE and thorough investigation into the FINRA Opco AML complaint WITHOUT implicating NITE when NITE was CLEARLY trading billions of shares of OTCM money laundering shells BEFORE and coinciding with the SEC et al facilitated "glitch" bailout? For UBSS, the DOJ dropped its cross border AML DPA complaint in 2010. UBSS was trading money laundering shells well after the DOJ claimed UBSS was in compliance with the cross border DPA. To be clear: BOTH NITE and UBSS knew CGFIA and APCX were money laundering shells when they traded billions of shares of each 2010-2013. Is that FACT disputed by the SEC? The SEC OBSTRUCTED a thorough investigation into the ENTIRETY of trading activity of NITE and UBSS in CGFIA and APCX: MY CLAIMS. Josh + +Sason/Hanover/ Magna knew CGFIA was a money laundering shell also + +https://www.sec.gov/Archives/edgar/data/1344394/000114420413041432/0001144204-13-041432-index.htm ALSO in my claims: Joshua Sason/Hanover Magna. CGFIA. Also my NewLead TCR1426518350699 and FreeSeas TCR1440274395191 separate but related TCR's where NITE was a top trader in both and BOTH TCR's were filed well in advance (years prior) to the Sason/Hanover/Magna February 2019 complaint. Here's one thing the SEC has been consistent about: The SEC ignores the role of executing BD's and MM's in these scams. WHY? Because NITE is the #1 OTCM shell trader. As far as the SEC is concerned Penny stock trading fairies convert worthless certificates into real money. NOI Executing BD's/MM's like NITE do. Did Oppenheimer sell this order flow to NITE? Who ultimately converted these worthless certificates to real money? As the number 1 OTCM money laundering shell trader it is statistically improbable the NITE has never been the focus of an SEC AML complaint. Per my TCR: what does the NITE Compliance Department do exactly? How many SAR's has NITE filed in the last 10 years? In a 2015 SIFMA speech then SEC Enforcement Director Ceresney was "SHOCKED" by the number of BD's filing 1 or ZERO SAR's. That was just 5 years ago. WHEN would NITE file a SAR releted to the billions of shares of OTCM money laundering shells it trades like CGFIA and APCX: BEFORE or AFTER it trades those + +BILLIONS of shares?Does NITE pull markets and alert regulators OR continue to trade billions of shares of OTCM + +money laundering shells in the face of GLARING AML red flags? In fact, in December 2019 the top traded + +NITE/VIRT OTCM money laundering shell was ELTZ + +https://www.sec.gov/cgi-bin/browse-edgar? + +action=getcompany&CIK=0001607281&owner=exclude&count=40&hidefilings=0 + +The SEC knows the people/entities in ELTZ well + +https://www.sec.gov/litigation/admin/34-46993.htm + +Strata Coal Company and Terrence A. Tecco: Admin. Proc. Rel. No. 34- + +46993 / December 13, 2002 + +Strata Coal Company ("Strata" or "the company") is a non-reporting Nevada shell corporation based in Frisco, Texas. Strata's shares are quoted on the Pink Sheets under the symbol SCOC. Until September 2002, the company was known as WesPac Technologies, at which time it changed its name to Strata. 2. + +https://www.sec.govinews/press-release/2019-16 + +SEC.gov I SEC Charges Broker-Dealer and Transfer Agent in Microcap Shell + +Factory Fraud + +The Securities and Exchange Commission today announced charges against a broker-dealer, a transfer agent, and three individuals for their roles in the creation of over a dozen undisclosed "blank check" + +companies from 2009 to 2014. + +www.sec.gov + +Doesn't the NITE/VIRT compliance Department have internet service in Jersey City? As a DIRECT result of the SEC obstructing a complete and thorough investigation into the ENTIRETY of trading activity in APCX and CGFIA, + +the top NITE/VIRT traded OTCM money laundering shell in December 2019 was AML red flags galore ELTZ. + +Illegal activity ACTIVELY facilitated by the SEC. The examples cited in this e mail are not exhaustive. + +And, for it's part AppTech is up and running again/still + +https://www.sec.gov/cgi-bin/browse-edgar?company=Apptech&owner=exclude&action=getcompany + +Unfortunately, AppTech is still up and running as a direct result of the aforementioned SEC " CLEARLY under + +estimating" otherwise known as CLEARLY OBSTRUCTING. + +In conclusion, The SEC solicits information from whistleblowers like me. The SEC uses whistleblower information + +to bring actions and then doesn't compensate whistleblowers for their information. + +OR + +The SEC uses whistleblower information to protect criminality perpetrated on the investing public so that this criminal activity can continue. BOTH are gross dereliction of the stated and MANDATED SEC Whistleblower statutes. To blame a whistleblower for the SEC's EXPLICIT and EXCLUSIVE responsibility to properly vet and distribute whistleblower information within the SEC as an excuse to deny Awards is also criminal activity. The SEC: criminals using whistleblower information to protect other criminals AND deny whistleblower rightful + +compensation for their information. + +I appeal the SEC preliminary determination and wish to file ANOTHER complaint with the SEC IG. + +Cheers! + +Christopher J Dilorio + +For 7 fucking years, the SEC has known about JMJ/Keener. I told them https://www.sec.gov/litigation/complaints/2020/comp-pr2020-72.pdf + +IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT + +OF FLORIDA SECURITIES AND EXCHANGE COMMISSION No. COMPLAINT + +SUMMARY - sec.gov + +5. Justin W. Keener, age 45, resides in San Juan, Puerto Rico.During the Relevant Period, Keener was a resident of Miami Beach, Florida. Keener registered the name "JMJ Financial" as a fictitious name in Florida + +in 2008 and used it to conduct the business described + +www.sec.gov + +In February 2019, the SEC brought an action against Joshua Sason/NewLead + +I told the SEC about Magna/ Sason ALSO in my 2013 TCR. https://www.sec.gov/litigation/litreleases/2019/Ir24403.htm + +Joshua Sason, et al. (Release No. LR-24403; Feb. 15, 2019) + +Washington, D.C., February 15, 2019 - The Securities and Exchange Commission today announced charges + +against four individuals and related businesses for their roles in two microcap frauds and unlawful + +securities offerings. + +vo.vw sec g ov + +AND, I filed separate but related NewLead and FreeSeas TCR's in 2015 + +Then there's the UBS AML complaint. + +ALSO my claims. For which I sent 10 (TEN) separate Award applications from a commercial fax machine in April/May 2019. AND I have YET to receive even a preliminary determination from the OWB/Norberg + +IG, I see your "investigation" into my very very serious accusations of Obstruction related to my information was + +thorough. In short, the SEC has and still is ripping me off. + +Janey, be a hun and update my TCR's/Awards cited in this e mail. + +And Ms Welshhans, a couple of questions for you: + +1) Have you read the FINRA WTFC Keener complaint? Fictitious notes Ring a bell? + +Same MO as Sason/Magna/NewLead/FreeSeas etc etc etc + +2) WHO executed the Keener OTCM trades in your complaint? Penny stock trading fairies? + +YES, NITE was a top trader in BOTH FreeSeas and NewLead + +The core business at NITE/VIRT is and ALWAYS has been: abusive naked shorting OTCM (and other) shells to + +facilitate money laundering. + +In short Ms Welshhans, NITE/VIRT converts these worthless certs into real money. NONE of + +JMJ/Sason/IBC/Ironridge/Asher etc etc etc activity takes place without a willing,corrupt, criminal, executing + +BD/MM like NITE/VIRT, CDEL etc + +Finally, The Keener SEC complaint is FURTHER evidence that FINRA has NO business enforcing US securities LAWS. When FINRA "invited" Keener to a disciplinary hearing almost 7 years ago, Keener told them to "fuck + +Christopher Dilorio Whistleblower + +Mr Peirce, + +Congratulations on your nomination as SEC Commissioner. I have read your paper on FINRA lack of + +accountability. I believe the SEC has abdicated its responsibility to enforce Broker Dealer compliance with the BSA to FINRA BECAUSE it is not accountable. The SEC has not initiated a single stand alone AML complaint. The Brown Brothers Harriman AML complaint IS my claim. ALL of the entities in the complaint are un named + +WHY? My SEC and IRS Whistleblower complaints explain why. + +Hello, My name is Chris Dilorio. I have filed extensive SEC and IRS Whistleblower complaints alleging a direct link between penny stock money laundering, domestic and foreign entities, Swiss Banks, and executing brokers like KCG and UBS. I can provide overwhelming evidence of SEC obstruction. Please read the FINRA Brown Brothers Harriman AML complaint. This is my claim. All of the entities in the complaint are un named. Why? The SEC is not only obstructing an investigation, they are aiding and abetting the activity. These are not far flung theories. The UBS Whistleblower Birkenfeld and his attorney sent 52,000 accounts to the SEC and DOJ. The DOJ at the influence of President Obama and Hillary Clinton entered into the UBS DPA based on just 4400. + +What is so egregious is the activity continues un abated today. + +Start with the so calledAugust 2012 Knight/KCG trading "glitch". Initial reports say the NYSE was breaking the trades. WHY did they stop. Former KCG CEO Joyce said he had a very frank discussion with then SEC Chair Schapiro where the SEC wanted to send a very strong message to market participants. Why not just continue to break the trades and hit KCG with a hefty fine? That would not create the conditions to grant KCG exception after exception to do their emergency funding which transferred 74% of the company to "glitch" funding participants and ultimate reverse merger partner GETCO. AND, despite claiming to having a "highly liquid + +balance sheet" KCG had to raise the entire amount of the loss. + +A very significant and public event was cited in a WSJ article where immediately following the "glitch"KCG inadvertently sent 4000 worthless securities to JPM in an attempt to secure a tri party financing where JPM + +guaranteed the loan. This is discussed in my attached TCR's and also the topic in a March 2014 letter I sent to the SEC. In the end, the emergency funding was NOT collateral based. The participants knew exactly what a fraud the KCG balance sheet was. After the stock was decimated to \$3, the deal was a convertible with a conversion + +price at a 50% discount or \$1.50/ share. There is much more, but this is a good start. + +Recently, KCG did a modified Dutch auction where they "sold" an asset (HotSpot) to an entity both KCG and GETCO were a major shareholder (BATS) KCG CEO Coleman called it a "highly competitive process". + +Virtually all of the proceeds went to buy back stock from "glitch" financing participants. The purchase price was \$14/share. The stock had never traded there and hasn't since. Reports say 82 million shares were tendered at or BELOW \$14. But they chose to repurchase 23 million shares AT \$1499779 I have overwhelming evidence that + +supports my allegations that the SEC is engaging in criminal obstruction to protect KCG. + +I) Current KCG Dan Coleman ran Equities at UBS during the massive REG Sho violations as well as the cross border activity detailed by Whistleblower Birkenfeld. White and Ceresney represented UBS prior to joining the + +SEC + +4) Read FINRA AML complaints against Brown Brothers Harriman. This is my claim. It links penny stock money laundering to executing brokers like KCG, domestic and foreign entities, and Swiss banks. ALL of the + +entities in the complaint are un named. WHY? + +5) The FINRA World Trade Financial AML complaint discusses several entities cited in my claims. The + +customer the complaint focuses on is Justin Keener. Still very much in business. The red flags cited by FINRA + +were cited in my claims as well. Yet still no investigation. + +6) in July 2015 I contacted Kevin Goodman Dir OCIE for Broker Dealrsat the SEC. He had never seen my information. The IG OCIE Madoff report mandated the OCIE to vet information. McKessy and Ceresney never + +sent my info to him + +7) I'm sure you are familiar with the Manning v Merrill,KCG,UBS et al litigation. The SEC does not want an + +investigation into my claims while the litigation is pending. + +8) My claims detail ex clearing trading activity by KCG and UBS. despite the glaring red flags in doing so. Ex clearing s the Obligation Warehouse. A NON GUARANTEED SERVICE set up by the SEC and DTCC to allow firms like KCG to circumvent close out requirements of Rule 204. Clearly contrary to the intent of the SEC authorization in Sec 17a of the 1934 Act to create a system of prompt and timely settlement and to remove + +impediments there of. + +In short, I told the SEC KCG was insolvent in 2011. Rather than investigate and prosecute, they chose to obstruct. The activity in my TCR's pit dates the "glitch". An investigation would show the SEC bailed out a + +criminal enterprise. Because of the obstruction, the activity continues today unabated in stocks like + +STBV,VELA,NEWL,FREE, and dozens more. The investing public remains at risk + +More to come Chris Dilorio \ No newline at end of file diff --git a/marker2/ds9/EFTA00087400/EFTA00087400.metadata.json b/marker2/ds9/EFTA00087400/EFTA00087400.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..74990aea1fad88f0ea9e61bddb3887f5d01d62cb --- /dev/null +++ b/marker2/ds9/EFTA00087400/EFTA00087400.metadata.json @@ -0,0 +1,3768 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087400.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 145, + "chars": 259174, + "elapsed_seconds": 108.36, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + 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"previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087400" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087545/EFTA00087545.md b/marker2/ds9/EFTA00087545/EFTA00087545.md new file mode 100644 index 0000000000000000000000000000000000000000..06985a35e607a5fb8f78fe349c4b8091819aa31f --- /dev/null +++ b/marker2/ds9/EFTA00087545/EFTA00087545.md @@ -0,0 +1,31 @@ +**To:** [REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] + +**Subject:** Fwd: Ghislaine Maxwell speaks from behind bars for the first time in the Mail on Sunday | Daily Mail Online + +**Date:** Sat, 13 Nov 2021 17:05:40 +0000 + +--- + +Begin forwarded message: + +**From:** [REDACTED] + +**Date:** November 13, 2021 at 12:00:10 PM EST + +**To:** [REDACTED] >, [REDACTED] + +[REDACTED] +[REDACTED] + +**Cc:** [REDACTED] + +**Subject:** Ghislaine Maxwell speaks from behind bars for the first time in the Mail on Sunday | Daily Mail Online + +Not sure if this is a concern, but a Daily Mail reporter somehow got an interview with her. + + + +Sent from my iPhone \ No newline at end of file diff --git a/marker2/ds9/EFTA00087545/EFTA00087545.metadata.json b/marker2/ds9/EFTA00087545/EFTA00087545.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..c95d3d247f4bb3cad1dffe230b5ca10ef774a847 --- /dev/null +++ b/marker2/ds9/EFTA00087545/EFTA00087545.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087545.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 738, + "elapsed_seconds": 3.79, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 33 + ], + [ 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+> He [REDACTED] sure thing, it's Dkt. No. 438. + +> > +> -----Original Message----- + +> From: [REDACTED] +> Sent: Saturday, November 13, 2021 12:59 PM + +> To: [REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] + +> Subject: Re: Ghislaine Maxwell speaks from behind bars for the first time in the Mail on Sunday | Daily Mail Online + +> > +> Could someone please give me the document number for our motion requesting the use of pseudonyms? +There's so much on that docket, it's a little difficult to find. Thanks! + +> > +> Sent from my iPhone + +>> On Nov 13, 2021, at 12:06 PM, [REDACTED] > wrote: +>> + +>> Thanks very much for flagging. The article suggests a fuller interview is coming out tomorrow or Monday. +Would you mind sending that along if you see it, please? + +>> > +>> -----Original Message----- + +>> From: [REDACTED] +>> Sent: Saturday, November 13, 2021 12:00 PM + +>> To: [REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] + +>> Subject: Ghislaine Maxwell speaks from behind bars for the first time in the Mail on Sunday | Daily Mail Online + +>> > +>> Not sure if this is a concern, but a Daily Mail reporter somehow got an interview with her. + +>> +>> +>> + +>> + +>> Sent from my iPhone \ No newline at end of file diff --git a/marker2/ds9/EFTA00087546/EFTA00087546.metadata.json b/marker2/ds9/EFTA00087546/EFTA00087546.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..6bfa1da5b40bb3fdd58e094c36b11051ebfc6210 --- /dev/null +++ b/marker2/ds9/EFTA00087546/EFTA00087546.metadata.json @@ -0,0 +1,76 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087546.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 1664, + "elapsed_seconds": 7.41, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 65 + ], + [ + "Text", + 48 + ], + [ + "Line", + 32 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 6 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087546" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087550/EFTA00087550.md b/marker2/ds9/EFTA00087550/EFTA00087550.md new file mode 100644 index 0000000000000000000000000000000000000000..696fad869a2d92e82a040be6d68767e21cf34d3a --- /dev/null +++ b/marker2/ds9/EFTA00087550/EFTA00087550.md @@ -0,0 +1,15 @@ +To: + +Cc: + +Subject: 3500 + +Date: Sun, 14 Nov 2021 18:26:16 +0000 + +Embedded: Fwd:JEXTERNALLI\_am\_a\_unknown\_MAXWELL\_Epstein\_victim\_.msg + +Could you please add this to NTW 3500? Thanks. + +Assistant United States Attorney Southern District of New York + +New York NY 10007 \ No newline at end of file diff --git a/marker2/ds9/EFTA00087550/EFTA00087550.metadata.json b/marker2/ds9/EFTA00087550/EFTA00087550.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..e4ce41115f7694300f896eba6cb669d70ec36b6e --- /dev/null +++ b/marker2/ds9/EFTA00087550/EFTA00087550.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087550.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 268, + "elapsed_seconds": 0.5, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 21 + ], + [ + "Line", + 11 + ], + [ + "Text", + 9 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087550" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087551/EFTA00087551.md b/marker2/ds9/EFTA00087551/EFTA00087551.md new file mode 100644 index 0000000000000000000000000000000000000000..4db8b3d87739c080b9565887bdc67cdd145afffb --- /dev/null +++ b/marker2/ds9/EFTA00087551/EFTA00087551.md @@ -0,0 +1,25 @@ +To: 'Nathan NYSD Chambers' + +Cc: Jeff Pagliuca ipagliuca@hmflaw.com>, Laura Menninger , "ceverdell@cohengresser.com" . "bcstemheim mac.com" " + +Subject: [EXTERNAL] U.S. v. Maxwell, Case No. 20 Cr. 330 (AJN) [Maxwell's Mom for Order re. Fed. R. Crim. P. 17(c) Sub] + +Date: Mon, 15 Nov 2021 04:57:02 +0000 + +Attachments: 2021.11.14\_Mtn\_for Order\_Auth\_a\_Sub\_Pursnt\_to\_F.R.Crim.P\_17(c) (3)\_re.\_Feldman\_.pdf; Ex.\_1.pdf + +Inline-Images: image00I.jpg + +Dear Judge Nathan: + +At the request of Jeffrey Pagliuca, please see attached Ms. Maxwell's Motion for an Order Authorizing a Subpoena Pursuant to Fed. R. Crim. P 17(c)(3). Pursuant to our established protocol, we are submitting the Motion and Exhibit to the Court under temporary seal to allow the government to propose any redactions it deems necessary. + +Regards, + +Nicole + +![](_page_0_Picture_11.jpeg) + +Nicole Simmons Haddon. Morgan and Foreman, P.C. 150 East 10th Avenue Denver, Colorado 80203 + +PH 303.831.7364 FX 303.832.2628 DIRECT: 720.287.5835 www.hmflaw.com nsImmons@hmflaw.com \ No newline at end of file diff --git a/marker2/ds9/EFTA00087551/EFTA00087551.metadata.json b/marker2/ds9/EFTA00087551/EFTA00087551.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..1421cb9cc7ac0f664d40f870654d4016c15a5c23 --- /dev/null +++ b/marker2/ds9/EFTA00087551/EFTA00087551.metadata.json @@ -0,0 +1,60 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087551.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1110, + "elapsed_seconds": 0.72, + "image_assets": [ + "_page_0_Picture_11.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 58 + ], + [ + "Line", + 29 + ], + [ + "Text", + 13 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087551" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087551/_page_0_Picture_11.jpeg b/marker2/ds9/EFTA00087551/_page_0_Picture_11.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..1eb438334833d99699a7ef795ce8fa3633fbf3b4 --- /dev/null +++ b/marker2/ds9/EFTA00087551/_page_0_Picture_11.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:69d917b8bf9067eb0450f29cee1ba64cea4c8e0f0dabc94823fa842f1375e1da +size 4381 diff --git a/marker2/ds9/EFTA00087552/EFTA00087552.md b/marker2/ds9/EFTA00087552/EFTA00087552.md new file mode 100644 index 0000000000000000000000000000000000000000..70251502c396ed3bdc7f7bc9b78b7bc7d6d7352f --- /dev/null +++ b/marker2/ds9/EFTA00087552/EFTA00087552.md @@ -0,0 +1,139 @@ +From: ' )" To: ' (USANYS)" czi Subject: RE: [EXTERNAL] RE: Call Date: Mon, 15 Nov 2021 22:30:43 +0000 + +Of course. Just need to pump real quick then can head down to you. + +From: (USANYS) Sent: Monday, November 15, 2021 5:28 PM To: Subject: Fwd: [EXTERNAL] RE: Call + +Can you join this call with me please? + +Begin forwarded message: + +From: "Kramer, Amanda K" < Date: November 15, 2021 at 4:24:15 PM EST To: " (USANYS)" < Cc: " I" < Subject: [EXTERNAL] RE: Call > + +Hi and + +I'm free today from 4:30 on. Please feel free to call my cell ( + +Best, Amanda + +Original Message + +From: (USANYS) Sent: Monday, November 15, 2021 3:24 PM To: Kramer, Amanda K < Cc: Subject: RE: Call + +[EXTERNAL] + +Hi Amanda, + +I hope you are doing well. Do you have a few minutes to chat? Please let us know some times that work for you. + +Thanks so much, + +Original Message + +From: Kramer, Amanda K < > Sent: Wednesday, February 24, 2021 8:35 AM To: Cc: Subject: Re: Call (USANYS) + +On Feb 24, 2021, at 8:17 AM, (USANYS) c > wrote: + +(EXTERNAL] + +Thanks, Amanda. 10:30 works for us. We can use the following dial-in: 1 .,916486%23> ,916486# + +Sent: Tuesday, February 09, 2021 4:22 PM + +To: (USANYS) + +Cc: + +Subject: RE: Call + +Apologies for the delay - I had full days set aside for witness interviews and was waiting for clarity from the client. It looks like I'm available Thursday 2:30-5 and Friday 2-4. Please let me know if those times work for you. + +Best, Amanda + +Original Message + +From: (USANYS) < Sent: Monday, February 8, 20217:08 PM To: Kramer, Amanda K Cc: Subject: RE: Call + +[EXTERNAL] + +Hi Amanda, + +So sorry to bother you, but we wanted to follow up on scheduling in light of our pre-trial motion opposition deadline. Can you please let us know some times that work for you to speak? + +Thanks so much, + +Original Message + +From: (USANYS) Sent: Saturday, February 06, 2021 1:08 PM To: 'Kramer, Amanda K' < > Cc: Subject: RE: Call + +Amanda, + +I hope all is well. Sorry to bother you on the weekend, but we wanted to send along the emails as discussed and reach out regarding scheduling. Can you please let us know some days and times that would be convenient for you to speak by phone early next week if possible? We are happy to speak whenever best for you. + +Thanks again, + +Original Message + +From: Kramer, Amanda K Sent: Friday, January 29, 2021 9:19 PM To: (USANYS) Cr: Subject: Re: Call >; < + +Hi all, + +I'm flexible on Tuesday before 2:00. Does that work? + +[EXTERNAL] + +Hi Amanda, + +I hope all is well with you. We are hoping to find a time for an initial call with you early next week. In advance of speaking, we wanted to send you your notes from a meeting in February 2016 and a link to the following article: http://www.nydailynews.cominew-yorkiny-jeffrey-epstein-maxwell-case-20201013-jmzhl7zdrzdgrbbs7yc6bfnszustory.html. + +Can you please let us know some times that work for you? + +Thanks so much, and have a good weekend, + +Assistant United States Attorney United States Attorney's Office Southern District of New York + +Tel: + +<2016.2.29 Meeting Notes and Business Cards.pdf> \ No newline at end of file diff --git a/marker2/ds9/EFTA00087552/EFTA00087552.metadata.json b/marker2/ds9/EFTA00087552/EFTA00087552.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..9144e9a88a9f12b031dde3b09c3ea41369502bb1 --- /dev/null +++ b/marker2/ds9/EFTA00087552/EFTA00087552.metadata.json @@ -0,0 +1,144 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087552.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 4, + "chars": 3745, + "elapsed_seconds": 1.54, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 79 + ], + [ + "Line", + 39 + ], + [ + "Text", + 18 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 81 + ], + [ + "Line", + 39 + ], + [ + "Text", + 30 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 78 + ], + [ + "Line", + 38 + ], + [ + "Text", + 18 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 3, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 28 + ], + [ + "Line", + 15 + ], + [ + "Text", + 11 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087552" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087556/EFTA00087556.md b/marker2/ds9/EFTA00087556/EFTA00087556.md new file mode 100644 index 0000000000000000000000000000000000000000..d62063d00b3963bb93f8be5b743d4dac38c4bb41 --- /dev/null +++ b/marker2/ds9/EFTA00087556/EFTA00087556.md @@ -0,0 +1,17 @@ +From: To: Nathan NYSD Chambers Cc: 11 4 >, Laura Menninger S .1•••••••• Jeff Pagliuca "Bobbi C. + +Subject: US v. Maxwell, 20 CR 330 (AJN) - Daubert Motion + +Date: The, 16 Nov 2021 04:05:50 +0000 + +Attachments: 2021.11.15\_Government 2nd Daubert.zip + +Chambers, + +Attached please find the Government's motion to preclude the remaining defense experts and attached exhibits. The Government is submitting this motion temporarily under seal. + +Respectfully submitted, + +Assistant United States Attorney Southern District of New York + +New York. New York 10007 \ No newline at end of file diff --git a/marker2/ds9/EFTA00087556/EFTA00087556.metadata.json b/marker2/ds9/EFTA00087556/EFTA00087556.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..7dbc7efd71d453c3f79114562a5561bf19d2e68b --- /dev/null +++ b/marker2/ds9/EFTA00087556/EFTA00087556.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087556.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 547, + "elapsed_seconds": 0.5, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 41 + ], + [ + "Line", + 21 + ], + [ + "Text", + 9 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087556" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087557/EFTA00087557.md b/marker2/ds9/EFTA00087557/EFTA00087557.md new file mode 100644 index 0000000000000000000000000000000000000000..5f6365bcd1883c43e78c1c2d5a8b2dddde728c6f --- /dev/null +++ b/marker2/ds9/EFTA00087557/EFTA00087557.md @@ -0,0 +1,13 @@ +From: ' (USANYS)" > Il (USANYS)" + +Subject: Epstein FOR Updates + +Date: Tue, 23 Nov 2021 16:50:50 +0000 + +Hi Public Corruption Chiefs, + +FYI, since the Times article came out today about Epstein's incarceration and death, BOP has been receiving multiple new requests for the records released in the FOIA matter (ABC, CNN, MuckRack). BOP plans to respond to those requests quickly and release the same records. + +One minor wrinkle: the FOIA specialist at BOP has tried to contact Mark Epstein a couple times regarding his communications from about a month ago. But so far he has not responded to her. She has asked if we have contact info for him. What I have is this phone number 917-543-2432 and these emails Mark Epstein < ;. and STACEY RICHMAN •,: >. I am going to confirm BOP has these, but please let me know if there is some other way to contact him. + +Thanks, Assistant United States Attorney White Plains, NY 10601 Telephone: \ No newline at end of file diff --git a/marker2/ds9/EFTA00087557/EFTA00087557.metadata.json b/marker2/ds9/EFTA00087557/EFTA00087557.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..aefc77541e11ee3111b2c6d111c8da8dc412a2a9 --- /dev/null +++ b/marker2/ds9/EFTA00087557/EFTA00087557.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087557.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 966, + "elapsed_seconds": 0.44, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 46 + ], + [ + "Line", + 22 + ], + [ + "Text", + 7 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087557" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087558/EFTA00087558.md b/marker2/ds9/EFTA00087558/EFTA00087558.md new file mode 100644 index 0000000000000000000000000000000000000000..87affc79f07f9d454ceca4f959cf640c3f9fee65 --- /dev/null +++ b/marker2/ds9/EFTA00087558/EFTA00087558.md @@ -0,0 +1,31 @@ +From: testimony To: testimon + +Subject: [EXTERNAL] 227815.002 USA V GHISLAINE MAXWELL 20 CR 330 (AJN) + +Date: Tue, 23 Nov 2021 17:41:39 +0000 + +Importance: Normal + +Attachments: unnamed + +## Microsoft Teams meeting + +Join on your computer or mobile app + +Click here to join the meeting + +Join with a video conferencing device + +Video Conference I + +Alternate VTC instructio• + +Or call in (audio only) + +United States, Houston + +Phone Conference - + +Find a local number I Reset PIN + +Learn More I Help I Meeting options \ No newline at end of file diff --git a/marker2/ds9/EFTA00087558/EFTA00087558.metadata.json b/marker2/ds9/EFTA00087558/EFTA00087558.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..4db7aee0910d10c6b0ea59e7a3ab608b17c0291b --- /dev/null +++ b/marker2/ds9/EFTA00087558/EFTA00087558.metadata.json @@ -0,0 +1,82 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087558.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 503, + "elapsed_seconds": 0.75, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Microsoft Teams meeting", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 31.212, + 210.48822021484375 + ], + [ + 224.17279052734375, + 210.48822021484375 + ], + [ + 224.17279052734375, + 229.36761474609375 + ], + [ + 31.212, + 229.36761474609375 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 41 + ], + [ + "Line", + 19 + ], + [ + "Text", + 15 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087558" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087559/EFTA00087559.md b/marker2/ds9/EFTA00087559/EFTA00087559.md new file mode 100644 index 0000000000000000000000000000000000000000..e953bd841d8307f73f210ab8f26bfaa413afe183 --- /dev/null +++ b/marker2/ds9/EFTA00087559/EFTA00087559.md @@ -0,0 +1,47 @@ +Start Date: 2021-11-24 19:00:00 +0000 + +End Date: 2021-11-24 19:30:00 +0000 + +Organizer: testimony ce + +Location: att prep call + +Class: X-PERSONAL + +Date Created: 2021-11-23 18:27:45 +0000 + +Date Modified: 2021-11-23 18:27:45 +0000 + +Priority: 5 + +DTSTAMP: 2021-11-23 17:41:37 +0000 + +Attendee: + +Alarm: Display the following message 15m before start + +Reminder + +Microsoft Teams meeting + +Join on your computer or mobile app + +Click here to join the meeting + +Join with a video conferencing device + +att@m.webex.com + +Video Conference ID: + +Alternate VTC instructions + +Or call in (audio only) + +United States, Houston + +Phone Conference ID: + +Find a local number I eset + +Learn More I Help I Meeting options \ No newline at end of file diff --git a/marker2/ds9/EFTA00087559/EFTA00087559.metadata.json b/marker2/ds9/EFTA00087559/EFTA00087559.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..7fb6fddb4e7171d51ac402f935b585b29868e14a --- /dev/null +++ b/marker2/ds9/EFTA00087559/EFTA00087559.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087559.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 687, + "elapsed_seconds": 0.99, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 51 + ], + [ + "Line", + 26 + ], + [ + "Text", + 25 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087559" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087560/EFTA00087560.md b/marker2/ds9/EFTA00087560/EFTA00087560.md new file mode 100644 index 0000000000000000000000000000000000000000..0cf0d995cf6de39a98ac5f22f79410e9fd4eae08 --- /dev/null +++ b/marker2/ds9/EFTA00087560/EFTA00087560.md @@ -0,0 +1,106 @@ +**To:** Nathan NYSD Chambers <[REDACTED]> + +**Cc:** [REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] + +**Subject:** [EXTERNAL] RE: [EXTERNAL EMAIL] Re: 20cr330, US v. Maxwell - [REDACTED]. +[REDACTED] Motion to Quash + +**Date:** Tue, 23 Nov 2021 22:46:02 +0000 + +**Attachments:** 2021.11.23 - \_ Letter \_ from \_ P. Smith to \_ Judge \_ Nathan \_ re \_ Document \_ Production.pdf + +--- + +Chambers - Please see the attached letter on behalf of [REDACTED], which we are submitting under temporary seal. + +Respectfully submitted, + +[REDACTED] +[REDACTED] +[REDACTED] + +New York, New York 10019 + +**Office** [REDACTED] | **Direct** [REDACTED] | **Mobile** [REDACTED] + +--- + +**From:** Nathan NYSD Chambers <[REDACTED]> + +**Sent:** Monday, November 22, 2021 8:04 PM + +**To:** [REDACTED] > + +**Cc:** [REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] + +**Subject:** [EXTERNAL EMAIL] Re: 20cr330, US v. Maxwell - [REDACTED]. [REDACTED] Motion to Quash + +Counsel: + +Please see the attached Order issued by the Court. + +Sincerely, +Chambers of the Hon. Alison J. Nathan + +--- + +**From:** [REDACTED] > + +**Sent:** Monday, November 22, 2021 4:43 PM + +**To:** Nathan NYSD Chambers <[REDACTED]> + +**Cc:** [REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] + +**CAUTION - EXTERNAL:** + +Chambers – Understanding that the defense has not yet filed its response to [REDACTED]. [REDACTED] motion to quash, we respectfully ask whether the Court intends to hear oral argument on [REDACTED]. [REDACTED] behalf (as requested in [REDACTED]. [REDACTED] motion) at the final pre-trial conference scheduled for tomorrow at 9:30 am. If so, we are prepared to appear. + +Respectfully submitted, + +[REDACTED] +[REDACTED] +[REDACTED] +New York, New York 10019 +**Office** [REDACTED] | **Direct** [REDACTED] | **Mobile** [REDACTED] + +--- + +**From:** [REDACTED] +**Sent:** Friday, November 19, 2021 7:42 PM +**To:** Nathan NYSD Chambers <[REDACTED]> +**Cc:** [REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] > +**Subject:** 20cr330, US v. Maxwell - [REDACTED]. [REDACTED] Motion to Quash + +Chambers – Attached please find [REDACTED]. [REDACTED] motion to quash the defendant’s Rule 17(c) subpoena, and a zip file of the referenced exhibits. We submit this letter motion and exhibits under temporary seal. + +Respectfully submitted, + +[REDACTED] +[REDACTED] +[REDACTED] +New York, New York 10019 +**Office** [REDACTED] | **Direct** [REDACTED] | **Mobile** [REDACTED] + +**CAUTION - EXTERNAL EMAIL:** This email originated outside the Judiciary. 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Nathan United States District Judge Southern District of New York 40 Foley Square New York, New York 10007 + +Re: United States v. Maxwell. No. 20 Cr. 330 + +![](_page_0_Picture_3.jpeg) + +Dear Judge Nathan: + +We represent the independent administrator of the Epstein Victims' Compensation Program. We write regarding the Court's order, dated November 22, 2021, denying motion to quash Maxwell's subpoena to her and ordering production of the subpoenaed documents by November 24, 2021 at noon. + +ends to comply with the Court's order and produce responsive documents to the Court. However, given the volume of materials and the steps necessary to ensure that documents produced fall within the scope of the subpoena, it is not possible to produce all materials by noon tomorrow. We understand that the volume of potentially responsive materials is approximately 6,000 to 7,000 pages, and we note that the original return date for the subpoena was November 29, 2021 at 8:30am. + +We intend to produce by noon tomorrow documents consisting of claim forms and any narratives signed by the four individuals identified in the subpoena, payment records, and releases executed by the four individuals. We intend to produce remaining responsive documents as soon as possible thereafter and respectfully request until November 29, 2021 at 8:30am (the original subpoena return date) to complete production. + +We are available should the Court have any questions. + +Respectfully submitted, + +/s/ Patrick J. Smith + +Patrick J. Smith Smith Villazor LLP + +cc: Al.et , AUSA AUSA AUSA Christian R. Everdell, Esq., Jeffrey S. Pagliuca, Esq., Laura A. Menninger, Esq., Mark Stewart Cohen, Esq., Bobbi C. Stemheim, Esq. (by e-mail) \ No newline at end of file diff --git a/marker2/ds9/EFTA00087562/EFTA00087562.metadata.json b/marker2/ds9/EFTA00087562/EFTA00087562.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..4015771f3b8aefd9f5e8f5dfd0a310f4e709a073 --- /dev/null +++ b/marker2/ds9/EFTA00087562/EFTA00087562.metadata.json @@ -0,0 +1,64 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087562.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1753, + "elapsed_seconds": 0.83, + "image_assets": [ + "_page_0_Picture_3.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 78 + ], + [ + "Line", + 37 + ], + [ + "Text", + 13 + ], + [ + "PageHeader", + 2 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087562" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087562/_page_0_Picture_3.jpeg b/marker2/ds9/EFTA00087562/_page_0_Picture_3.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..92ee3b16c518e1bc2c1a87419249aa3613d9423e --- /dev/null +++ b/marker2/ds9/EFTA00087562/_page_0_Picture_3.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:71da3d598d1696f65c9cbbafb9bb65f835c25349cb5d74059ef112529274f8af +size 1084 diff --git a/marker2/ds9/EFTA00087563/EFTA00087563.md b/marker2/ds9/EFTA00087563/EFTA00087563.md new file mode 100644 index 0000000000000000000000000000000000000000..eb9feb36f8b882322e7e8a536039f28d6b9ea770 --- /dev/null +++ b/marker2/ds9/EFTA00087563/EFTA00087563.md @@ -0,0 +1,31 @@ +To: + +Cc: + +Subject: RE: PLEASE READ: Project Safe Childhood - Case check ins + +Date: Wed, 02 Jun 2021 17:49:13 +0000 + +Hi all, + +The two cases I have listed here are the Jeffrey Epstein and Ghislaine Maxwell investigations. The Epstein case is closed as a result of his suicide, which is noted in the report. The Maxwell case is scheduled for trial in November 2021. + +Thanks, + +From: + +Sent: Wednesday, June 2, 2021 12:00 PM + +To: + +I • ' • - + +Hi all, + +If you are receiving this email, you have a child exploitation case listed in LIONS as being active. Please take a moment to open the attached PDF, search for your name, review the entries for all cases assigned to you, and respond by email to me and the GC chiefs (ol if a WP case) letting us know either (i) the entry is up to date or (ii) provide updates as to the status of your case (e.g., list charges, plea date, sentencing date, and/or note that certain investigative steps are imminent). If the case has been pending for some time without charges (several months or longer), please discuss with me or your unit chiefs whether additional action is needed or you should consider closing the case if there are no additional leads or other investigative action to be taken. Given the sensitivity of these cases, we want to make sure that no case remains idle for too long. + +Please respond no later than June 9, 2021. + +Thanks in advance, + +NEM \ No newline at end of file diff --git a/marker2/ds9/EFTA00087563/EFTA00087563.metadata.json b/marker2/ds9/EFTA00087563/EFTA00087563.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..2048f4b187a9d8fe811f2c8ac0b426313418b0da --- /dev/null +++ b/marker2/ds9/EFTA00087563/EFTA00087563.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087563.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1391, + "elapsed_seconds": 0.8, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 56 + ], + [ + "Line", + 26 + ], + [ + "Text", + 17 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087563" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087564/EFTA00087564.md b/marker2/ds9/EFTA00087564/EFTA00087564.md new file mode 100644 index 0000000000000000000000000000000000000000..953bdef8353ada7bf8bae0b856f3911e19f07e73 --- /dev/null +++ b/marker2/ds9/EFTA00087564/EFTA00087564.md @@ -0,0 +1,56 @@ +105 MAIN STREET +HACKENSACK, NJ 07601 +TEL: 201-457-0071 +FAX: 201-457-0072 + +WWW.FOYSEPLOWITZ.COM + +30 WALL STREET +8TH FLOOR +NEW YORK, NY 10005 +TEL: 212-709-8230 + +January 29, 2020 + +![](_page_0_Picture_159.jpeg) + +US Attorney's Office - SDNY +One Saint Andrew's Plaza +New York, NY 10007 + +**Re: US v. Tova Noel, et al +19 cr 830** + +Dear Counsel: + +I acknowledge receipt of your January 24, 2020 correspondence regarding the surveillance system at the MCC. Based on the information provided in your correspondence and pursuant to Fed. R. Crim. P. 16, please provide the following information and materials: + +1. 1. Documents and information related to the initial installation of the video surveillance system at the MCC before and after August 10, 2019, including the entity that was contracted to install it, the date it was installed, and a description of how it operates at MCC; +2. 2. The specific type and model of the video surveillance system before and after August 10, 2019; +3. 3. Rules and regulations regarding the maintenance of the video surveillance systems before and after August 10, 2019; +4. 4. All certifications, maintenance records and work orders, completed and outstanding, for the video surveillance system that was in place on and before August 10, 2019; +5. 5. The work order and the contract with the entity that replaced the video surveillance system on or about August 12, 2019; +6. 6. Please confirm whether there are any concealed cameras in the SHU and throughout MCC; +7. 7. Whether any MCC corrections officers/employees were advised that the video + +surveillance cameras were not operational or compromised in any way. If so, who are the corrections officers/employees, when were they advised, and how were they advised; + +- 8. What is the difference between the new video surveillance system and the video surveillance system that was previously in use for over 10 years; +- 9. Under the current video surveillance system, are the cameras installed in the same locations as the cameras under the old video surveillance system? If not, please specify which camera locations have changed and provide their prior and current locations; 10.A11 reports, communications. and documentation related to the "system failure" on or about July 29, 2019 and on or about August 8, 2019; 11.The identity and contact information to the technician employed by the MCC, who was aware of the August 8th system failure on DVR-2 and attempted to fix the problem; 12.All FBI reports and notes as it relates to its investigation of the destruction of video surveillance evidence at the MCC; 13.Incident reports, maintenance records, and documentation for Camera-2, Camera-3, and the Tier Cameras recorded to DVR-2 that were not recording on August 9, 2019 and August 10, 2019; +- 14. The indictment alleges that the defendants spent substantial portions of their shifts sitting at their desk, browsing the internet and moving around the common area of the SHU. Which specific video files contain this alleged conduct? For each video file, provide the date and time stamp of the alleged conduct; 15.The file number with the date and time stamp of any video surveillance that captures Jeffrey Epstein on the MCC video surveillance system; 16.All video surveillance seized by the Government as part of their investigation into Jeffrey Epstein's alleged July 23, 2019 suicide attempt, including any footage of Epstein from before or after the alleged suicide attempt; 17.As per paragraph #17 of the indictment, which specific video and time stamp makes clear that defendant Noel and Officer -1 did not perform the 4pm count; 18.As per paragraph #19 of the indictment, which specific video and time stamp shows that defendant Noel did not perform the 10pm count; + +- 19. As per paragraph #20 of the indictment, which video surveillance file contains defendant Noel briefly walk up to and then walk back from the tier where Epstein was housed; 20.As per paragraph #21 of the indictment, which specific video and time stamp makes clear that defendant Noel did not perform the 12am count; +- 21. What video surveillance if any, captures defendant Noel or defendant Thomas speaking with 'n August 10, 2019 after the discovery of Epstein's body; 22.Advise which video surveillance files capture the defendants on the computer conducting the internet searches referenced in paragraph #24 of the indictment; +- 23. What is the two-hour period that allegedly shows defendant Noel and Thomas sitting at their desk without moving and appearing to be asleep? Please provide the video date and time stamp of the alleged conduct; + +Given the volume of discovery, we are asking the Government to highlight where exactly on the video surveillance system the alleged incriminating evidence is contained. Doing so may assist in expediting the ability of the defense to be ready for trial. + +If you have any questions or concerns about the foregoing, please give me a call. Thank you for your thoughtful consideration. + +Sincerely, + +FOY & SEPLOWITZ LLC + +JASON E. FOY + +cc: Tova Noel \ No newline at end of file diff --git a/marker2/ds9/EFTA00087564/EFTA00087564.metadata.json b/marker2/ds9/EFTA00087564/EFTA00087564.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..f08bce00a04163df63c74eb77055b540f5143d6d --- /dev/null +++ b/marker2/ds9/EFTA00087564/EFTA00087564.metadata.json @@ -0,0 +1,152 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087564.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 5063, + "elapsed_seconds": 5.96, + "image_assets": [ + "_page_0_Picture_159.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 100 + ], + [ + "Line", + 39 + ], + [ + "Text", + 17 + ], + [ + "PageHeader", + 4 + ], + [ + "Picture", + 2 + ], + [ + "ListGroup", + 2 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 76 + ], + [ + "Line", + 37 + ], + [ + "ListItem", + 3 + ], + [ + "PageHeader", + 2 + ], + [ + "Text", + 1 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 56 + ], + [ + "Line", + 28 + ], + [ + "Text", + 7 + ], + [ + "ListItem", + 3 + ], + [ + "PageHeader", + 2 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087564" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087564/_page_0_Picture_159.jpeg b/marker2/ds9/EFTA00087564/_page_0_Picture_159.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..b626b83f7a3d557b611e541e1dc12e6fe5eb2443 --- /dev/null +++ b/marker2/ds9/EFTA00087564/_page_0_Picture_159.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:909dd825c8f952c8d4eae844531826ee20aa171b61c9bf349097a56170c2b7b6 +size 3606 diff --git a/marker2/ds9/EFTA00087567/EFTA00087567.md b/marker2/ds9/EFTA00087567/EFTA00087567.md new file mode 100644 index 0000000000000000000000000000000000000000..fa48eb43b0eeafa810351259a52e9cc0bc13089d --- /dev/null +++ b/marker2/ds9/EFTA00087567/EFTA00087567.md @@ -0,0 +1,65 @@ +**From:** "[REDACTED] (USANYS)" <[REDACTED]> +**To:** "[REDACTED] (USANYS)" <[REDACTED]> +**Cc:** "[REDACTED] (USANYS)" <[REDACTED]> + +**Subject:** RE: Attorney General's Award Nominations + +**Date:** Wed, 19 Feb 2020 17:30:03 +0000 + +--- + +You know, as everything else we do is taking a beating publicly, it'd be nice to be recognized for something so important. + +--- + +**From:** [REDACTED] (USANYS) <[REDACTED]> +**Sent:** Wednesday, February 19, 2020 12:28 PM +**To:** [REDACTED] (USANYS) <[REDACTED]> +**Cc:** [REDACTED] (USANYS) <[REDACTED]> +**Subject:** RE: Attorney General's Award Nominations + +The Exec Staff met yesterday to make our selections. I don't think Epstein would have been a contender, but I will circulate this in case anybody wants to consider changing their mind. + +--- + +**From:** [REDACTED] (USANYS) <[REDACTED]> +**Sent:** Wednesday, February 19, 2020 12:23 PM +**To:** [REDACTED] (USANYS) <[REDACTED]> +**Cc:** [REDACTED] (USANYS) <[REDACTED]> +**Subject:** RE: Attorney General's Award Nominations + +We'd like to nominate the prosecution of Jeffrey Epstein for an AG award. Although it ended without a conviction, as you are aware, the effort and initial success of the prosecution was remarkable. Here's a short write-up for now: + +On July 2, 2019, a federal grand jury in the Southern District of New York returned a sealed indictment (the "Indictment") charging Epstein with one count of sex trafficking of minors, in violation of 18 U.S.C. § 1591, and one count of conspiracy to commit sex trafficking of minors, in violation of 18 U.S.C. § 371. + +Beginning in at least 2002, Epstein enticed and recruited dozens of minor girls to engage in sex acts with him, for which he paid the victims hundreds of dollars in cash. He undertook this activity myriad locations, including his mansion in Manhattan, New York and his estate in Palm Beach, Florida. In both New York and Florida, Epstein perpetuated this abuse in similar ways. Victims were initially recruited to provide "massages" to Epstein, which would be performed nude or partially nude, would become increasingly sexual in nature, and would typically include one or more sex acts, including groping and direct or indirect contact with victims' genitals. Epstein paid his victims hundreds of dollars in cash for each separate encounter. Moreover, Epstein actively encouraged certain of his victims to recruit additional girls to be similarly sexually abused. He incentivized his victims to become recruiters by paying these victim-recruiters hundreds of dollars for each additional girl they brought to him. In this fashion, Epstein created a vast network of underage victims – as young as 14 – in locations including New York and Palm Beach. + +Epstein was initially investigated by the Southern District of Florida, which resulted in a 2007 non-prosecution agreement combined with a underage prostitution conviction in Florida state court. He was sentenced to 13 months in prison, some of which he served on work release. The process resulted in widespread criticism of the Department for its handling of victim notification issues, including substantial MVRA litigation in Florida. Leaving aside the merits of that litigation, the SDNY prosecution, though short-lived, was marked by remarkable coordination with victims whose trust we worked hard to gain successfully over the course of months, helping to restore the faith of those victims in the justice system. In addition, the Epstein matter – resulting in charges against one of the most heinous and prolific abusers of minors this century – took only 7 + +months from inception to charges. During that time, the team worked tirelessly to ensure both swift progress and that the investigation would remain entirely covert, due to the substantial flight risk Epstein posed were he to learn he was again under investigation. An indictment was secured against Epstein when he traveled abroad from his estate in the U.S. Virgin Islands in July 2019, with the expectation that he would fly to Teterboro airport upon his ultimate return to the U.S. That ultimately did happen, leading to Epstein's arrest on July 6, 2019. Epstein, who we then successfully detained pending trial after a bail argument before Judge Richard Berman, committed suicide in his cell at the MCC on August 10, 2019. + +SONY AUSAs: FBI: Special Agent NYPD TFO + +From: McEnany, John (USANYS) + +Sent: Thursday, February 6, 2020 10:05 PM + +To: + +Cc: r (USANYS) [Contractor] .c > + +Subject: Attorney General's Award Nominations + +Chiefs: it is time to submit nominations for the Attorney General's Awards. Our Office can submit six nominations. The list of awards is attached. Exceptional Service, Distinguished Service, and Fraud Prevention can be used to nominate a group of up to 15 persons from various agencies. Think also of exceptional work that was done by an AUSA or small group of AUSAs—the John Marshal awards are for AUSAs only. + +Here's the schedule: + +By Thursday, Feb. 6: send your suggested nominations to me. I need a little blurb about what the nomination is for, how complete the case or matter is, and who, and from what agencies, will be nominated. + +Friday, Feb. 7: the executive staff will start considering the suggestions to decide on what we will nominate. The executive staff will notify the selected nominees to prepare the nomination package. + +Thursday Feb. 26: all nomination packages must be completed and sent to Luke U. and to me where they will be reviewed for form and edited as need be. + +Monday, March 2: nomination packages submitted to EOUSA. + +MillIMPPMEIMMIOW Associate U.S. Attorney United States Attorney's Office Southern District of New York One St. Andrew's Plaza New York, NY 10007 \ No newline at end of file diff --git a/marker2/ds9/EFTA00087567/EFTA00087567.metadata.json b/marker2/ds9/EFTA00087567/EFTA00087567.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..1aebc79549c758a46d68697476c7dbf75696a28a --- /dev/null +++ b/marker2/ds9/EFTA00087567/EFTA00087567.metadata.json @@ -0,0 +1,106 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087567.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 5720, + "elapsed_seconds": 12.42, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 32 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 49 + ], + [ + "Line", + 24 + ], + [ + "Text", + 11 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 19 + ], + [ + "Line", + 10 + ], + [ + "Text", + 3 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087567" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087570/EFTA00087570.md b/marker2/ds9/EFTA00087570/EFTA00087570.md new file mode 100644 index 0000000000000000000000000000000000000000..e38ad587337dd5fc2e449fb453fe369905c823e8 --- /dev/null +++ b/marker2/ds9/EFTA00087570/EFTA00087570.md @@ -0,0 +1,143 @@ +To: + +Subject: FW: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +Date: Tue, 02 Nov 2021 16:04:48 +0000 + +Hi all, + +Could you please pull these bates ranges from the JPMC subpoena productions and save them in the Q&A folder for a witness named Patrick McLugh? He works at JPMC and will be testifying. + +Thanks! + +From: Stoddart, Allison + +Sent: Tuesday, November 2, 2021 10:57 AM + +To: ) + +Cc: Sahni, Anjan ; (USANYS) < >; + +Subject: RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +As we discussed last week, below are the Bates ranges of the account opening documents for three accounts that appear in the exhibits that you provided: + +- Account Number W23560001: JPM-SDNY-00001896 to JPM-SDNY-00001943 +- Account Number 739474324: JPM-SDNY-00002398 to JPM-SDNY-00002439 +- Account Number Q79961001: JPM-SDNY-00001829 to JPM-SDNY-00001849 + +Additionally, JPM-SDNY-00002539 to JPM-SDNY-00002570 contains onboarding documents for Ghislaine Maxwell, but they are not necessarily associated with Account Number 739116312. + +Please let us know if you have any questions. + +Thanks, Allison + +From: + +Sent: Wednesday, October 27, 2021 9:02 AM + +To: Stoddart, Allison + +Cc: Sahni, Anjan • ) cl ›; (USANYS) + +Subject: RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) + +EXTERNAL SENDER + +Sent: Wednesday, October 27, 2021 7:48 AM + +To: )\*c > + +Cc: Sahni, Anjan • (USANYS) >; + +Subject: RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +We wanted to provide an update on the trial witness topic. Do you have any time this afternoon or tomorrow for a brief call? + +Thanks, Allison + +From: Stoddart, Allison + +Sent: Monday, October 18, 2021 9:05 PM + +To: + +Cc: Sahni, Anjan ; (USANYS) + +Subject: RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) + +Great. Thanks, Appreciate it. + +Allison + +From: + +Sent: Monday, October 18, 2021 8:58 PM + +To: Stoddart, Allison + +Cc: Sahni, Anjan • ) (USANYS) + +Subject: RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) + +EXTERNAL SENDER + +Hi Allison, + +Thanks, that's not a problem. I'm attaching a broadly worded subpoena to the bank, but please let me know if you'd like me to direct this more specifically to a particular entity or officer. + +Thanks, + +From: Stoddart, Allison + +Sent: Monday, October 18, 2021 8:57 AM + +To: + +Cc: Sahni, Anjan • (USANYS) < >; + +Following up on our last discussion, JPMorgan is working on identifying a witness for trial. Are you able to provide JPMorgan with a trial appearance subpoena? + +Thanks very much, + +Allison + +Allison Stoddart I WilmerHale 7 World Trade Center 250 Greenwich Street New York, NY 10007 USA +1 212 295 6401(t) allison.stoddart@wilmerhale.com + +From: + +Sent: Friday, October 8, 2021 12:15 PM + +To: Stoddart, Allison + +Cc: Sahni, Anjan ; (USANYS) + +Subject: Re: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +EXTERNAL SENDER + +Hi Allison, + +I'm traveling for work for much of next week, but I'm available for a call anytime on Monday, or at 9 a.m. on Tuesday. I'm also available for a call this afternoon anytime from 4 pm onwards if that's easier. + +Thanks. + +On Oct 8, 2021, at 11:18 AM, Stoddart, Allison wrote: + +Thanks, . Could we find some time early next week to discuss? Are there certain windows that would work on your end? + +Thanks, Allison + +Allison Stoddart I WilmerHale 7 World Trade Center 250 Greenwich Street New York, NY 10007 USA +1 212 295 6401(t) allison.stoddart@wilmerhale.com + +Subject: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +EXTERNAL SENDER + +Anjan, Allison, + +Hope you're both doing well. Following up on our last conversation, we wanted to send along a few documents in order to facilitate our conversation about identifying an appropriate witness from JP Morgan. Attached is a zip file containing a few draft exhibits. We are still working on finalizing exhibits, but we thought it made sense to start the conversation about this sooner rather than later. Please let us know if you have any questions or if a call would be useful. + +Thanks, + +Assistant United States Attorney Southern District of New York One Saint Andrew's Plaza New York, NY 10007 \ No newline at end of file diff --git a/marker2/ds9/EFTA00087570/EFTA00087570.metadata.json b/marker2/ds9/EFTA00087570/EFTA00087570.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..467419608ecd96b51dc8efb9c20eadd940e80cbe --- /dev/null +++ b/marker2/ds9/EFTA00087570/EFTA00087570.metadata.json @@ -0,0 +1,152 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087570.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 4, + "chars": 4563, + "elapsed_seconds": 1.73, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 71 + ], + [ + "Line", + 35 + ], + [ + "Text", + 25 + ], + [ + "ListItem", + 3 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 78 + ], + [ + "Line", + 35 + ], + [ + "Text", + 30 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 77 + ], + [ + "Line", + 36 + ], + [ + "Text", + 21 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 3, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 27 + ], + [ + "Line", + 14 + ], + [ + "Text", + 10 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087570" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087574/EFTA00087574.md b/marker2/ds9/EFTA00087574/EFTA00087574.md new file mode 100644 index 0000000000000000000000000000000000000000..88d70231eba31bca025be526d6f5b5f32f3ec177 --- /dev/null +++ b/marker2/ds9/EFTA00087574/EFTA00087574.md @@ -0,0 +1,123 @@ +From:I + +Subject: RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +Date: Tue, 02 Nov 2021 16:55:25 +0000 + +All set, saved here: + +From: + +Sent: Tuesday, November 2, 2021 12:05 PM + +To: + +Subject: FW: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +Hi all, + +Could you please pull these bates ranges from the JPMC subpoena productions and save them in the Q&A folder for a witness named . He works at JPMC and will be testifying. + +Thanks! + +From: Stoddart, Allison < + +Sent: Tuesday, November 2, 2021 10:57 AM + +To: + +Cc: Sahni, Anjan (USANYS) ) < >; I ; + +Subject: RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +As we discussed last week, below are the Bates ranges of the account opening documents for three accounts that appear in the exhibits that you provided: + +- Account Number +- Account Number +- Account Number JPM-SDNY-00001896 to JPM-SDNY-00001943 JPM-SDNY-00002398 to JPM-SDNY-00002439 JPM-SDNY-00001829 to JPM-SDNY-00001849 + +Additionally, JPM-SDNY-00002539 to JPM-SDNY-00002570 contains onboarding documents for Ghislaine Maxwell, but they are not necessarily associated with Account Number + +Please let us know if you have any questions. + +Thanks, Allison + +From: + +Sent: Wednesday, October 27, 2021 9 02 AM + +EXTERNAL SENDER + +Hi Allison, + +Thanks— would 3 p.m. work for a call today? + +From: Stoddart, Allison Sent: Wednesday, October , 1 :4 AM To: I < > Cc: Sahni, Anjan (USANYS) ) < Subject: RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) >; + +Hi + +We wanted to provide an update on the trial witness topic. Do you have any time this afternoon or tomorrow for a brief call? + +Thanks, Allison + +From: Stoddart, Allison Sent: Monday, October 18, 2021 9:05 PM To: < Cc: Sahni, Anjan 4.1a; (USANYS) Subject: RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +Great. Thanks, Appreciate it. + +Allison + +From: Sent: Monday, October 18, 2021 8:58 PM To: Stoddart, Allison Cc: Sahni, Anjan (USANYS) ) Subject: RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) iS + +EXTERNAL SENDER + +Hi Allison, + +Thanks, that's not a problem. I'm attaching a broadly worded subpoena to the bank, but please let me know if you'd like me to direct this more specifically to a particular entity or officer. + +Sent: Monday, October From: Stoddart, Allison To: Cc: Sahni, Anjan >; (USANYS) Subject: RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +Maurene, Lara, + +Following up on our last discussion, JPMorgan is working on identifying a witness for trial. Are you able to provide JPMorgan with a trial appearance subpoena? + +Thanks very much, + +Allison + +Allison Stoddart I WilmerHale + +From: Sent: Friday, October 8, 2021 12:15 PM To: Stoddart, Allison Cc: Sahni, Anjan I < >; Subject: Re: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) (USANYS) + +EXTERNAL SENDER + +Hi Allison, + +I'm traveling for work for much of next week, but I'm available for a call anytime on Monday, or at 9 a.m. on Tuesday. I'm also available for a call this afternoon anytime from 4 pm onwards if that's easier. + +Thanks. + +On Oct 8, 2021, at 11:18 AM, Stoddart, Allison wrote: + +Thanks, . Could we find some time early next week to discuss? Are there certain windows that would work on your end? + +Thanks, Allison + +From: + +Sent: Friday, October 8, 2021 10:01 AM + +To: Sahni, Anjan Stoddart, Allison + +Cc: (USANYS) < + +Subject: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +EXTERNAL SENDER + +Anjan, Allison, + +Hope you're both doing well. Following up on our last conversation, we wanted to send along a few documents in order to facilitate our conversation about identifying an appropriate witness from JP Morgan. Attached is a zip file containing a few draft exhibits. We are still working on finalizing exhibits, but we thought it made sense to start the conversation about this sooner rather than later. Please let us know if you have any questions or if a call would be useful. + +Thanks, + +Assistant United States Attorney Southern District of New York One Saint Andrew's Plaza New York, NY 10007 \ No newline at end of file diff --git a/marker2/ds9/EFTA00087574/EFTA00087574.metadata.json b/marker2/ds9/EFTA00087574/EFTA00087574.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..fe1710bf305b4a535a87e10c91082d9d4bf27280 --- /dev/null +++ b/marker2/ds9/EFTA00087574/EFTA00087574.metadata.json @@ -0,0 +1,152 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087574.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 4, + "chars": 4146, + "elapsed_seconds": 1.37, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 74 + ], + [ + "Line", + 37 + ], + [ + "Text", + 25 + ], + [ + "ListItem", + 3 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 75 + ], + [ + "Line", + 37 + ], + [ + "Text", + 17 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 61 + ], + [ + "Line", + 29 + ], + [ + "Text", + 14 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 3, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 35 + ], + [ + "Line", + 18 + ], + [ + "Text", + 14 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087574" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087578/EFTA00087578.md b/marker2/ds9/EFTA00087578/EFTA00087578.md new file mode 100644 index 0000000000000000000000000000000000000000..4bcecaf9c25cedbb4a752204408a5613bc360697 --- /dev/null +++ b/marker2/ds9/EFTA00087578/EFTA00087578.md @@ -0,0 +1,185 @@ +**Event:** Re: [EXTERNAL] RE: Touhy Request in United States v. Ghislaine Maxwell, S2 20 Cr. 330 (AJN) + +--- + +**Start Date:** 2021-10-29 13:30:00 +0000 + +**End Date:** 2021-10-29 14:00:00 +0000 + +**Organizer:** [REDACTED] > + +**Class:** X-PERSONAL + +**Date Created:** 2021-10-29 13:18:55 +0000 + +**Date Modified:** 2021-10-29 13:18:55 +0000 + +**Priority:** 5 + +**DTSTAMP:** 2021-10-29 13:15:44 +0000 + +[REDACTED] + +**Alarm:** Display the following message 15m before start + +| Reminder + +--- + +**From:** [REDACTED] + +**Sent:** Wednesday, October 27, 2021 10:42 PM + +**To:** [REDACTED] + +**Cc:** [REDACTED] + +**Subject:** RE: [EXTERNAL] RE: Touhy Request in United States v. Ghislaine Maxwell, S2 20 Cr. 330 (AJN) + +9:30 is fine. + +[REDACTED] + +Office of the Associate Chief Counsel, New York +U.S. Customs and Border Protection +One World Trade Center, 50th Floor +Suite 50.100 +New York, NY 10007 + +OCC NY [including me] is teleworking during the Corona Crisis. You may always reach me by email or cell at + +Click here for the OCC Northeast website + +## PRIVILEGED AND CONFIDENTIAL- CIRCULATION RESTRICTED + +This electronic communication, along with any attachment(s), contains confidential U.S. Government information intended for internal government use only. This electronic communication and its attachment(s) also contain information that is privileged as well as exempt from public disclosure under the Freedom of Information Act, 5 U.S.C. §552, including attorney work product, material that is part of the agency's deliberative process, and/or communications between attorney and client concerning legal matters for which the client has sought professional advice. The contents of this electronic communication and its attachment(s) are solely intended for the use by the addressee(s) designated herein, and must be controlled, stored, handled, transmitted, distributed, and disposed of in a manner that restricts access to only the designated addressee(s) and to those within U.S. Customs and Border Protection (CBP) who have an official "need-to-know." + +If you are not a designated addressee of the electronic communication or a CBP official with a "need-to-know," you are prohibited from reviewing, using, copying, releasing, retransmitting, disseminating, disclosing, or otherwise sharing the communication or its attachments within or outside CBP without prior, written approval from the Commissioner of CBP and the Office of the Associate Chief Counsel, New York. Please notify the sender immediately and permanently delete this electronic communication, and any copies or printouts of the communication and its attachments. + +From: ) &It; + +Sent: Tuesda October 26 2021 6:17 PM + +To: Cc: + +Subject: RE: [EXTERNAL] RE: Touhy Request in United States v. Ghislaine Maxwell, S2 20 Cr. 330 (AJN) + +Thanks. We're free on Friday morning at 9:30 a.m. or later, if that works. + +From: + +Subject: RE: [EXTERNAL] RE: Touhy Request in United States v. Ghislaine Maxwell, S2 20 Cr. 330 (AJN) + +Thanks, + +I am available Friday at 8. If you all are available anytime tomorrow afternoon that would work as well. + +Best, + +Office of the Associate Chief Counsel, New York + +U.S. Customs and Border Protection + +One World Trade Center, 50th Floor + +Suite 50.100 + +New York, NY 10007 + +(fax) + +OCC NY [including me] is teleworking during the Corona Crisis. You may always reach me by email or cell at + +Click here for the OCC Northeast website + +## PRIVILEGED AND CONFIDENTIAL- CIRCULATION RESTRICTED + +This electronic communication, along with any attachment(s), contains confidential U.S. + +Government information intended for internal government use only. This electronic communication and its attachment(s) also contain information that is privileged as well as exempt from public disclosure under the Freedom of Information Act, 5 U.S.C. §552, including attorney work product, material that is part of the agency's deliberative process, and/or communications between attorney and client concerning legal matters for which the client has sought professional advice. The contents of this electronic communication and its attachment(s) are solely intended for the use by the addressee(s) designated herein, and must be controlled, stored, handled, transmitted, distributed, and disposed of in a manner that restricts access to only the designated addressee(s) and to those within U.S. Customs and Border Protection (CBP) who have an official "need-to-know." + +If you are not a designated addressee of the electronic communication or a CBP official with a "need-to-know," you are prohibited from reviewing, using, copying, releasing, retransmitting, + +disseminating, disclosing, or otherwise sharing the communication or its attachments within or outside CBP without prior, written approval from the Commissioner of CBP and the Office of the Associate Chief Counsel, New York. Please notify the sender immediately and permanently delete this electronic communication, and any copies or printouts of the communication and its attachments. + +From: [REDACTED] < [REDACTED]; + +Sent: Tuesday, October 26, 2021 1:40 PM + +To: [REDACTED] + +[REDACTED] + +Subject: RE: [EXTERNAL] RE: Touhy Request in United States v. Ghislaine Maxwell, S2 20 Cr. 330 (AJN) + +CAUTION: This email originated from outside of DHS. DO NOT click links or open attachments unless you recognize and/or trust the sender. If you feel this is a suspicious-looking email, please report by using the Report Phish button option. + +Hi [REDACTED] + +Thanks very much for reaching out. We're available for a call on Friday morning, if there's a time that works best for you. + +Thanks, + +[REDACTED] + +From: [REDACTED]; + +Sent: Monday, October 25, 2021 8:15 PM + +To: [REDACTED] + +Cc: [REDACTED] + +[REDACTED] + +Subject: Re: [EXTERNAL] RE: Touhy Request in United States v. Ghislaine Maxwell, S2 20 Cr. 330 (AJN) + +Good evening, + +Thank you for your email. I am cc'ing the other AUSAs who are handling this matter. One of them will be in touch with you to discuss. + +On Oct 25, 2021, at 6:03 PM, wrote: + +This office received the attached subpoena request in the above-referenced matter from Mr. Christian Everdell. Please let me know if you are available for a call to discuss background related to the documents that were previously provided to defense counsel and the circumstances related to this disclosure. A password for the second attachment will follow via separate cover. + +I am available for most of the day on Thursday. + +Regards, + +Office of the Associate Chief Counsel, New York U.S. Customs and Border Protection One World Trade Center, 50th Floor Suite 50.100 New York, NY 10007 + +(fax) + +OCC NY [including me] is teleworking during the Corona Crisis. You may always reach me by email or cell at + +Click here for the OCC Northeast website + +&It;image001.png> + +## PRIVILEGED AND CONFIDENTIAL- CIRCULATION RESTRICTED + +This electronic communication, along with any attachment(s), contains confidential U.S. Government information intended for internal government use only. This electronic communication and its attachment(s) also contain information that is privileged as well as exempt from public disclosure under the Freedom of Information Act, 5 U.S.C. §552, including attorney work product, material that is part of the agency's deliberative process, and/or communications between attorney and client concerning legal matters for which the client has sought professional advice. The contents of this electronic communication and its attachment(s) are solely intended for the use by the addressee(s) designated herein, and must be controlled, stored, handled, transmitted, distributed, and disposed of in a manner that restricts access to only the designated addressee(s) and to those within U.S. Customs and Border Protection (CBP) + +If you are not a designated addressee of the electronic communication or a CBP official with a "need-to-know," you are prohibited from reviewing, using, copying, releasing, retransmitting, disseminating, disclosing, or otherwise sharing the communication or its attachments within or outside CBP without prior, written approval from the Commissioner of CBP and the Office of the Associate Chief Counsel, New York. Please notify the sender immediately and permanently delete this electronic communication, and any copies or printouts of the communication and its attachments. + +&It;2021.10.14 Everdell LTO CBP re Touhy Request.pdf> + +&It;Subpoena JS Customs and Border Protection (D.C. Address).pdf> + +Microsoft Teams meeting + +Join on your computer or mobile app + +Click here to join the meeting + +Or call in (audio only) + ++1 332-249-0605"186166690# United States, New York City + +Phone Conference ID: 186 166 690# + +Find a local number I Reset PIN + +This Teams Meeting is hosted on a U.S. Government information system and is provided for U.S. Government-authorized use only. 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Max" <[REDACTED]> +**Subject:** RE: +**Sent:** Sun, 3 Mar 2002 15:27:59 -0000 + +Got it I will ring him today if I can. +Love you A xxx + +-----Original Message----- + +**From:** G. Max [mailto:[REDACTED]] +**Sent:** 03 March 2002 05:36 +**To:** The Invisible Man +**Subject:** + +Thought you would like to see what I sent +- Have a great time + +Gx + +I just gave Andrew your telephone no. He is interested in seeing the Nazca +Lines. He can ride but it is not his favorite sport ie pass on the horses. +Some sight seeing some 2 legged sight seeing (read intelligent pretty fun +and from good families) and he will be very happy. I know I can rely on you +to show him a wonderful time and that you will only introduce him to friends that you can trust and rely on to be friendly and discreet and fun. +He does not want to read about any trip in the papers whom or what he saw. +Call me if you have any questions - otherwise you can expect a very English +sounding gentleman on the phone to call up and say hi. I told him it would +be best if he made his plans directly with you. +The only part that I am jealous about is that he will get to see you and + +that he will be in Peru and have you as his tour guide for a day + +Besos + +Gx \ No newline at end of file diff --git a/marker2/ds9/EFTA00087584/EFTA00087584.metadata.json b/marker2/ds9/EFTA00087584/EFTA00087584.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..9ea97c4edb7669440263a1bac3b18cb47b8af519 --- /dev/null +++ b/marker2/ds9/EFTA00087584/EFTA00087584.metadata.json @@ -0,0 +1,46 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087584.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1291, + "elapsed_seconds": 4.71, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 20 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087584" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087585/EFTA00087585.md b/marker2/ds9/EFTA00087585/EFTA00087585.md new file mode 100644 index 0000000000000000000000000000000000000000..2abdfa2c4e6ad5c39f6c9a33954777d3cbb15b42 --- /dev/null +++ b/marker2/ds9/EFTA00087585/EFTA00087585.md @@ -0,0 +1,12 @@ +**From:** "The Invisible Man" <[REDACTED]> +**To:** "Ghislaine Maxwell (E-mail)" <[REDACTED]> +**Subject:** Summer Camp +**Sent:** Thu, 16 Aug 2001 11:09:45 +0100 + +I am up here at Balmoral Summer Camp for the Royal Family. Activities take place all day and I am totally exhausted at the end of each day. The Girls are completely shattered and I will have to give them an early night today as it is getting tiring splitting them up all the time! + +How's LA? Have you found me some new inappropriate friends? Let me know when you are coming over as I am free from 25th August until 2nd Sept and want to go somewhere hot and sunny with some fun people before having to put my nose firmly to the grindstone for the Fall. + +Any ideas gratefully received! + +See ya A xxx \ No newline at end of file diff --git a/marker2/ds9/EFTA00087585/EFTA00087585.metadata.json b/marker2/ds9/EFTA00087585/EFTA00087585.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..b1dfff0e07b74ec16412312e1b7f5a231fc41824 --- /dev/null +++ b/marker2/ds9/EFTA00087585/EFTA00087585.metadata.json @@ -0,0 +1,46 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087585.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 764, + "elapsed_seconds": 3.12, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 10 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087585" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087586/EFTA00087586.md b/marker2/ds9/EFTA00087586/EFTA00087586.md new file mode 100644 index 0000000000000000000000000000000000000000..d7d26e6e7c6d953b378d97566c86dcde7d074d07 --- /dev/null +++ b/marker2/ds9/EFTA00087586/EFTA00087586.md @@ -0,0 +1,47 @@ +To: Gibby From: "G. Max Subject Re: + +Too bad, I am already counting on you + +Gx + +At 12:02 PM 11/6/2001 -0500, you wrote: + +Don't count on me - I'm too old to be counted on... + +Gibby + +At 09:37 AM 11/6/01 -0500, you wrote: + +I am counting on you + +Gx + +At 05:41 AM 11/6/2001 -0500, you wrote: + +Good Morning... + +I returned today to find no suggestions in my emails for JE trainer - still looking have a few more rocks still to turn over - but not looking too hopeful... + +Gibby + +At 06:05 PM 11/2/01 -0500, you wrote: + +Your a star - he wants someone to come to the hse. The instructor has to be female youngish and attractive otherwise he will loose interest rapidly. He is looking for someone who can tone, flex and stretch + +Thanks - + +Your desperately seeking an instructor + +PS + +If you had to rate the top 10 gyms in the city where would they be + any masseuses in the same vein as the exercise instructor? + +At 05:56 PM 11/2/2001 -0500, you wrote: + +Where does he want to train in a facility or someone to come to the house - does he want a weight training person a stretcher/dancer type - give me a little more color and logistics and I'll see what I can do... + +exercise instructor to work out with. He likes, well you know what he likes. Plse can you call me or let me know if you know of anyone or if you can point me to the right direction to go to a gym where you know I can meet someone who might do the trick + +Thanks + +Gx \ No newline at end of file diff --git a/marker2/ds9/EFTA00087586/EFTA00087586.metadata.json b/marker2/ds9/EFTA00087586/EFTA00087586.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..689c7aac2de6c6b05e8f72bf32295d22d1b704f2 --- /dev/null +++ b/marker2/ds9/EFTA00087586/EFTA00087586.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087586.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 1417, + "elapsed_seconds": 1.18, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 67 + ], + [ + "Line", + 34 + ], + [ + "Text", + 24 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 17 + ], + [ + "Line", + 9 + ], + [ + "Text", + 3 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087586" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087588/EFTA00087588.md b/marker2/ds9/EFTA00087588/EFTA00087588.md new file mode 100644 index 0000000000000000000000000000000000000000..f6d8c9cc4a16323d4b47aa81b7e9a5f357dd5a5f --- /dev/null +++ b/marker2/ds9/EFTA00087588/EFTA00087588.md @@ -0,0 +1,59 @@ + + +
+ +
To: &i' k>
+ +From: "G. Max" < gt;
+ +Subject: Re: see you in new york
+ +
+ +At 03:50 PM 2/7/2004 -0600, you wrote:
+ +
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
+ +
+ +p.s. do you want a lesson?
+ +
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Gx


At 02:54 PM 10/4/2001 -0400, you wrote:
So you passed the ball to me?
My interest in fashion these days extends to what I am wearing tonight!



Original Message
From: G. Max < gt;
To: Philip Levine < gt;
Sent: Thu Oct 04 15:08:34 2001
Subject:

Spoke to - she told me that she was meeting you tom so I told her
that it m g possible that you have an interest in fashion and that she
should irritate you about an internship -(read beg and deliver) expect her
to be hopefully accommodating

Gx
From ???@??? Thu Oct 04 15:30:43 2001 To: From: "G. Max" < Subject: Cc: Bcc: X-Attachments: In-Reply-To: References: Message-Id: <5.0.0.25.2.20011004151632.00b04818@mail.mindspring.com> X-Eudora-Signature: \ No newline at end of file diff --git a/marker2/ds9/EFTA00087590/EFTA00087590.metadata.json b/marker2/ds9/EFTA00087590/EFTA00087590.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..90884307b7fefe97872025e8ad4301c73202bfd8 --- /dev/null +++ b/marker2/ds9/EFTA00087590/EFTA00087590.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087590.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 974, + "elapsed_seconds": 0.24, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 79 + ], + [ + "Line", + 40 + ], + [ + "Text", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087590" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087591/EFTA00087591.md b/marker2/ds9/EFTA00087591/EFTA00087591.md new file mode 100644 index 0000000000000000000000000000000000000000..cf576592b0d85c79440868c5ad4990c3ef0f95bb --- /dev/null +++ b/marker2/ds9/EFTA00087591/EFTA00087591.md @@ -0,0 +1,3 @@ +To: 4284063 sk tel.com From: G. Max Sent Sat 1/1/4501 5:00:00 AM (UTC) + +Hey, Why are you not in NY - remember I have 2 playmates for you \ No newline at end of file diff --git a/marker2/ds9/EFTA00087591/EFTA00087591.metadata.json b/marker2/ds9/EFTA00087591/EFTA00087591.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..b498d6fa3fc9b8df095baaf3f0606339c1af4f06 --- /dev/null +++ b/marker2/ds9/EFTA00087591/EFTA00087591.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087591.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 136, + "elapsed_seconds": 0.22, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 9 + ], + [ + "Line", + 5 + ], + [ + "Text", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087591" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087592/EFTA00087592.md b/marker2/ds9/EFTA00087592/EFTA00087592.md new file mode 100644 index 0000000000000000000000000000000000000000..256eefd4d32502513829e1444b9f893c0fffc501 --- /dev/null +++ b/marker2/ds9/EFTA00087592/EFTA00087592.md @@ -0,0 +1,87 @@ +**From:** "The Invisible Man" <[REDACTED]> +**To:** "G. Max" <[REDACTED]> +**Subject:** RE: Re: +**Sent:** Thu, 28 Feb 2002 06:30:20 -0000 + +I am overwhelmed at the kindness and generosity of the offers that are being made for me. + +I would love to do them all but fear that there would not be enough time! However I am afraid that horses and I do not mix particularly well but the trip to see the Lines sounds really interesting. As far as food is concerned I am very easy and will fit in with whatever he plans and I don't mind what time it is at all. As for girls well I leave that entirely to you and Juan Estoban! + +I am going to have more time after tomorrow to know what will happen and when in Peru so I will be in touch again on Friday. + +Masses of love A xxx + +-----Original Message----- + +**From:** G. Max [mailto [REDACTED]] +**Sent:** 28 February 2002 00:30 +**To:** [REDACTED] +**Subject:** Fwd: Re: + +>What do you think + +Gx + +**From:** "Juanesteban Ganoza" <[REDACTED]> +>To: "G. Max" <[REDACTED]> +>Subject: Re: +>Date: Wed, 27 Feb 2002 17:48:10 -0800 +>X-Mailer: Microsoft Outlook Express 4.72.3110.1 +> +>Ok, before we speak on the phone... +> +>There are several things we could do on Sunday, depending on what he feels +>like doing: +> +>We could ride Peruvian Paso horses in the morning > I would organize a small +>group of friends and get a few horses and go either to the beach or the +>fields. Then we can go to a nice summer home and do a small / private +lunch +>in front of the sea, and at night we can go to a local restaurant. The +>night time on Sunday is not going to be so "active," as a lot of the +>restaurants are closed, and on Sunday nites people do not go out much +except +>to go to a movie ( so no night club going). +> +>Instead of the Peruvian Pasos, we could also organize a Polo game if he +>plays polo and would rather ride that type of horse. +> +>Or we can rent a small plane and go to see the Nazca Lines, and then go +to +>another place that is in the area called Paracas and go water-skiing + +still + +>in the morning. Paracas is a very special bay for water-skiing, very flat + +>in the early morning and very windy latter on. We can then have lunch in a + +>very nice private Hacienda near by or come back to Lima to have lunch by the + +>sea. Lunches in Lima on the summer time are late, around 3:30 pm or 4 pm + +>(after lots of wine and beach). + +> + +> + +>About the girls... how old is he ? I doubt it that he will find someone + +>here, but we can try. + +>I am leaving now to go to the gym. I will be back to my office early + +>tomorrow; if you prefer to talk to me tonight you can reach me at my mobile + +>[REDACTED] + +>Besos + +>JE + +> + +> + +> \ No newline at end of file diff --git a/marker2/ds9/EFTA00087592/EFTA00087592.metadata.json b/marker2/ds9/EFTA00087592/EFTA00087592.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..1f694fe747d903771416552a61f10476ef07d5ca --- /dev/null +++ b/marker2/ds9/EFTA00087592/EFTA00087592.metadata.json @@ -0,0 +1,68 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087592.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2701, + "elapsed_seconds": 7.81, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 32 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 37 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087592" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087594/EFTA00087594.md b/marker2/ds9/EFTA00087594/EFTA00087594.md new file mode 100644 index 0000000000000000000000000000000000000000..a82c9fe3e11984aa258606ba3cdcf17afd4b31a0 --- /dev/null +++ b/marker2/ds9/EFTA00087594/EFTA00087594.md @@ -0,0 +1,27 @@ +From: "The Invisible Man" > To: "'G. Maxwell'" < > Subject: RE: Sent Sat, 18 Aug 2001 22:42:18 +0100 + +Distraught! + +You probably wouldn't know but I lost my valet on Thursday. He died in his sleep. He had been with me since I was 2. I am a little off balance as not only has my office been restructured, I have left the RN and now my whole life is in turmoil as I have no one to look after me. He was a real rock and almost a part of the family. + +If you have any good ideas as to how to get my mind back on track I'd be grateful for advice. + +See you real soon... I hope if you are coming over. + +A xxx + +Original Message + +From: G. Maxwell (mailto + +Sent: 16 August 2001 16:32 + +To: + +Subject: + +So sorry to dissapoint you, however the truth must be told. I have only been able to find appropriate friends. Will let you know about some church meetings on those dates + +Kisses + +Gx \ No newline at end of file diff --git a/marker2/ds9/EFTA00087594/EFTA00087594.metadata.json b/marker2/ds9/EFTA00087594/EFTA00087594.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..76256e971aa44a4584bc337f21bf356d76dd837e --- /dev/null +++ b/marker2/ds9/EFTA00087594/EFTA00087594.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087594.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 870, + "elapsed_seconds": 0.67, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 49 + ], + [ + "Line", + 25 + ], + [ + "Text", + 14 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087594" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087595/EFTA00087595.md b/marker2/ds9/EFTA00087595/EFTA00087595.md new file mode 100644 index 0000000000000000000000000000000000000000..f7eab9c8f3a2e2a78373a823ee4e2a8c8a19293d --- /dev/null +++ b/marker2/ds9/EFTA00087595/EFTA00087595.md @@ -0,0 +1,13 @@ +Terese + +35 looks 27. Sexy and lots of fun + +Sophia + +25 sexy half Asian. Big breasts- bar tender wild + +MI 23 Huge breasts Very wild — one to come to the hotel room + +25 V pretty wants to leave Sweden — works for Elle mag — + +Plse advise if you want me to pre set up any apts with these girls — time and place \ No newline at end of file diff --git a/marker2/ds9/EFTA00087595/EFTA00087595.metadata.json b/marker2/ds9/EFTA00087595/EFTA00087595.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..bc4340eb756c381d45478412bbf932e7abc4e513 --- /dev/null +++ b/marker2/ds9/EFTA00087595/EFTA00087595.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087595.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 304, + "elapsed_seconds": 0.42, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 19 + ], + [ + "Line", + 10 + ], + [ + "Text", + 7 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087595" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087596/EFTA00087596.md b/marker2/ds9/EFTA00087596/EFTA00087596.md new file mode 100644 index 0000000000000000000000000000000000000000..3996363e65c91dc1f35cc6010870474bfae8d5a0 --- /dev/null +++ b/marker2/ds9/EFTA00087596/EFTA00087596.md @@ -0,0 +1,501 @@ +To: Cc: ' " , USANYS)" + +Subject: RE: FAA Question + +Date: Wed, 29 Sep 2021 14:42:10 +0000 + +Importance: Normal + +HMI I hope all's well. We've had a chance to review the records, and we'd like to learn more about one aircraft in particular. From our conversation, it sounds like the best next step is to contact the title companies involved. Can you help us identify the right title companies for the below aircraft? + +Thanks, + +\*\* + +On December 30, 2008, Sikosrksy Aircraft helicopter, S-76C-2, serial number 760750, tail number N750A was sold to; Air Ghislaine Inc + +103 Fould Road, #202 + +Wilmington, Delaware 19803 + +302-636-1956 + +The registrant was Larry VISOSKI, he signed as Director of Aviation + +On February 11, 2010, Air Ghislaine Inc changed their name to Shmitka Air Inc. + +In March 2010, Air Ghislaine Inc changed the tail number from N750A to N722JE. On the 8050-64 the signature is not legibile but it looks + +similar to the signature of Lawrence VISOSKI. He signed as Director of Operations for Shmitka Air Inc., f/k/a Air Ghislaine Inc. + +On August 25, 2010, N722JE was registered to Freedom Air International Inc., 103 Fould Road, #202, Wilmington, Delaware 19803 + +The registrant was Darren K. INDYKE, he signed as Vice President + +According to a bill of sale dated July 26, 2011, Freedom Air International (Darren K. INDYKE) sold N722JE to ASI Wings LLC, Hartford, CT (Melinda Westbrook). + +On June 13, 2019, ASI Wings LLC sold N722JE to Hyperion Air LLC, 6100 Red Hook Quarter, B3, St. Thomas, U.S. Virgin Islands + +The registrant was Lawrence P. VISOSKI Jr., he signed as Manager + +Per a bill of sale dated May 13, 2021, Hyperion Air LLC (Larry VISOSKI) sold N722JE to Industrial Integrity Solutions Inc., Ontario, CA + +Richard Munkvold signed as CFO. + +From + +Sent: Tuesday, August 24, 2021 8:21 AM + +To: + +Cc: (uSANYS) ; + +Subject: RE: FAA Question + +2007 Gulfstream GV-SP (G550), serial number 5173 was assigned tail number N415LM in March 2017 and was registered to + +Chevron USA Inc., Oakland, CA. Per a bill of sale dated March 29, 2017, Chevron USA Inc sold Gulfstream N41SLM to; Plan D LLC + +6100 Red Hook Quarter, B3 + +St. Thomas, U.S. Virgins Islands + +It looks like Insured Aircraft Title Service in Oklahoma handled the transaction. + +https://insuredaircraft.com/ + +Per the Plan D LLC, statement in support of registering aircraft that was submitted to the FAA, Jeffrey E. EPSTEIN was a member + +and VISOSKI was the manager. Further, Plan D LLC was established in 2012 in the U.S. Virgin Islands. + +Per a request to the FAA dated August 07, 2017 from VISOSKI, they requested to change the tail number from N415LM to N2121E. + +In January 2018 they changed the tail number to N212JE. VISOSKI provided phone number and e-mail: + +On August 14, 2019 I was told that N212JE was owned by Jeffrey Epstein and was in a hangar at the Cobb County airport (KRYY) in Kennesaw, Georgia. + +Flight plans indicated N212JE operated on July 07, 2019 from Paris, France to Teterboro, NJ then on July 11, 2019 it operated from + +Teterboro, NJ to Brunswick, GA (KBQK). + +Per a bill of sale dated December 22, 2020, Lawrence VISOSKI on behalf of Plan D LLC "sold" N212JE to Six G Aviation LLC who "sold" it the same day + +to N550GP LLC in Ontario, CA. N212JE was registered on February 24, 2021 to N550GP and James PREVITI signed as manager of Frontier JV LLC, its member. + +in March 2021, they changed the tail number to N550GP and it's still registered as N550GP to N550GP LLC. + +It looks like Insured Aircraft Title Service in Oklahoma handled this transaction also. + +https://insuredaircraft.com/ + +I attached a picture of N212JE. + +xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx + +1969 Boeing 727, serial number 20115, N50515 was sold on January 19, 2001 by Real Estate Exchange Inc., Portland, OR to JEGE Inc. 457 Madison Avenue, 4th floor, New York, NY 10022. The signature on the aircraft registration application is not legible + +but they listed their title as President. They changed the tail number to N908JE in April 2001. On the 2013 re-registration application for N908JE, + +Darren K. INDYKE, Vice President signed as Vice President of JEGE Inc. + +They were the registered owner of N908JE from 2001 until October 05, 2019 when the registration was cancelled. + +The aircraft was on the Part 125 certificate of JEGE Inc. and the CEO was Jeffrey EPSTEIN, + +3800 Southern Blvd., Suite 204, West Palm Beach, FL 33406 Phone 561-317-3082. + +N908JE was certificated for passenger operations only (not cargo). + +N908JE has a business configuration with a kitchen and bedroom and has approximately 25 seats in the aircraft and they aren't economy seats. + +It was used for private business not charter flights. + +https://www.aircraft.com/aircraft/1237885/n908je-boeing-727-100 + +N908JE might be in Brunswick, Georgia (BQK). If you need confirmation of its location please advise. + +I think Insured Aircraft Title Service in Oklahoma handled the transaction. + +https:Mnsuredaircraft.com/ + +xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx + +In 1994, a 1974 Gulfstream G-1159B, serial number 151, N979GA was sold by Gulfstream to + +Hyperion Air Inc., Wilmington, Delaware. David RODGERS signed as the Chief Pilot and Jeffrey EPSTEIN signed as President. + +The signature of EPSTEIN looks similar to the signature on the NS0SJS that became N909JE documents. + +In May 1994 they changed the tail number to N9091E. In 1999 and 2013 we see Darren K. INDYKE name on documents on behalf of + +Hyperion Air Inc. In November 2013 they sold N9091E to Starbridge Landing Inc., Dover, Delaware (Oscar FARIA). + +The aircraft was deregistered on December 02, 2014 for export to Venezuela. + +Xxxxxxxxxxxxxxxxxxxxxxxxxxxxx + +tail number to N331JE. In August 2013 they transferred N331JE to Hyperion Air LLC, 6100 Red Hook Quarter, Bff, St. Thomas, U.S. Virgin Islands. + +The same players in the Inc and LLC are on the FAA registration paperwork - Darren INDYKE and Lawrence VISOSKI. + +In November 2019 they provide phone numbe + +In May 2020 they sold helicopter N331JE to CMG Aircraft Leasing Inc., Miami, FL (broker), who sold it the same day to QIR Air Resources LLC, + +Salt Lake City, Utah. In July 2020 they changed the tail number to N430D. + +No other aircraft registered to or indexed to Hyperion Inc or LLC, and none to Ossa Properties Inc. + +Xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx + +On May 30, 2013, 1988 Gulfstream G-IV, serial number 1085, tail number N423TT was registered to; JEGE, LLC + +6100 Red Hook Quarter, B3 + +St. Thomas, U.S. Virgin Islands 00802 + +The registrant was Lawrence VISOSKI, he signed as Manager + +In July 2013 they (Lawrence VISOSKI) changed the tail number to N212JE. In August 2017, they (Lawrence VISOSKI) changed the tail number to N120JE. + +According to the JEGE LLC, statement in support of registering aircraft submitted to the FAA in 2013, JEGE LLC was established in St. Thomas, U.S. Virgin Islands + +on October 19, 2012 and the members were Jeffrey EPSTEIN and Lawrence VISOSKI. + +In June 2019, an Aircraft Security Agreement for \$2,800,000.00 on N120JE was filed with the FAA reflecting JEGE Inc., 4160 Lovingwood Trail, Powder Springs, GA 30127 + +as assignor and Robert L. Stallings III, 601 McCarthy Boulevard, New Bern, NC 28562 as secured party. + +According to the JEGE LLC, statement in support of registering aircraft submitted to the FAA in 2019, JEGE LLC was established in St. Thomas, U.S. Virgin Islands + +on October 19, 2012 and the members were Aviation Development Group LLC and the manager was Thomas H. Huff. + +He is Thomas Harrison HUFF dob/ Ika/Powder Springs, GA + +He's a pilot and has been involved in aviation at the Cobb County airport (RYY), in Kennesaw, GA for many years. + +He is of interest to DEA S/A in Atlanta, G + +The aircraft is still registered to JEGE LLC, St. Thomas, U.S. s. + +I suspect HUFF bought JEGE LLC which included the aircraft. + +Xxxxxxxxxxxxxxxxxxxxxxxxxxxxx + +On December 30, 2008, Sikosrksy Aircraft helicopter, S-76C-2, serial number 760750, tail number N750A was sold to; Air Ghislaine Inc + +103 Fould Road, #202 + +Wilmington, Delaware 19803 + +The registrant was Larry VISOSKI, he signed as Director of Aviation + +On February 11, 2010, Air Ghislaine Inc changed their name to Shmitka Air Inc. + +In March 2010, Air Ghislaine Inc changed the tail number from N750A to N722JE. On the 8050-64 the signature is not legibile but it looks + +similar to the signature of Lawrence VISOSKI. He signed as Director of Operations for Shmitka Air Inc., f/k/a Air Ghislaine Inc. + +On August 25, 2010, N722JE was registered to Freedom Air International Inc., 103 Fould Road, #202, Wilmington, Delaware 19803 + +The registrant was Darren K. INDYKE, he signed as Vice President + +According to a bill of sale dated July 26, 2011, Freedom Air International (Darren K. INDYKE) sold N722JE to ASI Wings LLC, Hartford, CT (Melinda Westbrook). + +On June 13, 2019, ASI Wings LLC sold N722JE to Hyperion Air LLC, 6100 Red Hook Quarter, B3, St. Thomas, U.S. Virgin Islands + +The registrant was Lawrence P. VISOSKI Jr., he signed as Manager + +Per a bill of sale dated May 13, 2021, Hyperion Air LLC (Larry VISOSKI) sold N722JE to Industrial Integrity Solutions Inc., Ontario, CA + +On January 29, 2000, Air Ghislaine Inc, Wichita, KS purchased 6.25% in a Beech 400A jet, serial number RK-260, tail number N787TA. + +On May 01, 2009, Air Ghislaine Inc., sold their 6.25% to Flight Options LLC in Richmond Heights, Ohio. James P. Miller signed the bill of sale as + +Executive Vice President of Flight Options LLC, acting as attorney-in-fact for Air Ghislaine Inc. + +(this aircraft is currently assigned tail number N727KB) + +Flight Options provides fractional jet ownership. + +To identify the persons behind Air Ghislaine Inc., contact Flight Options LLC in Ohio. + +http://www.flightoptions.com/ + +Xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx + +On May 01, 2009, Air Ghislaine Inc., Richmond Heights, Ohio purchased 6.25% in a Beech 400A jet, serial number RK-244, tail number N439LX. + +On February 11, 2010, Air Ghislaine Inc. changed their name to Shmitka Air Inc. and on July 06, 2010 Shmitka Air Inc. changed their name to + +Freedom Air International Inc. + +On June 02, 2011, Freedom Air International Inc sold their 6.25% share in N439LX to Flight Options LLC in Cleveland, Ohio. Michael Metera signed the bill of sale as Director of Sales Administration of Flight Options LLC, acting as attorney-in-fact for + +Freedom Air International Inc. + +(this aircraft is currently assigned tail number N188TH) + +Flight Options provides fractional jet ownership. + +To identify the persons behind Shmitka Air Inc and Freedom Air International Inc., contact Flight Options LLC in Ohio. + +http://www.flightoptions.com/ + +Xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx + +Bell 407, serial number 53375, G-IORB was deregistered by the United Kingdom civil aviation authority on November 04, 2002 for + +export to the United States. G-IORB was sold on October 30, 2002 to; + +Air Ghislaine Inc + +475 Madison Avenue, 4th floor + +New York, NY 10022 + +It was registered as N491GM on November 13, 2002 to; + +Air Ghislaine Inc + +103 Fould Road + +Wilmington, Delaware + +The signature of the registrant is illegible but looks like that of VISOSKI. + +Based on a name change from Air Ghislaine Inc to Shmitka Air Inc , the aircraft was registered on February 23, 2010 to Shmitka Air Inc + +103 Fould Road, Suite 202 + +Wilmington, DE + +The registrant was Darren K. INDYKE, he signed as Vice President + +Based on a name change from Shmitka Air Inc to Freedom Air International Inc, the aircraft was registered on August 25, 2010 to + +Freedom Air International Inc + +103 Fould Road, Suite 202 + +Wilmington, DE + +The registrant was Darren K. INDYKE, he signed as Vice President + +On April 30, 2012, Freedom Air International Inc (Darren K. INDYKE) sold N491GM to Eagle Copters Ltd in Calgary, Canada. + +The aircraft was registered in a trust and subsequently deregistered on May 07, 2012 for export to Canada. + +It was later re-registered in the U.S. with tail number N405P.I. + +Xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx + +Freedom Air International Inc + +103 Foulk Road, Suite 202 + +Wilmington, Delaware + +The registrant was Darren K. INDYKE, he signed as Vice President. + +They changed the tail number in August 2011 to N162AD. Lawrence VISOSKI signed the 8050-64 as Director of Maintenance of + +Freedom Air International Inc to change the tail number from N162AE to N162AD. + +Per a bill of sale dated February 09, 2012, Freedom Air International Inc. (Darren K. INDYKE) sold N162AD to Greenwich Aerogroup Inc Brazil Leasing Inc + +Middletown, Delaware + +John F. KOHLER + +N162AD was deregistered on April 10, 2013 for export to Brazil. + +I ordered Blue Ribbon (certified) copies of the aircraft registration records of the ten aircraft and they will be sent via regular mail from the FAA in Oklahoma. + +In the next few hours you will receive an email with links to working copies of these aircraft registration files. + +No other aircraft registered to or indexed to Hyperion Inc/LLC, Plan D LLC, Ossa Properties Inc. or Jeffrey Epstein + +Ghislaine Maxwell + +Thomas World Air LLC + +Freedom Air Petroleum LLC + +NES LLC + +Maple, Inc. + +Nautilus Inc. + +No FAA certificates issued to Darren INDYKE. + +I hope this helps, + +Special Agent + +Federal Aviation Administration + +Law Enforcement Assistance Program + +Atlanta, GA + +Cel + +Fa)1 + +From: + +Sent: Wednesday, August 18, 2021 1:08 PM + +To: + +Cc: (USANYS) ) + +Subject: RE: FAA Question + +Thanks, + +From: + +Sent: Wednesday, August 18, 2021 1:07 PM + +To: + +Cc: ; (AT) (FBI) >; (AT) (FBI) > + +More will follow. + +Special Agent + +Federal Aviation Administration + +Law Enforcement Assistance Program + +Atlanta, GA + +cell + +fax + +From: + +Sent: Wednesday, August 18, 2021 12:41 PM + +To: + +< )'; < (USANYS) < >; + +Subject: RE: FAA Question + +Hi + +Thanks again for the helpful call this morning. Here is the list of entities we'd like you to use as search terms: + +Jeffrey Epstein + +Ghislaine Maxwell + +Air Ghislaine + +Thomas World Air LLC + +Hyperion Air LLC + +Freedom Air Petroleum LLC + +NES LLC + +Maple, Inc. + +Nautilus Inc. + +Thanks, + +From: + +Sent: Tuesday, August 17, 2021 3:56 PM + +To: + +Cc: (USANYS) < I < + +Subject: Re: FAA Question + +Anytime after 0930 is preferable. + +Special Agent + +Federal Aviation Administration + +Atlanta, GA + +cell + +fax + +Thanks, . We'll plan to give you a call tomorrow morning, assuming you're free to talk then. + +Thanks, + +From: + +Sent: Tuesday, August 17, 2021 3:30 PM + +To: + +Cc: S; (USANYS) < + +Subject: RE: FAA Question + +Hi! + +Feel free to call my cell at your convenience. + +Happy to help, + +Special Agent + +Federal Aviation Administration + +Law Enforcement Assistance Program + +Atlanta, GA + +Cell + +Fax + +From: + +Sent: Tuesday, August 17, 2021 3:25 PM + +To: + +Cc: ) < (USANYS) + +Subject: FAA Question + +Hi + +I hope all's well. I got your email from at the FBI. We are working on a case and could use some assistance from the FAA. Do you have a few minutes to talk sometime this week? + +Thanks, + +Assistant United States Attorney + +Southern District of New York + +1 Saint Andrews Plaza + +New York, New York 10007 \ No newline at end of file diff --git a/marker2/ds9/EFTA00087596/EFTA00087596.metadata.json b/marker2/ds9/EFTA00087596/EFTA00087596.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..85742efb43a24bed968d1008ff3e455d5c824acf --- /dev/null +++ b/marker2/ds9/EFTA00087596/EFTA00087596.metadata.json @@ -0,0 +1,234 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087596.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 7, + "chars": 15138, + "elapsed_seconds": 2.81, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 95 + ], + [ + "Line", + 47 + ], + [ + "Text", + 33 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 107 + ], + [ + "Line", + 53 + ], + [ + "Text", + 40 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 109 + ], + [ + "Line", + 54 + ], + [ + "Text", + 38 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 3, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 111 + ], + [ + "Line", + 55 + ], + [ + "Text", + 44 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 4, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 105 + ], + [ + "Line", + 53 + ], + [ + "Text", + 45 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 5, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 103 + ], + [ + "Line", + 51 + ], + [ + "Text", + 45 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 6, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 68 + ], + [ + "Text", + 36 + ], + [ + "Line", + 34 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087596" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087603/EFTA00087603.md b/marker2/ds9/EFTA00087603/EFTA00087603.md new file mode 100644 index 0000000000000000000000000000000000000000..a0a3aaccff327b141eaf733f5ee1fa558147e113 --- /dev/null +++ b/marker2/ds9/EFTA00087603/EFTA00087603.md @@ -0,0 +1,9 @@ +To: + +Subject: FYI re Epstein FOIA + +Date: Mon, 15 Jun 2020 22:53:30 +0000 + +The Civil Division is handling a FOIA request from the NYT to BOP regarding documents relating to Epstein. Some of the responsive documents reference Tartaglione. At this point, the team that is prosecuting the MCC guards has decided to withhold all of the pages that reference Tartaglione as potentially interfering with their prosecution. If their case ends before Tartaglione's trial finished, though, we will need to consider whether those documents need to be held back to prevent interference with our case. + +I don't think there's anything for us to do right now on this, but I wanted to put it on your radar. \ No newline at end of file diff --git a/marker2/ds9/EFTA00087603/EFTA00087603.metadata.json b/marker2/ds9/EFTA00087603/EFTA00087603.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..8cbb634c3d44968470528392683849fda596f0a0 --- /dev/null +++ b/marker2/ds9/EFTA00087603/EFTA00087603.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087603.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 689, + "elapsed_seconds": 0.37, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 21 + ], + [ + "Line", + 11 + ], + [ + "Text", + 6 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087603" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087604/EFTA00087604.md b/marker2/ds9/EFTA00087604/EFTA00087604.md new file mode 100644 index 0000000000000000000000000000000000000000..ac6dd60d9d0472ac3b6943eaac72c1e05587622f --- /dev/null +++ b/marker2/ds9/EFTA00087604/EFTA00087604.md @@ -0,0 +1,45 @@ +From: + +To: + +Subject: FW: The Spectator - Prince Andrew story + +Date: Mon, 15 Jun 2020 15:18:04 +0000 + +Inline-Images: -WRD000.jpg; image00I.jpg + +From: Matt McDonald + +Sent: Monday, June 15, 2020 11:12 AM + +To: + +Subject: The Spectator - Prince Andrew story + +Dear + +Our writer Dominic Green has written about Prince Andrew's correspondence with the Southern District of New York, and how it is being characterized by + +I was wondering whether you would be prepared to comment on the following excerpts from Mr Green's story. He attempted to contact the press office earlier today but was not able to get through to anyone: + +has actively misled the global media and the global audience, 'my source alleges. 'The Duke's legal team has dozens of email exchanges with the Southern District, proving that there has been full cooperation.' + +On January 27, denounced the Duke firm the steps ofEpstein's Manhattan townhouse. claimed to be acin a 'wall of silence' and 'zero co-operation from Andrew. But this, my source tells me, wasn't true: must have known we had an email trail.' + +\*\*\* + +...the DOJ made no effort to contact Prince Andrew durin Je re E stein's lifetime. Only after Epstein's death in August 2019 and the BBC's broadcast o accusations in November 2019, did the DOJ approach the Prince — not as a suspect, but as a witness. + +'The lawyers responded immediately,' I'm told. In early January, the Prince's new legal team suggested that they draft a proposal for how Andrew would deliver his witness statement. The DOJ, my source reports, accepted this approach. + +Although the DOJ wanted to talk with Andrew as a witness, seemed to imply that Andrew had aided Epstein's crimes: Epstein couldn't have done what he did without the assistance of others.' This, I'm told, was an 'overt breach of the DOJ:s own rules on how to engage with witnesses, and the need to maintain privacy and confidentiality'. + +After attack in January, there was a every frank exchange of views' between Andrew's lawyers and the Southern District. But Andrew's team played by the rules and didn't release entails that would prove they were negotiating with the Southern District in good faith. + +We plan to publish the story at 3pm ET, but can update the story to include any response. If this request for comment should be directed towards your press office, I'd appreciate it if you could pass it onto them - there is no way of contacting them on the SDNY site as their mailbox is full and no one is in the office. + +Yours sincerely, + +Matt McDonald + +Matt McDonald Managing Editor The Spectator US \ No newline at end of file diff --git a/marker2/ds9/EFTA00087604/EFTA00087604.metadata.json b/marker2/ds9/EFTA00087604/EFTA00087604.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..07b12b9e9d806320cbc16975e5967aa45b4f23e8 --- /dev/null +++ b/marker2/ds9/EFTA00087604/EFTA00087604.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087604.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2574, + "elapsed_seconds": 0.92, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 70 + ], + [ + "Line", + 34 + ], + [ + "Text", + 19 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 15 + ], + [ + "Line", + 8 + ], + [ + "Text", + 6 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087604" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087606/EFTA00087606.md b/marker2/ds9/EFTA00087606/EFTA00087606.md new file mode 100644 index 0000000000000000000000000000000000000000..71e22241b92561310001ae3235fa68fb29d50ab1 --- /dev/null +++ b/marker2/ds9/EFTA00087606/EFTA00087606.md @@ -0,0 +1,53 @@ +![](_page_0_Picture_0.jpeg) + +United States Attorney Southern District of New York + +The Silvio J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 + +October 4, 2021 + +## BY ELECTRONIC MAIL + +Christian Everdell, Esq. Mark Cohen, Esq. Cohen & Gresser LLP + +Laura Menninger, Esq. Jeffrey Pagliuca, Esq. Haddon, Morgan and Foreman, P.C. + +Bobbi Stemheim, Esq. Law Offices of Bobbi C. Stemheim + +Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) + +Dear Counsel: + +Today we are producing the materials listed in the below index. These discovery materials are stamped with control numbers SDNY\_GM\_02762476 through SDNY\_GM\_02762506. + +Please note that both this letter and the enclosed materials are governed by the July 31, 2020 Protective Order in this case. This letter is itself designated as "confidential," because it includes information regarding records designated as "confidential" under the Protective Order. Recently, the Department of Justice directed this office to cease the dissemination of materials marked with the word "confidential" in order to avoid potential confusion with markings reserved for classified documents. Accordingly, in order to note the appropriate designation of this production under the operative Protective Order in this case, the materials being produced today are marked with the following label: "SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17." This marking directly refers to the specific paragraphs of the Protective Order that govern today's production. + +An index of the materials contained in this production is below: + +| Bates Start | Bates End | Summary Description | Confidential Designation | +|------------------|------------------|------------------------------------|--------------------------| +| SDNY_GM_02762476 | SDNY GM 02762476 | Video | Confidential | +| SDNY GM 02762477 | SDNY GM 02762477 | | | +| | | ._8ES i United Kingdom | | +| SDNY_GM_02762478 | SDNY_GM_02762482 | = Deposition Documentsl | Confidential | +| SDNY_GM_02762483 | SDNY_GM_02762483 | JPMorgan Chase records | Confidential | +| SDNY GM 02762484 | SDNY GM 02762485 | Maps of Palm Beach area | | +| SDNY_GM_02762486 | SDNY_GM_02762487 | Palm Beach School District records | Confidential | +| SDNY_GM_02762488 | SDNY_GM_02762491 | Jeffrey Epstein travel records | | +| SDNY GM 02762492 | SDNY GM 02762500 | Ghislaine Maxwell travel records | | +| SDNY_GM_02762501 | SDNY_GM_02762501 | travel records | Confidential | +| SDNY_GM_02762502 | SDNY_GM_02762506 | FBI NY documents | | + +The Government recognizes that its discovery obligations are ongoing and will promptly produce any additional discoverable material of which it becomes aware. Please do not hesitate to reach out if you have any difficulty accessing these materials. + +Very truly yours, + +AUDREY STRAUSS United States Attorney + +by: s/ + +MN. + +• • rates Attorneys + +The Government received some of the files in a format we are not able to open but we are producing the .ecl files to you in an abundance of caution. \ No newline at end of file diff --git a/marker2/ds9/EFTA00087606/EFTA00087606.metadata.json b/marker2/ds9/EFTA00087606/EFTA00087606.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..6a0f8c3f4d547cf77eb1b24f8fad053e49a6d990 --- /dev/null +++ b/marker2/ds9/EFTA00087606/EFTA00087606.metadata.json @@ -0,0 +1,153 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087606.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 3436, + "elapsed_seconds": 0.75, + "image_assets": [ + "_page_0_Picture_0.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "U.S. Department of Justice", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 319.464, + 25.92 + ], + [ + 464.0820617675781, + 25.92 + ], + [ + 464.0820617675781, + 40.5 + ], + [ + 319.464, + 40.5 + ] + ] + }, + { + "title": "BY ELECTRONIC MAIL", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 69.156, + 169.29 + ], + [ + 211.1153564453125, + 169.29 + ], + [ + 211.1153564453125, + 182.9830322265625 + ], + [ + 69.156, + 182.9830322265625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 63 + ], + [ + "Line", + 31 + ], + [ + "Text", + 10 + ], + [ + "SectionHeader", + 2 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 58 + ], + [ + "Line", + 27 + ], + [ + "Text", + 10 + ], + [ + "PageHeader", + 1 + ], + [ + "Table", + 1 + ], + [ + "Footnote", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087606" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087606/_page_0_Picture_0.jpeg b/marker2/ds9/EFTA00087606/_page_0_Picture_0.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..eaef4b35de337abf594ef671bc5df9383e718996 --- /dev/null +++ b/marker2/ds9/EFTA00087606/_page_0_Picture_0.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:37f0e3e0dad758c46d0135b30e97a90c47638223427153e1b2eb0d5512e8251f +size 3586 diff --git a/marker2/ds9/EFTA00087608/EFTA00087608.md b/marker2/ds9/EFTA00087608/EFTA00087608.md new file mode 100644 index 0000000000000000000000000000000000000000..c948a5a4fd01a6c30db5d9f445d8c722a9131982 --- /dev/null +++ b/marker2/ds9/EFTA00087608/EFTA00087608.md @@ -0,0 +1,15 @@ +From: "a" alMIE> To: MMIEF(NY) I (FBI)" .MINIMM>, Cc: a (USANYS)" + +Subject: Discovery + +Date: Mon, 04 Oct 2021 19:36:24 +0000 + +Embedded: RE: Aircraft info .msg + +Hey + +I hope you had a nice weekend! Attached is an email chain from before I joined the case. I have the most recent email, but would you mind forwarding me the earlier ones, so I have all the emails and attachments? + +Thanks, Andrew + +Assistant United States Attorney Southern District of New York 1 Saint Andrews Plaza New York New York 0007 \ No newline at end of file diff --git a/marker2/ds9/EFTA00087608/EFTA00087608.metadata.json b/marker2/ds9/EFTA00087608/EFTA00087608.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..1133a58ac90003b03ae4b2f18a18e25cab2d7b7f --- /dev/null +++ b/marker2/ds9/EFTA00087608/EFTA00087608.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087608.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 501, + "elapsed_seconds": 0.46, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 35 + ], + [ + "Line", + 17 + ], + [ + "Text", + 8 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087608" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087609/EFTA00087609.md b/marker2/ds9/EFTA00087609/EFTA00087609.md new file mode 100644 index 0000000000000000000000000000000000000000..438afa41ffab56d2ff636fda80b8e11381c28bd5 --- /dev/null +++ b/marker2/ds9/EFTA00087609/EFTA00087609.md @@ -0,0 +1,19 @@ +To: + +Cc: + +Subject: Testifying Witness Questions + +Date: Mon, 04 Oct 2021 23:57:42 +0000 + +Attachments: 3501.116-007.pdf; 3501.116-012.pdf; 2006-08- 15 311 FBIINTERVIEWREGARDINGDAVIDROGERS.pdf + +I'm attaching the 302 for from an interview on August 22, 2006. The last paragraph refers to her providing a copy of the hours she worked at Epstein's residence as well as some notes she made at her time of employment. Can you please send the notes and the documents she provided? I don't believe we have them. + +Also can you please send the notes of the 8/15/06 interview of ? The 302 is attached. + +Thanksl + +Assistant United States Attorney United States Attorney's Office • + +Tel: \ No newline at end of file diff --git a/marker2/ds9/EFTA00087609/EFTA00087609.metadata.json b/marker2/ds9/EFTA00087609/EFTA00087609.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..cfc80d9c518a87dad7607ee4f8a0cf85ac2744b9 --- /dev/null +++ b/marker2/ds9/EFTA00087609/EFTA00087609.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087609.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 671, + "elapsed_seconds": 0.65, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 34 + ], + [ + "Line", + 17 + ], + [ + "Text", + 13 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087609" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087610/EFTA00087610.md b/marker2/ds9/EFTA00087610/EFTA00087610.md new file mode 100644 index 0000000000000000000000000000000000000000..1bd570b880623916e601e042a0362cf5579056af --- /dev/null +++ b/marker2/ds9/EFTA00087610/EFTA00087610.md @@ -0,0 +1,69 @@ +## FEDERAL BUREAU OF INVESTIGATION + +Date of leansalPlian 08/18/2006 + +DAVID ROGERS, dob 03/06/1953, residin at , telephone number(s) and cellular , was interviewed at the FEDERAL BUREAU OF INVESTIGATION, PALM BEACH COUNTY RESIDENT AGENCY's Office, West Palm Beach, Florida. Also present at the interview was ROGERS' attorney, BRUCE M. LYONS of LYONS AND SANDERS, 600 Northeast 3rd Avenue, Ft. Lauderdale, Florida 33304, telephone number(s) and IIIIIIIIIIIII (cellular). After being advised of the identity of their vewng agents and the nature of the interview, ROGERS provided the following information: + +ROGERS has been employed as a pilot for JEFFREY EPSTEIN since July 1991. His current salary is \$165,000.00 plus benefits. Prior to his employment with EPSTEIN, ROGERS sold aircraft for GLIMCHER, a company located near THE LIMITED Flight Department. ROGERS was employed there from 1987 to 1991. According to ROGERS, EPSTEIN has two other full time pilots, LARRY VISOSKI, and BILL HAMMOND. EPSTEIN also has a full time flight engineer, . On occasion, in 2004 and 2005, a contracted pilot, GARY ROXBURGH, was required to assist with flying EPSTEIN to different locations. + +ROGERS was the Chief Captain for EPSTEIN until January 2005. VISOSKI took over the responsibilities of Chief Pilot after a continual disagreement between EPSTEIN and ROGERS on landing techniques. This was a demotion and a decrease in pay for ROGERS. ROGERS stated that EPSTEIN was unhappy with the method in which ROGERS landed the aircraft when arriving at Palm Beach International Airport. + +ROGERS provided the interviewing agents, via a Grand Jury Subpoena, a copy of his 2004 and 2005 personal aircraft log book and passenger manifest forms. The passenger manifest forms were for all flights during 2004 and 2005 for a Boeing 727, tail number N908JE" and a Gulfstream, tail number N909JE. According to ROGERS, the passenger manifest forms were filled out by the Captain or Co-pilot every time either aircraft was used for travel. If ROGERS or the other pilots were unable to obtain the names of the individuals traveling with EPSTEIN, they would list the individuals on the passenger manifest form by gender, "male" or "female", or "passenger" or "pax". ROGERS stated that it was seldom that he + +Investigation on 08/15/2006 at West Palm Beach, Florida Files 31E-MM-108062 by SA Date dictated 08/15/2006 + +This document contains neither recommendations nor conclusions of the FBI. It is the property of Me FBI and is loaned to your agency, it and its contents are not to be distributed outside your agency. + +31E-MM-108062 + +Cm0mmi00aF1)-302a Rogers Mn 08/15/2006 "ate 2 + +would pilot either aircraft without EPSTEIN being a passenger on the planes. + +The Boeing 727, tail number N908JE, is owned by a subsidiary company of EPSTEIN, JEGE, INCORPORATED, and can fly up to 26 passengers. The Gulfstream, tail number N909JE, is owned and operated by another of EPSTEIN's subsidiary companies, HYPERION AIR, INCORPORATED, and can fly up to 12 passengers. ROGERS believes EPSTEIN has separate entities for each plane for liability reasons. ROGERS stated that EPSTEIN also owned a six passenger Helicopter, Bel 407, tail number 491GM. + +RODGERS stated that he would usually receive notification from VISOSKI or from EPSTEIN's office when flight arrangements were being made. Lead time for a tri most commonly was between eight to twenty-four hours. , EPSTEIN's personal assistant, was responsible for coordinating travel arrangements for EPSTEIN. ROGERS believed that took over primary duties as EPSTEIN's personal assistant from GHISLAINE MAXWELL in late 2001. would handle setting up the staff for EPSTEIN's visits to his multi residences as well as transportation needs to and from the airports. + +ROGERS advised that he had never witnessed any underage females aboard the aircrafts. However ROGERS did state that there had been to many to count when it came to females ranging in age from 21 to 23. ROGERS also said that he had never observed any sex toys aboard either of EPSTEIN's aircraft. + +When the interviewing agents asked ROGERS for specific telephone numbers for several individuals, ROGERS provided the information from a personal digital assistant(PDA). The below list of individuals, primarily, current and past employees of EPSTEIN, were provided by ROGERS: + +JEFFREY EPSTEIN - New York Residence, telephone number !!!! London residence tele hone number 0044767785771552; cellular phone number ; Columbus, Ohio residence telephone numbers an Cambridge, Massachusetts + +MILES ALEXANDER - Property Manager for EPSTEIN's residence in the U.S. Virgin Islands tele hone number and cellular telephone number + +31E-MM-108062 + +CmtirmathmotTElana Rogers ,On 08/15/2006 .Pne 3 + +BRYCE GORDON - Ranch Mana er for EPSTEIN's residence in New Mexico, telephone number + +JANUSZ BANASIAK - House manager for EPSTEIN's residence in Palm Beach, BANASIAK employed for possibly a year or lon er telephone number , cellular telephone number + +ALFREDO Last Name Unknown(LNU) - Prior House Manager for EPSTEIN's residence in Palm Beach, Florida + +MICHAEL LNU and SALLY LNU - prior House Managers for EPSTEIN's residence in Palm Beach, Florida + +- Executive Assistant to EPSTEIN, + +- Personal Assistant to EPSTEIN, cellular tele hone nu er , old cellular telephone number + +- irlfriend of EPSTEIN, cellular tele hone nu er , believed to be residing at , New York, New York. + +- possible Assistant to EPSTEIN re ardin construction projects, cellular telephone number + +- possible e lo ee to either EPSTEIN or GHILISINE MAXWELL, Assistant to , associate for the last two years + +personal assistant (ROGERS has not seen in aw ile) + +- Possible employee + +JEAN BRUNEL - associated to an Italian Modeling Agency + +IGOR ZINOVIEW - Personal trainer to EPSTEIN + +LANCE CALLOWAY - EPSTEIN's chef for the last year + +- EPSTEIN's chef prior to + +BRENT TINDALL - EPSTEIN's chef in 2004 \ No newline at end of file diff --git a/marker2/ds9/EFTA00087610/EFTA00087610.metadata.json b/marker2/ds9/EFTA00087610/EFTA00087610.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..5ac7a2c0fdf22365bf5c22dd14be92d28410ade0 --- /dev/null +++ b/marker2/ds9/EFTA00087610/EFTA00087610.metadata.json @@ -0,0 +1,154 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087610.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 5911, + "elapsed_seconds": 1.26, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "FEDERAL BUREAU OF INVESTIGATION", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 213.93699999999998, + 108.94200000000002 + ], + [ + 410.0017395019531, + 108.94200000000002 + ], + [ + 410.0017395019531, + 122.214599609375 + ], + [ + 213.93699999999998, + 122.214599609375 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 105 + ], + [ + "Line", + 51 + ], + [ + "Text", + 8 + ], + [ + "PageHeader", + 2 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 88 + ], + [ + "Line", + 42 + ], + [ + "Text", + 9 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 70 + ], + [ + "Line", + 33 + ], + [ + "Text", + 18 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087610" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087613/EFTA00087613.md b/marker2/ds9/EFTA00087613/EFTA00087613.md new file mode 100644 index 0000000000000000000000000000000000000000..49d65f5255bb46273ba2b27a6809f264b42d7693 --- /dev/null +++ b/marker2/ds9/EFTA00087613/EFTA00087613.md @@ -0,0 +1,107 @@ +From: " To: "Pileggi, Patricia Anne" Cc: " " < >' (USANYS)" + +Subject: RE: Date: Tue, 05 Oct 2021 14:12:15 +0000 + +Attachments: 2021.10.05\_Court\_Subpoenan Mar a\_Lago.pdf + +Hi Pat, + +Thanks a lot. A trial subpoena is attached. + +Thanks, + +From: Pileggi, Patricia Anne Sent: Friday, October 1, 2021 9:39 PM To: Cc: >; (USANYS) < Subject: [EXTERNAL] RE: + +I have been authorized to accept a subpoena on behalf of the custodian of records for Mar a Lago. + +Thanks - + +Pat + +From: imailto Sent: Thursday, September 30, 20214:53 PM To: Pileggi, Patricia Anne a Cc: (USANYS) Subject: [EXT] RE: + +Hi Pat, + +Thank a lot. We'd like to serve a subpoena to Mar a Lago for a records custodian and employment records. Please just let us know if there's a contact we should send it to, or we should serve it on them directly. + +Thanks, + +From: Pileggi, Patricia Anne Sent: Thursday, September 30, 2021 1:56 PM To: Cc: Subject: [EXTERNAL] RE: >; (USANYS) + +I have been speaking with Compliance Counsel for the Trump Organization who informs me that Mar a Lago does not have in house counsel. She has advised me that there are a number of different attorneys within the Trump Organization who are responsible for Mar a Lago. She asked that you let me know what information you are looking for and she will either give me that information or make sure that it is forwarded to the appropriate attorney. + +Thanks - + +Pat + +From: [mailto Sent: Thursday, September 30, 2021 1:21 PM To: Pileggi, Patricia Anne Cc: (USANYS) Subject: [EXT] RE: + +Hi Pat, + +I'm just following up on my voicemail yesterday. Can you share with us the contact info for Mar a Lago's in-house counsel? + +Thanks, + +From: Pileggi, Patricia Anne Sent: Friday, September 24, 2021 3:41 PM To: Cc: (USANYS) Subject: [EXTERNAL] RE: < + +I have been dealing with in house counsel on this, no other outside counsel. I can give you her name, but let me give her a heads up first that you will be calling. + +From: [mailto Sent: Friday, September 24, 2021 3:25 PM To: Pileggi, Patricia Anne Cc: Subject: [EXT] RE: (USANYS) + +Thanks for the update, Pat. On our call the other day, you mentioned that there's another lawyer representing Mar a Lago for this matter. Would you mind sharing his/her contact information? It might help if we talked to them directly. + +Thanks, + +From: Pileggi, Patricia Anne Sent: Friday, September 24, 2021 3:18 PM To: Cc: Subject: [EXTERNAL] RE: < >; (USANYS)< > + +So far, no news. The document that provided does not appear to be a business record - it was not a record that was prepared on a regular basis and doesn't know who prepared it. + +Best, + +Pat + +From: [mailto Sent: Friday, September 24, 2021 2:42 PM To: Pileggi, Patricia Anne Cc: (USANYS) Subject: [EXT] RE: + +Hi Pat, + +I hope all's well. I'm checking in to see if you have any news about Mar a Lago. I'm happy to jump on a call if there's an update. + +Thanks, + +From: Pileggi, Patricia Anne Sent: Wednesday, September 8, 2021 9:48 PM To: Cc: (USANYS) Subject: RE: + +Perfect. I'll circulate a calendar invite. + +From: ) [S rr Sent: Wednesday, September 8, 2021 9:38 PM To: Pileggi, Patricia Anne Cc: Subject: [EXT] RE: (USANYS) + +Hi Pat, + +No problem at all. How's 3:30 tomorrow? + +Thanks, + +From: Pileggi, Patricia Anne Sent: Wednesday, September 8, 2021 9:23 PM To: Cc: Subject: RE: (USANYS)< > + +Hi + +Sorry about the delayed response. Are you available at 3:00 pm or any time after that tomorrow? + +Sent: Tuesday, September 7, 2021 3:46 PM + +To: Pileggi, Patricia Anne c E> + +Cc: (USANYS) + +Subject: [EXT] + +CAUTION: External email. + +Pat, + +forwarded us your email about the subpoena to I'm generally free tomorrow afternoon or Wednesday afternoon for a call. Would sometime then work for you? + +Thanks, + +Assistant United States Attorney Southern District of New York + +This message and any attachments may contain confidential information protected by the attorney-client or other privilege. If you believe that it has been sent to you in error, please reply to the sender that you received the message in error. Then delete it. 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LEFCOURT, P.G. A PROFESSIONAL CORPORATION NEW YORK, NEW YORE 10OE1 + +GERALD B. LEFCOURT + +SHERYL E. REICH + +RENATO C. STABILE + +A. FRIEDMAN + +#### VIA FEDERAL EXPRESS + +Assistant United States Attorney Office of the United States Attorney Southern District \$ f Fl. rid + +West Palm Beach, Florida 33401 + +Dear + +TELEPHONE + +FACSIMILE + +February 23, 2007 + +Re: Jeffrey Epstein + +Thank you once again for meeting with us regarding our client, Jeffrey Epstein. + +As you know, in advance of last Tuesday's meeting we provided you with the recorded interviews of various witnesses taken in the state's investigation. At the meeting, we disclosed that, as part of our own preparation, we made working transcripts of these recordings. You have asked for copies of the transcripts and we have discussed various ways that that might be accomplished without compromising Mr. Epstein's position and rights. + +To assist in your bringing this investigation to a close, enclosed are highlighted excerpts of the transcripts. The excerpts support our argument that no federal prosecution should be brought in this matter. Please note that these transcripts are drafts and subject to further review and revision. They are provided as a courtesy and in furtherance of our discussions and therefore are not usable by you for any purposes. By accepting these transcripts you agree never to contend that any revisions made thereto compare unfavorably to the drafts provided; nor will you use the drafts otherwise to the detriment of Mr. Epstein. + +Assistant United States Attorney Office of the United States Attorney Southern District of Florida February 23, 2007 Page 2 + +The excerpts fall generally into the following five subject areas and are therefore so arranged in the numbered tabs. Note, the witnesses were not all asked the same questions and therefore, not every witness touched on every subject area we here consider relevant: + +Tab I: Mr. Epstein did not ask the women to touch, nor did the women in fact touch, his genitals; + +Tab 2: Mr. Epstein did not ask the women to engage, nor did they in fact engage, in sexual intercourse with him; + +Tab 3: Not only did Mr. Epstein not search out women under the age of 18, but the vast majority of the women from whom he received massages during the period were 18 or older. To the extent the witnesses were asked, they admitted being told that Mr. Epstein would not allow them into his house if they were not 18 and that if they were not 18, they were told (by friends, not by Mr. Epstein or anyone employed by Mr. Epstein) to lie about their age. Again, to the extent they were asked in the interviews, they admitted that, if the subject of age did come up in conversation with Mr. Epstein, those under 18 falsely claimed to him that they were 18; + +Tab 4: Mr. Epstein did not coerce, threaten or otherwise pressure the women in an effort to force them to do anything; to the extent they were asked, they admitted they understood they could decline to accede to any of Mr. Epstein's requests; and, + +Tab 5: Prior to going to Mr. Epstein's home, virtually all of the women were apprised of what they would be asked to do or, if they claimed they were not, they had no objection to what occurred, since they either returned to give further massages or they brought others to do so, or both. + +1 Of course, irrespective of what any particular witness said at her interview on any particular point, in • many instances fanciful claims are contradicted by the witness herself elsewhere in her statement, by documentary evidence, and/or by other witnesses. Moreover, the witnesses suffer from significant credibility problems based on universally accepted tests for credibility: bias, motive, prior bad acts, etc., some of which we have already previewed in the February 1, 2007, letter. + +• + +Assistant United States Attorney Office of the United States Attorney Southern District of Florida February 23, 2007 Page 3 + +• Finall . ursuant to our r uest we have included copies of the full working transcripts of the and recordings. If you have any questions regarding any of the materials we have provided please feel free to contact us. + +• + +Very truly yours, + +Gerald B. + +• cc: fl uty Chief, Northern Region Federal Bureau of Investigation Lilly Ann Sanchez, Esq + +• + +• + +• + +• + +![](_page_4_Picture_6.jpeg) + +:N RE: JEFFREY EPSTEIN + +DRAFT + +VIDEOTAPED :NTERVIEW OF + +warastrontmal + +Page 16 + +1 and that, r don,t know, we just don't talk anymore. + +2 Q Which was? + +3 A + +4 and -- + +5 A And III. I don't know if has ever slept + +6 with him. I can't speak for her. But he liked her the + +7 most. I don't know why he liked her the most but it was + +6 always working for him. And she wouldn't just bring + +9 girls. She would work for him. + +10 Q Now much money do you think she made? + +11 A I don't know. She never really the first time + +12 I brought her she made 200. After that I think she started + +13 making like 300. It's not accurate. Like I can't -- + +14 Q The more you do the move you get paid. + +15 A Pretty much. + +16 Q I know you said that. Mit -- + +17 A Richt. I think she made 300 after that I think + +18 she started making like 300 + +19 Q Does be make the girls touch him down there? + +20 A I don't. know. + +21 0 to that part of the message? + +22 A It wasn't with me. He never asked we to touch him + +23 or fondle him. He never asked me I don't know if he's + +24 ever asked the other girls. It was never really brought up. + +25 It wan always him touching then. + +Us. + +. + +• + +• + +. + +IN RE: JEFFREY EPSTBIN + +## DRAFT + +VIDEOTAPED INTERVTFX OF + +I + +I + +1 Q Three hundred. And that was the last time you +2 went? + +3 A (Nods head yes ) + +4 Q When he [REDACTED], you didn't have +5 a bra on? + +6 A I didn't have a bra on. + +7 Q You didn't have a bra on. And your buttocks? + +8 A Th-huh + +9 Q Was that over your panties or under your panties? + +10 A Like I have a thong on so. + +11 Q You had thongs. Okay All right Did he pull +12 you close to him? + +13 A Yeah. + +14 Q And all this while he was [REDACTED]? + +15 A (Nods head yes.) + +16 Q Did he have you touch him? + +17 A No. + +18 Q Aside from the massage, [REDACTED] +19 area? + +20 A Huh-huh. No. + +21 Q Did you bring anyone else other than -- + +22 A [REDACTED]. + +23 Q -- [REDACTED]? + +24 A [REDACTED]. + +25 Q [REDACTED]. Do you know [REDACTED] last name? + +Page 1 + +IN RE: JEFFREY E?STEIN + +DRAFT + +VIDEOTAPED INTERVIEW 0? + +![](_page_9_Picture_4.jpeg) + +• + +• + +r + +• + +• + +Page + +1 Q Right + +2 A They cover enough They don't show too much + +3 Q Okay. You messaged him? + +4 A Uh-huh. + +5 Q Did he try to touch you in any way? + +6 A No + +7 Q Did he introduce any toys or massagers slash + +6 vibrators? + +9 A No, Huh-huh + +10 Q Did he ask you to touch him? + +11 A Just to give him a massage. + +12 Q I mean -- + +13 A Oh, no. Huh-huh. + +14 Q NO? + +15 A t would have said no anyways That's gross. + +16 Q Okay Did he touch himself? + +17 A Yeah + +18 0 Okay• And I mean, t mean by Colleting himself, did + +18 he + +20 A Yeah. + +21 Q Okay. Co you know if he + +23 A He did. + +24 0 He did. Nes that the only time you ever went? + +25 A one time. + +1 + +IN RE: JEFFREY BPSTEIN + +# DRAFT + +• + +• + +• + +Page 12 + +A Okay. Ky bad. + +2 Q I was writing that quickly, and I was + +3 thinking + +4 A Okay. That's fine. + +5 Q All right. Was there anybody ever at the house + +6 that you provided a massage to aside from Jeffrey? + +7 A No. No. + +8 Q Curing tke lenhaegit47, 440:hlatOneAink -Inn to 'touch". + +9 him? + +. . + +to A No + +11 Q Did he touch himself? + +12 A Yea. + +13 Q Would he be just touching aimaelf or would he be + +14 + +15 A He woul~, + +l6 Q Okay. How would you kr.ow that the massage was + +,7 over? + +18 A + +19 Q + +20 A Yeah. + +2]. Q Again. I've talked to a lot of girls and so far 22 everything seems to be in the norm, so that's why I'm saying 23 don't, I know it's a little embarrassing. + +24 Did you ever meet any other girls that came to the 25 house? + +I + +IN RE: JEFFREY EPSTEIN + +. + +. + +• + +DRAFT + +TAPED INTERVIEF Cr + +-•• + +Page 12 + +1 Q •Did' he ever sek.\*Oi-tO tonal bin? + +2 A No. (Inaudible) I Wee, eurprieed about that + +3 because he never asked Out (inaudible). + +4 27 pracyrvk DAWOCN: + +5 Q Okay Eid you ever see him nude? Naked? + +6 A I wasn't paying attention. He got in the shower + +7 in front of to but I wasn't paying attention. + +8 Q So you can see -- the shower you corld see from + +9 the room? + +10 A There was the shower and then he has like a bath + +11 If you come up into his bedroom, I don't really remember. + +12 but if you coma into his room there's a shower. As you come + +13 into the bathroom part there's a shower right here. And + +14 then a massage table right here And then there was a couch + +15 going around right here. And Us shower (inaudible) ha took + +16 a shower and he's like feel comfortable and I was like okay. + +17 I don't remember if he asked me to take off my clothes, my + +18 top and my bottoms, but I think he did. I'm not sure. I + +19 have bad memory It was a long time ago. + +20 0 Okay So if you wanted to look, he would have + +21 been naked in front of you; you just made it a choice not to + +22 look? + +23 A Right. + +24 By DETECTIVE ■ + +**25 Q Okay** + +**•••••4•••••IIIIIMad.ligib•aroll.** + +1 Detective + +2 + +3 + +4 + +reference case number 05-368. The time now. by my watch. is + +6 approximately 6 minutes past 2pm on 3;151O5. (Inaudible) High Ridge Family + +7 Cerder, + +8 UNK: Just + +9 5 Okay, the Present also Is.. could you state your name + +10 please? + +11 + +12 C Spell your name please? + +13 • + +14 And your date of birth? + +15 + +16 S And you are? + +17 • Family Therapist. + +18 Could you spell your name please? + +19 + +20 • And you're her family therapist? Am I correct? + +21 U Yes. + +22 S Okay. I'm here today; and I have stated briefly My I'm here is in + +23 reference to an incident that happened to a friend of yours. o• a girt you know. + +E: Are you lying about anything? + +2 **-No swear on the bible.** + +**3• Okay. Swearing to God, that's good enough for me.** + +**•** + +**4 M. I swear to God.** + +**5 Okay. is there anything else you'd like to talk to me about?** + +**6 M: No, because that's about....nothing else about the whole thing.** + +**7 M: So that's it. You did not have any kind of sex with him.** + +**•** + +**•** + +**8 Heck no!! I will swear on my mother's grave...** + +**9 S You know what having sex with somebody means?** + +**10•. Yes, I know what having sex with somebody means.** + +**11.; Okay. You, at no time, touched his penis?** + +**12 M: At no time did i touch hit penis.** + +**13 5 At any time, did he touch you.... .** + +**14 At no time...** + +**15 5 Besides pulling his hands...** + +**16 Besides that, no times did he touch me.** + +**17 And just so I can be sure, you saw him whacking off once.** + +**18 Yes, I saw him.** + +**19 5 Okay. And as far as you think.....** + +**20 I think, I know, web, I couldn't say I know, but its the same noises were being** + +**21 made when he was (inaudible).** + +**22 5 And that's it. I thank you very much This will conclude the interv;ew. The time** + +**23 now by my watch Is approximately 3:05.** + +• + +• + +• + +:N RE: JEFFREY EPSTEIN + +## DRAFT + +TAPED INTERV:ZW OF + +## A Yeah. DI1AFT Page 6 + +Ckay. + +3 A Well, no. :t was the second time that' I gave him + +4 a massage The first time i went up with + +5 Q Okay. You want upstairs with IIIIII? + +6 A No, T was 11 the kitchen. + +7 Q You were in the kitchen That was -- you only had + +8 two times that you went tnere? + +9 A Yeah. + +1p Q the time you didn't do anything but just sit + +11 in the kitchen? + +12 A Yeah. + +13 Q Who did you sit in the kitchen with? + +14 A He had a coos that was there and he had -- there + +15 was \_i:ce two other girls there that :Ave with him. + +16 Q Okay, Did yo:z massage his back? Was he naked + +17 when you were massaging him? + +18 A Well, he had like a towel around his -- his upper + +19 was (inaudible) but he had like a towel around him. + +20 Q Okay. Did he over remove that towol? + +21 A No. + +22 Q When you were massaging him he never removed the + +23 lowe? + +24 A Nu. + +## 1 Private area? D1AFT Page ? + +2 A No. Ho. I wouldn't do that. + +3 Q You wouldn't do that.? + +4 Okay. Did he touch you in your private area? + +6 0 No. + +A No. No. + +7 A He kept like staring at Ire and like, I don't kdcw, + +3 1 just felt uncomfortable and I \_eft. But I heard other + +10 0 Righl . I'm concerned with you. I know abort. + +stories that like -- + +11 other stories and I've interviewed other people halm told me + +12 different things. ?hat's why I'm trying to find oat whet + +13 happened to you. Okay? + +14 A Oh-huh. + +15 0 You're the victim in this so that's why I'm trying + +16 tc find cut what happens to you + +17 A eh-huh. + +28 0 nay? Who took you upstairs to the room? + +29 • This girl that lives with him. + +• Clay. So took you 4p? + +21 A Yes. + +22 0 Did she tell you anything? Did she say anything? + +23 A Huh-huh. There's a manage table and she just + +24 laid a tower down and she said that 3e1(rey will be oLt EoL + +![](_page_20_Picture_9.jpeg) + +![](_page_20_Picture_10.jpeg) + +![](_page_20_Picture_11.jpeg) + +![](_page_20_Picture_12.jpeg) + +![](_page_20_Picture_13.jpeg) + +![](_page_20_Picture_14.jpeg) + +1 .: Detective + +2 + +3 + +4 + +5• I.D. OM reference case number05-368. The tine now, by my watch, is + +6 approximately 6 minutes past 2pm on 3/15105. (Inaudible) High Ridge Family + +• + +7 Center, + +8 UNK: Just + +9 Okay, the Present also is.. could you state your name + +10 please? + +11 + +12 • Spell your name please? + +13 + +14 And your date of birth? + +15 + +16 •: And you are? + +17 :amity Therapist. + +18 M. Could you spell your name please? + +19 + +20 And you're her family therapist? Am I correct? + +21 • Yes. + +22 • Okay. I'm here today; and I have stated briefly why I'm here is in + +23 reference to an Incident that happened to a friend of yours, o• a girl you Know. + +• + +2 3 4 5 N. 6 7 tqlkiPtS;• YetrOktfli7iii4vaadtittifideiStrx 441 . • .• 8 ■Heck.noff I tivill.sWeekon.nty indiffeesiravin: • •' 9 t411 - MOW 164fatina9911i4X 491ZiOnei:;0•Cly:iticii0 10 Yes, I know what baiting sex witli somebody rheartiat-. 11 Okay. You, at no time, touched his penis? 12 At no time did I touch his penis. 13 At any time. did he touch you..... 14 At no time... 15 Besides putting his hands... 16 ■ **Besides that, no times did he touch me. 17 And just so I can be sure, you saw him whacking off once. 18 Yes, I saw him. 19 • Okay. And as far as you think... 20I think, I know, well, I couldn't say I know, but it's the same noises were being 21 made when he was (riaudible). 22 And that's It. I thank you very much. This will conclude the Interview. she time 23 now by my watch is approximately 3:05 Afe you lying about anything? No. I'll swear on the bible. Okay. Swearing to God, that's good enough for me. I swear to God. Okay. Is them anything else you'd like to talk tome about? No, because that's about....nothing else about the whole thing.** + +IN RE: JEFFREY EPSTEIN + +## DRAFT + +VTD3OTAPED INTERVIEW OF + +Page 21 + +1 A (Shakes head no.) + +2 Q Okay. This case is basically an investigation, an +3 open investigation, so I appreciate it what we discuss stays +4 here. Okay? + +5 A Jh-huh. + +6 Q Don't tell anybody that we, that we talked. Okay? + +7 A Okay. + +8 Q Did you ever have any intercourse with him? + +9 A No. + +10 Q No oral? + +11 A (Shakes head no.) + +12 Q Nothing? + +13 A Nothing else. + +14 Q Okay. I'm going to show you a group of +15 photographs. I'm going to show you a group of six +16 photographs. Okay? I'm trying, trying to see if this [REDACTED] +17 is in these six photos. Okay? It's important that you look +18 at all six of them and be sure who you pick as the person as +19 [REDACTED]. Okay? She may or may not be in these six photos but +20 it's important for you to pick the right one. Okay? + +21 A Jh-huh + +22 Q Take your time looking at those six photos there. + +23 A I don't see her. + +24 Q She's not in those photos there? + +25 A No + +I + +![](_page_25_Picture_1.jpeg) + +![](_page_25_Picture_2.jpeg) + +![](_page_25_Picture_3.jpeg) + +![](_page_25_Picture_4.jpeg) + +![](_page_25_Picture_5.jpeg) + +![](_page_25_Picture_6.jpeg) + +![](_page_25_Picture_7.jpeg) + +![](_page_25_Picture_8.jpeg) + +• + +• + +• + +• + +• + +### DRAFT + +1 Defective + +2 + +3 + +4 + +• ID. #8059, reference case number 05-368. The time now, by my watch, is + +6 approximately 8 minutes past 2pm on 3:15/05. (Inaudible) + +7 + +8 UNK: Just + +9• Okay, the Present also is...could you elate your name + +10 please? + +11 U + +12 U Spell your name please? + +13 ▪ **S** + +14 U And your date of birth? + +15 + +1B U And you are? + +17 • a Family Therapist. + +18 Could you spell your name please? + +19 + +20 • And you're her family therapist? Am I correct? + +21 Yes. + +22 U Okay. I'm here today; and I have staled briefly why I'm here is in + +23 relevance to an Incident that happened to a mend of yours, rapid you Iciovr. + +Okay. After everything was done, okay, did he watch you get dressed? + +### DRAFT + +2 • No. Cause I was getng dressed while he was out there getting the \$300. I • 3 guess that's what he was doing. Theis the any thing he came back In with. le 4 wassail in a towel and stuff. + +5 In the room, al all, do you think "and i don't know if there is or not, but do you 6 think there is anything in there that may have recorded what you did? + +7 Oh my gosh.... + +B A video camera... + +B Oh my gosh. I ddn't think about that. There was lots of places there could have I C been one because there's pictures, that could have been, I don't know... + +t • When he walked out... the reason why I ask is because he walked out once and 12 then came back in, right? + +13 Yes. + +14 • So K could be Just so he coukl whack off. I was just curious. 1 don't know if lb there is or not + +18 If there was. I did not know about It. + +• + +17 • Okay. So you get dressed, you go downstairs. Where is that woman again? + +18 • Downstairs talking to and the other girl. + +19 Okay. + +20 They were having a conversation. + +21 • Okay. Al any time. did he speak to you or does he know how old you are. did he 22 know how old you were? + +23 Okay. Yes. And, as a matter of fact= Soktmeith sin l walla because , + +1 ██████████ said tell him you're 18 because if you're not, he won't let you in his house +2 So I said he was 18. As I was giving him a massage, he was like how old are +3 you. And then I was 18. But I kind of said it really fast because I didn't want to +4 make it sound like I was lying or anything. + +5 ██████████ So what other things did he ask you? + +6 ██████████ Um, how I know ██████████, what school I went to. + +7 ██████████ Did you tell him what school you went to? + +8 ██████████ Yeah but I told him ██████████ I didn't tell him ██████████. + +9 ██████████ Did he ask you what grade you were in or did you tell him what grade you were +10 in? + +11 ██████████ Yeah, he was like what grade are you in? Because I told him I was in 12th grade +12 still. + +13 ██████████ Okay. + +14 ██████████ Because I told him I was 18 so I had to... + +15 ██████████ So you told him you were in 12th grade? + +16 ██████████ Yes. + +17 ██████████ Are you sure? + +18 ██████████ Yes. + +19 ██████████ Okay. What else did you talk about? + +20 ██████████ Um, that's about it. And he was kind of asking me like how I knew ██████████, is +21 ██████████ nice to me and then he told me how he knew ██████████ and he was like, I was +22 kind of like, how do you know ██████████. Cause I brought up the conversation. He +23 said well I know ██████████ because she's been working for me for a long time. And + +IN RE: JEFFREY EPSTBIN + +# DRAFT + +TAPED INTERVIEW OF [REDACTED] + +• + +• + +1 BY DIT8CrIVE + +2 Q You said he + +4 A rn lever area + +5 Q Your lover area? Below your waist? + +6 A (Inaudible.) + +7 NY DETNOTIVI + +8 Q Okay. Eow long did he + +9 A A few seconds Not long It wasn't Long. + +10 0 Dkay. Did you tell him you didn't like that or -- + +11 A No. I told him -- I didn't tell him no and I + +12 didn't tell him that I wasn't comfortable I wasn't + +13 comfortable but T didn't tell him that And like I said, I + +14 made the stoney that day so.. + +15 0 Did yot guys discuss, anything? + +16 A Hub-huh, + +1/ Q Did he ask you your age? + +le A Yeah. I told him I was 18 + +19 Q You told hie you were 18? Okay. DLO he want you + +20 to come back? + +21 A Na said ha would love if I coma back sometime but + +22 I never vent back. + +23 Q You never went back. You only went one time + +24 What vas and doing when you were + +25 upstairs? + +IN RE: JEFFREY EPSTEIN + +# DRAFT + +VIDEOTAPED INTERVIEW OF [REDACTED] [REDACTED] + +#### • DRAFT + +Page 12 + +or be didn,t care? + +2 A I don't thitiA ha cared. Mc told re the younger + +3 the better. + +0 The younger th► **hatter? All right.** + +**A Pretty such that'. bow it worked Oa didn't --** + +**6 let es just put it this way. be -- I tried to bring hie, I** + +**7 tried to bring him a woman who was 23 and he didn't really** + +**\$ like it** + +**9 Q Ha didn't go for it?** + +**10** A Et'e not that ha didn't go for it. It's just that + +II be didn't dare for it And ha lilted the girls that are + +22 between the ages of like is and 20 + +13 Q Okay + +14 A But ffielatly the stint I -- I think seed of them lie + +15 about their age. I know that when I started off young I + +16 think be know better to belieVe e\* I think kie knew that I + +17 was younger, like 37, but I told him that I was like IS + +7.8 Q Okay + +19 A Mosciof the girls lied whoa they ge to there, + +20 0 Right. Because she was le.. + +21 A Yeah. Witte! them./ believe lied. + +22 0 Bow do you contact kin? now do you know when he , a + +23 in town and stuff like that? + +21 A calls us + +25 Q Ob. Calla you? + +IN RE: JEFFREY EPSTEIN + +# DRAFT + +VIDEOTAPED INTERVIEW OF [REDACTED] + +1 A Yeah \$100 more just to take my shirt off. + +2 Q Okay. And you said you didn't do it. + +3 A No. + +4 Q Okay. Did [REDACTED] on the second time? + +5 A Yeah. + +6 Q And did he ever [REDACTED]? + +7 A Actually the second time like it wasn't that bad + +8 because he was like on the phone all the time and so he + +9 wasn't paying attention to what was going on. + +10 Q Did he ever at any point [REDACTED] the second + +11 time? + +12 A No. Not that I remember + +13 Q Did he ever ask you any questions or speak to you + +14 or ask you anything? + +15 A Well, he tried to talk to you just to make you + +16 comfortable with the situation like where do you work and + +17 like how much do you make at your work and then he start + +18 saying you can make more with me, but I didn't feel like it + +19 was right. + +20 Q Did he ever know your real age? + +21 A After a while like because somebody told me. + +22 Q That you were -- + +23 A Yeah. + +24 Q -- 17? + +25 A Like [REDACTED] us. We were supposed to say we + +1 wort 10 + +2 C hot who to\_d you that to say Oat? + +3 + +5 A was the oau who brought everything to + +6 everyone at school That's acw we know smut it Then she + +7 took and took me + +9 Q Okay. So oath time you did go, did get + +9 money tor taking you or -- + +10 A Well, went with Re twice 1 glass. And that + +11 was it. Then I want w\_th + +12 Q Okay. And did she make money? Did IIII make + +13 money for taking you to him? + +\_4 A No, I ass taking her. + +tR Q Oh. you ware ta ng bet So you brought -- + +16 A She knew about it and ere ask me if I could toll + +17 he: because she didn't know waste it was But I didn't get + +money out- of that. + +19 0 Okay. bid anybody suer help you do a massage + +20 him? + +21 A No. Mi asked,\* do it with her and T didn't + +22 feel com£o:tsbte + +23 0 al1 right. All right lalk to me \*boar the third + +24 tiro you went. + +25 A 1 don't remember :t was like kind of always -- + +Z.••••••••• • + +1 + +IN RE: JEFFREY EDSTBIN + +# DRAFT + +1 A + +7 Q Okay. + +3 A Because he was like, made a big sigh of relief 4 like he had been done and he just got right back up and -- + +Page 13 + +5 Q Do you kno + +7 A I think it was + +9 0 Okay. As I told you before and I explained to 10 you woe, what he did was wrong, okay? + +probably. + +11 A Uh.hub. + +12 Q I want to reassure you on that. Okay? + +13 At any point did he ever ask you to leave your 14 phone number or -- + +15 A to Ha didn't aak ne for anything like I think 16 be asked ma my name in the beginning + +17 Q Did he know your age? + +18 A I don't taint -- he did. I think he did. + +19 Downstairs was like oh,. well, if tMy ask you ho0 20 old. are you just way you're 16 but he never asked ne how old 21 1 was. + +22 0 Okay, + +23 A I thought you had to be a'elitalivage to mi,s4se 24 someone, + +2S 0 Do you have any formal massage training, + +IN RE: JEFFREY BPSTEIN + +# DRAFT + +VIDEOTAPED INTERVIEW OF [REDACTED] + +Page 9 + +1 Q Okay All right Rhen you would go back and do 2 the massage, would it, would it waintain the same or were 3 more things -- + +4 A Well, no I mean I would take my jeans off a lot 5 of times or whatever but that was that. I never slept with 6 him. I never did anything to him. Nothing like that + +7 Q Okay Is it safe to \*sane, that you provided the 8 manage wearing ocly panties? + +9 A Yee. + +10 Q Okay. During the massage that you gave him, did 11 ha ever touch rata + +12 A Like I moan he would like :ouch my hip or whatever 13 but I mean that, that's really it + +14 Q Okay. + +15 A And if Ismerlikeasked, if I ever said I wasn't 16 comfortable with it, he's like or I don't went you to touch 17 me, he'd be like fine. (inaudible.; + +1.8 0 Aral this all occurred when you were 18 though, 19 right? + +20 A ub-hub. I bad bead 1\$ for like eight mouths, nine 21 months already. My birthday's leo I had boon 19 tor 22 a while. + +23 Q Okay. You're 19 now though right? + +24 A Y04. Y114. + +25 0 it was about a year ago when you met him. + +IN RE: JEFFREY EPSTEIN + +# DRAFT + +TAPED INTERVIEW OF [REDACTED] + +PAGE 1 OF 1 + +## DI1AFT + +Page + +1 that's it / lust told bin -- + +2 Q Did he come up bare or did you meet with Le in 3 Florida? + +4 A He care up have. + +Q oh, he cane up here? + +6 A Yeah. + +7 Q He sec you right here? + +• + +8 A Not here I didn't went to meet. I met hal at 9 Val-Matt and I just -- he just kept asking as questions that 10 I didn't know the answer to so + +11 Q Has he an investigates/ Wes he an attorney? + +12 A I don't know. I don't chink he wa■ **an attorney 13 because be kept saying the information he's getting from me 14 is going to go to Jef£'s attorney so I don't think he wan an 15 attorney.** + +**16 BY DETECTIVE** + +**17 Q What kind of questions was he asking? If the 18 police were involved?** + +**19 A Yeah If -- how the police got involved I said** + +**20 I don't know What kind of questions they were asking I** + +**22 said I don't know because I haven't been questioned yet.** + +**22 And just like bow old I was whet I went there and basically 23 like you guys are asking what I did when I went there** + +**24 sy cracrIVE** + +**25 Q Wow how old were you when you first started going** + +1 there? + +2 A Bightten. I'm 19 now this last ██████. + +3 Q ██████ of ██████, right? + +4 A Yeah. And I turned 19 (inaudible) + +5 Q And did he question ██████ at the same time? + +6 A Did the guy? No. + +7 Q Did he ever? + +8 A No. ██████ said she didn't want to + +9 Q Okay. And he said he was a representative of + +10 Jeffrey Epstein? + +11 A Yes. + +12 Q Did he call you or did Jeffrey or ██████ -- + +13 A No, he called me. This is the number. It's + +14 ██████ -- + +15 Q Uh-huh. + +16 A -- ██████ + +17 Q Okay. When was this you met him? + +18 A Like two, three -- it was Friday or Saturday + +19 Q Did he come by himself? + +20 A Yeah. + +21 Q Did he tape the conversation? + +22 A No He asked me if he could. I said no. + +23 BY DETECTIVE ██████ + +24 Q Okay. If he reaches out to you again, just give + +25 him my number and have him call me. + +IN RE: JEFFREY EPSTEIN + +# DRAFT + +1 A All I had was my underwear. + +2 Q Just pantles? + +3 A Yes. + +4 Q No bre? + +5 A No + +6 Q Okay. How did are you now? You're -- + +7 A I'm 20. + +8 Q You're 20. So a couple months ago you would have + +9 been what. L92 + +10 A Yeah. + +11 Q Well, your birthday is in [REDACTED] + +12 A Uh-huh. + +13 Q All right. So July, August you would have been + +14 19, 20 On the verge of 20? + +15 A Uh-huh. + +16 Q So what else happened when you provided him the +17 massage? + +18 A That's just it. He had a towel over his private +19 parts and he was just laying on the table and I was just +20 massaging from his knees down for about 45 minutes and she +21 said all I had to do was give him a massage for an hour so +22 that's what I did. And then like ter minutes before we were +23 getting ready to leave he asked her to leave because we were +24 in the room together and all I had to do was massage his +25 chest and that's it. He had the towel on him and about five + +IN RE: JEFFREY EPSTEIN + +# DRAFT + +TAPED INTERVIEW OF [REDACTED] + +1 night want to give a massage and I said I don't know. Then + +2 he asked re about what : wanted to do when I grew up and + +3 stuff like that and i asked him what he did and he said he + +4 was like a scientist basically. + +5 + +illt i AS + +7 Q + +8 A tib, I don,C.thlekSO.c. • + +9 q Weil it wou:d have been 16 if it was a year ago, + +10 right? + +11 A Well it like was almost a year eco. (Inaudible) + +12 D. + +13 0 Okay. During the naesage did you -- were yoti + +14 naked + +15 A No. 1 had my clothes on. + +16 0 You had all your clothes on? + +17 A Oh-huh. + +18 G Okay. Did he touch you in any way? + +19 A He was like kind of like leaning towards it but I + +20 was like you could toll I was shy so I think that's why he + +21 didn't try. But I heard about other girls that he -- that + +22 he got flirtatious with them and he made them take oft tteir + +23 clothes and stuff. + +24 0 Okay. What that was the first time you went, + +![](_page_47_Picture_3.jpeg) + +![](_page_47_Picture_4.jpeg) + +![](_page_47_Picture_5.jpeg) + +![](_page_47_Picture_6.jpeg) + +![](_page_47_Picture_7.jpeg) + +![](_page_47_Picture_8.jpeg) + +![](_page_47_Picture_9.jpeg) + +![](_page_47_Picture_10.jpeg) + +![](_page_47_Picture_11.jpeg) + +![](_page_47_Picture_13.jpeg) + +IN RE: JEFFREY EPSTEIN + +DRAFT + +VIDEOTAPED INTERVIEW OF + +![](_page_48_Picture_4.jpeg) + +1 Q One time. How much did he pay you for that? + +2 A \$300. + +3 Q Okay. All right. He never was there ever a 4 time you felt uncomfortable? + +A No. Like I'm very comfortable with like he asked me that too and he's like are you uncomfortable and like as 7 weird as it sounds I'm very comfortable with myself so like 8 it didn't really bother me. And I needed the money so, you 9 know, my boyfriend and I were having a hard time so I did 1c what I had to do, you know? + +11 Q I understand. I understand. That was the only 12 time you ever went? + +13 A One time. And I think I dropped her off once and 14 got her an hour later when her car was down or something. + +15 Q Okay. And -- + +16 A He had like a massage room, like a bed and like he 17 has this + +18 Q Massage bed or like a bed bed? + +19 A No, like a massage bed. Uh-huh. A massage bed. + +20 Q Okay. And where was this? What part of the house 21 was this? + +A His house is massive. We went in through the kitchen, up the stairs around, so it was like I guess towards the front on like the second floor maybe. Maybe over the pool or something like that. + +I + +• + +. + +IN RE: JEFFREY EPSTEIN + +## DRAFT + +VIDEOTAPED INTERVIEW OF + +![](_page_50_Picture_4.jpeg) + +1 Q Okay. All right. When you would go back and do +2 the massage, would it, would it maintain the same or were +3 more things -- + +4 A Well, no. I mean I would take my jeans off a lot +5 of times or whatever but that was that. I never slept with +6 him. I never did anything to him. Nothing like that. + +7 Q Okay. Is it safe to assume that you provided the +8 massage wearing only panties? + +9 A Yes. + +10 Q Okay. During the massage that you gave him, did +11 he ever touch you? + +12 A Like I mean he would like touch my hip or whatever +13 but I mean that, that's really it. + +14 Q Okay. + +15 A And if I ever like asked, if I ever said I wasn't +16 comfortable with it, he's like or I don't want you to touch +17 me, he'd be like fine. (Inaudible.) + +18 Q And this all occurred when you were 18 though, +19 right? + +20 A Uh-huh. I had been 18 for like eight months, nine +21 months already. My birthday's in [REDACTED] so I had been 18 for +22 a while. + +23 Q Okay. You're 19 now though right? + +24 A Yes. Yes. + +25 Q It was about a year ago when you met him. + +IN RE: JEFFREY EPSTEIN + +# DRAFT + +1 want to tell you any wrong information. + +2 Q Okay. That's fine. + +3 A But I don't -- + +4 Q That's fine. You have not had any contact with +5 [REDACTED]? + +6 A No. Only thing I know of her is that I guess +7 she's working at (inaudible) now. + +8 Q Did you ever leave your phone number for him to +9 call you? + +10 A No. He never had my number and I never had his +11 number. + +12 Q Okay. + +13 A He'd call through [REDACTED]. + +14 Q He'd go through [REDACTED]. And you never gave [REDACTED] +15 any money? + +16 A Huh-huh. + +17 Q Okay. + +18 BY DETECTIVE [REDACTED]: + +19 Q Were you afraid when you were in there? + +20 A I wasn't afraid. I guess I should have been +21 (inaudible) but I wasn't afraid but I wasn't very +22 comfortable. + +23 Q Were you afraid to say no to anything? + +24 A No. I could have said no but at that time I was +25 in debt. I was in a lot of debt and I needed that money and + +IN RE: JEFFREY EPSTEIN + +DRAFT + +VIDEOTAPED INTERVIEW OF + +![](_page_54_Picture_4.jpeg) + +## DOM + +Jeffrey's. + +2 Q Okay. Obviously this is an ongoing investigation. + +I would appreciate it if anybody does call you from the house to try to find out information or ask you questions about what if the police have contacted you, I would appreciate it if you called me. You have my card, right? + +A I have it somewhere. I'm not sure what I did with it though to be honest. + +Okay. + +10 A Thank you. + +11Q Okay. Just a few more questions. + +12 When you had intercourse, obviously that was 13 consensual? + +14 A Uh-huh. + +15 Q Okay. He's never forced himself or forced 16 anything on you? + +17 A No. + +18 Q Did you bring anyone to the house? + +19 A Yes. I brought two people but each of them only 20 went once. + +2: Q Okay. Who were those people? + +22 A A girl named + +23 Q Uh-huh. + +24 A And a girl named + +25 Q And? + +I + +IN RE: JEFFREY EPSTEIN + +• + +# DIIAFT + +• + +TAPED INTERVIEW OF + +• + +1 But I haven't because I haven't known him that long. + +2 Q Okay. Your first time you went you just sat in 3the kitchen and waited for , correct? + +A Uh-huh. Yeah. Plus he wanted to meet me. + +5Q Okay. As you've gone, tell me has anything 6escalated from just a massage? + +A No. Like the first time I went, I waited. The second time I went, I stayed in all my clothes and like gave him a massage. And then I think it was probably the third I time I went he asked me if I'd like to get like more naked or whatever and I said no. I just didn't feel comfortable. After that he never asked me anything that made me feel uncomfortable. + +14 Q Do you give the massage in your undergarments? + +15 A No. + +16Q Completely clothed? + +17 A Completely clothed, yeah. + +18 Q Okay. + +19 A I mean he's asked me but I said no because I just 20 don't feel comfortable doing that. + +21 Q Has he touched you? + +22 A No. + +23 Q Has he + +24A The closest he came to touching me was giving me a 25hug goodbye. But not inappropriate (inaudible). + +1 Q Massaged what? His -- + +2 A His back and his lower back and his feet. + +3 Q All right. Okay. Have you ever seen him naked? + +4 A No. In a towel but that's it. + +5 Q That's it. Has he ever touched you? + +6 A No. + +7 Q Has he ever touched himself while you were +8 massaging? + +9 A No. He was mostly like on the phone. Like my +10 friend told me, he's perverted but he's never that way +11 toward me. He asked me once. + +12 BY DETECTIVE [REDACTED]: + +13 Q What did he ask you? + +14 A He asked me like the third time I went there. + +15 Q To do what? + +16 A If I wanted to get naked or do anything more and I +17 said no and I think he could tell I was like uncomfortable +18 with it so... + +19 BY DETECTIVE [REDACTED]: + +20 Q Okay. All right. So aside from [REDACTED] and +21 Jeffrey, did you meet anybody else in the house? + +22 A I met -- yeah, but I don't know like I didn't meet +23 them but I've seen them. Like I was never formally +24 introduced but I've seen a little like short -- I don't even +25 know. Some lady out there didn't speak that well English + +• IN RE: JEFFREY EPSTEIN + +• + +• + +DRAFT + +TAPED INTERVIEW OF + +![](_page_59_Picture_4.jpeg) + +• + +• 7 A And called me and told me that Jeff had wanted me to come back and then I went down there. + +> 3 Q Okay. Do you recall when this was? + +9 10 11 A No. I know it started like this time last year because I think about January is the last time I went when I met my boyfriend and he didn't want me going down there. + +12 Q So January of this year was the last time you went? + +14 A Yeah. + +15 16 Q Okay. All right. So she calls you and tells you to come + +17 A (Inaudible.) + +18 19 Q -- tells you to come to the house to provide, to work? + +20 A Uh-huh. + +21 Q Did anything happen during that massage? + +22 23 24 25 A No. The only thing he ever did was he tried to grab my butt and I told him I didn't feel comfortable with that and he always said that if you didn't feel comfortable just to let him know. He didn't want you to feel + +# DRAFT + +1 Q Okay. When the second time you went, how did you, 2 how were you contacted? + +3A Asked -- when he asked -- when he gave me \$300 and 4 asked me to come back, I had left him my cell phone number. + +5Q Okay. + +• + +## DRAFT + +1 uncomfortable. + +2 Q Was that on the second massage? + +3 4 A No. Probably about towards the end because I was fully clothed until the third massage. + +3 Q Okay. + +5 7 B 9 10 11 12 A That was the massage. That's when just I did it in my bra and underwear. And then after that is when I started feeling uncomfortable with it because he was like why don't you take that off and I was like no. And then just -- he never pressured me. He never forced me to do anything. But he would like try to talk you into it and I didn't feel comfortable with it. + +1 3 • Okay. So you recall both -- the first two times? + +14 A Uh-huh. + +15 Q Did he touch himself during the second massage? + +16 A I guess kinda he would sometimes. + +17 • What do you mean? + +18 29 20 A Well not -- like towards the end when I was in my bra and underwear like sometimes when I would be rubbing his chest then he would. + +21 Q Okay. Did he do it on the second time you went? + +22 A No. + +23 24 Q Okay. The third time you went, how were you contacted to go? + +25 A called me again. I + +4 + +IN RE: JEFFREY EPSTEIN + +DRAFT + +TAPED INTERVIEW OF + +• + +![](_page_62_Picture_4.jpeg) + +1 there's more to that. More to the massage. Okay? That's +2 why I didn't want mom to be in here. And you can talk to me +3 about anything. Okay? Like I said, I've interviewed other +4 people already who have told me what transpired in that +5 room. I know it's going to be difficult for you but... + +6 A Well, the first time I went there I did a massage +7 and he was just asking me a lot of questions. He seemed +8 like really nice. And then he kept like staring at me and +9 stuff. And then like I did a massage and he just kept +10 looking at me and he was like oh, you're being shy and I'm +11 like yeah. And he's like do you feel uncomfortable and I +12 was like yeah, a little bit. And he's like okay. And he +13 said well do you want to stop, and I was like no, it's okay. +14 And he was like why are you like being shy and I was like +15 oh, I don't know. And then he would like change the subject +16 and he started talking about other things. And then when we +17 were done he said that if like I wanted to come back and do +18 more then he would like pay me more and then I would have to +19 talk to [REDACTED] and I could come back. + +20 Q Okay. What kind of questions did he ask you as +21 you were massaging him? + +22 A He was asking about -- it was a year ago. I don't +23 remember everything but... + +24 Q Right. + +25 A He was just asking me if I had any friends that + +IN RE: JEFFREY EPSTEIN + +## DRAFT + +TAPED :NTERVIEW OF + +![](_page_64_Picture_4.jpeg) + +Okay. At what point did he reach out to try to 2 touch you? + +A While he just before he started to rub his nipples he goes I'm going to touch you the way that I like to be touched and I was like I don't feel comfortable that way. I'm fine. I'll continue to give you a massage but I don't want -- I'm very uncomfortable. Because before she told me if I felt uncomfortable just tell him and he'd back off. So I told him that I was uncomfortable like after he 10 started to touch me and he kept after that. + +11 Q Okay. He touched your buttocks? + +12 A Yes. + +13 Q Did he + +14 A i would not let him. No. + +15 Q Okay. And you mentioned your breast area. + +16 A Right. + +37 Q Did he try to touch your buttocks under the shorts 18 or -- + +19 A At first it was just outside my pants and then he tried to -- I had a belt on with my jeans so he tried to go like inside from behind but he could not and I was like I'm not comfortable. + +23 Q Okay. He put his hands under your shirt? + +21 A. Correct. + +25 Q Okay. And you had a bra on, correct? + +• + +• + +• + +• + +IN RE: JEFFREY EPSTEIN + +DRAFT + +VIDEOTAPED INTERVIEW OF + +9 10 5 Because that was one of Jeffrey's rules-. 114:had a probleth 6 wfth girls coming to the house that didrifft \_know, what they were getting into. He would met yob know/ make sure these girls know what I expect. }lag' sum \*hey know what they want. Because 'then th1154 get Ai that mOtIEZ don't want -- they need to know. + +11 12 As far as case, she knew everything she was getting herself into. It was all volunteered. + +13 :4 Okay. What did you tell her that she was going to do? + +15 16 17 :8 3.9 20 21 22 23 24 25 A I told her the same thing. I told her I -- you know, this guy Jeffrey -- she came to me saying she needed money, da da da da da. I basically told her about it. She was like, you know, what do you have to do. I told her, I was like, you know, the more you do the more you make. That's it. You're going to have to take -- you're going in order to make money you're going to have to go up there, you're going to take your clothes off. But the more you do is the more you make. She walked out of there with \$300 so she obviously and evidently let him do a little more. Plus on her way home she kind of told me what she did. + +### DRAF T + +A Yeah, just to bring a girl. + +Q And the girl that was going knew that she would 3 have to massage him? + +4 A She knew everythid . She knew everything. + +• + +• + +• + +• + +• + +#### DRAFT + +A calls us when she gets in town. calls 2 us to let us know when he's available. + +3 Q Oh, okay. + +A I've called him maybe once or twice to see if he was in town when I used to work for him but primarily would call us to let us know when he's in and when he wants people to work for him. + +8 Q So she would call you and say okay, he's coming in 9 Friday? + +10 A Friday at 7 he wants someone to work for him. 11 Saturday around 12. + +12 Q Okay. Let's talk about for a minute. Okay? + +13 A Okay. + +14 Q at the time was dating your cousin, right? + +15 A Uh-huh. + +16 Q Okay. She told you she needed to make money. She 17 knew -- did she know you worked.for Jeffrey? + +18 A I told her. + +19 Q You hid told her you worked for Jeffrey? + +20 A Uh-huh. + +22. Q And did ybu tell her what it entailed? + +22 A (Nods head yes.) + +23 Q Okay. So she knew that? + +24 A She knew everything before she even agreed to it- + +25 Q So She knevY there 'wat going: to hate to he seine + +..a + +1 kind of -- + +2 A Contact. Pretty much, yeah. I told her. I told +3 he exactly what his expectations were. I told her what goes +4 on with the girls that go up there. I told her like it's +5 your call. I was like if you want to do this, fine. If +6 not, fine. But when you go in that room I don't want to +7 hear you say oh, I didn't know he was going to do all that +8 because I'm telling you now what he's expecting. + +9 Q And basically it's touching? + +10 A Fondling. + +11 Q Fondling? + +12 A Looking, whatever. And I told her just remember +13 the more you do, the more you make. But that's up to you. +14 She asked me and I flat out told her I wouldn't, I wouldn't +15 do more. + +16 Q Okay. Yeah. You made that clear that you +17 wouldn't do more. + +18 A No. Screw that. + +19 Q But as far as [REDACTED] is concerned -- + +20 A Yeah. + +21 Q -- what did she tell you that happened in that +22 room? + +23 A Exact words? If I can recall when she came +24 downstairs, when she came downstairs me and her and I +25 believe it was [REDACTED] I was with, we all walked out. We got + +A What do you mean? + +Q Like if they, they wanted to work, how did you approach them? Say listen, I got this guy in Palm Beach? + +A For the most part because like I said, two were my friends. The others were like my acquaintances. It was a little more easier talking to them about it because I knew them. + +Just take a deep breath. Take a deep breath because I can see you working up again. You're working up the tears. I can see it. I don't want to get you like that. + +A I pretty much would just ask them. + +13 Q Straight up? + +A If you're looking for extra money let me know. This guy down in Palm Beach, he's really, really, really wealthy. You have to give him a massage. That's all I would tell them. Then if they were interested or told me, yes, I want to do it, I would go in detail with them before they would actually agree. If they told me, oh, that sounds good, I'm interested, then I would tell them okay, I want to let you know this is what you have to do. This is what is going to go on. + +23 Q Did you tell them that you were going to make money for bringing them over? + +A Most part I believe they knew. knew. + +### UllAFT + +you're breaking me off more. And they did. And after that Jeffrey said he didn't want her working after she started agruing. That's the only problem that I can think of. + +DETECTIVE : So when you -- to be specific, when you took somebody, they knew they would have to ge.4:haked they:wpuid Hay" to massage him. + +THE WITNMSS: They kilevis.Wilact, they were getting into prior tb showing up. That was Jeffrey's rule. Tell them what they're getting into because I don't want an -- + +> DETECTIVE : Argument. THE WITNESS: Yeah. + +DETECTIVE : And is now, is 17. When do you think you took her there? In order of events, when do you think you took there? + +THE WITNESS: She was 16 when I took her there. It was her -- I took her probably like 8 months ago. It's been a while. It's been a while. I don't know the exact dates because, like I said, I haven't contacted him in a while. But it was a while ago. + +DETECTIVE : Now does she live near you, + +IN RE: JEFFREY EPSTEIN + +# DRAFT + +TAPED INTERVIEW OF [REDACTED] + +Page + +1 A Me and both sat in the kitchen that day. + +2Q Okay. So is the one that worked? + +A Yes. + +Q Okay. Each girl that you went with, + +, those are the ones that did the work? + +6A Yeah. + +Q And sat in the kitchen? + +A That one day. When I was -- + +9 Q Okay. -Acrd 4g tbu 4ny -torlveASations, in the 10 car with either Or that may 11 have had with them as far as what to expect? + +1.2 A I think I remember telling that if he tells you hey, you know what I mean, if you want to do anything else you're still free to say no and he'll, you know what I mean? He would -- something to the extent where like hey, if he's like will you do this feel free to say no and he'll be okay with it pretty much. + +18 Q Okay. And what you mean by he wants to do this, 19 it's more than a massage? + +20 A Right. + +21 Q Okay. What do you know of that goes on up in the 22 massaging or working -- + +23 A Nobody ever wanted to tell me anything. Just that 24 they were giving massages and that was it. I didn't even 25 want to really know too much. + +IN RE: JEFFREY EPSTEIN + +## DRAFT + +VIDEOTAPED INTERVIEW OF + +I + +4 + +I + +• + +• + +0 + +5 Q Okay. , I've talked to a lot of girls and I pretty much know what goes on, okay -- + +6 A Uh-huh. + +7 8 9 10 11 Q -- to some extent. So I want you to feel free to talk to me without any problems. Trust me, there's nothing you're going to say that's going to shock me. I've talked to a lot of girls that visited the house. So this girl took you. + +12 A Uh-huh. + +13 14 Q And told you for -- a massage for \$200. Did she tell you you'd have to provide the massage naked? + +15 16 17 A She said that I might have to take off my clothes but that I'd be able to leave on my underwear which was true. + +18 19 • Okay. So talk to me about the first time you went to the house. + +20 21 22 23 24 A I went -- went in with me and brought me upstairs to the room that's like off to the side of his bedroom and showed me how to set up the table and where all the lotion is and everything. And then she went outside to wait for me. + +25 Q Okay. + +## DRAFT + +Page 4 + +to be true. And as I found out it wasn't quite what she 2 said. Just he asks the girls to take off their clothes and give him a massage and he likes watching them I guess. + +'rape: + +Date: + +Time: + +Participants: + +PBPD & + +October 11, 2005 + +4:10 p.m. + +Det. DETECTIVE + +(introduces the recording and asks most questions) + +Bet. : DETECTIVE 2 + +Abbreviations: Lii.• unintelligible + +// = voices overlap + +DRAFT + +1 Um, a couple of days later, I believe it was a Saturday night. I'm 2 almost positive it was, cause I know I didn't have to go to school 3 the next day. Urn, and definitely wasn't a Friday. So it next 4 Saturday night after that. She set it up, and I picked her up from 5 the her apartment, and we drove to the island and I worked, urn, 6 and he paid her three or four hundred dollars to bring me. + +7 8 DETECTIVE: Okay. + +9 10 And that was it. + +11 12 DETECTIVE: All right. Urn, and this was a year and a half ago, correct? + +13 14 Maybe two, I'm not sure, I didn't really keep track + +15 16 DETECTIVE: //Okay. How old were you when you first, uh, went over there? + +17 18 If it was two years ago I was sixteen, if it was a year and a half, I 19 would have been sixteen or seventeen, I don't know. + +20 21 DETECTIVE: Okay. + +22 23 Like, I really don't know. + +24 25 DETECTIVE: Okay. When you first went to give a massage, urn, you were 26 explained that, it was just a massage? + +27 28 Just a massage. + +29 30 DETECTIVE: Okay. Did she explain, urn, how you would have to be dressed to 31 give a massage? + +32 33 She said that he wanted cute girls, so I looked cute, did my best, I 34 didn't — I•didn't think that it was what irwas. I'!wasn't naïve 35 enough.to think that he was gonna pay.metwo•hundted dollars just 36 for nothing, [stutters) LI don't know, like I don't know what was 37 going through my head. I absOlutely'don't lcnpw. And I - the back • 38 of my mind I was thinking,, oh; btu 1 39 was also.thinIcing; youltnow,.at the same time,-is she -fucking 40 crazy? Like, this guy's not gonna pay you money for not doing 41 anything, not letting him cop.a feel or nothing. You know? So I 42 didn't know what to think, I was like oh, I'll just go and I'll feel it 43 out and if I don't like it, I'll leave. Like, in the middle of it, like I 44 don't care. If he does something that I have a problem with then 45 I'll leave. + +IN RE: JEFFREY EPSTEIN + +DRAFT + +VIDEOTAPED INTERVIEW OF + +![](_page_79_Picture_4.jpeg) + +• + +### DIU + +2 3 QWould he ask, ask you obvioutly if they were cool with it or felt coMfOrtable With it? + +I can't (inaudible) money. + +4A Uhhuh. And like I:vbaldialwaye :te3A ttlethi.rO 5know, what the situation was bedaute liketwasnYt told.the told. 6whold -- at first S was not torn the wholeAltUatiolis + +7 Q Whit did tell you tiou .would: lave' to %do? + +BA Illigtold me I would 'tut take my Shirt off and 9 give a massage and that was the end, + +10 Q Topless or a bra? + +11 A Topless. + +12 Q Okay. + +13 A So that was it. + +14 Q Okay. Was there ever a time that you ever told 15 him hey, I'm not comfortable with that? + +16 A The first time he asked me if I would take my 17 jeans off and I told him I wasn't comfortable with that. + +18 Q Okay. + +19 A I think that's really it. + +20 Q Again, you're not in any trouble. I'm, I'm just 21 trying to -- + +22 A Uh-huh. + +23 Q Was there ever a time that he ever tried to touch 24 your vagina? + +25 A Yes. + +• + +• + +• + +IN RE: JEFFREY EPSTEIN + +## DRAFT + +TAPED INTERVIEW OF + +![](_page_81_Picture_4.jpeg) + +• + +• + +• + +• + +### DRAFT + +1 A Seventeen. + +2 Q You were 17. Okay. And you went there with whom? + +3 A Page 3 + +4 Q brought you? + +5 A Yes. + +6 Q Okay. Did she tell what were -- um, what you 7 were required to do? + +8 A She said that I could giOe Jeffrey a massage and that he would pay me to do that. t\_didn't havt 'to do anything with him. She said tilatAie might ask me to take off a piece of clothing if that was okay with me. She said if not, I didn't have to. + +13 Q Okay. So when did you go? + +14 A When? + +15 Q Yeah. When was this? + +16 A I don't remember. It was a long time ago. + +17 Q Was it a year ago? + +19 A It was a long time ago because -- + +19 Q More than a year? Less than a year? + +20 A It had to be in November or December. + +21 Q Of last year? + +22 A Yeah. + +23 Q Okay. + +24 A And it was after November. + +25 Q When you walked into the house? + +• + +• + +• + +• + +• + +• + +## D 1 1 + +A Uh-huh. + +Q What school did you go to? + +A I went to (inaudible). + +Q Okay. So you have your high school diploma? + +A Uh-huh. + +6 Q Okay. You understand all these questions I'm 7 asking you, right? + +8 A Uh-huh. + +9 Q Okay. Like I said, I know some of this stuff is to hard to talk about but it's important because basically 11 you're a potential victim here. + +12 A Uh-huh. + +13 Q Okay? What kind of panties did you have? Was it 14 a thong underwear or regular panties? + +15 A A thong. + +16 Q It was a thong. + +17 BY DETECTIVE + +18 Q Did he ever tell you to wear anything specific? + +19 A No. Actually I was just wearing jeans and a 20 shirt. I mean I wasn't dressed in any certain way. + +21 BY DETECTIVE + +22 Q Okay. Did she explain to you that you may have to 23 take off your clothes and -- + +24 A She said I may have to and said if I didn't want 25 to that I don't have to. + +• + +• + +• + +• + +• + +• + +IN RE: JEFFREY EPSTEIN + +## DRAFT + +TAPED INTERVIEW OF + +![](_page_84_Picture_4.jpeg) + +• + +• + +• + +• + +• + +## DRAFT + +Page 3 + +raise your right hand for me. Do you solemnly swear to tell the truth, the whole truth and nothing but the truth so help you God? + +A I do. + +5 Q Okay. In your words, tell me exactly how you met 6 this gentleman in Palm Beach. + +A My friends, well, not really friends. told me in class that she found a way of making money. You can get money. And then she said that if I ever told anybody she'd beat my ass and so I didn't even know what she was talking about but I was like okay. She said this guy's house, a place where old guys are. And just massage him for 45 minutes and get \$200. And so she picked me up after work. We went down there. Right before we got in there she's like oh, he might ask you to like take off your shirt or something. But I didn't -- it didn't matter so I said okay. And I went in his house. A lady escorted me up to his room. Had a bed on it. + +19 Q Okay. Let me back you up for a second. + +20 A Oh-huh. + +21 Q You said this was right before Christmas. 22 Christmas of last year or the year before? + +23 A Last year. + +24 Q Last year. + +25 A Uh-huh. + +IN RE: JEFFREY EPSTEIN + +# DRAFT + +TAPED INTERVIEW OF [REDACTED] + +• + +• + +• + +• + +• + +• + +#### DRAFT + +1 was working for him. + +2 A Yeah. Everybody knew that. + +3 Q I know that. + +4 5 6 7 A So I just was like I don't know .your that well. We wanted to make M4ney off, of me :and . I just Wanted to go with bdcause she kneW hith and she knew like the situation so I went with her. + +8 o How far has gone with him? + +9 10 11 A She really doesn't go into detail. I mean I know she's gone farther than me but she doesn't really go into detail about it. + +12 13 Q Okay. Is there anything else that you'd like to add to this statement? + +14 A No. + +15 DETECTIVE : No. Okay. At this time + +16 I'm going to go ahead and conclude the statement. + +17 The time by my watch is 12:10. + +18 (Thereupon, the interview ended.) + +19 + +20 + +21 + +22 + +23 + +24 + +IN RE: JEFFREY EPSTEIN + +# DRAFT + +TAPED INTERVIEW OF [REDACTED] + +• + +• + +• + +• + +• + +B A It was probably about almost a year ago. + +9 Q Okay. Okay. + +10 11 12 13 14 A And he -- I went there once with her and she gave him a massage and then she asked me if I wanted to do it and then I did it or whatever and then after that like he kind of scared me when I went there so I just decided not to go back. + +15 16 Q Okay. The first time you went with , did you go upstairs with him? + +17 A No, I stayed down in the kitchen. + +18 19 Q Okay. Did tell'you that --.- what was entailed as to what had to be done? + +20 21 22 23 A Well she said the first time you go it's just like a massage and she said like well, the more you go supposedly the more he like expedts and starts flirting with girls and that's what kind of like scared me. + +24 25 Okay. I've interviewed other girls and they've told me pretty much the same thing about the massage but + +## DRAFT + +Page 3 + +1 information and we are conducting an investigation. We were 2here last night, spoke with your mom and dad. If you can 3just start from the beginning as to how you met him. + +4 A Okay. + +Q And how it came about. + +6 A I met him through my friend + +Okay. How long ago was that? + +Page 4 + +1 there's more to that. More to the massage. Okay? That's why I didn't want mom to be in here. And you can talk to me 3 about anything. Okay? Like I said, I've interviewed other people already who have told me what transpired in that 5 room. I know it's going to be difficult for you but... + +A Well, the first time I went there I did a massage and he was just asking me a lot of questions. He seemed 8 like really nice. And then he kept like staring at me and stuff. And then like I did a massage and he just kept 10 looking at me and he was like oh, you're being shy and I'm like yeah. And he's like do you feel uncomfortable and I was like yeah, a little bit. And he's like okay. And he said well do you want to stop, and I was like no, it's okay. And he was like why are you like being shy and I was like oh, I don't know, And then he would like change the subject and he started talking about other things. And then when we 17 were done he said that if like I wanted to come back and do more then he would like pay me more and then I would have to talk to and I could come back. + +20 Q Okay. What kind of questions did he ask you as you were massaging him? + +A He was asking about -- it was a year ago. I don't remember everything but... + +Q Right. + +A He was just asking me if I had any friends that + +1 2 3 4 might want to give a massage and I said I don't know. Then he asked me about what I wanted to do when I grew up and stuff like that and I asked him what he did and he said he was like a scientist basically. + +5 Q Okay. Did he ever ask you how old you were? + +6 A No. + +7 • No. Did he know that you were 17? + +8 A No, I don't think so. + +9 10 • Well it would have been 16 if it was a year ago, right? + +11 12 A Well it like was almost a year ago. ;Inaudible) 17. + +13 14 Q Okay. During the massage did you -- were you naked or -- + +15 A No. I had my clothes on. + +16 Q You had all your clothes on? + +17 A Uh-huh. + +18 Q Okay. Did he touch yOu in any way? + +19 20 21 22 23 A He was like kind of like leaning towards it but I was like you could tell I was shy so I think that's why he didn't try. But I heard about other girls that he -- that he got flirtatious with then and he made them take off their clothes and stuff. + +24 25 Q Okay. What -- that was the first time you went, right? + +Okay. Have you received any massage training? + +A No. + +Q No. I have to ask. + +Was one of the two girls that was in the 5 kitchen with you? + +6 A Yes. + +Q Okay. Did you ever go back to his house? + +8 A Well, I just went there twice. + +9 Q Right. + +io A After that -- + +11 Q After that you've never come back? Never went 12 back? + +13 How much did you receive for the massage? + +14 A Two hundred. + +15 Q You received 200. + +16 Okay. Did explain to you what was going to 17 be involved? + +18 A She said the first time you go there you pretty 19 much just give a 'massage, but the more you go there like the 20 more he expects. And that's it. That scared me. + +21 Q That's what scared you? + +22 BY DETECTIVE + +23 Q Did she say (inaudible) or did she (inaudible -- + +24 A SaY didn't have to 'say it exactly but she implied 25like, you know, like takingyour.dlothes Off and fluff kilts 4 + +### IMAFT + +Page 9 + +1 that. + +2 BY DETECTIVE • • + +3 Okay. So you didn't remove any of your clothing? + +4 A No. + +6 A I don't know. It was a long time ago. I don't + +8 Okay. + +9 A I don't want to tell you wrong. + +10 11 12 I know. And I know you already told your mom what happened. And like I said, I know this is hard for you but... + +13 14 A I was just scared. I just didn't want my name to like -- + +15 16 17 Q Don't worry. You're not the only person I've talked to. Okay? There's a lot of people that I've talked to and I'm going to talk to. + +18 How did you get to his house? + +19 A With + +20 21 in the kitchen. took you the first time and you sat + +22 A Yeah. + +23 Q What about the second time? + +24 A The second time I drove and she came with me. + +25 Because I didn't want to -- + +Q What were you wearing? 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HOURS + +9/6/03 SAT 12:30-1:30 1 HOUR AIRPORT PICK-UP COOK +9/9/03 TUES 9:00-4:00 7 HOURS HOUSE SIT WORKERS +9/10/03 WED 9:00-2:00 5 HOURS " +9/11/03 THURS 10:00-12:30 2 1/2 HOURS " +9/12/03 FRI 1:00-2:00 1 HOUR " +9/15/03 MON 9:00-6:00 9 HOURS " (PEADON'S CLEANING) +9/16/03 TUES 9:00-4:00 7 HOURS " (PC COMPUTER WORKER) +9/17/03 WED 11:30 - 6:30 7 HOURS " (DRAPE HANGER NO SHOW/ PC WORKER) + +TOTAL: 39.5 HOURS X 20 = \$ 790.00 +10/20/03 MON 10:00 AM-8:00 PM 10 HOURS (PEADON'S) +10 HOURS X 20 = \$200 +NEW TOTAL = \$990.00 + +\*WORKERS AT HOUSE: CASSIDY AIR- (REPAIR WORK & CHANGE AIR FILTERS), +PAINTER, CARPENTER, ELECTRICIAN, PC COMPUTER WORKER, PEADON'S CLEANING, +LARRY & CHRISTOF FOR CARS, GEROME (OUTSIDE LANDSCAPE & YARD WORK) + +PLEASE FEED-X CHECK TO: +[REDACTED] + +[REDACTED] PLEASE CALL ME TO CONFIRM THAT YOU RECEIVED THIS FAX- THANKS +SO MUCH + +HOURS X 26 = \$ 7.50 +10 HOURS X 26 = \$ 17.50 +10 HOURS X 26 = \$ 37.50 +10 HOURS X 26 = \$ 57.50 +10 HOURS X 26 = \$ 87.50 +10 HOURS X 26 = \$ 110.50 +10 HOURS X 26 = \$ 130.50 +10 HOURS X 26 = \$ 150.50 +10 HOURS X 26 = \$ 180.50 +10 HOURS X 26 = \$ 210.50 +10 HOURS X 26 = \$ 240.50 +10 HOURS X 26 = \$ 270.50 +10 HOURS X 26 = \$ 300.50 +10 HOURS X 26 = \$ 330.50 +10 HOURS X 26 = \$ 360.50 +10 HOURS X 26 = \$ 390.50 +10 HOURS X 26 = \$ 420.50 +10 HOURS X 26 = \$ 450.50 +10 HOURS X 26 = \$ 480.50 +10 HOURS X 26 = \$ 510.50 +10 HOURS X 26 = \$ 540.50 +10 HOURS X 26 = \$ 570.50 +10 HOURS X 26 = \$ 600.50 +10 HOURS X 26 = \$ 630.50 +10 HOURS X 26 = \$ 660.50 +10 HOURS X 26 = \$ 690.50 +10 HOURS X 26 = \$ 720.50 +10 HOURS X 26 = \$ 750.50 +10 HOURS X 26 = \$ 780.50 +10 HOURS X 26 = \$ 810.50 +10 HOURS X 26 = \$ 840.50 +10 HOURS X 26 = \$ 870.50 +10 HOURS X 26 = \$ 900.50 +10 HOURS X 26 = \$ 930.50 +10 HOURS X 26 = \$ 960.50 +10 HOURS X 26 = \$ 1000.50 +10 HOURS X 26 = \$ 1000.50 + +ATTENTION: [REDACTED] +FAX: [REDACTED] + +FROM: [REDACTED] + +[REDACTED] HOURS + +11/09/03 SUN 1 HOUR COLLECT MAIL & PUT IN STAFF HOUSE & CHECK HOUSE +11/10/03 MON 1 HOUR COLLECT MAIL & PUT IN STAFF HOUSE & CHECK HOUSE +11/11/03 TUES 1 HOUR " " " " " " " +11/12/03 WED 1 HOUR " " " " " + +11/13/03 THURSDAY 9:00 A.M. - 4:00 P.M. READONS, COMPUTER WORKER IN CABANA +& GROCERY SHOPPING. (CARMINE'S) + +11 HOURS X \$20.00 = \$ 220.00 TOTAL + +PLEASE FEED YOU CHECK TO +[REDACTED] +[REDACTED] + +[REDACTED] PLEASE CALL ME TO CONFIRM THAT YOU RECEIVED THIS FAX - THANKS +III + +ATTENTION- + +FAX: + +FROM [REDACTED] + +[REDACTED] HOURS + +12/01/03 MON 8:00 AM- 8:00 PM 12 HOURS + +HOUSE SIT- WORKERS: PEADON CLEANERS, PAINTER, ARCHITECT (DOUGLAS), +NATIONAL POOL, MAC GRAY, LENNY ELECTRICIAN, BISHOP WATER & BRENT +(CHEF) STAYING IN GUEST HOUSE + +12/02/03 TUES 8:00 AM- 8:30 PM 12.5 HOURS + +HOUSE SIT- WORKERS: PEADON CLEANERS ARCHITECT & WAITED FOR PLUMBER- + +12/03/03 WED 8:00 AM- 4:00 PM 8 HOURS + +HOUSE SIT- PEADON CLEANERS PEST EXTERMINATOR, PAINTER, & PLUMBER +[REDACTED] + +32.5 HOURS X \$20.00 = \$ 650.00 TOTAL + +[REDACTED] HOURS + +Please Fed-x check [REDACTED] + +THANK YOU VERY MUCH.....HAPPY HOLIDAYS!!!!!! + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +ATTENTION- +FAX [REDACTED] + +FROM [REDACTED] + +[REDACTED] HOURS + +| 1/27/04 | TUES | 1:00 PM- 9:00 PM | HOUSE SIT (WORKERS-
PEADON CLEANERS & GEROME) | +|---------|-------|------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------| +| 1/28/04 | WED | 9:00 AM- 9:00PM | HOUSE SIT (WORKERS-PEADONS,
LENNY FIXED GARDEN LIGHT & PUT
PANEL IN A/C UNIT & GEROME) | +| 1/29/04 | THURS | 9:00 AM- 6:30PM | HOUSE SIT (WORKERS-PEADON'S, GEROME,
ALAN FROM CASSIDY AIR & INSPECTOR TO
CHECK A/C)- ALSO PUT
MERCEDES IN FRONT OF HOUSE FOR
JEFFERY'S FRIEND TO BORROW | +| 1/30/04 | FRI | 1 HOUR | GET MAIL & CHECK HOUSE | +| 1/31/04 | SAT | 1 HOUR | GET MAIL & CHECK HOUSE | +| 2/1/04 | SUN | 1 HOUR | CHECK HOUSE | +| 2/2/04 | MON | 1 HOUR | GET MAIL, CHECK HOUSE & PUT MERCEDES
BACK IN GARAGE | + +**TOTAL HOURS =33 1/2 HOURS X \$20 = \$670.00** + +PLEASE FED X OR MAIL CHECK TO + +[REDACTED] + +**\* THANK YOU!!** + +ATTENTION: +FAX: [REDACTED] + +FROM: [REDACTED] + +[REDACTED] HOURS + +6/24/04 THUR 1 HOUR +GET DOOR CODE FROM (WPB) STAFF AND VERIFY WHAT IS NEEDED +WHILE STAFF OUT OF TOWN + +6/28/04 MON 1 HOUR +BRING MAIL IN STAFF HOUSE AND CHECK ON MAIN HOUSE + +6/30/04 WED 1 HOUR +BRING MAIL IN STAFF HOUSE AND CHECK ON MAIN HOUSE + +7/02/04 FRI 1 HOUR +SEND MAIL IN FED-X BOX TO NY AND CHECK ON MAIN HOUSE + +7/04/04 SUN 11:00 AM 12:00PM STHOUR +GREET NEW YORK STAFF AND GIVE DOOR CODE + +5 HOURS X \$20.00 S \$100.00 TOTAL + +DOOR CODE FROM (WPB) +STAFF OUT OF TOWN + +Please MAIL check to: [REDACTED] STAFF HOUSE + +THANK YOU ! + +[REDACTED] STAFF HOURS + +[REDACTED] STAFF HOURS CIVIL + +[REDACTED] S \$100.00 + +ATTENTION: [REDACTED] +FAX [REDACTED] + +FROM [REDACTED] + +[REDACTED] HOURS + +8/24/04 TUES 12:00 NOON-5:00 PM +LYNN AND JOJO- OUT FOR THE DAY +PEADON'S CLEANING +JOHN C CASSIDY AIR CAME AND CHANGED AIR FILTER +COLLECTED MAIL AND PLUT IN STAFF HOUSE +SENT [REDACTED] THEIR MAIL AND GAVE POST OFFICE THEIR NEW ADDRESS +CALLED CABLE COMPANY TO SET APPOINTMENT TO FIX TV IN BLUE ROOM +CALLED SHUTTER COMPANY AND MADE APPOINTMENT TO FIX SHUTTER + +8/25/04 WED - 1 HOUR +CALLED BOTH CABLE COMPANY AND SHUTTER COMPANY TO CANCEL +SINCE MR. EPSTEIN IN TOWN ON THURSDAY + +8/27/04 FRI- 4:00 PM- 6:00 PM +MET WITH MS. MAXWELL TO DISCUSS WHAT NEEDS TO BE FIXED AROUND +HOUSE-SHE PAID ME \$1,000 TOWARDS MY HOURS. STILL OWES \$380 AND +MONEY FOR SHOPPING AT CARMINES + +8/31/04 TUES (NO CHARGE) +CALLED AND HAD WATER DELIVERED +CONFIRMED WITH [REDACTED] THAT SHE WANTED LENNY TO FIX SHUTTERS +HAD [REDACTED] FAX LENNY A PAPER CONFIRMING THE QUOTE WAS +APPROVED TO THE STAFF HOUSE + +8 HOURS x 20.00= \$160.00 + +Please MAIL check to: [REDACTED] TO DIS +WE \$1,000 TO +SPEND AT CARMINES + +THANK YOU! +[REDACTED] +[REDACTED] +[REDACTED] + +ATTENTION: [REDACTED] / MS. MAXWELL +FAX: [REDACTED] + +FROM [REDACTED] + +[REDACTED] HOURS + +10/21/04 THUR (2 HOURS) +PICKED UP CHRISTOPH AND DROVE TO HOUSE TO GET MERCEDES +UNLOCKED HOUSE AND TURNED OFF ALARM THEN RESET ALARM +FOLLOWED CHRISTOPH TO REPAIR SHOP AND DROVE HIM BACK TO JET AVIATION +CALLED BISHOP WATER COMPANY TO CONFIRM THAT WATER WILL BE DELIVERED +TODAY + +2 HOURS x 20.00 = \$40.00 + +LE HESSE + +TH MOOL HESSE'S + +Please MAIL check to: [REDACTED] +(NEW ADDRESS UNTIL HOUSE IS BUILT) + +[REDACTED] + +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] + +THANK YOU! + +ATTENTION: [REDACTED] / MS. MAXWELL +FAX: [REDACTED] + +FROM [REDACTED] + +[REDACTED] HOURS + +8/04/05 THUR (1 HOURS) 7:00-8:00 PM +Received call from Benham Securities and checked entire house and grounds +Tried to reset alarm [REDACTED] + +8/05/05 FRI (2 HOURS) 1:00-3:00 PM +Spoke to Richard and was asked to reset alarm +Called alarm company and a technician explained how to reset alarm +Alarm was reset and house is fine + +3 HOURS x 20:00 = \$60.00 + +ALONE [REDACTED] + +Please MAIL check to: +(ADDRESS UNTIL HOUSE IS BUILT) + +[REDACTED] + +THANK YOU! + +to \$20,000 + +Epstein House + +Main House [REDACTED] + +Staff [REDACTED] + +Alarm [REDACTED] + +Password [REDACTED] + +![](_page_8_Picture_11.jpeg) + +LYNN & JOJO + +1 AIL NEEDS TO BE SENT + +~~VIA~~ ~~BO~~ FED-X ON + +THOR. + +I CALL + +2 A PICK UP. JUST +IP TOP COPY. + +3 Y WILL GIVE YOU A +K UP #. AND PICK + +UP BY BACK SERVICE +~~BOOK~~ DOOR. + +1-5 + +TH + +~~BOOK BY KNOWN~~ + +Lynn & JoJo + +① I sent [REDACTED] +mail to their correct address +and called Post office to make +sure all future mail will be sent to them + +② I scheduled the cable company +to come on Thursday. This is their +soonest appointment. Ghislaine asked +me to make an appointment because +the TV in the Blue Room does not +get a clear reception. + +③ SHUTTER COMPANY will come +EARLY THURSDAY TO MEASURE +SHUTTER NEXT TO GHISLAINE'S +DESK. THE SHUTTER WILL NOT +ROLL DOWN. ~~E~~ + +\* BOTH CABLE COMPANY & SHUTTER COMPANY +will CALL ME ON MY CELL PHONE TO +MAKE SURE JEFFREY & GHISLAINE ARE NOT +HERE. + +Jeffrey E. 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I was planning to have paras mark pages 6-8, but let's discuss briefly in morning. One thing I wanted to ask you. + +**From:** [REDACTED] + +**Sent:** Tuesday, October 5, 2021 2:27 PM + +**To:** [REDACTED] + +**Cc:** [REDACTED] + +**Subject:** RE: Testifying Witness Questions + +Just FYI, the notes and documents for [REDACTED] were in 31E-MM-108062 – GJ 1A4. They are attached here as well. + +Special Agent [REDACTED] + +FBI New York Field Office + +Child Exploitation/Human Trafficking + +Desk: [REDACTED] + +**From:** [REDACTED] > + +**Sent:** Monday, October 4, 2021 7:58 PM + +**To:** [REDACTED] + +**Cc:** [REDACTED] + +**Subject:** [EXTERNAL EMAIL] - Testifying Witness Questions + +I'm attaching the 302 for [REDACTED] from an interview on August 22, 2006. The last paragraph refers to her providing a copy of the hours she worked at Epstein's residence as well as some notes she made at her time of employment. Can you please send the notes and the documents she provided? I don't believe we have them. + +Also can you please send the notes of the 8/15/06 interview of [REDACTED]? The 302 is attached. + +Thanks! + +[REDACTED] + +[REDACTED] +Assistant United States Attorney +United States Attorney's Office +Southern District of New York +One St. Andrew's Plaza +New York, New York 10007 + +Tel: \ No newline at end of file diff --git a/marker2/ds9/EFTA00087723/EFTA00087723.metadata.json b/marker2/ds9/EFTA00087723/EFTA00087723.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..2d1cdcb6c9c035378b098b00eb2a150e9a8811a8 --- /dev/null +++ b/marker2/ds9/EFTA00087723/EFTA00087723.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087723.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 1570, + "elapsed_seconds": 7.03, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 63 + ], + [ + "Text", + 58 + ], + [ + "Line", + 32 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 3 + ], + [ + "Line", + 2 + ], + [ + "Text", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087723" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087725/EFTA00087725.md b/marker2/ds9/EFTA00087725/EFTA00087725.md new file mode 100644 index 0000000000000000000000000000000000000000..8e3a2df41c4389a784a72e32591de3272cbd50e7 --- /dev/null +++ b/marker2/ds9/EFTA00087725/EFTA00087725.md @@ -0,0 +1,69 @@ +**From:** "[REDACTED]" <[REDACTED]> +**To:** "[REDACTED] (USANYS)" <[REDACTED]>, "[REDACTED] (NY) (FBI)" <[REDACTED]>, "[REDACTED] (NY) (FBI)" <[REDACTED]> +**Cc:** "[REDACTED]" <[REDACTED]> + +**Subject:** [EXTERNAL] Re: GM - Witnesses + +**Date:** Wed, 06 Oct 2021 19:42:26 +0000 + +--- + +Is [REDACTED] testifying as a custodian for a particular company/organization? + +**Detective** [REDACTED] +**NYPD / FBI** +**Child Exploitation Human Trafficking Task Force** +**Office:** [REDACTED] + +--- + +**From:** [REDACTED] (USANYS) <[REDACTED]> +**Sent:** Wednesday, October 6, 2021 3:33 PM +**To:** [REDACTED] <[REDACTED]>; [REDACTED] (NY) (FBI) <[REDACTED]>; [REDACTED] (NY) (FBI) <[REDACTED]> +**Cc:** [REDACTED] <[REDACTED]> +**Subject:** RE: GM - Witnesses + +Thanks so much, [REDACTED]! I don't have other info on [REDACTED]. Here is [REDACTED] current address and number: + +[REDACTED], [REDACTED] +[REDACTED] + +--- + +**From:** [REDACTED] <[REDACTED]> +**Sent:** Wednesday, October 6, 2021 2:28 PM +**To:** [REDACTED] (USANYS) <[REDACTED]>; [REDACTED] (NY) (FBI) <[REDACTED]>; [REDACTED] (NY) (FBI) <[REDACTED]> +**Cc:** [REDACTED] <[REDACTED]> +**Subject:** [EXTERNAL] Re: GM - Witnesses + +Hey guys, + +Can you provide us with a little more information on the following witnesses. DOB's would be great or approximate age but if not maybe who they are, why they are testifying, city or state they are from? [REDACTED] is attached to this email, and she is assisting us with doing all the checks for the witnesses. + +Thanks! + +1. [REDACTED] +2. [REDACTED] + +**Detective** [REDACTED] +**NYPD / FBI** +**Child Exploitation Human Trafficking Task Force** +**Office:** [REDACTED] + +--- + +To: (NY) (FBI) •t > + +Cc: + +Subject: GM - Witnesses + +## CAUTION! EXTERNAL SENDER + +STOP WHEN UNSURE. Never click on links or open attachments if sender is unknown, and never provide user ID or password. Suspicious? Please report to this email address: reportphishing@gypd.org + +Below is the list of potential testifying witnesses as discussed. Please run rap sheets as discussed. Do you think you could get them to us by Wednesday or Thursday? Call if you have any questions, thanks! + +1 + +Assistant United States Attorney United States Attorney's Office Southern District of New York One St. Andrew's Plaza New York, New York 10007 Tel: \ No newline at end of file diff --git a/marker2/ds9/EFTA00087725/EFTA00087725.metadata.json b/marker2/ds9/EFTA00087725/EFTA00087725.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..97c25c8d2d3492ddec15ab321e3629679ace4ab3 --- /dev/null +++ b/marker2/ds9/EFTA00087725/EFTA00087725.metadata.json @@ -0,0 +1,120 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087725.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2309, + "elapsed_seconds": 6.73, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "CAUTION! EXTERNAL SENDER", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 229.5, + 125.55000000000001 + ], + [ + 382.0681457519531, + 125.55000000000001 + ], + [ + 382.0681457519531, + 138.83416748046875 + ], + [ + 229.5, + 138.83416748046875 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 101 + ], + [ + "Line", + 43 + ], + [ + "Text", + 40 + ], + [ + "ListGroup", + 2 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 41 + ], + [ + "Line", + 19 + ], + [ + "Text", + 9 + ], + [ + "SectionHeader", + 1 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087725" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087727/EFTA00087727.md b/marker2/ds9/EFTA00087727/EFTA00087727.md new file mode 100644 index 0000000000000000000000000000000000000000..e235ac107641b3af2d06683f18babf0e09d822ce --- /dev/null +++ b/marker2/ds9/EFTA00087727/EFTA00087727.md @@ -0,0 +1,789 @@ +## United States v. Ghislaine Maxwell 20 Cr. 330 INN/ Testifying Witness 3500 Material 10/25/2021 + +| | Date | Description | Attorney Produced to Defense | +|----------|------------|-----------------------|------------------------------| +| | 2021.02.01 | Notes from phone cal | 2021.04.23 | +| 3502402 | 202102 01 | Testimony disclosure | 2021.04.23 | +| 3502-003 | 2021.03.03 | Notes from phone cal | 2021.04.23 | +| 3502404 | 2021.04.09 | Interview notes | 2021.04.23 | +| 3502405 | 2021.04.21 | | 2021.04.23 | +| | | S e | | +| 3502-006 | | some | 2021.04.23 | +| 3502-007 | | Contract for services | 2021.04.23 | +| 3502-008 | 2021.10.21 | Notes | 2021.10.25 | +| 3502-009 | 2021.10.24 | Notes | 2021.10.25 | +| 3502-010 | 2006 | Article | 2021.10.25 | +| 3502-011 | 2009 | Article | 2021.10.25 | +| 3502-012 | 2010 | Article | 2021.10.25 | +| 3502-013 | 2014 | Article | 2021.10.25 | +| 3502-014 | 2015 | Article | 2021.10.25 | +| 3502-015 | 2015 | Article | 2021.10.25 | +| 3502-016 | 2015 | Article | 2021.10.25 | +| 3502-017 | 2016 | Article | 2021.10.25 | +| 3502-018 | 2017 | Article | 2021.10.25 | +| 3502-019 | 2018 | Article | 2021.10.25 | +| 3502-020 | 2018 | Article | 2021.10.25 | +| 3502-021 | 2019 | Article | 2021.10.25 | +| 3502-022 | 2020 | Article | 2021.10.25 | +| 3502-023 | 2021 | Article | 2021.10.25 | +| 3502-024 | 2021 | Article | 2022.10.25 | +| 3502025 | 2021.10.15 | Notes | 2021.10.25 | + +| 3503 | Date | Description | Attorney Produced to Defense | +|----------|------------|---------------------|------------------------------| +| 3501001 | | Curriculum vitae | 2021.09.15 | +| 3501002 | | 31E.NT-3027571 | 2021.10.11 | +| 3503-003 | 2021.08.25 | Notes | 2021.10.11 | +| 3503-006 | 2019.08.09 | Email | 2021.10.11 | +| 3503-005 | 2019.08.20 | Email | 2021.10.11 | +| 3503-006 | 2019.08.23 | Email | 2021.10.11 | +| 3503-007 | 2019.09.04 | Email | 2021.10.11 | +| 3503-008 | 2019.09.09 | Email | 2021.10.11 | +| 3503-009 | 2019.09.16 | Email | 2021.10.11 | +| 3503-010 | 2019.09.30 | Email | 2021.10.11 | +| 3501011 | 2019.10.21 | Email | 2021.10.11 | +| 3503-012 | 2019.11.12 | Email | 2021.10.11 | +| 3503-013 | 2020.02.10 | Email | 2021.10.11 | +| 3501014 | 2020.03.02 | Email | 2021.10.11 | +| 3503-015 | 2020.03.03 | Email | 2021.10.11 | +| 3503-016 | 2020.03.04 | Email | 2021.10.11 | +| 3503-017 | | Attachment to email | 2021.10.11 | +| 3503-018 | 2020.03.18 | Email | 2021.10.11 | +| 3503-019 | 2020.03.31 | Email | 2021.10.11 | +| 3503-020 | 2020.04.07 | Email | 2021.10.11 | +| 3503-021 | 2020.05.12 | Email | 2021.10.11 | +| 3503-022 | 2020.05.14 | Email | 2021.10.11 | +| 3503-023 | | Attachment to email | 2021.10.11 | +| 3503-024 | 2020.05.29 | Email | 2021.10.11 | +| 3503-025 | | Attachment to email | 2021.10.11 | +| 3503-026 | 2020.06.17 | Email | 2021.10.11 | +| 3501-027 | 2020.06.17 | Email | 2021.10.11 | +| 3503-028 | 2020.06.19 | Email | 2021.10.11 | +| 3503-029 | 2020.06.19 | Email | 2021.10.11 | +| 3503-030 | 2020.06.20 | Email | 2021.10.11 | +| 3503-031 | 2020.06.23 | Email | 2021.10.11 | +| 3503-032 | | Attachment to email | 2021.10.11 | +| 3503-033 | 2020.07.07 | Email | 2021.10.11 | +| 3503-034 | 2020.07.07 | Email | 2021.10.11 | +| 3503-035 | 2020.07.13 | Email | 2021.10.11 | +| 3503-036 | | Attachment to email | 2021.10.11 | +| 3503-037 | 2020.07.13 | Email | 2021.10.11 | +| 3503-038 | | Attachment to email | 2021.10.11 | +| 3503-039 | 2020.07.13 | Email | 2021.10.11 | +| 3503-040 | | Attachment to email | 2021.10.11 | +| 3503-041 | 2020.07.13 | Email | 2021.10.11 | +| 3503-042 | 2020.07.14 | Email | 2021.10.11 | +| 3503-043 | 2020.07.14 | Email | 2021.10.11 | +| 3503-044 | 2020.07.14 | Email | 2021.10.11 | +| 3503-045 | 2020.07.15 | Email | 2022.10.11 | + +| 3503-046 | 2020.07.15 | Email | 2021.10.11 | +|-----------|------------|---------------------|------------| +| 3503-047 | 2020.07.20 | Email | 2021.10.11 | +| 3503-048 | | Attachment to email | 2021.10.11 | +| 3503-049 | 2020.07.20 | Email | 2021.10.11 | +| 3503-050 | 2020.07.21 | Email | 2021.10.11 | +| 3503-051 | 2020.07.22 | Email | 2021.10.11 | +| 3503-052 | 2020.07.23 | Email | 2021.10.11 | +| 3503-053 | | Attachment to email | 2021.10.11 | +| 3503-054 | 2020.07.23 | Email | 2021.10.11 | +| 3503-055 | | Attachment to email | 2021.10.11 | +| 3503-056 | 2020.07.24 | Email | 2021.10.11 | +| 3503-057 | | Attachment to email | 2021.10.11 | +| 3503-058 | 2020.07.24 | Email | 2021.10.11 | +| 3503-059 | 2020.07.26 | Email | 2021.10.11 | +| 3503-060 | 2020.07.27 | Email | 2021.10.11 | +| 3503-061 | 2020.07.27 | Email | 2021.10.11 | +| 3503-062 | 2020.07.27 | Email | 2021.10.11 | +| 3503-063 | 2020.07.28 | Email | 2021.10.11 | +| 3503-064 | 2020.07.28 | Email | 2021.10.11 | +| 3503-065 | 2020.0803 | Email | 2021.10.11 | +| 3503-066 | 2020.0800 | Email | 2021.10.11 | +| 3503-067 | | Attachment to email | 2021.10.11 | +| 3503-068 | 2020.0806 | Email | 2021.10.11 | +| 3503-069 | 2020.0819 | Email | 2021.10.11 | +| 3503-070 | 2020.10.02 | Email | 2021.10.11 | +| 3503-071 | | Attachment to email | 2021.10.11 | +| 3503-072 | | Attachment to email | 2021.10.11 | +| 3503-073 | 2020.10.05 | Email | 2021.10.11 | +| 3503-074 | 2020.10.08 | Email | 2021.10.11 | +| 3503-075 | 2020.10.08 | Email | 2021.10.11 | +| 3503-076 | 2020.10.09 | Email | 2021.10.11 | +| 3503-077 | 2020.10.09 | Email | 2021.10.11 | +| 3503-078 | 2020.10.12 | Email | 2021.10.11 | +| 3503-079 | 2020.10.13 | Email | 2021.10.11 | +| 3503-080 | 2020.10.14 | Email | 2021.10.11 | +| 3503-081 | 2020.10.15 | Email | 2021.10.11 | +| 3503-082 | 2020.10.15 | Email | 2021.10.11 | +| 3503-0/13 | 2020.10.16 | Email | 2021.10.11 | +| 3503-084 | 2020.10.16 | Email | 2021.10.11 | +| 3503-085 | 2020.10.19 | Email | 2021.10.11 | +| 3503-086 | 2020.10.19 | Email | 2021.10.11 | +| 3503-087 | 2020.10.20 | Email | 2021.10.11 | +| 3503-0/18 | 2020.10.21 | Email | 2021.10.11 | +| 3503-089 | 2020.10.21 | Email | 2021.10.11 | +| 3503-090 | 2020.10.23 | Email | 2021.10.11 | +| 3503-091 | 2020.10.26 | Email | 2021.10.11 | +| 3503-092 | | Attachment to email | 2021.10.11 | +| 3503-093 | 2020.10.26 | Email | 2021.10.11 | +| 3503-094 | | Attachment to email | 2021.10.11 | +| 3503-095 | 2020.10.26 | Email | 2021.10.11 | +| 3503-096 | | Attachment to email | 2021.10.11 | +| 3503-097 | 2020.10.26 | Email | 2021.10.11 | +| 3503-098 | | Attachment to email | 2021.10.11 | +| 3503-099 | | Attachment to email | 2021.10.11 | +| 3503-100 | | Attachment to email | 2021.10.11 | +| 3503-101 | | Attachment to email | 2021.10.11 | +| 3503-102 | 2020.10.26 | Email | 2021.10.11 | +| 3503-103 | | Attachment to email | 2021.10.11 | +| 3503-104 | | Attachment to email | 2021.10.11 | +| 3503-105 | 2020.10.27 | Email | 2021.10.11 | +| 3503-106 | 2020.10.27 | Email | 2021.10.11 | +| 3503-107 | 2020.10.29 | Email | 2021.10.11 | +| 3503-108 | 2021.04.30 | Email | 2021.10.11 | + +| 3504 | | | | +|----------|------------|--------------------------|------------------------------| +| | Dote | Desalption | Attorney Produced to Defense | +| 3504 001 | 2003.10.05 | Palm Beach Police Report | 2021.10 11 | +| 3504-002 | 2003.10.05 | Palm Beach Police Report | 2011.10.11 | +| 3504-003 | 2005.11.09 | Palm Beach Police Report | 2021.10.11 | +| 3504-004 | 2005.11.10 | Palm Beach Police Report | 2021.10.11 | +| 3504-005 | 2005.11.10 | PBPD recording | 2021.10.11 | +| 3504-006 | 2005.11.10 | Letter | 2021.10.11 | +| 3504-007 | 2005.11.17 | Driver information | 2021.10.11 | +| 3504-008 | 2005.11.21 | Police Report | 2021.10.11 | +| 3504-009 | 2005.11.21 | worn statement | 2021.10.11 | +| 3504-010 | 2005.11.21 | worn statement | 2021.10.11 | +| 3504-011 | 2005.11.21 | worn statement | 2021.10.11 | +| 3504-012 | 2006.05.01 | a m ac Police Report | 2021.10.11 | +| 3504-013 | 2006.05.01 | Palm Beach Police Report | 2021.10.11 | + +| 3504.014 | 2006.05.01 | Palm 8each Police Report | | +|----------|------------|--------------------------|------------| +| 3504.015 | 2006.08.26 | Palm 8each Police Report | 2021.10.11 | +| 3504.016 | 2006.10.20 | Memorandum | 2021.10.11 | +| 3504.017 | 2006.12.04 | Driver Information | 2021.10.11 | +| 3504.018 | 2006.12.04 | Criminal history check | 2021.10.11 | +| 3504.019 | 2007.02.01 | Letter | 2021.10.11 | +| 3504420 | 2007.12.11 | Letter | 2021.10.11 | +| 3504421 | 2009.09.08 | Deposition, Volume I | 2021.10.11 | +| 3504422 | 2009.09.08 | Deposition, Volume II | 2021.10.11 | +| 3504423 | 2016.06.01 | Deposition Celli:lit 1 | 2021.10.11 | +| 3504424 | 2016.06.01 | Deposition Celli:4e 2 | 2021.10.11 | +| 3504425 | 2016.06.01 | Deposition Exhibit 3 | 2021.10.11 | +| 3504426 | 2016.06.01 | Deposition Eldalit 4 | 2021.10.11 | +| 3504.027 | 2016.06.01 | Deposition ExhbitS | 2021.10.11 | +| 3504028 | 2016.06.01 | Deposition EXhilit 6 | 2021.10.11 | +| 3504029 | 2016.06.01 | Deposition EXhiSit 7 | 2021.10.11 | +| 3504030 | 2016.06.01 | Deposition transcript | 2021.10.11 | +| 3504031 | 2016.09.15 | Sworn Affidavit | 2021.10.11 | +| 3504032 | 2019.07.13 | Interview 302 | 2021.10.11 | +| 3504033 | 2019.07.13 | Notes | 2021.10.11 | +| 3504034 | 2020.02.19 | Interview 302 | 2021.20.11 | +| 3504035 | 2020.02.19 | Notes | 2021.10.11 | +| 3504036 | 2020.06.28 | Grand jury transcript | 2021.20.11 | +| 3504037 | 2020.09.28 | Notes | 2021.10.11 | +| 3504038 | 2021.03.29 | Grand jury transcript | 2021.10.11 | +| 3504039 | 2021.06.08 | Notes | 2021.10.11 | +| 3504040 | 2021.06.24 | Notes | 2021.10.11 | +| 3504.041 | 2021.07.14 | Notes | 2021.10.11 | +| 3504042 | | Criminal history check | 2021.10.11 | +| 3504043 | | Criminal history check | 2021.10.11 | + +| 2021.10.11 | +|-------------------| +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | + +| 3305 | Date | Desaiption | Attorney Produced to Defense | +|----------|------------|-------------------------|------------------------------| +| 3505001 | 2006.12.14 | Driver information | 2021.10.11 | +| 3505002 | 2007.05.08 | Transcript | 2021.10.11 | +| 3505003 | 2007.06.07 | Letter | 2021.10.11 | +| 3505.004 | 2007.07.03 | Driver information | 2021.10.11 | +| 3505005 | 2007.08.07 | Interview 302 | 2021.10.11 | +| 3505006 | 2007.08.07 | Notes | 2021.10.11 | +| 3505007 | 2007.08.07 | Property receipt | 2021.10.11 | +| 3505008 | 2007.08.28 | Oecbration | 2021.10.11 | +| 3505009 | 2007.09.07 | Driver Information | 2021.10.11 | +| 3505010 | 2007.09.07 | Criminal history check | 2021.10.11 | +| 3505011 | 2007.09.07 | Driver reformation | 2021.10.11 | +| 3505012 | 2007.09.07 | Criminal history check | 2021.10.11 | +| 3505013 | 2007.09.07 | Criminal history check | 2021.10.11 | +| 3505014 | 2007.09.07 | Search records | 2021.10.11 | +| 3505015 | 2007.09.07 | Criminal history check | 2021.10.11 | +| 3505016 | 2007.09.07 | Criminal history cheds | 2021.10.11 | +| 3505017 | 2008.01.10 | Letter | 2021.10.11 | +| 3505018 | 2008.03.18 | Transcript | 2021.10.11 | +| 3505019 | 2008.06.19 | Starr submission to DAG | 2021.10.11 | +| 3505020 | 2008.06.30 | Letter | 2021.10.11 | +| 3505021 | 2008.07.10 | Letter | 2021.10.11 | +| 3505022 | 2008.07.10 | Letter | 2021.10.11 | +| 3505023 | 2008.09.02 | Letter | 2021.10.11 | +| 3505024 | 2008.12.05 | Letter | 2021.10.11 | +| 3505025 | 2009.02.09 | Complaint | 2021.10.11 | +| 3505026 | 2009.02.13 | Plaintiff respome | 2021.10.11 | +| 3505027 | 2009.03.23 | Plaintiff notice | 2021.10.11 | +| 3505028 | 2009.06.17 | Letter | 2021.10.11 | +| 3505029 | 2009.06.17 | Letter | 2021.10.11 | +| 3505030 | 2009.08.13 | Transcript | 2021.10.11 | +| 3505031 | 2009.08.31 | Transcript | 2021.10.11 | +| 3505032 | 2009.08.31 | Summary report | 2021.10.11 | +| 3505033 | 2009.09.10 | Medical records | 2021.10.11 | +| 3505-034 | 2009.10.20 | Ctuestionaire | 2021.10.11 | +| 3505035 | 2009.10.21 | Transcript | 2021.10.11 | +| 3505036 | 2009.10.21 | Medical examination | 2021.10.11 | +| 3505037 | 2009.10.24 | Notes | 2021.10.11 | +| 3505038 | 2009.11.06 | Plaintiffs Notice | 2021.10.11 | +| 3505039 | 2009.11.09 | Medical records | 2021.10.11 | +| 3505040 | 2009.11.13 | Medical report | 2021.10.11 | +| 3505041 | 2009.12.02 | Plaintiffs Notice | 2021.10.11 | +| 3505042 | 2009.12.03 | Response | 2021.10.11 | +| 3505043 | 2009.12.04 | Deposition | 2021.10.11 | +| 3505044 | 2009.12.04 | Deposition | 2021.10.11 | +| 3505045 | 2009.12.04 | Deposition EXhitit | 2021.10.11 | +| 3505.046 | 2009.12.04 | Deposition Exhibit | 2021.10.11 | + +| 3505-047 | 2009.12.04 | Deposition Exhibit | 2021.10.11 | +|----------|------------|------------------------------|------------| +| 3505.048 | 2009.12.09 | Notes | 2021.10.11 | +| 3505.049 | 2009.12.18 | Settlement Resolution Notice | 2021.10.11 | +| 3505.050 | 2010.10.14 | Arrest report | 2021.10.11 | +| 3505.051 | 2011.03.12 | FBI Report | 2021.10.11 | +| 3505.052 | 2011.03.12 | FBI Report | 2021.10.11 | +| 3505-053 | 2011.04.20 | Arrest report | 2021.10.11 | +| 3505-054 | 2011.11.16 | Arrest report | 2021.10.11 | +| 3505-055 | 2012.02.28 | Arrest report | 2021.10.11 | +| 3505-056 | 2012.09.30 | Arrest report | 2021.10.11 | +| 3505057 | 2013.03.07 | Arrest report | 2021.10.11 | +| 3505-058 | 2014.02.26 | Transcript | 2021.10.11 | +| 3505.059 | 2019.03.19 | Interview 302 | 2021.10.11 | +| 3505-060 | 2019.03.19 | Notes | 2021.10.11 | +| 3505.061 | 2019.07.23 | Email | 2021.10.11 | +| 3505.062 | 2019.08.07 | Ema4 | 2021.10.11 | +| 3505.063 | 2019.08.23 | Emasl | 2021.10.11 | +| 3505-064 | 2020.02.25 | Ems] | 2021.10.11 | +| 3505.065 | 2020.03.10 | Emasl | 2021.10.11 | +| 3505-066 | 2020.07.07 | Ems] | 2021.10.11 | +| 3505-067 | 2020.07.16 | Email | 2021.10.11 | +| 3505-068 | 2020.07.17 | Interview 302 | 2021.10.11 | +| 3505-069 | 2020.07.17 | Notes | 2021.10.11 | +| 3505-070 | 2020.07.17 | Email | 2021.10.11 | +| 3505-071 | | Attachment to email | 2021.10.11 | +| 3505-072 | | Attachment to email | 2021.10.11 | +| 3505-073 | 2020.08.11 | Notes | 2021.10.11 | +| 3505-074 | 2020.08.11 | Interview 302 | 2021.10.11 | +| 3505-075 | 2020.08.11 | Notes | 2021.10.11 | +| 3505.076 | 2021.01.19 | Interview 302 | 2021.10.11 | +| 3505.077 | 2021.01.19 | Notes | 2021.10.11 | +| 3505.078 | 2021.01.20 | Criminal history check | 2021.10.11 | +| 3505-079 | 2021.01.20 | Interview 302 | 2021.10.11 | +| 3505-080 | 2021.01.20 | Notes | 2021.10.11 | +| 3505-081 | 2021.01.21 | Interview 302 | 2021.10.11 | +| 3505.082 | 2021.01.21 | Notes | 2021.10.11 | +| 3505.083 | 2021.01.21 | Exhibit to notes | 2021.10.11 | +| 3505084 | 2021.01.28 | Ems | 2021.10.11 | +| 3505085 | 2021.03.29 | Grand Jury presentation | 2021.10.11 | +| 3505-086 | 2021.03.29 | Transcript | 2021.10.11 | +| 3505.087 | 2021.04.18 | Ems | 2021.10.11 | +| 3505-088 | 2021.06.07 | Notes | 2021.10.11 | +| 3505.089 | 2021.06.09 | Notes | 2021.10.11 | +| 3505.090 | 2021.06.23 | Notes | 2021.10.11 | +| 3505.091 | 2021.06.24 | Notes | 2021.10.11 | +| 3505-092 | 2021.07.13 | Notes | 2021.10.11 | +| 3505-093 | 2021.08.16 | Notes | 2021.10.11 | +| 3505-094 | 2021.08.19 | Email | 2021.10.11 | +| 3505-095 | 2021.08.19 | Text message | 2021.10.11 | +| 3505-096 | 2021.08.19 | Text message | 2021.10.11 | +| 3505-097 | 2021.08.26 | Notes | 2021.10.11 | +| 3505-098 | | Notes | 2021.10.11 | +| 3505-099 | | Notes | 2021.10.11 | +| 3505-100 | | Answers to Interrogatories | 2021.10.11 | +| 3505401 | | Criminal history check | 2021.10.11 | +| 3505-102 | | Criminal history check | 2021.10.11 | +| 3505-103 | | PlainUffsRmponw | 2021.10.11 | +| 3505404 | | Plaintiffs Notice | 2021.10.11 | +| 3505105 | | Photographs | 2021.10.11 | +| 3505-106 | | Answers to Interrogatories | 2021.10.11 | +| 3505-107 | | Criminal history check | 2021.10.11 | + +| 2021.10.11 | +|------------| +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | + +| | Date | Description | Attorney Produced to Defense | +|----------|------------|------------------------|------------------------------| +| allIM | 2009.11.06 | Deposition transcript | 2021.10.11 | +| 3505002 | 2021.06.23 | Interview 302 | 2021.10.11 | +| 3505-003 | 2021.06.23 | Exhibit to notes | 2021.10.11 | +| 3505-00S | 2021.06.23 | Notes | 2021.10.11 | +| 3505-005 | 2021.07.13 | Notes | 2021.10.11 | +| 3505-006 | 2021.07.15 | Notes | 2021.10.11 | +| 3505-007 | 2021.08.24 | Text messages | 2021.10.11 | +| 3505-008 | 2021.08.24 | Text messages | 2021.10.11 | +| 3505-009 | 2021.08.27 | Notes | 2021.10.11 | +| 3505-010 | | Criminal history check | 2021.10.11 | +| 3505-011 | | Criminal history check | 2021.10.11 | +| 3505-012 | | Criminal history check | 2021.10.11 | +| 3505-013 | | Criminal history check | 2021.10.11 | +| 3505-014 | | Text messages | 2021.10.11 | + +| 3507 3507001 | Date 2006.01.11 | Description Memorandum | Attorney Produced to Defense 2021 10 11 | +|--------------|-----------------|--------------------------|-----------------------------------------| +| 1507002 | 2006.07.13 | Palm Beach Police Report | 2021.10.11 | +| 3507-003 | 2006.12.04 | Criminal history check | 2021.10.11 | +| 3507-004 | 2007.01.11 | Interview 302 | 2021.10.11 | +| 3507-005 | 2007.01.19 | Memorandum | 2021.10.11 | +| 3507-006 | 2007.02.02 | Interview 302 | 2021.10.11 | +| 3507-007 | 2007.02.02 | Notes | 2021.10.11 | +| 3507-008 | 2007.02.02 | Exhibit to notes | 2021.10.11 | +| 3507-009 | 2007.05.22 | Transcript | 2021.10.11 | +| 3507-010 | 2007.07.30 | Declaration | 2021.10.11 | +| 3507-011 | 2010.02.16 | Transcript | 2021.10.11 | +| 3507-012 | 2021.09.27 | Interview 302 | 2021.10.11 | +| 3507-013 | 2021.09.27 | Notes | 2021.10.11 | +| 3507-014 | | Criminal history check | 2021.10.11 | +| 3507-015 | | Criminal history check | 2021.10.11 | + +| a | Data | Description | ADemry Produced to Defense | +|----------|------------|---------------|----------------------------| +| | 2021.09.02 | Interview 302 | 2021.10.11 | +| 3508-002 | 2021.09.02 | Notes | 2021.10.11 | +| 3508-003 | 2021.10.18 | Notes | 1021.10.25 | + +| Date | Description | Attorney | Produced to Defense | +|----------|-------------|---------------|---------------------| +| 3509-001 | 2019.09.19 | Interview 302 | 2021.10.11 | +| 3509-002 | 2019.09.19 | Notes | 2021.10.11 | +| 3509-003 | 2019.11.14 | Interview 302 | 2021.10.11 | +| 3509-004 | 2019.11.14 | Notes | 2021.10.11 | +| 3509-005 | 2019.12.17 | Interview 302 | 2021.10.11 | +| 3509-006 | 2019.12.17 | Notes | 2021.10.11 | +| 3509-007 | 2020.01.17 | Complaint | 2021.10.11 | +| 3509-008 | 2020.02.27 | Interview 302 | 2021.10.11 | +| 3509-009 | 2020.02.27 | Notes | 2021.10.11 | +| 3509-010 | 2020.03.20 | Email | 2021.10.11 | +| 3509-011 | 2020.04.03 | Notes | 2021.10.11 | +| 3509-012 | 2020.06.03 | Email | 2021.10.11 | +| 3509-013 | 2020.06.08 | Email | 2021.10.11 | +| 3509-014 | 2020.06.08 | Email | 2021.10.11 | +| 3509-015 | 2020.06.26 | Email | 2021.10.11 | +| 3509-016 | 2020.06.28 | Transcript | 2021.10.11 | +| 3509-017 | 2020.07.12 | Email | 2021.10.11 | +| 3509-018 | 2020.08.03 | Email | 2021.10.11 | +| 3509-019 | 2020.08.03 | Email | 2021.10.11 | +| 3509-020 | 2021.03.23 | Interview 302 | 2021.10.11 | +| 3509-021 | 2021.03.23 | Notes | 2021.10.11 | +| 3509-022 | 2021.08.17 | Notes | 2021.10.11 | +| 3509-023 | 2021.09.02 | Interview 302 | 2021.10.11 | +| 3509-024 | 2021.09.02 | Notes | 2021.10.11 | +| 3509-025 | 2021.09.14 | Notes | 2021.10.11 | +| 3509-026 | 2021.10.21 | Notes | 2021.10.11 | +| 3509-027 | | Text messages | 2021.10.11 | +| 3509-028 | 2021.10.13 | Notes | 2021.10.25 | +| 3509-029 | 2021.10.14 | Notes | 2021.10.25 | + +| | Date | Desolation | Attorney Produced to Defense | +|----------|------------|----------------------|------------------------------| +| | 2020.01.14 | Interview 302 | 2021.10.11 | +| 3510402 | 2020.01.14 | Notes | 2021.10.11 | +| 3510-003 | 2020.06.28 | Grand iury transtrut | 2021.10.11 | +| 3510.006 | 2021.05.03 | Notes | 1021.10.11 | +| 3510.005 | 2021.08.30 | Interview 302 | 1021.10.11 | +| 3510.006 | 2021.08.30 | Notes | 1021.10.11 | +| 3510.007 | 2021.08.31 | Interview 302 | 2021.10.11 | +| 3510.008 | 2021.08.31 | Notes | 2021.10.11 | +| 3510-009 | 2021.09.01 | Text messages | 2021.10.11 | +| 3510.010 | | Text messages | 2021.10.11 | +| 3510-011 | | Text messages | 2021.10.11 | + +| 3511 —MIIII | Data | Description | Attorney Produced to Defense | +|-------------|------------|---------------------|------------------------------| +| | 2021.07.30 | Email | 2021.10.11 | +| 3511-002 | 2021.08.05 | Email | 2021.10.11 | +| 3511-003 | | Attachment to email | 2021.10.11 | + +| 3512 | Date | Description | Attorney | Produced to Defense | +|----------|------------|--------------------------|----------|---------------------| +| 3512-001 | 2003.10.15 | Palm Beach Police Report | | 2021.10.11 | + +| 3512-002 | | Palm Beath Po= ce firport | 2021.10.11 | +|----------|------------|---------------------------|------------| +| 3512.003 | | Palm Beath Po' ce Rcport | 2021.10.11 | +| 3512.004 | 2021.05.19 | Notes | 2021.10.11 | +| 3512.005 | 2021.06.08 | Notes | 2021.10.11 | +| 3512.006 | 2021.07.13 | Notes | 2011.10.11 | + +| a 3513-001 3513-002 3513-003 3513-004 3513-00S 3513-006 3513-007 3513-008 | Date 1995.11.07 2019.08.27 2019.08.27 2019.08.27 2019.09.19 2019.09.19 2019.09.20 2019.10.03 | Description Letter Interview 302 Notes Transcript Interview 302 Notes Email FBI Report | Attorney Produced to Defense 2021.10.11 2021.10.11 2021.10.11 2021.10.11 2021.10.11 2021.10.11 2021.10.11 2021.10.11 | +|---------------------------------------------------------------------------|----------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------| +| 3513.009 | 2019.12.15 | Intenekw 302 | 2021.10.11 | +| 3513-010 | 2019.12.15 | Notes | 2021.10.11 | +| 3513.011 | 2019.12.15 | Exhibit to Notes | 2021.10.11 | +| 3513-012 | 2019.12.15 | Exhibit to Notes | 2021.10.11 | +| 3513-013 | 2019.12.15 | Exhibit to Notes | 2021.10.11 | +| 3513-014 | 2019.12.15 | Exhibit to Notes | 2021.10.11 | +| 3513-015 | 2019.12.15 | Exhibit to Notes | 2021.10.11 | +| 3513-016 | 2019.12.15 | Exhibit to Notes | 2021.10.11 | +| 3513-017 | 2019.12.15 | Exhibit to Notes | 2021.10.11 | +| 3513-018 | 2019.12.15 | Exhibit to Notes | 2021.10.11 | +| 3513-019 | 2019.12.15 | Exhibit to Notes | 2021.10.11 | +| 3513-020 | 2019.12.15 | Exhibit to Notes | 2021.10.11 | +| 3513-021 | 2019.12.15 | Exhibit to Notes | 2021.10.11 | +| 3513-022 | 2019.12.27 | Email | 2021.10.11 | +| 3513-023 | 2019.12.28 | Email | 2021.10.11 | +| 3513-024 | 2020.06.28 | Transcript | 2021.10.11 | +| 3511-02S | 2020.07.13 | Letter | 2021.10.11 | +| 3511-026 | 2020.07.14 | Email | 2021.10.11 | +| 3513-027 | 2020.07.14 | Transcript | 2021.10.11 | +| 3511-028 | 2020.12.15 | Email | 2021.10.11 | +| 3513-029 | 2021.03.29 | Transcript | 2021.10.11 | +| 3511-030 | 2021.06.30 | Criminal historyreport | 2021.10.11 | +| 3511-011 | 2021.07.27 | Interview 302 | 2021.10.11 | +| 3511-032 | 2021.07.27 | Notes | 2021.10.11 | +| 3513-033 | 2021.07.28 | Notes | 2021.10.11 | +| 3511-034 | 2021.07.29 | Notes | 2021.10.11 | +| 3511-035 | 2021.08.24 | Notes | 2021.10.11 | +| 3511-036 | 2021.08.24 | Email | 2021.10.11 | +| 3511-037 | 2021.09.01 | Interview 302 | 2021.10.11 | +| 3513-038 | 2021.09.01 | Notes | 2021.10.11 | +| 3511-039 | 2021.09.01 | Exhibit to Notes | 2021.10.11 | +| 3513-000 | 2021.09.02 | Naes | 2021.10.11 | +| 3511-001 | 2021.09.02 | Interview 302 | 2021.10.11 | +| 3513-002 | 2021.09.02 | Exhibit to Notes | 2021.10.11 | +| 3513-003 | 2021.09.02 | Exhibit to Notes | 2021.10.11 | +| 3513.014 | 2021.09.02 | Exhibit to Notes | 2021.10.11 | +| 3513-005 | 2021.09.03 | Notes | 2021.10.11 | +| 3513-046 | 2021.10.06 | Criminal historyreport | 2021.10.11 | +| 3513-007 | | NYS OVS Application | 2021.10.11 | +| 3513-008 | | NYS OVS Application | 2021.10.11 | +| 3513-009 | | NYS OVS Application | 2021.10.11 | +| 3511-050 | | Text messages | 2021.10.11 | +| 3511-051 | | Text messages | 2021.10.11 | +| 3511-052 | | Text messages | 2021.10.11 | +| 3513-053 | 2019.09.05 | Email | 2021.10.25 | +| 3513-054 | | Attachment to email | 2021.10.25 | +| 3513-055 | 2019.10.03 | Email | 2021.10.25 | +| 3513-056 | 2019.10.03 | Email | 2021.10.25 | +| 3513-057 | 2019.10.04 | Email | 2021.10.25 | +| 3513-058 | 2019.10.15 | Email | 2021.10.25 | +| 3513-059 | 2021.10.24 | Notes | 2021.10.25 | + +| 3514 | Date | Description | Attorney Produced to Defense | +|----------|------------|---------------|------------------------------| +| 3510.001 | 1006.11.15 | Interview 302 | 2021.10.11 | +| 3510.002 | 2006.11.15 | Naes | 2021.10.11 | +| 3510.003 | 2007.07.30 | Dedaration | 2021.10.11 | +| 3510.004 | 2019.07.15 | Transcript | 2021.10.11 | +| 3510.005 | 2019.08.27 | Transcript | 2021.10.11 | +| 3510.006 | 2019.09.28 | Interview 302 | 2021.10.11 | +| 3510.007 | 2019.09.28 | Notes | 2021.10.11 | +| 3510.008 | 2019.09.29 | Email | 2021.10.11 | + +| 3514-009 | 2019.09.29 | Email | 2021.10.11 | +|----------|------------|-------------------------|-----------------| +| 3514-010 | 2019.10.28 | Email | 2021.10.11 | +| 3514-011 | 2019.11.12 | Complaint | 2021.10.11 | +| 3514-012 | 2020.05.09 | Notes | 2021.10.11 | +| 3514-013 | 2020.06.28 | Transcript | 2021.10.11 | +| 3514-014 | 2020.07.14 | Transcript | 2021.10.11 | +| 3514-015 | 2020.12.15 | Email | 2021.10.11 | +| 3514-016 | 2020.12.15 | Letter | 2021.10.11 | +| 3514-017 | 2021.03.29 | Transcript | 2021.10.11 | +| 3514-018 | 2021.05.11 | FBI Report | 2021.10.11 | +| 3514-019 | 2021.06.29 | FBI Report | 2021.10.11 | +| 3514-020 | 2021.06.29 | FBI Report | 2021.10.11 | +| 3514-021 | 2021.06.30 | Criminal history report | 2021.10.11 | +| 3514-022 | 2021.06.30 | Criminal history report | 2021.10.11 | +| 3514-023 | 2021.07.26 | Interview 302 | 2021.10.11 | +| 3514-024 | 2021.07.26 | Notes | 2021.10.11 | +| 3514-025 | 2021.07.29 | Notes | 2021.10.11 | +| 3514-026 | 2021.09.17 | Interview 302 | 2021.10.11 | +| 3514-027 | 2021.09.17 | Notes | 2021.10.11 | +| 3514-028 | 2021.09.17 | Exhibit to notes | 2021.10.11 | +| 3514-029 | 2021.09.17 | Exhibit to notes | 2021.10.11 | +| 3514-030 | 2021.09.18 | Notes | 2021.10.11 | +| 3514-031 | | Photographs | 2021.10.11 | +| 3514-032 | | Photographs | 2021.10.11 | +| 3514-033 | | Photographs | 2021.10.11 | +| 3514-034 | | Photographs | 2021.10.11 | +| 3514-035 | | Photographs | 2021.10.11 | +| 3514-036 | | Photographs | 2021.10.11 | +| 3514-037 | | Photographs | 2021.10.11 | +| 3514-038 | | Photographs | 2021.10.11 | +| 3514-039 | | Photographs | 2021.10.11 | +| 3514-040 | 2019.10.15 | Email | 2021.10.11 | +| 3514-041 | | Photograph | 2021.10.11 | +| 3514-042 | 2008.03.17 | Search Warrant | 2021.10.11 | +| 3514-043 | 2008.03.17 | Search Warrant | 2021.10.11 | +| | | | Sigrid McCawley | + +| 2021.10.11 | +|------------| +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | + +| 3115 | Date | Description | Attorney Produced to Defense | +|-----------|------------|---------------|------------------------------| +| | 2020.08.24 | Interview 302 | 2021.10.11 | +| 3515-002 | 2020.08.24 | Notes | 2021.10.11 | +| 3515-003 | 2021.05.06 | Notes | 2021.10.11 | +| 3515-00.4 | | Text messages | 2021.10.11 | +| 3515-005 | | Text messages | 2021.10.11 | +| 3515-006 | | Text messages | 2021.10.11 | + +| all= 3516-001 3516-002 3516-003 3516-004. 3516-005 3516-006 3516-007 3516-008 3516-009 3516-010 | Date Description 2020.12.18 Interview 302 2021.01.13 Interview 302 2021.01.13 Notes 2021.03.29 Transcript 2021.06.07 Notes 2021.06.22 Notes 2021.07.12 Notes 2021.07.16 Email 2021.07.16 Email Criminal history report | Attorney Produced tO Defense 2021.10.11 2021.10.11 2021.10.11 2021.10.11 2021.10.11 2021.10.11 2021.10.11 2021.10.11 2021.10.11 2021.10.11 | +|-------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------| +| 3516.011 | Criminal history report | 2021.10.11 | +| 3516.012 | Criminal history | 2021.10.11 | +| 3516.013 | Criminal history report | 2021.10.11 | +| 3516014 | Search records | 2021.10.11 | +| 3516-015 | Criminal history report | 2021.10.11 | + +| 3517 | Date | Description | Attorney Produced to Defense | +|----------|------------|-------------------------|------------------------------| +| 3517.031 | 2006.08.17 | Crimisal history report | 2021.10.11 | +| 3517-002 | 2006.08.17 | Interview 302 | 2021.10.11 | +| 3517-003 | 2006.08.17 | Exhibit to 302 | 2021.10.11 | +| 3517-004 | 2021.06.30 | Interview 302 | 2021.10.11 | +| 3517-005 | 2021.06.30 | Notes | 2021.10.11 | +| 3517-006 | 2021.06.30 | Exhibit to notes | 2021.10.11 | +| 3517-007 | 2021.07.14 | Notes | 2021.10.11 | +| 3517-008 | | Text messages | 2021.10.11 | +| 3517009 | | Notes | 2011.10.11 | + +| SO W | | | | | | +|----------|------------|-------|-------------|----------|---------------------| +| | Deb | | Description | Attorney | Produced to Defense | +| 3518-001 | 2019.09.16 | Notes | | | 2021.10.11 | +| 3518-002 | 2021.09.24 | Notes | | | 2021.10.11 | + +| 3518-003 | 2021.09.27 | Notes | 2021.10.11 | +|----------|------------|---------------------|------------| +| 3518004 | 2021.09.27 | Email | 2021.10.11 | +| 3518-005 | | Attachment to Email | 2021.10.11 | +| 3518-006 | | Attachment to Email | 2021.10.11 | +| 3518-007 | | Attachment to Email | 2021.10.11 | +| 3518008 | | Attachment to Email | 2021.10.11 | +| 3518-009 | | Attachment to Email | 2021.10.11 | +| 3518010 | | Voicemail | 2021.10.11 | +| 3518-011 | | Voicemail | 1021.10.11 | + +| | Date | | Description | Attorney | Produced to Defense | +|----------|------------|-----------------------|-------------|----------|---------------------| +| 3519-001 | 2021.04.26 | Notes | | | 2021.10.11 | +| 3519-002 | | Criminal histcrycheds | | | 2021.10.11 | + +| .3 025. | | | | +|----------|------------|-----------------|------------------------------| +| | Date | Description | Attorney Produced to Defense | +| | 2019.07.06 | F& 302 | 2021.10.11 | +| 3520-002 | 2019.07.06 | Text message | 2021.10.11 | +| 3520-003 | 2019.07.06 | Text message | 2021.10.11 | +| 3520-006 | 2019.07.06 | Text message | 2021.10.11 | +| 3520-005 | 2019.07.11 | FBI 302 | 2021.10.11 | +| 3520-006 | 2019.07.11 | FBI 302 | 2021.10.11 | +| 3520-007 | 2019.07.12 | FBI 302 | 2021.10.11 | +| 3520-008 | 2019.07.15 | Email | 2021.10.11 | +| 3520-009 | 2019.07.15 | Email | 2021.10.11 | +| 3520-010 | 2019.07.31 | FBI 302 | 2021.10.11 | +| 3520-011 | 2019.08.02 | FBI 302 | 2021.10.11 | +| 3520-012 | 2019.08.02 | Email | 2021.10.11 | +| 3520-013 | 2019.08.13 | Notes and email | 2021.10.11 | +| 3520-014 | 2019.09.17 | Email | 2021.10.11 | +| 3520-015 | 2020.05.22 | Email | 2021.10.11 | +| 3520-016 | 2021.04.29 | Notes | 2021.10.11 | +| 3520-017 | 2021.06.10 | Email | 2021.10.11 | +| 3520-018 | | Notes | 2011.10.11 | + +| | Date | | Description | Attorney | Produced to Defense | +|----------|------------|---------|-------------|----------|---------------------| +| 3521-001 | 2021.01.29 | FBI 302 | | | 2021.10.11 | +| 3521-002 | 2021.01.29 | Notes | | | 2021.10.11 | + +| Date | Description | Attorney | Produced to Defense | +|----------|-------------|-------------------------------------|---------------------| +| 3522-001 | 2003.10.05 | Palm Beach Police Department report | 2021.10.11 | +| 3522-002 | 2005.09.23 | Palm Beach Police Department report | 2021.10.11 | +| 3522-003 | 2005.11.07 | Palm Beach Police Department report | 2021.10.11 | +| 3522-004 | 2006.09.29 | Grand Jury records | 2021.10.11 | +| 3522-005 | 2021.05.09 | Email | 2021.10.11 | +| 3522-006 | 2021.05.20 | Notes | 2021.10.11 | +| 3522-007 | 2021.06.08 | Notes | 2021.10.11 | +| 3522-008 | 2021.07.15 | Notes | 2021.10.11 | +| 3522-009 | | Voicemail | 2021.10.11 | + +| | Date | Description | Attorney Produced to Defense | +|----------|------------|-------------------------------------|------------------------------| +| 3521001 | 2006.01.27 | T-Molele records | 2021.10.11 | +| 3521002 | 2006.01.30 | Driver .formation | 2021.10.11 | +| 3523-003 | 2006.02.13 | Palm Beach Police Department report | 2021.10.11 | +| 3523-004 | 2006.08.15 | FBI 302 | 2021.10.11 | +| 3523-005 | 2006.08.15 | Notes | 2021.10.11 | +| 3523-006 | 2016.06.03 | Deposition transcript | 2021.10.11 | +| 3523-007 | 2016.06.03 | Deposition exhibit | 2021.10.11 | +| 3523-008 | 2016.06.03 | Deposition exhibit | 2021.10.11 | +| 3523-009 | 2016.06.03 | Deposition exhibit | 2021.10.11 | +| 3523-010 | 2016.06.03 | Deposition exhibit | 2021.10.11 | +| 3523-011 | 2016.06.03 | Deposition exhibit | 2021.10.11 | +| 3523-012 | 2016.06.03 | Deposition exhibit | 2021.10.11 | +| 3523-013 | 2016.06.03 | Deposition exhibit | 2021.10.11 | +| 3523-014 | 2016.06.03 | Deposition exhibit | 2021.10.11 | +| 3523-015 | 2016.06.03 | Deposition exhibit | 2021.10.11 | +| 3523-016 | 2019.07.06 | FBI 302 | 2021.10.11 | +| 3523-017 | 2020.02.07 | Proffer agreement | 2021.10.11 | +| 3523-018 | 2020.02.07 | FBI 302 | 2021.10.11 | +| 3523-019 | 2020.02.07 | Notes | 2021.10.11 | +| 3523-020 | 2020.06.28 | Grand jury transcript | 2021.10.11 | +| 3523-021 | 2020.07.17 | Declaration | 2021.10.11 | +| 3523-022 | 2021.03.29 | Grand jury transcript | 2021.10.11 | +| 3523-023 | 2021.07.30 | Notes | 2021.10.11 | +| 3523-024 | 2021.08.17 | Notes | 2021.10.11 | + +| 3523-025 | 2021.08.18 | Notes | | 2021.10.11 | +|----------|------------|------------|-----------------|------------| +| 3523-026 | | Flight lop | | 2021.10.11 | +| 3523-027 | | Flight lop | | 2021.10.11 | +| 3523-028 | | Notes | | 2021.10.11 | +| 3523-029 | | Notes | Brendan Quigley | 2021.10.11 | + +| 2021.10.11 | +|------------| +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | +| 2021.10.11 | + +| _MilillMil 3524-002 | Date 1006.08.01 2006.12.04 | Desaiptlon Records search Records search | Attorney Produced to Defense 2021.10.11 2021.10.11 | +|---------------------|----------------------------|------------------------------------------|----------------------------------------------------| +| 3524.003 | 2007.01.23 | W2 | 2021.10.11 | +| 3524-004 | 2007.02.14 | Letter | 2021.10.11 | +| 3524-005 | 2007.05.23 | Employment 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Produced to Defense | +|----------|------------|-------------|----------|---------------------| +| 3525-001 | 2021.09.21 | Notes | | 2021.10.11 | +| 3525-002 | 2021.09.21 | Email | | 2021.10.11 | +| 3525-003 | 2021.09.21 | Voicemail | | 2021.10.11 | + +| | Date | Description | Attorney Produced to Defense | +|----------|------------|-------------|------------------------------| +| 3526-001 | 2021 09.22 | Notes | 2021.10.11 | +| 3526-002 | 2021 09.22 | Notes | 2021.10.11 | + +| 3517 3527 002 3527-003 | Date 2006.11.27 2006.11.27 2009.10.15 | Description FBI 302 W2 Depasition transcript | Attorney Produced to Defense 2021.10.11 2021.10.11 2021.10.11 | +|------------------------|---------------------------------------|----------------------------------------------|---------------------------------------------------------------| +| 3527.004 | 2019.07.09 | FBI 302 | 2021.10.11 | +| 3527-005 | 2020.10.07 | FBI 302 | 2021.10.11 | +| 3527006 | 2020.10.07 | Notes | 2021.10.11 | +| 3527-007 | 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Mollo Building One Saint Andrew's Plaza New York, New York 10007 + +October 26, 2021 + +## BY ECF + +The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 + +Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +Dear Judge Nathan: + +The Government respectfully submits this letter in response to the Court's Order dated October 22, 2021, attaching the Court's draft preliminary remarks to be recorded and played before each questionnaire session and directing the parties to suggest any proposed edits by letter. (Dkt. No. 366). The Government has no objection to the Court's proposed remarks. However, the Government seeks clarification from the Court of the following line in the Court's draft remarks: "Throughout the selection process and if you are selected as a juror, although the lawyers and I will know your names, we will only refer to you in Court by your juror number." (Id. at 3). In particular, the Government respectfully requests that the Court clarify for the parties when during the July selection process that the parties will be provided with the names of prospective jurors. + +The Government understands that during the jury selection process, prospective jurors will only be referred to in open court by their juror numbers. The Government seeks confirmation that, consistent with the practice in other high profile cases in this District using jury questionnaires, the parties will be provided the prospective jurors' names no earlier than November 16, 2021, the day that oral voir dire begins. See, e.g., United States v. Skelos, 15 Cr. 317 (KMW); United States + +v. Kaloyeros, et at, 16 Cr. 776 (VEC); United States v. Percoco, et at, 16 Cr. 776 (VEC); cf. Oct. 12, 2021 Tr. at 7:14-8:1, United States v. Parnas, 19 Cr. 725 (JPO) (denying defense's request for a second day of jury selection to allow time for background research on potential jurors; no juror questionnaire used). Here, the time between the administration of the jury questionnaire, oral voir dire, and the start of trial is significantly more extended in light of, among other things, COVID-19 precautions. + +As the Court has noted, the purpose of the jury questionnaire process is to streamline challenges for cause. Juror identities are not necessary for that process. The Government submits that having identifying information for jurors for weeks in advance of selection would be unusual, and is not necessary, because "the purpose of the voir dire is to ascertain disqualifications, not to afford individual analysis in depth to permit a party to choose a jury that fits into some mold that he believes appropriate for his case." United States v. Barnes, 604 F.2d 121, 138 (2d Cir. 1979) (citations omitted). For similar reasons, the Government respectfully requests that peremptory challenges be exercised at the conclusion of voir dire and not on November 29, 2021, the day that trial is scheduled to commence. + +Accordingly, the Government respectfully requests that the Court clarify for the parties when during the jury selection process the parties will be provided with the names of prospective jurors. + +Respectfully submitted, + +DAMIAN WILLIAMS United States Attorney + +By: s/ + +Assistant United States Attorneys Southern District of New York + +Cc: Defense Counsel (By ECF) \ No newline at end of file diff --git a/marker2/ds9/EFTA00087736/EFTA00087736.metadata.json b/marker2/ds9/EFTA00087736/EFTA00087736.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..19a0e6e852c7a2f327b4bc5cd21456fb2cb91a8c --- /dev/null +++ b/marker2/ds9/EFTA00087736/EFTA00087736.metadata.json @@ -0,0 +1,179 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087736.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 3464, + "elapsed_seconds": 0.69, + "image_assets": [ + "_page_0_Picture_0.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "U.S. Department of Justice", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 319.464, + 25.11 + ], + [ + 463.7979431152344, + 25.11 + ], + [ + 463.7979431152344, + 40.0670166015625 + ], + [ + 319.464, + 40.0670166015625 + ] + ] + }, + { + "title": "BY ECF", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 69.156, + 168.48 + ], + [ + 119.39903259277344, + 168.48 + ], + [ + 119.39903259277344, + 182.5670166015625 + ], + [ + 69.156, + 182.5670166015625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 61 + ], + [ + "Line", + 31 + ], + [ + "Text", + 8 + ], + [ + "SectionHeader", + 2 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 38 + ], + [ + "Line", + 20 + ], + [ + "Text", + 3 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 17 + ], + [ + "Line", + 9 + ], + [ + "Text", + 5 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087736" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087736/_page_0_Picture_0.jpeg b/marker2/ds9/EFTA00087736/_page_0_Picture_0.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..99e8b574107eb66d40364c7519a345440634774c --- /dev/null +++ b/marker2/ds9/EFTA00087736/_page_0_Picture_0.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:80c7c0f51f1d8cd2eff02bcdc09463948795225afef32f1099b9da9746b344a5 +size 3526 diff --git a/marker2/ds9/EFTA00087739/EFTA00087739.md b/marker2/ds9/EFTA00087739/EFTA00087739.md new file mode 100644 index 0000000000000000000000000000000000000000..12211b53ade34a04d243da082d759dbf2d821780 --- /dev/null +++ b/marker2/ds9/EFTA00087739/EFTA00087739.md @@ -0,0 +1,21 @@ +| From: | "[REDACTED]" < [REDACTED] > | +|---------------------|------------------------------------------------------------------------------| +| To: | "[REDACTED] (USANYS)" < [REDACTED] >, "[REDACTED] (NY) (FBI)" < [REDACTED] > | +| Cc: | "[REDACTED]" < [REDACTED] > | +| Subject: | [EXTERNAL] Re: [REDACTED] Interview | +| Date: | Tue, 26 Oct 2021 18:31:18 +0000 | +| Attachments: | [REDACTED] | + +Detective NYPD / FBI Child E loitation Human Trafficking Task Force Ofice: + +From: (USANYS) Sent: Saturday, October 23, 2021 2:42 PM To: Cc: Subject: • Interview (NY) (FBI) + +## CAUTION! EXTERNAL SENDER + +STOP WHEN UNSURE. Never click on links or open attachments if sender is unknown, and never provide user ID or password. Suspicious? Please report to this email address: reportphishing@nypd.org + +HIM, Can you please send us the notes for the email (and the 302 as soon as it is ready)? + +Thanks, Lara + +Assistant United States Attorney United States Attorney's Office Southern District of New York Tel \ No newline at end of file diff --git a/marker2/ds9/EFTA00087739/EFTA00087739.metadata.json b/marker2/ds9/EFTA00087739/EFTA00087739.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..428b44030d9f48b5b81fc5cb4c6f211525315e27 --- /dev/null +++ b/marker2/ds9/EFTA00087739/EFTA00087739.metadata.json @@ -0,0 +1,86 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087739.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1321, + "elapsed_seconds": 1.37, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "CAUTION! EXTERNAL SENDER", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 212.97599999999997, + 385.55999999999995 + ], + [ + 399.67523193359375, + 385.55999999999995 + ], + [ + 399.67523193359375, + 399.6035461425781 + ], + [ + 212.97599999999997, + 399.6035461425781 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 63 + ], + [ + "Line", + 30 + ], + [ + "Text", + 6 + ], + [ + "Table", + 1 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087739" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087740/EFTA00087740.md b/marker2/ds9/EFTA00087740/EFTA00087740.md new file mode 100644 index 0000000000000000000000000000000000000000..0a667c327ad6ea43cadcc0ebcc2aed1c83f4c783 --- /dev/null +++ b/marker2/ds9/EFTA00087740/EFTA00087740.md @@ -0,0 +1,13 @@ +To: + +Cc: :Mr (USANYS)" + +Subject: black book + +Date: Tue, 26 Oct 2021 20:45:28 +0000 + +Attachments: Pages\_from\_Epstein\_Blackbook\_OCR.pdf + +Could you please scan this page from the original black book and send it to us? + +Thanks! \ No newline at end of file diff --git a/marker2/ds9/EFTA00087740/EFTA00087740.metadata.json b/marker2/ds9/EFTA00087740/EFTA00087740.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..83a11097c4c56e7a9b4e730dfcf70837c4c82ff6 --- /dev/null +++ b/marker2/ds9/EFTA00087740/EFTA00087740.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087740.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 227, + "elapsed_seconds": 0.5, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 19 + ], + [ + "Line", + 10 + ], + [ + "Text", + 9 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087740" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087741/EFTA00087741.md b/marker2/ds9/EFTA00087741/EFTA00087741.md new file mode 100644 index 0000000000000000000000000000000000000000..237a8cace2c5d9391b6854d57fa8fa440ef4d273 --- /dev/null +++ b/marker2/ds9/EFTA00087741/EFTA00087741.md @@ -0,0 +1,43 @@ +From: ' To: Cc: USANYS)" < >, (USANYS)" USANYS " + +Subject: FW: U.S. v. Maxwell, Case No. 20 Cr. 330 (AN) [Ms. Maxwell's Fed. R. Evid. 412 Motion] + +Date: Thu, 28 Oct 2021 04:14:11 +0000 + +Attachments: Ms. Maxwell's FRE 412 Motion.zip + +Inline-Images: image001.jpg + +Hi Chiefs, + +And here is the defense 412 motion. Our response is due Monday, and any hearing is tentatively set for November 5. + +Thanks, + +From: Nicole Simmons + +Sent: Wednesday, October 27, 2021 11:57 PM + +To: 'Nathan NYSD Chambers' • + +Cc: Jeff Pagliuca a Laura Menninger •ca + +(USANYS) + +Subject: [EXTERNAL] U.S. v. Maxwell, Case No. 20 Cr. 330 (AJN) [Ms. Maxwell's Fed. R. Evid. 412 Motion) + +Dear Judge Nathan: + +At the request of Jeffrey Pagliuca, please see attached Ms. Maxwell's Fed. R. Evid. 412 Motion and supporting documents. + +Regards, + +Nicole Simmons + +![](_page_0_Picture_18.jpeg) + +Nicole Simmons Haddon. Morgan and Foreman P.C. + +Denver, Colorado 80203 + +www hmllow com \ No newline at end of file diff --git a/marker2/ds9/EFTA00087741/EFTA00087741.metadata.json b/marker2/ds9/EFTA00087741/EFTA00087741.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..431160530e79ec389484863247da7963adef8c4e --- /dev/null +++ b/marker2/ds9/EFTA00087741/EFTA00087741.metadata.json @@ -0,0 +1,60 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087741.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 935, + "elapsed_seconds": 1.03, + "image_assets": [ + "_page_0_Picture_18.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 61 + ], + [ + "Line", + 31 + ], + [ + "Text", + 21 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087741" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087741/_page_0_Picture_18.jpeg b/marker2/ds9/EFTA00087741/_page_0_Picture_18.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..1de7fc9233bc1d5dac9d7a09a3766b0ba81c4392 --- /dev/null +++ b/marker2/ds9/EFTA00087741/_page_0_Picture_18.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:03d3d7b5aa1485ad1fc90984ce24285c6fd14cf460a1e2cc9ec854f6512725c9 +size 4311 diff --git a/marker2/ds9/EFTA00087742/EFTA00087742.md b/marker2/ds9/EFTA00087742/EFTA00087742.md new file mode 100644 index 0000000000000000000000000000000000000000..6748a432939a33068ec192346a9f60e4314106bc --- /dev/null +++ b/marker2/ds9/EFTA00087742/EFTA00087742.md @@ -0,0 +1,223 @@ +UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +x UNITED STATES OF AMERICA SUPERSEDING INDICTMENT S1 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x + +#### COUNT ONE (Conspiracy to Entice Minors to Travel to Engage in Illegal Sex Acts) + +The Grand Jury charges: + +#### OVERVIEW + +1. The charges set forth herein stem from the role of GHISLAINE MAXWELL, the defendant, in the sexual exploitation and abuse of multiple minor girls by Jeffrey Epstein. In particular, from at least in or about 1994, up to and including at least in or about 1997, MAXWELL assisted, facilitated, and contributed to Jeffrey Epstein's abuse of minor girls by, among other things, helping Epstein to recruit, groom, and ultimately abuse victims known to MAXWELL and Epstein to be under the age of 18. The victims were as young as 14 years old when they were groomed and abused by MAXWELL and Epstein, both of whom knew that certain victims were in fact under the age of 18. + +2. As a part and in furtherance of their scheme to abuse minor victims, GHISLAINE MAXWELL, the defendant, and Jeffrey Epstein enticed and caused minor victims to travel to + +Epstein's residences in different states, which MAXWELL knew and intended would result in their grooming for and subjection to sexual abuse. Moreover, in an effort to conceal her crimes, MAXWELL repeatedly lied when questioned about her conduct, including in relation to some of the minor victims described herein, when providing testimony under oath in 2016. + +# FACTUAL BACKGROUND + +3. During the time periods charged in this Indictment, GHISLAINE MAXWELL, the defendant, had a personal and professional relationship with Jeffrey Epstein and was among his closest associates. In particular, between in or about 1994 and in or about 1997, MAXWELL was in an intimate relationship with Epstein and also was paid by Epstein to manage his various properties. Over the course of their relationship, MAXWELL and Epstein were photographed together on multiple occasions, including in the below image: + +![](_page_1_Picture_4.jpeg) + +4. Beginning in at least 1994, GHISLAINE MAXWELL, the defendant, enticed and groomed multiple minor girls to engage in sex acts with Jeffrey Epstein, through a variety of means and methods, including but not limited to the following: + +a. MAXWELL first attempted to befriend some of Epstein's minor victims prior to their abuse, including by asking the victims about their lives, their schools, and their families. MAXWELL and Epstein would spend time building friendships with minor victims by, for example, taking minor victims to the movies or shopping. Some of these outings would involve MAXWELL and Epstein spending time together with a minor victim, while some would involve MAXWELL or Epstein spending time alone with a minor victim. + +b. Having developed a rapport with a victim, MAXWELL would try to normalize sexual abuse for a minor victim by, among other things, discussing sexual topics, undressing in front of the victim, being present when a minor victim was undressed, and/or being present for sex acts involving the minor victim and Epstein. + +c. MAXWELL'S presence during minor victims' interactions with Epstein, including interactions where the minor victim was undressed or that involved sex acts with Epstein, helped put the victims at ease because an adult woman . was present. For example, in some instances, MAXWELL would + +massage Epstein in front of a minor victim. In other instances, MAXWELL encouraged minor victims to provide massages to Epstein, including sexualized massages during which a minor victim would be fully or partially nude. Many of those massages resulted in Epstein sexually abusing the minor victims. + +d. In addition, Epstein offered to help some minor victims by paying for travel and/or educational opportunities, and MAXWELL encouraged certain victims to accept Epstein's assistance. As a result, victims were made to feel indebted and believed that MAXWELL and Epstein were trying to help them. + +e. Through this process, MAXWELL and Epstein enticed victims to engage in sexual activity with Epstein. In some instances, MAXWELL was present for and participated in the sexual abuse of minor victims. Some such incidents occurred in the context of massages, which developed into sexual encounters. + +5. GHISLAINE MAXWELL, the defendant, facilitated Jeffrey Epstein's access to minor victims knowing that he had a sexual preference for underage girls and that he intended to engage in sexual activity with those victims. Epstein's resulting abuse of minor victims included, among other things, touching a victim's breast, touching a victim's genitals, placing a sex toy such as a vibrator on a victim's genitals, + +directing a victim to touch Epstein while he masturbated, and directing a victim to touch Epstein's genitals. + +#### MAXWELL AND EPSTEIN'S VICTIMS + +6. Between approximately in or about 1994 and in or about 1997, GHISLAINE MAXWELL, the defendant, facilitated Jeffrey Epstein's access to minor victims by, among other things, inducing and enticing, and aiding and abetting the inducement and enticement of, multiple minor victims. Victims were groomed and/or abused at multiple locations, including the following: + +a. A a multi-story private residence on the Upper East Side of Manhattan, New York owned by Epstein (the "New York Residence"), which is depicted in the following photograph: + +![](_page_4_Picture_5.jpeg) + +b. An estate in Palm Beach, Florida owned by Epstein (the "Palm Beach Residence"), which is depicted in the following photograph: + +![](_page_5_Picture_2.jpeg) + +c. A ranch in Santa Fe, New Mexico owned by Epstein (the "New Mexico Residence"), which is depicted in the following photograph: + +![](_page_5_Picture_4.jpeg) + +d. MAXWELL's personal residence in London, England. + +7. Among the victims induced or enticed by GHISLAINE MAXWELL, the defendant, were minor victims identified herein as Minor Victim-1, Minor Victim-2, and Minor Victim-3. In particular, and during time periods relevant to this Indictment, MAXWELL engaged in the following acts, among others, with respect to minor victims: + +a. MAXWELL met Minor Victim-1 when Minor Victim-I was approximately 14 years old. MAXWELL subsequently interacted with Minor Victim-1 on multiple occasions at Epstein's residences, knowing that Minor Victim-1 was under the age of 18 at the time. During these interactions, which took place between approximately 1994 and 1997, MAXWELL groomed Minor Victim-1 to engage in sexual acts with Epstein through multiple means. First, MAXWELL and Epstein attempted to befriend Minor Victim-1, taking her to the movies and on shopping trips. MAXWELL also asked Minor Victim-1 about school, her classes, her family, and other aspects of her life. MAXWELL then sought to normalize inappropriate and abusive conduct by, among other things, undressing in front of Minor Victim-1 and being present when Minor Victim-1 undressed in front of Epstein. Within the first year after MAXWELL and Epstein met Minor Victim-1, Epstein began sexually abusing Minor Victim-1. MAXWELL was present for + +and involved in some of this abuse. In particular, MAXWELL involved Minor Victim-1 in group sexualized massages of Epstein. During those group sexualized massages, MAXWELL and/or Minor Victim-1 would engage in sex acts with Epstein. Epstein and MAXWELL both encouraged Minor Victim-1 to travel to Epstein's residences in both New York and Florida. As a result, Minor Victim-1 was sexually abused by Epstein in both New York and Florida. Minor Victim-1 was enticed to travel across state lines for the purpose of sexual encounters with Epstein, and MAXWELL was aware that Epstein engaged in sexual activity with Minor Victim-1 after Minor-Victim-1 traveled to Epstein's properties, including in the context of a sexualized massage. + +b. MAXWELL interacted with Minor Victim-2 on at least one occasion in or about 1996 at Epstein's residence in New Mexico when Minor Victim-2 was under the age of 18. Minor Victim-2 had flown into New Mexico from out of state at Epstein's invitation for the purpose of being groomed for and/or subjected to acts of sexual abuse. MAXWELL knew that Minor Victim-2 was under the age of 18 at the time. While in New Mexico, MAXWELL and Epstein took Minor Victim-2 to a movie and MAXWELL took Minor Victim-2 shopping. MAXWELL also discussed Minor Victim-2's school, classes, and family with Minor Victim-2. In New Mexico, MAXWELL began her efforts to groom Minor Victim-2 for abuse by Epstein by, among other things, providing + +an unsolicited massage to Minor Victim-2, during which Minor Victim-2 was topless. MAXWELL also encouraged Minor Victim-2 to massage Epstein. + +c. MAXWELL groomed and befriended Minor Victim-3 in London, England between approximately 1994 and 1995, including during a period of time in which MAXWELL knew that Minor Victim-3 was under the age of 18. Among other things, MAXWELL discussed Minor Victim-3's life and family with Minor Victim-3. MAXWELL introduced Minor Victim-3 to Epstein and arranged for multiple interactions between Minor Victim-3 and Epstein. During those interactions, MAXWELL encouraged Minor Victim-3 to massage Epstein, knowing that Epstein would engage in sex acts with Minor Victim-3 during those massages. Minor Victim-3 provided Epstein with the requested massages, and during those massages, Epstein sexually abused Minor Victim-3. MAXWELL was aware that Epstein engaged in sexual activity with Minor Victim-3 on multiple occasions, including at times when Minor Victim-3 was under the age of 18, including in the context of a sexualized massage. + +# MAXWELL'S EFFORTS TO CONCEAL HER CONDUCT + +8. In or around 2016, in the context of a deposition as part of civil litigation, GHISLAINE MAXWELL, the defendant, repeatedly provided false and perjurious statements, under oath, regarding, among other subjects, her role in facilitating the + +abuse of minor victims by Jeffrey Epstein, including some of the specific events and acts of abuse detailed above. + +#### STATUTORY ALLEGATIONS + +9. From at least in or about 1994, up to and including in or about 1997, in the Southern District of New York and elsewhere, GHISLAINE MAXWELL, the defendant, Jeffrey Epstein, and others known and unknown, willfully and knowingly did combine, conspire, confederate, and agree together and with each other to commit an offense against the United States, to wit, enticement, in violation of Title 18, United States Code, Section 2422. + +10. It was a part and object of the conspiracy that GHISLAINE MAXWELL, the defendant, Jeffrey Epstein, and others known and unknown, would and did knowingly persuade, induce, entice, and coerce one and more individuals to travel in interstate and foreign commerce, to engage in sexual activity for which a person can be charged with a criminal offense, in violation of Title 18, United States Code, Section 2422. + +#### Overt Acts + +11. In furtherance of the conspiracy and to effect the illegal object thereof, the following overt acts, among others, were committed in the Southern District of New York and elsewhere: + +a. Between in or about 1994 and in or about 1997, when Minor Victim-1 was under the age of 18, MAXWELL participated in multiple group sexual encounters with Epstein and Minor Victim-1 in New York and Florida. + +b. In or about 1996, when Minor Victim-1 was under the age of 18, Minor Victim-1 was enticed to travel from Florida to New York for purposes of sexually abusing her at the New York Residence, in violation of New York Penal Law, Section 130.55. + +c. In or about 1996, when Minor Victim-2 was under the age of 18, MAXWELL provided Minor Victim-2 with an unsolicited massage in New Mexico, during which Minor Victim-2 was topless. + +d. Between in or about 1994 and in or about 1995, when Minor Victim-3 was under the age of 18, MAXWELL encouraged Minor Victim-3 to provide massages to Epstein in London, England, knowing that Epstein intended to sexually abuse Minor Victim-3 during those massages. + +(Title 18, United States Code, Section 371.) + +# COUNT TWO (Enticement of a Minor to Travel to Engage in Illegal Sex Acts) + +The Grand Jury further charges: + +12. The allegations contained in paragraphs 1 through 8 of this Indictment are repeated and realleged as if fully set forth within. + +13. From at least in or about 1994, up to and including in or about 1997, in the Southern District of New York and elsewhere, GHISLAINE MAXWELL, the defendant, knowingly did persuade, induce, entice, and coerce an individual to travel in interstate and foreign commerce to engage in sexual activity for which a person can be charged with a criminal offense, and attempted to do the same, and aided and abetted the same, to wit, MAXWELL persuaded, induced, enticed, and coerced Minor Victim-1 to travel from Florida to New York, New York on multiple occasions with the intention that Minor Victim-1 would engage in one or more sex acts with Jeffrey Epstein, in violation of New York Penal Law, Section 130.55. + +(Title 18, United States Code, Sections 2422 and 2.) + +## COUNT THREE (Conspiracy to Transport Minors with Intent to Engage in Criminal Sexual Activity) + +The Grand Jury further charges: + +14. The allegations contained in paragraphs 1 through 8 of this Indictment are repeated and realleged as if fully set forth within. + +15. From at least in or about 1994, up to and including in or about 1997, in the Southern District of New York and elsewhere, GHISLAINE MAXWELL, the defendant, Jeffrey Epstein, and others known and unknown, willfully and knowingly did combine, conspire, confederate, and agree together and with each other to commit an offense against the United States, to + +wit, transportation of minors, in violation of Title 18, United States Code, Section 2423(a). + +16. It was a part and object of the conspiracy that GHISLAINE MAXWELL, the defendant, Jeffrey Epstein, and others known and unknown, would and did, knowingly transport an individual who had not attained the age of 18 in interstate and foreign commerce, with intent that the individual engage in sexual activity for which a person can be charged with a criminal offense, in violation of Title 18, United States Code, Section 2423(a). + +# Overt Acts + +17. In furtherance of the conspiracy and to effect the illegal object thereof, the following overt acts, among others, were committed in the Southern District of New York and elsewhere: + +a. Between in or about 1994 and in or about 1997, when Minor Victim-1 was under the age of 18, MAXWELL participated in multiple group sexual encounters with EPSTEIN and Minor Victim-1 in New York and Florida. + +b. In or about 1996, when Minor Victim-1 was under the age of 18, Minor Victim-1 was enticed to travel from Florida to New York for purposes of sexually abusing her at the New York Residence, in violation of New York Penal Law, Section 130.55. + +c. In or about 1996, when Minor Victim-2 was under the age of 18, MAXWELL provided Minor Victim-2 with an unsolicited massage in New Mexico, during which Minor Victim-2 was topless. + +d. Between in or about 1994 and in or about 1995, when Minor Victim-3 was under the age of 18, MAXWELL encouraged Minor Victim-3 to provide massages to Epstein in London, England, knowing that Epstein intended to sexually abuse Minor Victim-3 during those massages. + +(Title 18, United States Code, Section 371.) + +## COUNT FOUR (Transportation of a Minor with Intent to Engage in Criminal Sexual Activity) + +The Grand Jury further charges: + +18. The allegations contained in paragraphs 1 through 8 of this Indictment are repeated and realleged as if fully set forth within. + +19. From at least in or about 1994, up to and including in or about 1997, in the Southern District of New York and elsewhere, GHISLAINE MAXWELL, the defendant, knowingly did transport an individual who had not attained the age of 18 in interstate and foreign commerce, with the intent that the individual engage in sexual activity for which a person can be charged with a criminal offense, and attempted to do so, and + +aided and abetted the same, to wit, MAXWELL arranged for Minor Victim-1 to be transported from Florida to New York, New York on multiple occasions with the intention that Minor Victim-1 would engage in one or more sex acts with Jeffrey Epstein, in violation of New York Penal Law, Section 130.55. + +(Title 18, United States Code, Sections 2423(a) and 2.) + +# COUNT FIVE (Perjury) + +The Grand Jury further charges: + +20. The allegations contained in paragraphs 1 through 8 of this Indictment are repeated and realleged as if fully set forth within. + +21. On or about April 22, 2016, in the Southern District of New York, GHISLAINE MAXWELL, the defendant, having taken an oath to testify truthfully in a deposition in connection with a case then pending before the United States District Court for the Southern District of New York under docket number 15 Civ. 7433, knowingly made false material declarations, to wit, MAXWELL gave the following underlined false testimony: + +> Q. Did Jeffrey Epstein have a scheme to recruit underage girls for sexual massages? If you know. + +A. I don't know what you're talking about. + +- Q. List all the people under the age of 18 that you interacted with at any of Jeffrey's properties? +- A. I'm not aware of anybody that I interacted with, other than obviously [the plaintiff] who was 17 at this point. + +(Title 18, United States Code, Section 1623.) + +## COUNT SIX (Perjury) + +The Grand Jury further charges: + +22. The allegations contained in paragraphs 1 through 8 of this Indictment are repeated and realleged as if fully set forth within. + +23. On or about July 22, 2016, in the Southern District of New York, GHISLAINE MAXWELL, the defendant, having taken an oath to testify truthfully in a deposition in connection with a case then pending before the United States District Court for the Southern District of New York under docket number 15 Civ. 7433, knowingly made false material declarations, to wit, MAXWELL gave the following underlined false testimony: + +- Q: Were you aware of the presence of sex toys or devices used in sexual activities in Mr. Epstein's Palm Beach house? A: No, not that I recall. . . . Q• Do you know whether Mr. Epstein possessed sex toys or devices used in sexual activities? +- A. No. + +• • • + +- Q. Other than yourself and the blond and brunette that you have identified as having been involved in three-way sexual activities, with whom did Mr. Epstein have sexual activities? + +- A. I wasn't aware that he was having sexual activities with anyone when I was with him other than myself. + +- Q. I want to be sure that I'm clear. Is it your testimony that in the 1990s and 2000s, you were not aware that Mr. Epstein was having sexual activities with anyone other than yourself and the blond and brunette on those few occasions when they were involved with you? + +- A. That is my testimony, that is correct. + +• • • + +- Q. Is it your testimony that you've never given anybody a massage? + +- A. I have not given anyone a massage. + +Q• You never gave Mr. Epstein a massage, is that your testimony? + +- A. That is my testimony. + +Q• You never gave [Minor Victim-2] a massage is your testimony? + +- A. I never gave (Minor Victim-2] a massage. + +(Title 18, United States Code, Section 1623.) + +Zi Tte OF PERSON + +SA41'f AUDREY RAUSS Acting nited States Attorney Form No. USA-33s-274 (Ed. 9-25-58) + +# UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +## UNITED STATES OF AMERICA + +v . + +GHISLAINE MAXWELL, + +Defendant. + +# SUPERSEDING INDICTMENT + +S1 20 Cr. 330 (AJN) + +(18 U.S.C. §§ 371, 1623, 2422, 2423(a), and 2) + +AUDREY STRAUSS + +Acting United States Attorney + +Foreperson \ No newline at end of file diff --git a/marker2/ds9/EFTA00087742/EFTA00087742.metadata.json b/marker2/ds9/EFTA00087742/EFTA00087742.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..87f8f7f42b866ab3a1ffc3c3882cf9ad9e7f46ad --- /dev/null +++ b/marker2/ds9/EFTA00087742/EFTA00087742.metadata.json @@ -0,0 +1,1086 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087742.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", 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"preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 193, + "elapsed_seconds": 0.61, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 19 + ], + [ + "Text", + 12 + ], + [ + "Line", + 10 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087760" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087761/EFTA00087761.md b/marker2/ds9/EFTA00087761/EFTA00087761.md new file mode 100644 index 0000000000000000000000000000000000000000..14b7ab944d65af7a1957300c589d8cf02c752166 --- /dev/null +++ b/marker2/ds9/EFTA00087761/EFTA00087761.md @@ -0,0 +1,105 @@ +![](_page_0_Picture_0.jpeg) + +# U.S. Department of Justice + +United States Attorney Southern District of New York + +Tht Sill Ill .1 Molt, Budding + +October 7, 2020 + +# VIA ECF + +The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse + +Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +Dear Judge Nathan: + +The Government respectfully submits this letter to provide additional information in response to the Court's prior inquiry regarding the Government's plan to obtain and review other investigative files, created and maintained by other offices, which are related to the abovereferenced case. In particular, at the initial conference in this matter on July 14, 2020, the Court asked the Government about its plan to ensure timely review the files of other agencies for potential disclosures in this case and highlighted the Court's expectation that the Government would be thoughtful and probing in its assessment of such a review. Consistent with the Government's commitment to take a thorough and transparent approach to its disclosure obligations, this letter outlines the relevant investigative files of which the Government is currently aware and describes the Government's approach as to each. + +# I. Background Regarding the Government's Rule 16 Discovery Productions + +The charges in this case arise out of an investigation conducted by the United States Attorney's Office for the Southern District of New York ("USAO-SDNY"), the Federal Bureau of Investigation ("FBI") New York Office, and the New York Police Department (the "NYPD") (collectively, the "Prosecution Team"). That investigation was opened in 2018 and remains ongoing. The Government has copies of the full investigative files for this case from the USAO-SDNY, the FBI New York Office, and the NYPD (the "Prosecution Team Files"). The bulk of the productions to date have come from the Prosecution Team Files. The Government is continuing to review the Prosecution Team Files for any additional materials that warrant disclosure. + +Specifically, to date, the Government has produced approximately 328,863 pages of discovery to the defense in this case. Those materials include, among other things, photographs, documents seized during searches, search warrants, search warrant applications, financial records, travel records, property records, phone records, law enforcement reports, and other subpoena + +returns. The Government is continuing the process of reviewing and preparing productions of electronic discovery materials, which include extractions of data from numerous electronic devices. The Government expects that it will meet the November 9, 2020 deadline for the completion of electronic discovery productions. Additionally, the Government recognizes that its disclosure obligations are ongoing, and the Government will continue to review the Prosecution Team Files for any additional discoverable or exculpatory materials. In particular, the Government is aware of its obligations under Brady v. Maryland, 373 U.S. 83 (1963) and its progeny, and will promptly produce any exculpatory material of which it becomes aware. + +The Government's Rule 16 discovery productions do not include witness statements or material under Giglio v. United States, 405 U.S. 150 (1972) and its progeny, consistent with the common practice and law within this Circuit. As indicated in a prior letter, the Government intends to produce all such materials to the defense well in advance of trial.' Specifically, although the parties have not yet conferred regarding a schedule for disclosure of witness statements, the Government is prepared to produce all statements and impeachment material for witnesses it expects to call at trial as early as four weeks prior to trial. Additionally, the Government is prepared to produce any statements by witnesses who it does not expect to call at trial as early as eight weeks prior to trial, subject to restrictions to protect those individuals' privacy to be negotiated by the parties. + +# II. Applicable Law Governing Disclosure of Other Investigative Files + +The disclosure obligations set forth in Federal Rule of Criminal Procedure 16, Brady, and Giglio apply to materials in the Government's "possession." As a general matter, though "[a]n individual prosecutor is presumed ... to have knowledge of all information gathered in connection with his office's investigation of the case[,] . knowledge on the part of persons employed by a different office of the government does not in all instances warrant the imputation of knowledge to the prosecutor . ." United States v. Avellino, 136 F.3d 249, 255 (2d Cir. 1998) (citations omitted); see also United States v. Locascio, 6 F.3d 924, 948-49 (2d Cir. 1993) (declining to "infer the prosecutors' knowledge simply because some other government agents knew about" additional evidence where federal prosecutors were unaware of documents in possession of FBI agents who were "uninvolved in the investigation or trial of the defendants"); United States v. Quinn, 445 F.2d 940, 944 (2d Cir. 1971) (declining to impute knowledge of prosecutor in Florida to prosecutor in New York and noting that the "Department of Justice alone has thousands of employees"). The imposition of such "an unlimited duty on a prosecutor to inquire of other offices not working with the prosecutor's office on the case in question would inappropriately require [courts] to adopt `a monolithic view of government' that would `condemn the prosecution of criminal cases to a state of paralysis.'" Avellino, 136 F.3d at 255 (quoting United States v. Gambino, 835 F. Supp. 74, 95 (E.D.N.Y. 1993)). Thus, discovery and disclosure obligations only extend to "information known + +1 The Government recognizes that its Brady obligations include the disclosure of witness statements containing exculpatory information. To date, the Government is not aware of any exculpatory material contained in any witness statements, but it will continued to review its files, including witness statements, for such material. If the Government becomes aware of any Brady material from any source, it will promptly disclose such material to the defense. + +to persons who are a part of the `prosecution team' . . . who perform investigative duties or make strategic decisions about the prosecution of the case," including "police officers and federal agents who submit to the direction of the prosecutor and participate in the investigation." United States v. Barcelo, 628 F. App'x 36, 38 (2d Cir. 2015) (quoting United States v. Stewart, 433 F.3d 273, 298 (2d Cir. 2006)). + +In considering whether Rule 16 and Brady apply to records in the possession of another government agency, a prosecutor's duty extends to reviewing such evidence only where the Government conducts a loint investigation" with that agency or branch of government. See United States v. Middendorf, No. 18 Cr. 36 (JPO), 2018 WL 3956494, at \*4-.5 (S.D.N.Y. Aug. 17, 2018) (no joint investigation between Government, Public Company Accounting Oversight Board ("PCAOB") and Securities and Exchange Commission ("SEC") where PCAOB was not involved in witness interviews or developing prosecutorial strategy, and SEC was not involved in the grand jury presentation, reviewing the fruits of the Government's investigation, or developing prosecutorial strategy); United States v. Collins, 409 F. Supp. 3d 228, 241-43 (S.D.N.Y. 2019) (no joint investigation between U.S. Attorney's Office and SEC where the two entities conducted a small number of joint interviews and engaged in limited sharing of information with each other); United States v. Finnerty, 411 F. Supp. 2d 428, 433 (S.D.N.Y. 2006) (no joint investigation between Government and New York Stock Exchange ("NYSE") where documents sought were "the product of an investigation that was undertaken by the NYSE of its own practices, and there [wa]s no suggestion that the Government participated in that investigation"). + +Moreover, the involvement of agents from one component of an agency in an investigation does not render the entirety of that agency part of the prosecution team. See, e.g., United States v. Stein, 424 F. Supp. 2d 720, 723 (S.D.N.Y. 2006) ("While the prosecution's disclosure obligation in some circumstances may extend to materials beyond the knowledge of the individual prosecutors assigned to a case, it does not extend to the collective knowledge of the entire United States government or even to the entire government agency concerned."); see also Locascio, 6 F.3d at 949 (refusing to impute to AUSAs knowledge of reports prepared by FBI agents who were "uninvolved in the investigation or trial of the defendants"); cf. United States v. Ghailani, 687 F. Supp. 2d 365, 372 (S.D.N.Y. 2010) (holding that, in the context of a speedy trial motion, other members of the Department of Justice who were involved in making decisions about timing and progress of the case were part of the "government" for Rule 16 purposes). + +As the foregoing precedents recognize, the factors relevant in determining whether an agency or a component of an agency are part of the prosecution team, and therefore their records are in the "possession" of the Government include whether the agency or component: "(1) participated in the prosecution's witness interviews, (2) was involved in presenting the case to the grand jury, (3) reviewed documents gathered by or shared documents with the prosecution, (4) played a role in the development of prosecutorial strategy, or (5) accompanied the prosecution to court proceedings." Middendorf, 2018 WL 3956494, at \*4. + +# III. The Government's Plan to Review Certain Files from the Florida Investigation + +# A. Relevant Background Regarding the Florida Investigation (2005-2010) + +Between approximately 2005 and 2010, and as detailed further below, members of the Palm Beach Police Department, the Palm Beach State's Attorney's Office, the U.S Attorney's Office for the Southern District of Florida ("USAO-SDFL"), and the FBI's Palm Beach Resident Agency (the "FBI Florida Office") conducted a separate investigation and prosecution of Jeffrey Epstein for his sexual abuse of minors in Florida (the "Florida Investigative Team" and the "Florida Investigation," respectively). The Prosecution Team in this case had no involvement in the Florida Investigation, which predated the instant investigation by approximately eight years? Similarly, the Florida Prosecution Team and the agencies involved in the Florida Investigation have had no involvement in the investigative, charging, or prosecutorial strategy decisions of the Prosecution Team in this case. Accordingly, under the governing law of this Circuit as discussed above, there is no basis for deeming the Florida Prosecution Team a part of the current Prosecution Team, and the Government does not believe it has any legal obligation to obtain or review the investigative files of those agencies. As discussed below, however, the Government is nevertheless prepared to go significantly above and beyond its disclosure obligations by requesting files from the Florida Investigation that have at least some potential to contain materials that could be relevant to the instant case, and by reviewing and producing those materials as appropriate in this case.3 + +2 As detailed herein, during the course of its investigation, the Prosecution Team has gathered some documents related to the Florida Investigation, principally consisting of the FBI Florida Office's case file for the Florida Investigation. Those materials are being treated as a part of the Prosecution Team's files and will be produced, to the extent covered by Rule 16 or any other disclosure obligation, to the defendant in this case. + +3 In addition to the Florida Investigation, the Government is aware, through public reporting among other means, of a number of other investigations into matters relating to Jeffrey Epstein. For example, it has been publicly reported that local agencies in the U.S. Virgin Islands, Paris, and London have conducted and may still be conducting investigations into Epstein, which may include investigation into his sexual abuse of minors. There has also been public reporting regarding investigations into Epstein's finances, including an investigation by the U.S. Attorney's Office in the U.S. Virgin Islands, and into the conditions of Epstein's confinement while serving his sentence following the Florida Investigation. Additionally, the USAO-SDNY conducted an investigation into Epstein's suicide and is currently prosecuting two corrections officers as a result of that investigation. See United States v. Noel and Thomas, 19 Cr. 830 (AT). Separately, the FBI ' ice investigated and ultimately prosecuted an em lo ee of E stein's named for obstruction of justice, see United States v. 0 Cr. 80015 (KAM), and the Prosecution Team has received some files from that case. The Government does not intend to further seek out or review the investigative files of any such cases, which are completely unrelated to the subject matter of the instant prosecution and/or have been conducted by entities that are not part of this Prosecution Team and, in some instances, the Department of Justice. + +#### B. The Government's Plan for Obtaining and Reviewing Certain Files from the Florida Investigation + +As an initial matter, beginning during the course of its investigation, the Government has obtained the entirety of the FBI Florida Office's case file from the Florida Investigation. The Government has already made productions from that file, is continuing to review that file, and intends to produce at the appropriate point any additional material in that file warranting disclosure in this case. That file includes, among other things, any FBI-302 of any relevant witness interview; any relevant materials obtained pursuant to federal grand jury subpoena as part of that investigation; and any relevant material seized during a search of Epstein's Palm Beach residence conducted as part of that investigation. The Government believes the FBI file contains substantially all of the prior witness statements made during the Florida Investigation, including, if applicable, any prior statements made by witnesses the Government intends to call at trial in this case. + +In total, the Government has identified six potential sources of material related to the Florida Investigation, and has been requesting and reviewing materials from those sources as follows: + +First, the Palm Beach Police Department ("PBPD") opened its investigation into Jeffrey Epstein in or about 2005. During the course of that investigation, the PBPD, among other things, conducted numerous witness interviews, issued multiple subpoenas for documents,4 and executed a search warrant at Epstein's Palm Beach Residence. In or about 2006, the PBPD referred its investigation to the FBI Florida Office. It is the Government's understanding that the PBPD provided its entire investigative file to the FBI Florida Office. As discussed above, the Prosecution Team already has a copy of the full FBI Florida Office file and, as such, has been reviewing and will continue to review the PBPD file for any material that warrants disclosure in this case. Additionally, the Government has contacted the Records Specialist at the PBPD, who informed the Government that the PBPD has no additional investigative files beyond what it already provided to the FBI Florida Office. Out of an abundance of caution, however, the Government asked the Records Specialist to provide the Prosecution Team with a copy of the files still in PBPD's possession related to the Florida Investigation. In response, the PBPD Records Specialist provided the Government with 60 pages of documents, which the Prosecution Team reviewed for any material that is non-duplicative and warrants disclosure in this case. The Prosecution Team has identified five of those pages as non-duplicative and intends to produce those five pages as part of its next discovery production to the defense. + +Second, the Palm Beach State's Attorney's Office (the "PBSA"), working with the PBPD, among other agencies, handled the Florida state investigation and prosecution of Jeffrey Epstein between approximately 2005 and 2010 (when Epstein completed his sentence). As a result of that investigation and prosecution, Epstein pled guilty to procuring an underage girl for prostitution and soliciting a prostitute. Prior to September 14, 2020, the Prosecution Team had never received any documents directly from the PBSA and did not have the PBSA's full investigative file. + +4 As detailed below, these subpoenas were issued by the Palm Beach State's Attorney's Office. + +Although the PBSA is not part of the Prosecution Team, the Government has nevertheless communicated with the PBSA and requested that the PBSA provide the Prosecution Team with its entire investigative file, to the extent it still exists. In response, on September 14, 2020, the PBSA provided the Prosecution Team with an electronic copy of its entire case file regarding the Florida Investigation, which consists of 4,421 pages of documents, 43 audio files, and 6 video files. The Government is reviewing that file for any material that is non-duplicative of other material previously obtained and that warrants disclosure in this case. + +Third, the FBI Florida Office conducted a prior federal investigation into Jeffrey Epstein between approximately 2006 and 2010. As noted above, the electronic files from the FBI Florida Office are accessible by the FBI New York Office, which has provided the Government with a complete set of FBI electronic files from both its Florida Office and its New York Office for this case. The Government has reviewed those files for discoverable materials. The physical files from the FBI Florida Office, which are contained in approximately 24 boxes, have all been transferred to the FBI New York Office and are in the possession of the Prosecution Team. Those files have been scanned and put into an electronic review platform. The Government has previously reviewed those files and is continuing to do so for discoverable materials. In addition, and as noted above, some items from the FBI Florida Office file have already been produced as part of prior discovery productions in this case. + +Fourth, the USAO-SDFL participated in the federal investigation of Jeffrey Epstein between approximately 2006 and 2010. Before today, the Prosecution Team had never received any documents from the USAO-SDFL and did not have the USAO-SDFL's investigative file. Indeed, aside from notifying the SDFL at an executive level that the SDNY was opening its own Epstein investigation in 2018, the Prosecution Team had no substantive communications with the USAO-SDFL about the Prosecution Team's investigation or prosecution until after indicting this case. However, after the initiation of this prosecution, the Government communicated with the USAO-SDFL and requested that the USAO-SDFL provide the Prosecution Team with a copy of its entire investigative file, so that the Prosecution Team could review the files for material that warrants disclosure in this case. The USAO-SDFL agreed to provide its entire file, which is contained in approximately 28 boxes, to the Prosecution Team. Accordingly, the Government hired a vendor to copy the entire USAO-SDFL file and load that file into an electronic review platform. The Government received the electronic copy of the USAO-SDFL file from the vendor today and intends to review that file for materials that warrant disclosure in this case. + +Fifth, internal Department of Justice emails relating to the prior Florida Investigation have been gathered by the Department of Justice's Office of Professional Responsibility ("OPR"), as part of its unrelated investigation into the resolution of the prior Florida Investigation.5 In particular, during the course of its investigation, OPR gathered a significant volume of emails, to the extent they had been preserved and remained accessible, from a number of USAO-SDFL attorneys, including a number of supervisors in that office and the primary line Assistant U.S. Attorney who worked on the Florida Investigation ("Attorney-1"). + +5 This OPR investigation has been publicly acknowledged by the Department of Justice. + +Although the Government does not believe it has any obligation to gather or review emails sent or received by attorneys at the USAO-SDFL as part of their separate, prior investigation, the Government nonetheless intends to gather and review the emails sent to or from Attorney-1 to the extent those emails were preserved and gathered by OPR. As noted, Attorney- I was the primary line assistant on that investigation, and Attorney-1's emails are thus the most likely to contain communications with or regarding potential witnesses. The Government has already obtained Attorney-l's emails from OPR, and given the volume, the Government intends to load those emails into an electronic review platform and then conduct targeted searches of those emails for terms relevant to this case, including the defendant's name and the names of victims and witnesses. Based on our understanding of the USAO-SDFL investigation, we do not believe that there are a substantial number of overlapping victims or witnesses between that investigation and this prosecution. But to the extent searches of Attorney-1 's emails reveal non-duplicative Giglio or 3500 material for any such victims or witnesses, the Government will produce any such identified material consistent with any schedule for pre-trial disclosures set by the Court. The Government does not intend to request or review emails for any other USAO-SDFL or Department of Justice attorney or otherwise perform a comprehensive review of the internal e-mails of that prosecutor's office from its wholly separate investigation, including by asking for any other material gathered by OPR as part of its investigation. + +Sixth, beginning in or about 2019, attorneys with the United States Attorney's Office for the Southern District of Georgia ("USAO-SDGA") were designated to participate in the representation of the United States in civil litigation brought by Epstein victims for violations of the Crime Victim Rights Act ("CVRA") by the USAO-SDFL in connection with the Florida Investigation after the USAO-SDFL was recused from that civil litigation. The Government intends to contact the USAO-SDGA and ask whether it (a) had any substantive communications with witnesses relevant to this prosecution during its participation in the CVRA civil litigation, or (b) gathered any information regarding the defendant, Ghislaine Maxwell. If so, the Government will request any and all records regarding those topics and will review those records for materials that warrant disclosure in this case. Otherwise, the Government does not intend to request or review any materials from the USAO-SDGA. + +As noted above, none of these other offices or agencies has played any role in the investigation or prosecution of this case. In particular, none of these offices and agencies has participated in witness interviews or taken any other investigative steps with the Prosecution Team. Nor did any representative of these other offices or agencies play any role in developing strategy, making charging decisions, or presenting this case to the grand jury. Accordingly, although the Government maintains that none of these agencies is part of the Prosecution Team in this case, given the similarity of the nature of the conduct investigated in this case and the conduct investigated by those other offices and agencies, the Government is prepared to undertake the extensive efforts described above to obtain and review additional material. The Government will continue to produce any portion of those materials that warrants disclosure in this case, including in connection with its production of Giglio and 3500 material. + +Page 8 + +#### **IV. Conclusion** + +Consistent with its representations to the Court at the initial conference in this matter, the Government is committed to maintaining a thorough, careful, and comprehensive approach to its disclosure obligations. The Government is prepared to address any questions the Court may have or to provide any additional information upon request. + +Respectfully submitted, + +AUDREY STRAUSS + +Acting United States Attorney + +By: + +![]()[REDACTED] / [REDACTED] / [REDACTED] + +Assistant United States Attorneys + +Southern District of New York + +Tel: [REDACTED] + +Cc: *All counsel of record*, via ECF \ No newline at end of file diff --git a/marker2/ds9/EFTA00087761/EFTA00087761.metadata.json b/marker2/ds9/EFTA00087761/EFTA00087761.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..3b49506c700302df92d82cefe6edbf4cb24ba062 --- /dev/null +++ b/marker2/ds9/EFTA00087761/EFTA00087761.metadata.json @@ -0,0 +1,519 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087761.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 8, + "chars": 24703, + "elapsed_seconds": 4.32, + "image_assets": [ + "_page_0_Picture_0.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "U.S. Department of Justice", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 319.464, + 55.89000000000001 + ], + [ + 463.6681213378906, + 55.89000000000001 + ], + [ + 463.6681213378906, + 71.103515625 + ], + [ + 319.464, + 71.103515625 + ] + ] + }, + { + "title": "VIA ECF", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 197.64 + ], + [ + 124.17471313476562, + 197.64 + ], + [ + 124.17471313476562, + 212.853515625 + ], + [ + 68.544, + 212.853515625 + ] + ] + }, + { + "title": "I. 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Sadly, she passed way within the past month. I don't think she had any connection to the SD Fla. She worked a lot with when he was Chief of Public Corruption. She was really a great person. + +From: '\* => Sent: Wednesday, February 17, 2021 6:08 PM To: ) ‹ " Cc: Ic =>; (USANYS) + +Subject: Hi + +Hope you're both doing well! and=and I are currently briefing some issues in the Ghislaine Maxwell case, and we've come across a factual issue that we were hoping you might be able to help us with. The name i'MMa appears to be referenced in a file from the Southern District of Florida, and the defense is suggesting that this person worked at SDNY. If you could possibly help us figure out whether this person ever worked here, that would be incredibly helpful. + +Thanks so much, + +Assistant United States Attorney + +Southern District of New York \ No newline at end of file diff --git a/marker2/ds9/EFTA00087771/EFTA00087771.metadata.json b/marker2/ds9/EFTA00087771/EFTA00087771.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..cc5c46178934f6ddd81550c169f2eda8d5b444d3 --- /dev/null +++ b/marker2/ds9/EFTA00087771/EFTA00087771.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087771.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1178, + "elapsed_seconds": 0.58, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 73 + ], + [ + "Line", + 31 + ], + [ + "Text", + 10 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087771" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087772/EFTA00087772.md b/marker2/ds9/EFTA00087772/EFTA00087772.md new file mode 100644 index 0000000000000000000000000000000000000000..228bb2e8ef5fe25cfdf8a60b0fecebd16f2332f0 --- /dev/null +++ b/marker2/ds9/EFTA00087772/EFTA00087772.md @@ -0,0 +1,15 @@ +From: " " alMIE> + +To:" + +Cc: " + +Subject: + +Date: Tue, 11 Aug 2020 16:51:05 +0000 + +Attachments: ranscript\_Vol\_l\_(6-24-16).pdf; 16).pdf ranscript\_Vol\_2\_(6-24- + +As we discussed, I'm attaching the deposition transcripts. + +Assistant United States Attorney Southern District of New York \ No newline at end of file diff --git a/marker2/ds9/EFTA00087772/EFTA00087772.metadata.json b/marker2/ds9/EFTA00087772/EFTA00087772.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..d4af813b0a8ba39b2d09dbf7629fa47811959dfb --- /dev/null +++ b/marker2/ds9/EFTA00087772/EFTA00087772.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087772.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 284, + "elapsed_seconds": 0.68, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 24 + ], + [ + "Text", + 14 + ], + [ + "Line", + 12 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087772" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087773/EFTA00087773.md b/marker2/ds9/EFTA00087773/EFTA00087773.md new file mode 100644 index 0000000000000000000000000000000000000000..e4523752057ec4799f15e59ee38a30bea7995316 --- /dev/null +++ b/marker2/ds9/EFTA00087773/EFTA00087773.md @@ -0,0 +1,11 @@ +From: "Blase. Nicholas (USANYSr + +To: MilarEM=M=ME + +Cc: "M EMEME MIS + +Subject: Maxwell + +Date: Thu, 17 Sep 2020 15:51:28 +0000 + +This will probably sound ridiculous, but I promised I'd ask (since it's from a credible publication): A reporter has heard rumors that Maxwell claims she was in possession of video(s) Epstein captured of Dershowitz and other high-profile individuals at the time of her arrest and may be using them to negotiate with you... \ No newline at end of file diff --git a/marker2/ds9/EFTA00087773/EFTA00087773.metadata.json b/marker2/ds9/EFTA00087773/EFTA00087773.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..6e66e06b91bf23cf1dc85316a5b8984d66662fc5 --- /dev/null +++ b/marker2/ds9/EFTA00087773/EFTA00087773.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087773.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 448, + "elapsed_seconds": 0.38, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 22 + ], + [ + "Line", + 9 + ], + [ + "Text", + 6 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087773" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087774/EFTA00087774.md b/marker2/ds9/EFTA00087774/EFTA00087774.md new file mode 100644 index 0000000000000000000000000000000000000000..2e177ff2902286a88a22b131aa0be194aceecdbb --- /dev/null +++ b/marker2/ds9/EFTA00087774/EFTA00087774.md @@ -0,0 +1,230 @@ +### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +x UNITED STATES OF AMERICA v. GHISLAINE MAXWELL, Defendant. x + +S2 20 Cr. 330 (AJN) + +#### GHISLAINE MAXWELL'S MOTION IN LIMINE TO EXCLUDE EVIDENCE RELATED TO ACCUSER-3 + +Christian R. Everdell COHEN & GRESSER LLP + +![](_page_0_Picture_5.jpeg) + +Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. + +![](_page_0_Picture_7.jpeg) + +Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim + +![](_page_0_Picture_9.jpeg) + +Attorneys for Ghislaine Maxwell + +## TABLE OF CONTENTS + +| | Page | +|----------------------------------------------------------------------------|---------------------------------------------------------------------------------| +| PRELIMINARY STATEMENT | 1 | +| BACKGROUND | 2 | +| ARGUMENT | 5 | +| I. Applicable Law | 5 | +| II. Evidence Related to Accuser-3 Is Not Proof of the Charged Conspiracies | 7 | +| III. | Evidence Related to Accuser-3 Is Not Admissible Under Rule 404(6) and Should be | +| Excluded Under Rule 403 | 10 | +| IV. | In the Alternative, the Court Should Preclude the Government and Accuser-3 from | +| by Epstein, and Give the Jury an Appropriate Limiting Instruction | 14 | +| CONCLUSION | 16 | + +## TABLE OF AUTHORITIES + +| | Page(s) | +|----------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------| +| Cases | | +| Daubert v. Merrell Dow Pharmaceuticals, Inc. ,
509 U.S. 579 (1993)..... | 12 | +| Esquivel-Quintana v. Sessions ,
137 S. Ct. 1562 (2017)..... | 14 | +| Grunewald v. United States ,
353 U.S. 391 (1957)..... | 8 | +| Huddleston v. United States ,
485 U.S. 681 (1988)..... | 5, 6 | +| Salinas v. United States ,
522 U.S. 52 (1997)..... | 8 | +| United States v. Bagaric ,
706 F.2d 42 (2d Cir. 1983)..... | 6, 7, 8 | +| United States v. Benussi ,
216 F. Supp. 2d 299 (S.D.N.Y. 2002), aff'd sub nom. United States v. Salmonese , 352 F.3d 608 (2d Cir. 2003) ..... | 8 | +| United States v. Carboni ,
204 F.3d 39 (2d Cir. 2000)..... | 6 | +| United States v. Concepcion ,
983 F.2d 369 (2d Cir. 1992)..... | 6 | +| United States v. Cummings ,
60 F. Supp. 3d 434 (S.D.N.Y. 2014) vacated on other grounds 858 F.3d 763
(2d Cir. 2017)..... | 6, 7, 8, 9 | +| United States v. Curley ,
639 F.3d 50 (2d Cir. 2011)..... | 5, 6, 11, 13 | +| United States v. Dolney ,
No. 04-CR-159 (NGG), 2005 WL 2129169 (E.D.N.Y. Sept. 1, 2005) ..... | 10, 15 | +| United States v. Figueroa ,
618 F.2d 934 (2d Cir. 1980)..... | 13 | + +| United States v. Garcia, | | +|----------------------------------------------------------------------------------------|-------------| +| 291 F.3d 127 (2d Cir. 2002) United States v. Mahsffr, | 11 | +| Fed. App'x 797 (2d Cir. 2008) United States v. McCallum, | 9 | +| 584 F.3d 471 (2d Cir. 2009) United States v. Mills, | 5, 6, 11 | +| 895 F.2d 897 (2d Cir. 1990) United States v. Nektalov, | 12 | +| 325 F. Supp. 2d 367 (S.D.N.Y. 2004) United States v. Pascarella, | 6, 8, 9, 10 | +| 84 F.3d 61 (2d Cir. 1996) United States v. Sliker, | 11 | +| 751 F.2d 477 (2d Cir. 1984) United States v. Townsend, | 12 | +| No. S1 06 CR. 34 (JFK), 2007 WL 1288597 (S.D.N.Y. May 1, 2007) United States v. Walla, | 6, 9, 10 | +| No. 14—CR-213 (MKB), 2014 WL 3734522 (S.D.N.Y. July 25, 2014) | 12 | + +# Statutes + +| 18 U.S.C. § 2422(a) | 7 | +|---------------------|--------| +| 18 U.S.C. § 2423(a) | 7 | +| Mann Act | passim | + +# Other Authorities + +| Fed. R. Evid. 401 | 12 | +|----------------------|--------| +| Fed. R. Evid. 402 | 11, 12 | +| Fed. R. Evid. 403 | passim | +| Fed. R. Evid. 404(b) | passim | +| Fed. R. Evid. 702 | 12 | +| Fed. R. Evid. 704 | 12 | + +Ghislaine Maxwell respectfully moves in lintine to exclude evidence related to Accuser-31 because it is not probative of the charged conspiracies and inadmissible under Rule 404(b) and Rule 403 of the Federal Rules of Evidence. In the alternative, Ms. Maxwell respectfully moves (1) to preclude the government and Accuser-3 from referring to Accuser-3 as a "minor" or asserting that she was a "minor" at the time of the alleged sex acts, (2) to preclude the government and Accuser-3 from representing that she was "sexually abused" by Jeffrey Epstein, and (3) for an appropriate limiting instruction concerning Accuser-3's testimony. + +## PRELIMINARY STATEMENT + +The government and the defense agree on at least this much about Accuser-3: + +- I. She was not a minor in the United Kingdom when she alleges that she was sexually abused by Jeffrey Epstein in 1994-1995; +- 2. She cannot establish that Ms. Maxwell or Jeffrey Epstein ever caused, or sought to cause, her to travel while she was a minor; and +- 3. She cannot establish that she was a minor in the United States when she alleges that she engaged in sex acts with Jeffrey Epstein at his various residences. + +Even if we assume for the sake of argument that everything Accuser-3 alleges is true (which it is not), she has not alleged any illegal conduct whatsoever, much less conduct "in furtherance of" a conspiracy to entice or cause minor girls to travel to engage in unlawful sexual activity with Epstein. + +It seems evident that the government originally included Accuser-3's allegations in the indictment as evidence of the charged conspiracies because it did not know that she was above the age of consent in the U.K. The government presented Accuser-3's allegations to the grand jury incorrectly assuming that she was a minor and that the alleged sex acts between Epstein and + +This individual is described in the S2 Superseding Indictment as Minor Victim-3. Similarly, we refer to the individuals identified in the indictment as Minor Victim-I and Minor Victim-2 as Accuser-I and Accuser-2, respectively. + +Accuser-3 were illegal. Indeed, referring to Accuser-3 in the indictment as "Minor Victim-3" is entirely misleading — there is no evidence that she was a "minor" when any of the alleged sex acts took place. + +Nevertheless, even after the defense pointed out in our pretrial motions that Accuser-3 was not a minor and had not alleged any illegal conduct, the government repeated her allegations verbatim to the grand jury and in the S2 Superseding Indictment. This was not only misleading, it was also an end-run around Rule 404(b). Simply including the conduct alleged by Accuser-3 in the indictment does not mean that it is evidence of the charged conspiracies. The conduct alleged by Accuser-3 is not within the scope of the charged conspiracies and the Court should not admit this evidence as proof of those charges. Nor should the Court admit this evidence as "other act" evidence under Rule 404(b). This evidence would only be offered to show criminal propensity, despite the alleged conduct being entirely legal, and would mislead the jury and unfairly prejudice Ms. Maxwell. Accordingly, the Court should exclude evidence related to Accuser-3. + +# BACKGROUND + +The original indictment against Ms. Maxwell, filed on June 29, 2020, and the first superseding indictment, filed on July 8, 2020, included the following allegations related to Accuser-3: + +> MAXWELL groomed and befriended [Accuser-3] in London, England between approximately 1994 and 1995, including during a period of time in which MAXWELL knew that [Accuser-3] was under the age of 18. Among other things, MAXWELL discussed [Accuser-3's] life and family with [Accuser-3]. MAXWELL introduced [Accuser-3] to Epstein and arranged for multiple interactions between [Accuser-3] and Epstein. During those interactions, MAXWELL encouraged [Accuser-3] to massage Epstein, knowing that Epstein would engage in sex acts with [Accuser-3] during those massages. [Accuser-3] provided Epstein + +with the requested massages, and during those massages, Epstein sexually abused [Accuser-3]. MAXWELL was aware that Epstein engaged in sexual activity with [Accuser-3] on multiple occasions, including at times when [Accuser-3] was under the age of 18, including in the context of a sexualized massage. + +See Indictment (Dkt. 001) ¶ 7(c); S1 Superseding Indictment (Dkt. 017) ¶ 7(c). Both indictments also alleged the following as an overt act of the charged conspiracies: "Between in or about 1994 and in or about 1995, when [Accuser-3] was under the age of 18, MAXWELL encouraged [Accuser-3] to provide massages to Epstein in London, England, knowing that Epstein intended to sexually abuse [Accuser-3] during those massages." See Indictment (Dkt. 001) ¶¶ 11(d), 17(d); S 1 Superseding Indictment (Dkt. 017)¶¶ 11(d), 17(d). + +Ms. Maxwell filed a pretrial motion to strike the allegations related to Accuser-3 as surplusage on the grounds that they could not support the charged conspiracies and were unfairly prejudicial to Ms. Maxwell. See Def.'s Mem. in Supp. of Mot. to Strike Surplusage from Superseding Indictment (Dkt. 146) at 1-3, 6-9. Ms. Maxwell noted that (1) according to Accuser-3's own allegations, she was above the legal age of consent in the United Kingdom (16 years old) when the sex acts supposedly took place and therefore any sex acts that occurred were lawful and could not be considered "sexual abuse"; and (2) the indictment did not allege any travel by Accuser-3, in interstate or foreign commerce or otherwise, let alone as a result of any action taken by Ms. Maxwell or Epstein, which was a critical element of both charged conspiracies. Id. at 4-5. + +In its opposition, the government scrambled to paper over these problems by providing a much fuller proffer of Accuser-3's expected testimony. See Gov't Mem. in Opp. to Def.'s Pretrial Motions (Dkt. 204) at 158-59 & n.56. The government attempted to defend its use of the phrase "sexual abuse" by asserting that the description was "factually accurate" because + +Accuser-3 was expected to testify at trial that "her subjective experience of these acts with a much older man as traumatic, exploitative, and abusive." Id. at 162 n.57 (emphasis added). The government also represented for the first time that Accuser-3 is expected to testify that after the first two sexual encounters with Epstein in London, Epstein and Ms. Maxwell "invited [Accuser-3] to travel with them to Florida, the U.S. Virgin Islands, and New York" and that during the course of those trips, Accuser-3 gave Epstein additional massages during which they engaged in sex acts. Id. at 159. The government conceded, however, that Accuser-3 "does not recall whether she was 17 or 18 when she took her first trip at Epstein and the defendant's invitation." Id. Accordingly, Accuser-3 cannot establish that she was a minor when she traveled or when she allegedly engaged in sex acts with Epstein in the United States. + +Despite having been alerted to the problems with Accuser-3's evidence, the government repeated the same allegations related to Accuser-3 in the second superseding indictment filed after the pretrial motions were fully briefed. See S2 Superseding Indictment (Dkt. 187) ("S2 Indictment") ¶19(c), 13(d), 19(d). These included the misleading allegations that Accuser-3 was a "minor" and that Epstein had "sexually abused" her. Id. + +In its opinion and order denying Ms. Maxwell's motion to strike, the Court agreed that the indictment did not allege that Accuser-3 traveled in interstate commerce or was underage during sexual encounters with Epstein. 4/16/2021 Opinion and Order (Dkt. 207) at 27. Nevertheless, the Court stated that it could not "rule out that the allegations may reflect conduct undertaken in furtherance of the charged conspiracy or be relevant to prove facts such as Maxwell's state of mind." Id. The Court further stated that it would reserve the issue for trial and allow Ms. Maxwell to renew her motion then. Id. + +For the reasons stated below, the Court should not admit evidence related to Accuser-3 at trial as evidence of the charged conspiracies or as "other act" evidence under Rule 404(b). In the alternative, the Court should preclude the government and Accuser-3 from referring to Accuser-3 as a "minor" or asserting that Accuser-3 was a "minor" at the time of the alleged sex acts. The Court should also preclude the government and Accuser-3 from representing that Epstein "sexually abused" her and give the jury an appropriate limiting instruction that the alleged conduct was lawful and that the sexual activity cannot be considered "illegal" or "criminal" or "unlawful" for the purposes of the crimes charged in the indictment.2 + +### ARGUMENT + +# I. Applicable Law + +Rule 404(6) of the Federal Rules of Evidence governs the admissibility of evidence of "crimes, wrongs, or acts" other than those charged in the indictment. United States v. Curley, 639 F.3d 50, 56 (2d Cir. 2011) (quoting Fed. R. Evid. 404(b)). The rule provides, in relevant part: + +- (1) Prohibited Uses. Evidence of any other crime, wrong, or act is not admissible to prove a person's character in order to show that on a particular occasion the person acted in accordance with the character. +- (2) Permitted Uses. This evidence may be admissible for another purpose, such as proving motive, opportunity, intent, preparation, plan, knowledge, identity, absence of mistake, or lack of accident. + +Fed. R. Evid. 404(b)(1)-(2). For other act evidence to be admissible under Rule 404(b), (1) it must be offered for a proper purpose, (2) it must be relevant to a disputed issue, and (3) the probative value of the evidence cannot be substantially outweighed by its potential for unfair + +2 For the same reasons, Ms. Maxwell also renews her motion to strike the allegations related to Accuser-3 from the S2 Indictment. + +prejudice pursuant to Rule 403; in addition, (4) at defendant's request, the district court should give the jury an appropriate limiting instruction. United States v. McCallum, 584 F.3d 471, 475 (2d Cir. 2009) (citing Huddleston v. United States, 485 U.S. 681, 691-92 (1988)). "'Other act' evidence serves a proper purpose so long as it is not offered to show the defendant's propensity to commit the offense." Curley, 639 F.3d at 57 (citing Fed. R. Evid. 404(b)). + +When the government must prove a conspiracy charge, evidence of other acts committed "in furtherance of the conspiracy" is not "other act" evidence under Rule 404(b), but rather, it is direct evidence of the acts charged in the Indictment. United States v. Townsend, No. SI 06 CR. 34 (JFK), 2007 WL 1288597, at \*1 (S.D.N.Y. May I, 2007) (citing United States v. Concepcion, 983 F.2d 369, 392 (2d Cir. 1992)). However, "other acts" are only admissible as evidence of a conspiracy "as long as they are within the scope of the conspiracy." United States v. Cummings, 60 F. Supp. 3d 434, 437 (S.D.N.Y. 2014) vacated on other grounds 858 F.3d 763 (2d Cir. 2017) (quoting United States v. Bagaric, 706 F.2d 42, 64 (2d Cir. 1983)). + +Evidence of uncharged conduct is not considered other act evidence under Rule 404(6) "if it [1] arose out of the same transaction or series of transactions as the charged offense, [2] if it is inextricably intertwined with the evidence regarding the charged offense, or [3] if it is necessary to complete the story of the crime on trial." United States v. Nektalov, 325 F. Supp. 2d 367, 370 (S.D.N.Y. 2004) (quoting United States v. Carboni, 204 F.3d 39, 44 (2d Cir. 2000)). However, "where it is not manifestly clear that the evidence in question is intrinsic proof of the charged crime, the proper course is to proceed under Rule 404(b)." Townsend, 2007 WL 1288597, at \*1 (citing Nektalov, 325 F. Supp. 2d at 372). + +## II. Evidence Related to Accuser-3 Is Not Proof of the Charged Conspiracies + +Accuser-3's allegations, which pertain only to the Mann Act conspiracies charged in Counts One and Three of the S2 Indictment, are irrelevant to the charged conspiracies and do not offer any proof supporting those charges. The S2 Indictment alleges that Ms. Maxwell conspired with Epstein to (i) violate 18 U.S.C. § 2422(a), with the objective of enticing one or more individuals to travel in interstate and foreign commerce for the purpose of engaging in unlawful sexual activity (S2 Indictment¶¶ 11-12); and (ii) violate 18 U.S.C. § 2423(a), with the objective of transporting an individual under age 18 with the intent that the individual engage in unlawful sexual activity (id. ¶¶ 17-18). As an overt act in furtherance of these conspiracies, the government alleges that Ms. Maxwell "encouraged [Accuser-3] to provide massages to Epstein in London, England, knowing that Epstein intended to sexually abuse [Accuser-3] during those massages." Id. ¶¶ 13(d), 19(d) (emphasis added). The Indictment further alleges that Epstein "sexually abused" Accuser-3. Id. ¶ 9c. + +There is no cogent basis for the government to assert that Accuser-3's allegations are direct evidence of the charged conspiracies. The object of the alleged conspiracies was to entice or cause one or more minors to travel in interstate or foreign commerce in order to engage in unlawful sexual activity. The government concedes that Accuser-3 (1) was not a minor under U.K. law when she allegedly engaged in sex acts with Epstein in London, (2) cannot establish that she was invited to travel to the United States when she was under the age of 18, and (3) cannot establish that she was a minor when she allegedly engaged in sex acts with Epstein in the United States. See Gov't Mem. in Opp. to Def.'s Pretrial Motions (Dkt. 204) at 158-59, 162-163 & nn.57-58. Accuser-3 will therefore not provide any proof that Ms. Maxwell "furthered" an alleged conspiracy to cause minors to travel for the purpose of engaging in unlawful sexual activity. Accordingly, the conduct she alleges is not "within the scope of the conspiracy" and + +should not be admitted as evidence of the conspiracies. See Cummings, 60 F. Supp. 3d at 437 (quoting Bagaric, 706 F.2d at 64); see also United States v. Benussi, 216 F. Supp. 2d 299, 311 (S.D.N.Y. 2002), affd sub nom. United States v. Sabnonese, 352 F.3d 608 (2d Cir. 2003) (the "scope of the conspiratorial agreement" is the key to determining whether "an overt act may properly be regarded as in furtherance of the conspiracy" (quoting Grunewald v. United States, 353 U.S. 391, 397 (1957)). + +In its opposition to Ms. Maxwell's motion to strike, the government argued that because a conspiracy "does not require a completed substantive crime," Accuser-3's allegations could still be admitted as direct proof of the charged conspiracies even though she did not travel as a minor or engage in illegal sex acts because Ms. Maxwell allegedly "groomed" her to engage in those sex acts. Gov't Mem. in Opp. to Def.'s Pretrial Motions (Dkt. 204) at 161-163 (citing Salinas v. United States, 522 U.S. 52, 65 (1997)). That argument misses the mark. While it is true that a conspiracy does not require a completed substantive crime, Salinas itself states that "[a] conspirator must intend to further an endeavor which, if completed, would satisfy all of the elements of a substantive criminal offense." Salinas, 522 U.S. at 65. As to Accuser-3, the completed endeavor—La, her alleged sex acts with Epstein—was not a substantive criminal offense. Even if we accept her allegations as true (which we do not), there is nothing unlawful about encouraging an adult to engage in entirely lawful sex acts. Hence, Accuser-3's allegations are not direct proof of the charged conspiracies regardless of whether Ms. Maxwell allegedly "groomed" her (which she did not). + +The Court should not admit Accuser-3's allegations as intrinsic proof of the charged conspiracies either. See Nektalov, 325 F. Supp. 2d at 370 (listing three categories of "intrinsic" proof not considered Rule 404(b) evidence). The Mann Act conspiracies in the S2 Indictment + +allege three distinct episodes of alleged sexual abuse, in three different locations, involving three separate accusers. The allegations of Accuser-3 stand on their own and are not "inextricably intertwined" with the allegations of Accuser-1 or Accuser-2, nor do they stem from "the same series of transactions." In fact, they have no bearing on or connection to those allegations whatsoever. Because Accuser-Vs allegations are conceptually distinct, they are also not "necessary to complete the story" of the charged conspiracies. See Cummings, 60 F. Supp. 3d at 438 (defendant's prior crack arrests and firearms conviction not sufficiently connected to underlying conspiracy to distribute crack and possessing firearms to be admissible); Townsend, 2007 WL 1288597, at \*2 (defendant's prior narcotics and firearm transactions with the same confidential informant not "inextricably intertwined" with the charged narcotics conspiracy, even though the conduct was "generally similar to the conduct underlying the offenses charged in the indictment"); United States v. Mahal, 477 F. Supp. 2d 560, 566 (E.D.N.Y. 2007) vacated in part on other grounds 285 Fed. App'x 797 (2d Cir. 2008) (similar prior financial crime not inextricably linked to the charged crime where prior act "was a separate, discrete offense that may be conceptually segregated from the charged offenses without impairing the jury's ability to understand the facts underlying the schemes alleged in the indictment"); Nektalov, 325 F. Supp. 2d at 369-70 (prior similar money laundering transactions between defendant and cooperating witness not "inextricably intertwined" with the charged money laundering offense or "necessary to complete the story" of the charged conspiracy (emphasis in original)). + +The fact that the government included Accuser-3's allegations in the S2 Indictment is of no consequence. Although Rule 404(b) typically governs the admissibility of "other acts" that are not charged in the indictment, in this case, the government evidently charged the conduct under the mistaken belief that Accuser-3 was a minor when she engaged in sex acts with Epstein: Q. And did you also testify earlier that . .. [Accuser-3] told you that Maxwell asked her to give Epstein massages when she was a minor? + +A. Yes. + +3513-024 (6/29/2020 Grand Jury Testimony of FBI Special Agen 11 (emphasis added) (attached as Exhibit A). The government repeated this error when they returned the S2 Indictment. See 3513-029 (3/29/2021 Grand Jury Testimony of NYPD Detective MM) at 11 (attached as Exhibit B). The government's error in including Accuser-3's allegations in the indictment does not somehow convert this evidence into proof of the charged conspiracies. Such a rule would allow the government to entirely circumvent Rule 404(b) simply by charging other act conduct in the indictment. + +Moreover, without a proper limiting instruction, there is a serious risk that the July will view this lawful conduct as evidence of criminal propensity. See United States v. Dothey, No. 04-CR-159 (NGG), 2005 WL 2129169, at \*2 (E.D.N.Y. Sept. 1, 2005) (benefit of applying Rule 404(b) is "the value that a limiting instruction will have in ensuring that the jury does not view the defendants' alleged prior conduct as evidence of the defendants' propensity to engage in criminal activity"). At the very least, it is not "manifestly clear" that the evidence related to Accuser-3 is proof of the charged Mann Act conspiracies. Accordingly, "the proper course is to proceed under Rule 404(b)." Townsend, 2007 WL 1288597, at \*1 (citing Nektalov, 325 F. Supp. 2d at 372). + +### III. Evidence Related to Accuser-3 Is Not Admissible Under Rule 404(b) and Should be Excluded Under Rule 403 + +The Court should also not admit evidence related to Accuser-3 as Rule 404(b) evidence because it will be offered solely to show Ms. Maxwell's criminal propensity and will be unfairly prejudicial to Ms. Maxwell and will mislead the jury into believing that the alleged sex acts between Epstein and Accuser-3 were unlawful.; + +The Second Circuit takes an "inclusionary approach" to Rule 404(b) evidence, which admits "other act" evidence "that does not serve the sole purpose of showing the defendant's bad character and that is neither overly prejudicial under Rule 403 nor irrelevant under Rule 402. Curley, 639 F.3d at 56 (citing United States v. Pascarella, 84 F.3d 61, 69 (2d Cir. 1996)). The inclusionary approach, however, does not permit the government "to offer, carte blanche, any prior act of the defendant in the same category of [activity]." McCallum, 584 F.3d at 475 (quoting United States v. Garcia, 291 F.3d 127, 137 (2d Cir. 2002)). If other act evidence is offered for the purpose of establishing the defendant's knowledge or intent, the government must "identify a similarity or connection between the two acts that makes the prior act relevant to establishing knowledge of the current act." Id. (quoting Garcia, 291 F.3d at 137). + +The government has argued that the conduct alleged by Accuser-3 is admissible under Rule 404(b) to prove Ms. Maxwell's knowledge, intent, and modus operandi. See Gov't Mem. in Opp. to Def.'s Pretrial Motions (Dkt. 204) at 167. This argument is unavailing. Accuser-3's evidence could not possibly be proof that Ms. Maxwell knew of Epstein's "attraction to minor girls" and knew that Epstein used massage to initiate sexual contact "with minor girls" because Accuser-3 was not a minor when the alleged sex acts took place. Id. For the same reason, Accuser-3's evidence could not possibly be proof that Ms. Maxwell "intended for minor girls to engage in sex acts with Epstein." Id. + +3 As noted in Ms. Maxwell's Motion in Limine to Exclude the Government's Rule 404(b) Evidence, the government did not give proper 404(b) notice with respect to any of its proposed 404(b) evidence, which includes Accuser-3's evidence. Nevertheless, we respond on the merits to the admissibility of Accuser-3's evidence under Rule 404(b) in the event the Court determines that the government's additional disclosures concerning Accuser-3 in its Memorandum in Opposition to Defendant's Pretrial Motions are sufficient to satisfy its notice obligations under Rule 404(b). See Gov't Mem. in Opp. to Def.'s Pretrial Motions (Dkt. 204) at 157-169. + +The government's modus operandi argument appears to rest on the premise that "grooming," however broadly that may be defined, constitutes a distinctive pattern of criminal activity. See id.4 As the government itself pointed out, the characteristics of the modus operandi must be "sufficiently idiosyncratic to permit a fair inference of a pattern's existence." United States v. Sliker, 751 F.2d 477, 487 (2d Cir. 1984)); see also United States v. Walla, No. 14—CR-213 (MICE), 2014 WL 3734522, at \*13 (S.D.N.Y. July 25, 2014) ("Rule 404(b) permits evidence of similar acts to prove a `signature crime,' i.e., a modus operandi where the crimes are `so nearly identical in method as to ear-mark them as the handiwork of the accused."' (quoting United States v. Mills, 895 F.2d 897, 907 (2d Cir. 1990)). Here, Accuser-3 alleges that Ms. Maxwell asked her "about her life and family," as she is alleged to have done with the other accusers. Gov't Mem. in Opp. to Def.'s Pretrial Motions (Dkt. 204) at 158. But engaging in social pleasantries and polite conversation does not in any way establish a unique or "signature" pattern of behavior. See Walla, 2014 WL 3734522, at \*13 (prior acts that share similarities with the charged offenses do not establish a modus operandi without a "signature" pattern of conduct) (collecting cases). In sum, Accuser-3's evidence will not be offered for any permissible purpose under Rule 404(b) and will just serve as evidence of criminal propensity. The Court should therefore exclude it. + +The Court should also exclude Accuser-3's evidence under Rule 403 because it will unfairly prejudice Ms. Maxwell and mislead the jury as to the legality of the alleged conduct and the purpose of its admission. Rule 403 provides that relevant evidence "may be excluded if its probative value is substantially outweighed by the danger of unfair prejudice, confusion of the + +Ms. Maxwell has moved separately to exclude the testimony of the government's proposed expert witness concerning "grooming" under Federal Rules of Evidence 401, 402, 403, 404, 702, 704, and Dauber( v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 (1993). + +issues, or misleading the jury, or by considerations of undue delay, [or] waste of time." Fed. R. Evid. 403. According to the government, Accuser-3 is expected to testify that she was "sexually abused" by Epstein, not because she was underage and incapable of consent by law, but because her "subjective experience" of these incidents was that they were "traumatic, exploitative, and abusive." Gov't Mem. in Opp. to Def.'s Pretrial Motions (Dkt. 204) at 162 n.57. If Accuser-3 is allowed to testify that she felt she was "sexually abused" by Epstein, the jury will naturally assume that the alleged sex acts were illegal, when they were not. Indeed, even if she is not allowed to use the phrase "sexual abuse," the mere fact that Accuser-3 will be testifying about alleged sex acts that she participated in with a much older man when she was 17 years old will likely lead the jury to assume that the conduct was illegal, especially after they have heard the expected testimony of the other accusers in this case. + +Hence, there is a strong likelihood that the jury will be misled by Accuser-3's evidence and will misapply it in evaluating Ms. Maxwell's guilt or innocence to the charged Mann Act conspiracies, both of which require that Ms. Maxwell acted with the intent that the accusers would engage in illegal or criminal sexual activity. This risk substantially outweighs the limited probative effect of Accuser-3's evidence. Even if the Court were to give the jury an appropriate limiting instruction, there is a substantial risk that it would not be sufficient to ensure that the jury did not misinterpret or misapply this evidence. See Curley, 639 F.3d at 60 (quoting United States v. Figueroa, 618 F.2d 934, 946 (2d Cir. 1980) ("limiting instructions cannot be regarded as a guaranty against prejudice")). Accordingly, the Court should exclude Accuser-3's evidence. + +### IV. In the Alternative, the Court Should Preclude the Government and Accuser-3 from Representing that Accuser-3 Was a "Minor," or that She Was "Sexually Abused" by Epstein, and Give the Jury an Appropriate Limiting Instruction + +If the Court determines that the evidence related to Accuser-3 is admissible, either as direct evidence of the charged conspiracies or as 404(b) evidence, the Court should (I) preclude the government and Accuser-3 from referring to Accuser-3 as a "minor" or asserting that she was a "minor" at the time of the alleged sex acts, (2) preclude the government and Accuser-3 from representing that she was "sexually abused" by Jeffrey Epstein, and (3) give the July an appropriate limiting instruction related to Accuser-3's testimony. + +The government concedes that Accuser-3 alleges that she was 17 years old and above the age of consent in the U.K. when she purportedly engaged in sex acts with Epstein in London. The government further concedes that Accuser-3 cannot establish that she was under the age of 18 when she alleges that she first traveled to the United States and engaged in sex acts with Epstein at his residences. Accuser-3 was therefore not a minor under the laws of the relevant jurisdictions when the alleged sex acts and the alleged international travel took place. It follows that the Court should not permit the government or Accuser-3 to refer to herself as a "minor" or claim that she was a minor when she allegedly engaged in sex acts with Epstein. + +Similarly, the Court should not permit the government and Accuser-3 to assert that she was "sexually abused" by Epstein. The phrase "sexual abuse" connotes criminal activity, even though the alleged conduct was lawful. See Esquivel-Quintana v. Sessions, 137 S. Ct. 1562, 1569 (2017) ("'Sexual abuse of a minor,' the Government accordingly contends, 'most naturally connotes conduct that (1) is illegal, (2) involves sexual activity, and (3) is directed at a person younger than 18 years old."') (quoting government's brief) (emphases added). Notwithstanding Accuser-3's "subjective experience" of these incidents, the use of the phrase "sexual abuse" should not be allowed because it will mislead the jury into thinking that Accuser-3 engaged in "criminal sexual activity" with Epstein. That, in turn, may cause the jury to improperly convict Ms. Maxwell based on a false assumption. + +Finally, the Court should give the jury an appropriate limiting instruction to ensure that the July understands that the alleged conduct was not unlawful and does not consider it as improper propensity evidence. If Accuser-3 is allowed to testify that she engaged in sex acts with Epstein in London when she was 17, as the government has proffered, the jury will almost certainly assume that the alleged conduct was unlawful, as it would be in certain U.S. states, and that the testimony is being offered to prove that Epstein and Accuser-3 engaged in "illegal sexual activity" in London. Accordingly, if Accuser-3 is allowed to testify, we request that the Court give the jury a limiting instruction containing the following points: + +- The legal age of consent for sexual activity in the United Kingdom is 16 years old. That was also the legal age of consent from 1994- 1995, when Accuser-3 alleges she engaged in sex acts with Jeffrey Epstein in London when she was 17 years old. +- The alleged conduct that Accuser-3 has described in her testimony was therefore not illegal. If you find that these incidents took place, I instruct you that this sexual activity cannot be considered "illegal" or "criminal" or "unlawful" for purposes of the crimes charged in the indictment. + +If the Court determines that Accuser-3's testimony may be admitted as 404(b) evidence, Ms. Maxwell further requests that the Court also give the jury an appropriate propensity instruction. See Doiney, 2005 WL 2129169, at \*2 ("In the absence of such a limiting instruction, there exists a legitimate concern that the jury might misapply [the] evidence to conclude that if the defendants engaged in criminal conduct prior to the charged conspiracy, then the conduct at issue in these charges must also be criminal."). + +### CONCLUSION + +For the foregoing reasons, the Court should exclude evidence related to Accuser-3 because it is not probative of the charged conspiracies and inadmissible under Rule 404(b) and Rule 403 of the Federal Rules of Evidence. In the alternative, Ms. Maxwell respectfully requests that the Court (1) preclude the government and Accuser-3 from referring to Accuser-3 as a "minor" or asserting that she was a "minor" at the time of the alleged sex acts, (2) preclude the government and Accuser-3 from representing that she was "sexually abused" by Jeffrey Epstein, and (3) give the jury an appropriate limiting instruction concerning Accuser-3's testimony that includes the points discussed above. + +Dated: October 18, 2021 New York, New York + +Respectfully submitted, + +Is/ Christian R. Everdell Christian R. Everdell COHEN & GRESSER LLP New York, NY Phone: + +Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Denver, CO Phone: + +Bobbi C. Sternheim Law Offices of Bobbi C. Sternheim + +Attorneys for Ghislaine Maxwell + +**CERTIFICATE OF SERVICE** + +I hereby certify that on October 18, 2021, I served by email, pursuant Rule 2(B) of the Court's individual practices in criminal cases, the within memorandum and any accompanying exhibits upon the following: + +![]()U.S. Attorney's Office, SDNY +One Saint Andrew's Plaza +New York, NY 10007 + +![]()*/s/ Christian Everdell* + +--- \ No newline at end of file diff --git a/marker2/ds9/EFTA00087774/EFTA00087774.metadata.json b/marker2/ds9/EFTA00087774/EFTA00087774.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..d52d4c6ee53b85e2deaeeb19ef7b31855425d906 --- /dev/null +++ b/marker2/ds9/EFTA00087774/EFTA00087774.metadata.json @@ -0,0 +1,1096 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087774.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 21, + "chars": 38861, + "elapsed_seconds": 7.9, + "image_assets": [ + "_page_0_Picture_5.jpeg", + "_page_0_Picture_7.jpeg", + "_page_0_Picture_9.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 71.28 + ], + [ + 281.419189453125, + 71.28 + ], + [ + 281.419189453125, + 99.7330322265625 + ], + [ + 68.544, + 99.7330322265625 + ] + ] + }, + { + "title": "GHISLAINE MAXWELL'S MOTION IN LIMINE \nTO EXCLUDE EVIDENCE RELATED TO ACCUSER-3", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 154.836, + 277.83000000000004 + ], + [ + 458.4354553222656, + 277.83000000000004 + ], + [ + 458.4354553222656, + 305.9830627441406 + ], + [ + 154.836, + 305.9830627441406 + ] + ] + }, + { + "title": "TABLE OF CONTENTS", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 238.68, + 71.28 + ], + [ + 374.134521484375, + 71.28 + ], + [ + 374.134521484375, + 86.9830322265625 + ], + [ + 238.68, + 86.9830322265625 + ] + ] + }, + { + "title": "TABLE OF AUTHORITIES", + "heading_level": null, + "page_id": 2, + "polygon": [ + [ + 229.5, + 96.38999999999999 + ], + [ + 383.9746398925781, + 96.38999999999999 + ], + [ + 383.9746398925781, + 111.43353271484375 + ], + [ + 229.5, + 111.43353271484375 + ] + ] + }, + { + "title": "Statutes", + "heading_level": null, + "page_id": 3, + "polygon": [ + [ + 68.544, + 439.83000000000004 + ], + [ + 116.69366455078125, + 439.83000000000004 + ], + [ + 116.69366455078125, + 455.9830322265625 + ], + [ + 68.544, + 455.9830322265625 + ] + ] + }, + { + "title": "Other Authorities", + "heading_level": null, + "page_id": 3, + "polygon": [ + [ + 68.544, + 543.51 + ], + [ + 166.91055297851562, + 543.51 + ], + [ + 166.91055297851562, + 559.8630218505859 + ], + [ + 68.544, + 559.8630218505859 + ] + ] + }, + { + "title": "PRELIMINARY STATEMENT", + "heading_level": null, + "page_id": 4, + "polygon": [ + [ + 219.096, + 275.40000000000003 + ], + [ + 391.927978515625, + 275.40000000000003 + ], + [ + 391.927978515625, + 290.8535461425781 + ], + [ + 219.096, + 290.8535461425781 + ] + ] + }, + { + "title": "BACKGROUND", + "heading_level": null, + "page_id": 5, + "polygon": [ + [ + 258.264, + 468.18 + ], + [ + 353.04595947265625, + 468.18 + ], + [ + 353.04595947265625, + 484.3535461425781 + ], + [ + 258.264, + 484.3535461425781 + ] + ] + }, + { + "title": "ARGUMENT", + "heading_level": null, + "page_id": 8, + "polygon": [ + [ + 267.44399999999996, + 303.75 + ], + [ + 344.6179504394531, + 303.75 + ], + [ + 344.6179504394531, + 318.6035461425781 + ], + [ + 267.44399999999996, + 318.6035461425781 + ] + ] + }, + { + "title": "I. 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of America, + +—v— + +Ghislaine Maxwell, + +Defendant. + +![](_page_0_Picture_5.jpeg) + +20-CR-330 (AJN) + +ORDER + +ALISON J. NATHAN, District Judge: + +At the telephone conference scheduled to take place on October 21, 2021, in which the Court will discuss jury selection matters and logistics with the parties, the Court will hear from counsel regarding the unopposed request to seal their joint proposed juror questionnaire and voir dire. See Dkt. No. 339. The Court will also inquire as to whether the sealing request extends to the Court's draft questionnaire and voir dire and any justification for such sealing. + +In the meantime, the Court will today transmit via email its draft questionnaire and draft voir dire to the parties so that the drafts can be discussed at the conference tomorrow. After the Court explains how jury selection will proceed, the parties should be prepared to raise any objections to the Court's draft questionnaire and voir dire. + +SO ORDERED. + +Dated: October 20, 2021 New York, New York + +ALISON J. NATHAN United States District Judge \ No newline at end of file diff --git a/marker2/ds9/EFTA00087795/EFTA00087795.metadata.json b/marker2/ds9/EFTA00087795/EFTA00087795.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..37b0d9c39c679e02a7ded9008926c250ddfe456b --- /dev/null +++ b/marker2/ds9/EFTA00087795/EFTA00087795.metadata.json @@ -0,0 +1,88 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087795.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1128, + "elapsed_seconds": 0.77, + "image_assets": [ + "_page_0_Picture_5.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 70.38, + 72.9 + ], + [ + 282.5491943359375, + 72.9 + ], + [ + 282.5491943359375, + 100.4830322265625 + ], + [ + 70.38, + 100.4830322265625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 59 + ], + [ + "Line", + 30 + ], + [ + "Text", + 13 + ], + [ + "PageFooter", + 2 + ], + [ + "SectionHeader", + 1 + ], + [ + "Picture", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087795" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087795/_page_0_Picture_5.jpeg b/marker2/ds9/EFTA00087795/_page_0_Picture_5.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..92d5e6c7d66ae77c7603d5d6186e12054f20dafc --- /dev/null +++ b/marker2/ds9/EFTA00087795/_page_0_Picture_5.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:2bf5db37b1c3fb25fb739e64bcea625920b93bc0af1a2c844f17f4eea4a13371 +size 12128 diff --git a/marker2/ds9/EFTA00087796/EFTA00087796.md b/marker2/ds9/EFTA00087796/EFTA00087796.md new file mode 100644 index 0000000000000000000000000000000000000000..4de9a45274077fb3196a6167fe914df3a55464a9 --- /dev/null +++ b/marker2/ds9/EFTA00087796/EFTA00087796.md @@ -0,0 +1,62 @@ +![](_page_0_Picture_92.jpeg) + +![](_page_0_Picture_93.jpeg) + +July 9, 2021 + +Honorable Alison J. Nathan +United States District Judge +United States Courthouse + +![](_page_0_Picture_96.jpeg) + +Re: *United States v. Ghislaine Maxwell* +S2 20 Cr. 330 (AJN) + +Dear Judge Nathan: + +The below-signed counsel of record for Ghislaine Maxwell submit this letter in response to the Court's order of July 2, 2021. (Dkt. 312). + +Ms. Maxwell's counsel of record have scrupulously complied with Local Criminal Rule 23.1 and assiduously refrained from any involvement with the media, despite repeated, persistent and borderline-harassing requests for comment. The statements in the New York Daily News Op-Ed piece were from Mr. Markus, who is not counsel of record in this case. These statements did not violate Rule 23.1. Nevertheless, it is appropriate that Mr. Markus, not Ms. Maxwell's counsel of record, be afforded the opportunity to address the government's unfounded complaints by separate letter response.1 + +We feel compelled to point out, however, that the government's position betrays a double standard that exists for public statements made by the government, its agents, and the alleged accusers and their counsel. + +After Ms. Maxwell was arrested just over a year ago, Acting U.S. Attorney [REDACTED] gave a deliberate press conference in blatant violation of Rule 23.1 espousing comment and opinion beyond the facts and circumstances of the arrest. The government filed a "speaking + +--- + +1 Indeed, the government's letter to the Court raising this issue was directed to Mr. Markus, not counsel of record. + +indictment" which provided the narrative for choreographed press conference. IN exceeded the text of the indictment and went off-script, as did members of law enforcement involved in the investigation whom invited to speak. Collectively, these members of the government, who were directly involved in the investigation and prosecution of this case, purposely villainized Ms. Maxwell and gave the accusers — the individuals who will testify before a jury — the imprimatur of credibility. The press conference was the government's unbridled opportunity to deliver an extrajudicial opening statement in the court of public opinion and the media has followed its lead ever since. + +Similarly, counsel for undisclosed Accusers 1 to 4 have made numerous public statements without any reprisal or public reprimand by the government. They have participated in countless podcasts, documentaries, and other media and print publications espousing personal opinions regarding Ms. Maxwell's "guilt or innocence" and the "merits of the case," commenting on her "character and reputation," the "possibility of a plea of guilty to the offense charged or a lesser offense," and continually jeopardizing her right to a fair trial.2 + +Undersigned counsel wrote to the government expressing concern about a particular counsel's public remarks as that counsel has (we believe) previously represented one of the accusers. The government responded that "[t]o our knowledge, [that lawyer] does not represent any of the witnesses the Government expects to call at trial in this case. Because this individual does not represent any witnesses in this case, we do not see a need to raise this issue with the Court." Now, the government asserts that the Court needs to know about a lawyer who is not + +2 Ms. Maxwell previously brought to the Court's attention violations of Local Crim. R. 23.1 by David Boies, Esq. and his law partner, Sigrid McCawley, Esq., each having filed a notice of appearance as intervenors for accusers, as well as Bradley Edwards, Esq. (See Dkt. 27 at 4.) Many of their public and incendiary comments occurred after this Court "wam[ed] counsel and agents for the parties and counsel for potential witnesses that going forward it will not hesitate to take appropriate action in the fact of violations of any relevant rules." (Dkt. 28) (July 23, 2020). + +representing any party or witness to the case. Their position on the applicability of Rule 23.1 apparently fluctuates depending on who is talking to the press. + +Accordingly, we would ask the Court to be mindful of two important points. First, Ms. Maxwell has been, and continues to be, the subject of an unquestionable tsunami of adverse publicity every day, which is surely impacting the pool of jurors in the Southern District of New York. Second, efforts to persuade the public and the government that a defendant should not be prosecuted are permissible. See Gentile v. State Bar of Nevada, 501 U.S. 1030, 1043 (1991) ("A defense attorney may pursue lawful strategies to obtain dismissal of an indictment or reduction of charges, including an attempt to demonstrate in the court of public opinion that the client does not deserve to be tried."). + +Respectfully submitted: + +/s/ + +Bobbi C. Stemheim + +/s/ + +Christian R. Everdell + +Is/ + +Laura A. Menninger + +Is/ + +Jeffrey S. Pagliuca + +cc: Government counsel + +David Oscar Markus, Esq. \ No newline at end of file diff --git a/marker2/ds9/EFTA00087796/EFTA00087796.metadata.json b/marker2/ds9/EFTA00087796/EFTA00087796.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..32ce05a56982748ee039bf23f6e6bc8cb89d75ec --- /dev/null +++ b/marker2/ds9/EFTA00087796/EFTA00087796.metadata.json @@ -0,0 +1,166 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087796.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 5008, + "elapsed_seconds": 5.87, + "image_assets": [ + "_page_0_Picture_92.jpeg", + "_page_0_Picture_93.jpeg", + "_page_0_Picture_96.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "LAW OFFICES OF BOBBI C. 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Nathan United States District Court Southern District of New York + +Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +Dear Judge Nathan: + +Even though I do not currently represent Ms. Maxwell in any proceedings and have never entered an appearance in connection with her trial before Your Honor, the Government submitted a letter "to bring to the Court's attention" an article that I wrote on June 30, 2021, and asked that the Court "issue an order pursuant to Local Rule 23.1(h)" directed at me. (Dkt. No. 309). This Court ordered that I respond (Dkt. No. 312), and I do so here. I respectfully request that the Court deny the Government's request for the following reasons: + +## I. The local rules do not apply as I do not currently represent Ghislaine Maxwell in any proceeding and have not entered an appearance in this Court. + +Because undersigned counsel does not currently represent Ms. Maxwell in any court and has never entered an appearance as her lawyer in this Court, the local rules do not apply. See, e.g., Local Rule 23.1(h) (explaining that the Court "may issue a special order governing such matters as extrajudicial statements by parties and witnesseslikely to interfere with the rights of the accused to a fair trial by an impartial jury") (emphasis added). Because undersigned counsel does not represent a party or a witness, the Government's request should be denied. + +Undersigned counsel was previously retained to represent Ms. Maxwell's family. Then, when this Court denied her third bail application, undersigned counsel was retained to represent Ms. Maxwell in the Second Circuit on her bail appeal (and not regarding the merits of the case). That proceeding is concluded, and undersigned counsel no longer represents Ms. Maxwell in any capacity. + +![](_page_0_Picture_12.jpeg) + +Moreover, undersigned counsel has never entered an appearance in this Court and does not represent Ms. Maxwell in connection with her upcoming trial. In fact, undersigned counsel and Ms. Maxwell's trial team have been very careful to keep the representation separate. I have not been provided any of the trial discovery. + +The local rules do not and could not reach lawyers who do not represent a client (or witness) in a pending case because of the First Amendment. Gentile v. State Bar of Nevada, 501 U.S. 1030, 1074 (1991) (stating that "lawyers representing clients in pending cases may be regulated" by substantial prejudice standard and not heightened general First Amendment standard of clear danger) (emphasis added); id. at 1076 ("The regulation of attorneys' speech is limited—it applies only to speech that is substantially likely to have a materially prejudicial effect ... applying equally to all attorneys participating in a pending case") (emphasis added); see also United States v. Brown, 218 F.3d 415 (5th Cir. 2000) (discussing the factors to consider in entering a gag order for "trial participants'). + +The Government, however, argues that because Local Rule 23.1(a) states that lawyers "associated" with the "pending criminal litigation" are subject to the restrictions in local rules, the rule applies to undersigned counsel because of the appellate litigation in the Second Circuit regarding bail. As explained above, that litigation is concluded. The Government cites no authority for the proposition that the local rules would apply to a lawyer who previously entered an appearance in another court regarding litigation that has been concluded, nor could it since the Supreme Court has foreclosed such an expansive view of the ability to gag individuals not involved in the trial itself. + +Recognizing the weakness of its position, the Government states that because I asked for permission to bring my cell phone into the courtroom for the arraignment,' I must be associated with the litigation. But that example disproves the Government's claim that I am associated with this case. It is true that I asked the Court for permission to bring my phone into the courtroom, but the Court denied the request and said that I would have to enter an appearance in order to do so, as only lawyers actually associated with the proceedings could obtain permission to enter with electronics. Because I had not entered an appearance for Ms. Maxwell in this Court, I was not given such permission. + +Finally, the Government itself has taken the position that not all lawyers who have a connection to this case are governed by the local rules. For example, Ms. Maxwell's trial lawyers brought to the Government's attention that one of the accuser's + +1 At that time, I represented Ms. Maxwell before the Second Circuit and it was a few days before the oral argument. This was the only proceeding before this Court that I have attended in person or on Zoom. + +lawyers was making outrageously false statements to the press.2 The prosecution responded: "Spencer Kuvin does not represent any of the witnesses the Government expects to call at trial in this case. Because this individual does not represent any witnesses in this case," the local rules did not apply to him and there was no "need to raise this issue with the Court." + +## II. Even if the local rules somehow applied to undersigned counsel, the Op-Ed did not violate the local rule. + +Even if the local rule applies to a lawyer who does not currently represent a party or a witness and has never appeared in the trial court, the opinion piece here did not violate the rule. + +First, there is no risk of danger or prejudice to the upcoming trial because the Op-Ed raised the same argument — that the Cosby decision applied to Ms. Maxwell's case — that was filed in public pleadings that were quoted by the press. No confidential information was disclosed.2 Ms. Maxwell's trial lawyers made the very same argument in a public pleading that was quoted by the press. (Dkt. No. 310). In that public pleading, Ms. Maxwell's lawyers argue: + +The Pennsylvania Supreme Court held that DA Castor's promise was enforceable and that DA Ferman's prosecution of Mr. Cosby ten years later on the same charges violated his Due Process rights. (Id. at 78-79). As a result, the Court vacated Mr. Cosby's conviction. ad. at 79). In so holding, the Court noted the following: + +Interactions between a prosecutor and a criminal defendant, including circumstances where the latter seeks enforcement of some promise or assurance made by the former, are not immune from the dictates of due process and fundamental fairness. (Id. at 55). + +The same principle applies to Ms. Maxwell's case. As in Cosby, the government is trying to renege on its agreement and prosecute Ms. Maxwell over 25 years later for the exact same offenses for which she was granted immunity in the NPA. Indeed, the principle applies even more strongly in Ms. Maxwell's case because the NPA was a formal + +2 Emma Parry, Will She Survive?, (May 6, 2021), + +https://www.thesun.co.uk/news/14875477/ghislaine-maxwell-plea-deal-same-fate-asenstein/ + +3 See Gentile, 501 U.S. at 1074 (explaining that the risk of influencing a potential jury exists for trial lawyer because they "have special access to information through discovery and client communications" that others do not have). + +written agreement, as opposed to an informal promise like the one in Cosby. This is not consistent with principles of fundamental fairness. + +(emphasis added). + +The press (including Bloomberg, NBC, the New York Post, and Forbes)4 reported on this argument by Ms. Maxwell's lawyers. Accordingly, there is no substantial likelihood that the Op-Ed, which made the very same arguments that were made by Ms. Maxwell's lawyers and covered extensively in the press, will interfere with a fair trial, and the Government does not even really attempt to argue to the contrary.5 + +Second, Ms. Maxwell's family, and undersigned as counsel for her family, have the right to respond to the numerous lawyers, witnesses, and surrogates who are speaking to the press and making it impossible for Ms. Maxwell to receive a fair trial. As Justice Kennedy explained in Gentile, "in some circumstances press comment is necessary to protect the rights of the client and prevent abuse." Such "statements have the full protection of the First Amendment." Gentile, 501 U.S. at 1058 (Kennedy, J., concurring). + +The press has been unrelenting and overwhelmingly prejudicial in its coverage of Ms. Maxwell and her family, fueled by statements from involved parties about the matters at issue. It is not an understatement to say that 99.9% of the press coverage is pro-government and anti-Maxwell. The press has already tried and convicted her. And the Government has done nothing to control its surrogates, which has only made the problem worse. How can Ms. Maxwell be expected to receive a fair trial when lawyers for the accusers are holding press conferences, leaking information, and + +4 See, e.g., httos://www.bloombera.com/news/articles/2021-07-02/ahislaine-maxwellsays-cosbv-ruling-should-end-her-abuse-case; httos://www.nbcnews.com/news/usnews/ghislaine-maxwell-s-lawyers-cite-cosby-case-bid-have-sex-n1273037; https://nypost.com/2021/07/02/ghislaine-maxwell-should-be-sprung-from-prison-justlike-bill-cosby-lawyers/; and https://www.forbes.com/sites/joewalsh/2021/07/02Jghislaine-maxwell-tells-judge-hercase-should-be-tossed-out-like-cosbvs/?sh=68a89d9578bc + +6 The Government also complains that the Op-Ed described the accusations as "stale" and "flimsy." But both descriptions have been used in publicly filed pleadings. Moreover, many of the accusations are in fact decades old, and similar descriptive words have been held not to violate the rules. See, e.g., Law360, Brooklyn U.S. Attorney's Pretrial Remarks Fair Game, Judge Says, July 1, 2021 (reporting that Judge Dora Irizarry held that U.S. Attorney's comments that defendant had engaged in a "spree" of robberies that were "unprecedented" did not violate the local rule and also did not prejudice the defendant), story available at: https://tinyurl.comfribnu2kfz + +otherwise making wholly inappropriate comments to the press? + +For example, Spencer Kuvin (who represents some of Maxwell's accusers) was interviewed for a recent show on Peacock called Epstein's Shadow: Ghislaine Maxwell, which aired June 24, 2021. On Episode 3, Mr. Kuvin, who is identified as "Victim's Attorney," stated: "When you capture someone like [Ghislaine Maxwell] I don't besmirch the U.S. Government from taking a victory lap. To be able to come back one year later and say 'we've got the co-conspirator', they wanted a little good press, as well they should. Take her down and embarrass the hell out of her. It's what she deserves." In another example, Brad Edwards, counsel to numerous accusers, changed the subtitle of his book Relentless Pursuit after Ms. Maxwell's arrest from "My fight for the victims of Jeffrey Epstein" to "My fight for the victims of Jeffrey Epstein and Ghislaine Maxwell."6 + +These examples do not amount to a drop in the bucket of the overwhelming press against Ms. Maxwell, which has been instigated or fueled by the Government and its witnesses. The "circus atmosphere" and "hostile" press that led to a reversal in the Sam Sheppard case are no match for what is occurring here. See Sheppard v. Maxwell, 384 U.S. 333 (1966) (reversing conviction based on hostile television and radio reporting of case: "Given the pervasiveness of modern communications and the difficulty of effacing prejudicial publicity from the minds of the jurors, the trial courts must take + +6 There are countless other examples of the accusers' lawyers appearing on TV, podcasts, radio, print (including writing books about the case), and social media, making inflammatory and many times, untrue statements that will make it impossible for Ms. Maxwell to receive a fair trial (some of which occurred after the Court's Order about speaking with the media). See, e.g., Armchair Expert Podcast, August 6, 2020, Interview with Brad Edwards, counsel to accusers ("Q. How do you explain or what is your theory on Ghislaine Maxwell? Brad Edwards: So she needed money and Epstein needed connections. They were kind of the perfect pair. And then she realized, hey, this is this guy who has this crazy sex addiction that I can't fulfill. And I think she would have done anything for him. And so she starts feeding him and just fuels the addiction. Without her, there would be no Jeffrey Epstein, we wouldn't be talking. None of this would have happened. ... She created him. The first people that were brought to him to start this pyramid, they were brought by her. None of this could have grown. He could not have become who he was without her. She created the monster, no doubt about it."); BBC Panorama, December 2, 2019, interview with David Boies ("I must say I think she is very culpable. She was a central part of the Epstein sex trafficking operation. Er, she played an important role in recruiting, grooming, manipulating. Host: She denies all of this of course. [10 seconds of silence] Boies: Um, if you say so."); David Boies at press conference on the courthouse steps after the arraignment, April 24, 2021 (urging listeners not to have sympathy for Ms. Maxwell despite her conditions of confinement and her frail appearance); Sigrid McCawley, Lifetime, Surviving Jeffrey Epstein, August 15, 2020 ("Ghislaine was the master."). + +strong measures to ensure that the balance is never weighed against the accused."). The Government's contention that the prosecution won't receive a fair trial based on my statements is completely divorced from the reality of what is occurring in the media in this case.? + +Third, the Government has helped to create a totally unlevel playing field and it should not be heard to complain. For starters, the Government conducted an over-thetop press conference upon Ms. Maxwell's arrest — with blowups, photographs, soundbites, inflammatory language, and strategic pauses to get the most impactful photo opportunity, all designed to stir up the press, inflame the passions of the public, and prejudice the potential jury against Ms. Maxwell. And it worked. The Government's press conference was one of, if not the most, covered Government's press conferences in U.S. history. The Government's complaint about an Op-Ed that discusses the legal impact of the Cosby decision is the definition of chutzpah. + +![](_page_5_Picture_3.jpeg) + +Then-U.S. Attorney conducting a press conference on the arrest of Ms. Maxwell with visual aides + +The Government did not stop with the unjust press conference. It has continued to inflame the press with inappropriate and untruthful statements, thinking that + +TIn any event, Rule 23.1(h), which the Government cites as the authority to issue a "special order" here, is actually better viewed as concerned with the rights of the accused than the Government. See Rule 23.1(h) ("The Court, on motion of either party or on its own motion, may issue a special order governing such matters as extrajudicial statements by parties and witnesses likely to interfere with the rights of the accused to a fair trial by an impartial jury....") (emphasis added). + +because it is doing so in pleadings, it is not crossing the line in the local rules. For example, the Government filed in a public pleading that Ms. Maxwell was vaccinated while at MDC. (Dkt. No. 196). There was no valid reason for saying this at all, let alone in a public pleading. (Imagine if the defense publicly filed medical information about one of the accusers). But it believed that it could legally speak to the media in such a fashion. + +The Government also falsely claimed that Ms. Maxwell had an "eye mask" and that she was responsible for the stench in her cell. Id. Both claims were proven to be untrue. She has never been provided an eye mask and the stench in her cell is caused by a sewage problem in the jail, which has been well-documented by other inmates and judges. But the damage was done. The media went into a feeding frenzy, reporting the false Government statements and ignoring the truth when it came out. As Mark Twain said, "a lie can travel halfway around the world while the truth is still putting on its shoes." The Government's responsibility for the fair administration of justice commands it to foster a realignment of the scales. + +The Government's request should be denied because (1) undersigned counsel does not currently represent Ms. Maxwell, and (2) the Op-Ed did not violate the local rules. + +Sincerely, + +/s/ David Oscar Markus David Oscar Markus \ No newline at end of file diff --git a/marker2/ds9/EFTA00087799/EFTA00087799.metadata.json b/marker2/ds9/EFTA00087799/EFTA00087799.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..b2e65214743abc00299f7deab1e1a68c3610c0b9 --- /dev/null +++ b/marker2/ds9/EFTA00087799/EFTA00087799.metadata.json @@ -0,0 +1,379 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087799.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 7, + "chars": 16647, + "elapsed_seconds": 1.24, + "image_assets": [ + "_page_0_Picture_12.jpeg", + "_page_5_Picture_3.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "VIA EMAIL TO CHAMBERS", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 63.647999999999996, + 147.42000000000002 + ], + [ + 244.4344024658203, + 147.42000000000002 + ], + [ + 244.4344024658203, + 162.11248779296875 + ], + [ + 63.647999999999996, + 162.11248779296875 + ] + ] + }, + { + "title": "I. 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Produced : 02/21/2020 12:22:37 + +Produced By : + +Case Details + +Case Reference + +IDMS Reference + +Examiner + +Case Service Level + +Analysis Type + +Case Classification Level + +Service Level + +Open Date/Time + +Due Date/Time + +Case Status + +Contact Name + +Assigned Staff Member Name + +Record Status + +Case Background + +Background Attachment(s) + +Technical Review + +Technical Review + +Appropriate examinations have been performed to address request + +Report is clear and understandable + +The procedures performed were adequately documented and + +0453 + +2019-010614 + +PRIORITY + +False Statements + +UNCLASSIFIED + +30 Days + +12/12/2019 23:30:58 (-0500) + +01/11/2020 23:59:59 (-0500) + +Open + +Unlocked + +Request to analyze three BOP issued cell phones surrounding the Epstein suicide and investigation into staff failure to do proper rounds and falsification of documents. + +\*"Phones were not seized as evidence, no collection, no disposal, no ECDs. All phones manually reviewed on site at BOP and returned to users.\*\*\* + +Policy Memo 2019-02 re DOJ Order 2740.1A.pdf Manual Phone Review - notes and photos.docx + +Yes + +Yes + +Yes + +Exam documentation was sufficiently detailed to enable reproduction of the Yes results + +The interpretations and conclusions of the examiner were reasonable Yes + +Report is consistent with the examination documentation Yes + +Results media has been spot checked N/A + +Examiner performing review Date of review SA 02/13/2020 + +### Contact Details + +First Name + +Last Name + +Sector + +Primary Email + +Authority Contact Name + +Authority Contact Email + +Authority Status Approved + +# Case Assets + +New York Field Office + +Product Name iPhone + +Case Process Photos of devices and screenshots + +Tracked Asset No + +Asset Type Hardware + +Case Collection + +#### Evidence Details + +Evidence Reference 0001 + +Evidence Type PDA/Smart Phone + +Logged In + +Date/Time 02/12/2020 12:07:23 (-0500) + +Storage Location Disposed + +Priority + +Description + +Property Number 0214 207677 + +Seized Date/Time 08/22/2019 09:05:26 (-0500) + +Seized By/Produced + +By + +Powered Off Time 00:00:00 (+0000) + +Processing Result N/A + +Archived + +N/A BOP issued Samsung Galaxy S9 - + +No + +Notes Manual review only for messages related to job performance failure/Epstein suicide; SIM card and MicroSD not analyzed. + +Conducted By (Name) + +Manufacturer Samsung + +Model Galaxy S9 SM-G960U + +Serial Number R58M21CC8LB + +IMEI Label 355028093551622 + +Handset Type Touch Screen + +Handset Colour Black + +PIN/Security Code Locked No + +Damaged No + +Battery Flat No + +Capacity Value 0.00 Bytes + +Included SIM Card No + +Included Memory Card No + +Accessories No + +Attachment(s) IMG 0110.JPG + +Imaging Details + +Start Date/Time 01/01/0001 09:05:00 (-0500) + +End Date/Time 08/22/2019 09:20:00 (-0500) + +Conducted By (Name) + +Primary Extraction Software Manual Review + +Engineering Card Created No + +SMS Messages 1 + +Notes Manual review - 1 message of potential relevancy captured via screenshot. + +Evidence Reference 0002 + +Evidence Type PDA/Smart Phone + +Logged In 02/12/2020 12:11:20 (-0500) + +Date/Time + +Storage Location Disposed + +Priority N/A + +Description BOP Samsung Galaxy S9 issued to + +Property Number 0214 207672 + +Seized Date/Time 08/22/2019 09:15:07 (-0500) + +Seized By/Produced + +By + +Powered Off Time 00:00:00 (+0000) + +Processing Result N/A + +Archived No + +Pre-Imaging Details + +Manufacturer Model Serial Number IMEI Label Handset Type Handset Colour Samsung Galaxy S9 SM-G960U R58M210CDHX 355028093486118 Touch Screen Black PIN/Security Code Locked No No No 0.00 Bytes No No No IMG 0114.JPG Notes Damaged Battery Flat Capacity Value Included SIM Card Included Memory Card Accessories Attachment(s) Imaging Details Start Date/Time 08/22/2019 09:15:00 (-0500) End Date/Time 08/22/2019 09:27:00 (-0500) Conducted By (Name) Primary Extraction Software Manual Review Engineering Card Created No Notes Manual review - no items of relevance located. Evidence Reference 0003 Evidence Type Logged In Date/Time Storage Location Priority Description Property Number Seized Date/Time PDA/Smart Phone 02/12/2020 12:13:16 (-0500) Disposed N/A BOP Samsung Galaxy S9 issued to 0214 207675 08/22/2019 09:40:05 (-0500) Seized By/Produced By Powered Off Time 00:00:00 (+0000) Processing Result N/A Archived No Manual review only for messages related to job performance failure/Epstein suicide; SIM card and MicroSD not analyzed. Pit-Imaging Details Start Date/Time 08/22/2019 09:40:00 (-0500) End Date/Time 08/22/2019 10:08:00 (-0500) Conducted By (Name) Manufacturer Samsung Model Galaxy S9 SM-G960U Serial Number R58M210D9MR IMEI Label 355028093495721 + +Handset Type Touch Screen Handset Colour Black PIN/Security Code Locked No Damaged No Battery Flat No Capacity Value 0.00 Bytes Included SIM Card No Included Memory Card No Accessories No Attachment(s) IMG 0117.JPG Imaging Details Start Date/Time 08/22/2019 09:40:00 (-0500) End Date/Time 08/22/2019 10:08:00 (-0500) Conducted By (Name) Primary Extraction Software Manual Review Engineering Card Created No Notes Manual review - no items of relevance located. 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device from network + +photos on [REDACTED] phone second set ending with property # + +manual review by [REDACTED] + +![](_page_4_Picture_16.jpeg) + +![](_page_5_Picture_0.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00087819/EFTA00087819.metadata.json b/marker2/ds9/EFTA00087819/EFTA00087819.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..a488b9343cbc5b732d4b0fb6f83e39b4e69fa08b --- /dev/null +++ b/marker2/ds9/EFTA00087819/EFTA00087819.metadata.json @@ -0,0 +1,226 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087819.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 7, + "chars": 945, + "elapsed_seconds": 2.82, + "image_assets": [ + "_page_0_Picture_18.jpeg", + "_page_1_Picture_0.jpeg", + 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Not sure if he is reaching out to you or not but remember to stick to the script. \*Can't comment on that. + +Wednesday, August 14, 2019 + +10Just sent you an email + +7:56 AM \ No newline at end of file diff --git a/marker2/ds9/EFTA00087826/EFTA00087826.metadata.json b/marker2/ds9/EFTA00087826/EFTA00087826.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..4d5f0af13eb12f1bb97967c7b6f80d0a4d01d554 --- /dev/null +++ b/marker2/ds9/EFTA00087826/EFTA00087826.metadata.json @@ -0,0 +1,64 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087826.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 450, + "elapsed_seconds": 1.61, + "image_assets": [ + "_page_0_Picture_1.jpeg", + "_page_0_Picture_2.jpeg", + "_page_0_Picture_3.jpeg", + "_page_0_Picture_4.jpeg", + "_page_0_Picture_10.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 70 + ], + [ + "Line", + 17 + ], + [ + "Text", + 11 + ], + [ + "Picture", + 5 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087826" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087826/_page_0_Picture_1.jpeg b/marker2/ds9/EFTA00087826/_page_0_Picture_1.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..d352c6bf6ffb0e7bd6db18f6f615460109233695 --- /dev/null +++ b/marker2/ds9/EFTA00087826/_page_0_Picture_1.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:78115e461e85581bc0cebd058bc8b5fd68f302f0058c232874ec7f9762c96083 +size 9216 diff --git a/marker2/ds9/EFTA00087826/_page_0_Picture_10.jpeg b/marker2/ds9/EFTA00087826/_page_0_Picture_10.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..c16bb8a113e30574b2dadffd1a54d6bf206b307d --- /dev/null +++ b/marker2/ds9/EFTA00087826/_page_0_Picture_10.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:d945baa3be3017db6046959a5432f522bbfb8d49514b9b5846176fe1b682f7fa +size 11399 diff --git a/marker2/ds9/EFTA00087826/_page_0_Picture_2.jpeg b/marker2/ds9/EFTA00087826/_page_0_Picture_2.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..b3b1bed44be4fc7da2160f9a58b96bf010010073 --- /dev/null +++ b/marker2/ds9/EFTA00087826/_page_0_Picture_2.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:5980eaaf8d14c4460047c9d1cd5682181e24e4d505919acd8f44b6a5371853ea +size 2249 diff --git a/marker2/ds9/EFTA00087826/_page_0_Picture_3.jpeg b/marker2/ds9/EFTA00087826/_page_0_Picture_3.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..cb58c03cfb90f12f7fc136ae9a347f75c125a57a --- /dev/null +++ b/marker2/ds9/EFTA00087826/_page_0_Picture_3.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:0af25cf4341e5f3c00ea634f97903ad98df64e37a6e799c22439969f26a3ba7f +size 2568 diff --git a/marker2/ds9/EFTA00087826/_page_0_Picture_4.jpeg b/marker2/ds9/EFTA00087826/_page_0_Picture_4.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..77bdd474af8df56ea3906535d214317fd9e40967 --- /dev/null +++ b/marker2/ds9/EFTA00087826/_page_0_Picture_4.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:0751d6444a2b89d3d3140fa62d44c1c2d474dcfaaa20c1b0cd4c4f22f84fdd5a +size 1461 diff --git a/marker2/ds9/EFTA00087827/EFTA00087827.md b/marker2/ds9/EFTA00087827/EFTA00087827.md new file mode 100644 index 0000000000000000000000000000000000000000..0f91059e608b674d9f554ae32e649a5175868c9f --- /dev/null +++ b/marker2/ds9/EFTA00087827/EFTA00087827.md @@ -0,0 +1,32 @@ +## Office of the Inspector General REPORT OF FORENSIC EXAMINATION + +| SUBMITTER | | DATE SUBMITTED CASE NUMBER | +|-------------------------------|-----------------------|-----------------------------------------------------| +| Special Agent | New York Field Office | August 13, 2019 2019-010614 | +| OFFICE CONDUCTING EXAMINATION | CYBER ID | SUBJECT(S) | +| Cyber Investigations Office | 0384 | Correctional Officer Michael Thomas, Federal Bureau | + +## Synopsis + +On August 22, 2019, U.S. Department of Justice Office of the Inspector General (OIG), C ber Investi ations Office (CYBER) Special Agent (SA) and Assistant Special Agent in Charge received and manually reviewed Devices 1-3 at the Federal Bureau of Prisons (BOP) Metropolitan Correctional enter, located in New York, NY. M and were assisted by OIG Washington Field Office SA and OIG Fraud Detection Office SA . Devices 1-3 were BOP issued mobile devices which were provided to CYBER in order to determine whether or not they contained any unauthorized communication related to the suicide of Jeffery Epstein. + +OIG New York Field Office SA was investigating alleged BOP employee misconduct related to Epstein's suicide, and sought the review of Devices 1-3 out of an abundance of caution. There were no allegations of misconduct against the BOP employees to whom Devices 1-3 had been issued. Accordingly, CYBER personnel elected to perform only manual reviews of the phones to limit the disruption of service and to minimize the intrusiveness of the review. In order to fully analyze the BOP devices with forensic tools, CYBER would have had to have manipulated settings on each phone which would have resulted in a loss of data and the need to wipe and reissue each one. The manual review did not limit the data CYBER would have been able to recover using forensic tools for this model phone. + +On December 7, 2019, submitted an OIG Digital Forensics Examination Request form seeking a review of Devices 1-3 for the aforementioned data. + +The CYBER manual review consisted of a search for communication capable applications on each device, excluding email. Onl i.tative tl device messaging application on each device was found to meet the criteria of the search. and reviewed all messages within the application that occurred after Epstein's suicide + +## SENSITIVE BUT UNCLASSIFIED + +| EXAMINER NAME AND TITLE: SA REVIEWER NAME AND TITLE: | ASAC | +|------------------------------------------------------|-----------------------------------| +| SIGNATURE: | Digitally signed by | +| Justice,ou=OIG,cn | 09.2342.19200300.100.1.1=15001002 | +| 0.9.2342.19200300.100.1.1=15001001073402 | 300273 | +| Date: 2020.02202137x11 | Dale 2020.02.21 07A2A4 -0\$00, | + +on the morning of August 10, 2019. The search did not reveal any messages that appeared to contain inappropriate or unauthorized communication related to Epstein's death. Only one message, located on Device I, was found to relate to the topic of Epstein. The message appeared to be an appropriate exchange that served to reiterate the staff's instructions not to comment on the ongoing matter. A copy of the message can be viewed by clicking this link. + +All documentation related to this forensic request will be retained by CYBER on the Archive Network Attached Storage located in the New York City lab under this case number. + +A LIMA forensic case management system report containing all examiner process notes, photos, tool details and forms associated with this request is incorporated by reference, and has been provided to the requestor in electronic format with this report. The analysis result file provided to is also included in electronic format with this report. \ No newline at end of file diff --git a/marker2/ds9/EFTA00087827/EFTA00087827.metadata.json b/marker2/ds9/EFTA00087827/EFTA00087827.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..d329ab50ef12fc1dc8bf420709f5390509f4475d --- /dev/null +++ b/marker2/ds9/EFTA00087827/EFTA00087827.metadata.json @@ -0,0 +1,166 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087827.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 4052, + "elapsed_seconds": 0.63, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Office of the Inspector General REPORT OF FORENSIC EXAMINATION", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 33.04999923706055, + 74.52 + ], + [ + 593.64, + 74.52 + ], + [ + 593.64, + 89.85357666015625 + ], + [ + 33.04999923706055, + 89.85357666015625 + ] + ] + }, + { + "title": "Synopsis", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 34.272, + 302.94 + ], + [ + 92.74044799804688, + 302.94 + ], + [ + 92.74044799804688, + 318.9735412597656 + ], + [ + 34.272, + 318.9735412597656 + ] + ] + }, + { + "title": "SENSITIVE BUT UNCLASSIFIED", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 216.036, + 656.1 + ], + [ + 406.67291259765625, + 656.1 + ], + [ + 406.67291259765625, + 671.8535461425781 + ], + [ + 216.036, + 671.8535461425781 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 102 + ], + [ + "Line", + 47 + ], + [ + "Text", + 4 + ], + [ + "SectionHeader", + 3 + ], + [ + "Table", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 29 + ], + [ + "Line", + 15 + ], + [ + "Text", + 4 + ], + [ + "PageFooter", + 3 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087827" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087829/EFTA00087829.md b/marker2/ds9/EFTA00087829/EFTA00087829.md new file mode 100644 index 0000000000000000000000000000000000000000..33e3db227afa1dc15dbd960d4ee4d13f20c89fc2 --- /dev/null +++ b/marker2/ds9/EFTA00087829/EFTA00087829.md @@ -0,0 +1,60 @@ +**From:** "[REDACTED]" <[REDACTED]> +**To:** "[REDACTED]" <[REDACTED]> +**Cc:** "[REDACTED]" <[REDACTED]>, "[REDACTED] (USANYS)" <[REDACTED]>, "[REDACTED] (USANYS)" <[REDACTED]> +**Subject:** Re: Epstein investigation, [REDACTED] prosecution memo +**Date:** Thu, 16 Apr 2020 14:04:12 +0000 + +--- + +Same thanks + +On Apr 16, 2020, at 9:56 AM, [REDACTED] <[REDACTED]> wrote: + +Same thanks + +On Apr 16, 2020, at 09:54, [REDACTED] <[REDACTED]> wrote: + +Same here, thanks. + +Sent from my iPhone + +On Apr 16, 2020, at 9:46 AM, [REDACTED] (USANYS) <[REDACTED]> wrote: + +Good for me + +Sent from my iPhone + +On Apr 16, 2020, at 9:39 AM, [REDACTED] (USANYS) <[REDACTED]> wrote: + +[Does that work for you guys?](#) + +--- + +**From:** Berman, Geoffrey (USANYS) <[REDACTED]> +**Sent:** Thursday, April 16, 2020 9:38 AM +**To:** [REDACTED] <[REDACTED]>; Strauss, Audrey (USANYS) +<[REDACTED]>; [REDACTED] <[REDACTED]> +<[REDACTED]>; [REDACTED] <[REDACTED]> +**Cc:** [REDACTED] (USANYS) <[REDACTED]>; [REDACTED] (USANYS) <[REDACTED]>; +[REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]>; +**Subject:** RE: Epstein investigation, [REDACTED] prosecution memo + +Thanks for the memo. Can we have a conference call on Monday at 11am? Geoff + +--- + +**From:** [REDACTED] <[REDACTED]> +**Sent:** Wednesday, April 15, 2020 5:39 PM +**To:** Berman, Geoffrey (USANYS) <[REDACTED]>; [REDACTED]; [REDACTED]; +[REDACTED] +(USANYS) <[REDACTED]> + +) + +Subject: RE: Epstein investigation, prosecution memo + +![](_page_1_Picture_3.jpeg) + +thanks, + +Assistant U.S. Attorney Southern District of New York \ No newline at end of file diff --git a/marker2/ds9/EFTA00087829/EFTA00087829.metadata.json b/marker2/ds9/EFTA00087829/EFTA00087829.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..a1cb9236b053d491594435d2cd0c5bdaf15eb9f1 --- /dev/null +++ b/marker2/ds9/EFTA00087829/EFTA00087829.metadata.json @@ -0,0 +1,90 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087829.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 1558, + "elapsed_seconds": 44.67, + "image_assets": [ + "_page_1_Picture_3.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 85 + ], + [ + "Text", + 42 + ], + [ + "Line", + 38 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 13 + ], + [ + "Text", + 8 + ], + [ + "Line", + 7 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087829" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087829/_page_1_Picture_3.jpeg b/marker2/ds9/EFTA00087829/_page_1_Picture_3.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..6afcdab8fc02d3bc975d810859f422580084224c --- /dev/null +++ b/marker2/ds9/EFTA00087829/_page_1_Picture_3.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:1035533a5c85476e88d0bf5bb047ccb681db761fcae045161abf673853316057 +size 17146 diff --git a/marker2/ds9/EFTA00087831/EFTA00087831.md b/marker2/ds9/EFTA00087831/EFTA00087831.md new file mode 100644 index 0000000000000000000000000000000000000000..5843acfd62917372c1a73ac0892527c2bf4078f6 --- /dev/null +++ b/marker2/ds9/EFTA00087831/EFTA00087831.md @@ -0,0 +1,51 @@ +![](_page_0_Picture_1.jpeg) + +United States Attorney Southern District of New York + +86 Cheettbers sum New York New Yoe\* 10007 + +April 15, 2020 + +## By ECF + +The Honorable Paul A. Engelmayer United States District Judge Southern District of New York 40 Foley Square New York, NY 10007 + +Re: The New York Times Co. v. Federal Bureau of Prisons, 20 Civ. 833 (PAE) + +Dear Judge Engelmayer: + +This Office represents defendant the Federal Bureau of Prisons ("BOP") in this Freedom of Information Act ("FOIA"), 5 U.S.C. § 552, action brought by plaintiff the New York Times Company (the "Times"). The parties respectfully submit this joint letter pursuant to the Court's Orders of March 5 and 13, 2020. See Dkt. Nos. 8, 10. The initial pretrial conference in this matter is currently scheduled to be held at 11:00 AM on April 20, 2020. See Dkt. No. 10. The parties respectfully propose that the initial pretrial conference be adjourned if this letter sufficiently addresses the present issues in this case. + +On January 30, 2020, the Times filed its complaint initiating this action. See Dkt. No. 1. The Times seeks, pursuant to FOIA, the release of certain documents related to Jeffrey Epstein, the deceased defendant in United States v. Jeffrey Epstein, No. 19-CRIM-00490 (S.D.N.Y.), and his BOP custody. On March 4, 2020, the Government filed its Answer to the Times's complaint. See Dkt. No. 7. BOP has not produced any documents in response to the Times's request. The Government's position is that any documents potentially responsive to the Times's request are exempt from disclosure under FOIA, including under FOIA Exemption 7(A), which protects from disclosure records or information compiled for law enforcement purposes "to the extent that the production of such law enforcement records or information . . . could reasonably be expected to interfere with enforcement proceedings?' 5 U.S.C. § 552(bX7)(A). + +The parties anticipate filing cross-motions for summary judgment on whether BOP's withholdings are appropriate under FOIA, but have failed to agree on a schedule for summary judgment briefing. The Government proposes to file its motion for summary judgment by July 15, 2020, with plaintiff's opposition and cross-motion for summary judgment due by August 17, 2020, the Government's reply and opposition due by September 7, 2020, and plaintiff's reply due by September 28, 2020. The Government respectfully requests a longer period of time than usual to file its opening brief and declaration in this matter because of the national emergency arising from COVID-19, to which the Government and BOP have dedicated substantial resources and which has affected BOP's operations and staffing, including BOP's FOIA staffing. + +The Times acknowledges the disruption caused by the COVID-19 pandemic and is of course willing to be flexible on the timing of summary judgment briefing. However, the time sought by the Government appears to the Times unnecessary for a case filed in January 2020 involving a + +blanket assertion of exemptions. Accordingly, the Times proposes that the Government file its motion for summary judgment by May 25, 2020 and that The Times file its opposition and crossmotion for summary judgment by June 29, 2020, with the Government's reply and opposition due by July 20, 2020, and The Times's reply due by August 10, 2020. + +The parties do not believe that settlement is possible at this time. + +As this is a FOIA action, the parties anticipate that any legal issues will be resolved through cross-motions for summary judgment without discovery. See, e.g., Wood y. FBI, 432 F.3d 78, 85 (2d Cir. 2005); Carney v. U.S. Dep'r of Justice, 19 F.3d 807, 812-13 (2d Cir. 1994). Accordingly, the parties respectfully request that they not be required to submit the proposed case management plan and scheduling order called for in the Court's Orders of March 5 and 13, 2020, particularly in light of the proposed summary judgment briefing schedule proposed herein. See Dkt. Nos. 8, 10. + +The parties thank the Court for its consideration of this submission. + +Respectfully submitted, + +GEOFFREY S. BERMAN United States Attorney + +By: / + +86 Chambers Street, 3rd Floor New York, NY 10007 Telephone: Fax: ( 7 Email: + +Cc (by ECF): Counsel of Record + +4/15/20 + +The Court appreciates this letter. The parties will not be required to submit a proposed case management plan and scheduling order. The initial pretrial conference will be held telephonically, as scheduled, at 11 a.m. on April 20, 2020. + +Dial-In: (888) 363-4749 or (215) 446-3662 + +Access Code: 4684906 + +SO ORDERED. Pa A. PAUL A. 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First, will your client participate in a voluntary interview, either in person or via video, with our office? Second, will your client answer questions — in writing or otherwise -- about the full range of topics relevant to our ongoing investigation, including events not covered by the currently pending indictment against Ghislaine Maxwell? + +Please note that we will interpret a repeat of your client's offer to answer written questions relevant to the Maxwell indictment as an answer in the negative as to both questions. + +Best, + +Assistant United States Attorney Southern District of New York 1 St. Andrew's Plaza New York, NY 10007 + +From: Gary Bloxsome Sent: Monday, September 14, 2020 5:39 AM To: Cc: Richardson (USANYS) Subject: Re: Reference materials further to our call > >; Daniel Cundy Jennifer + +Dear + +Our client has offered voluntarily to provide a written witness statement in relation to the criminal indictment against Ghislaine Maxwell and has also offered to answer questions in writing in relation to events relevant to that indictment even if they fall outside of the period of the indictment (1994 to 1997). + +We look forward to hearing from you further. + +Kind regards + +Gary + +Gary Bloxsome I Partner + +Blackfords LLP 15 Old Bailey I London I EC4M 7EF DX 161400 Old Bailey 5 I 020 3427 3343 I www.blackfords.com + +![](_page_1_Picture_6.jpeg) + +COVID-19 — Please see our website here for our updated position in relation to Coronavirus. + +In the meantime if you need to speak to one of our lawyers, please leave a voicemail by dialling 020 8686 6232 where we will respond to the messages in the order they are received or by emailing your enquiry to covidPblackfords.com + +Blackfords LLP is a limited liability partnership registered in England & Wales with registered number OC325398 at Hill House, 1 Mint Walk, Croydon, CR0 lEA. 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 10 Sep 2020, at 21:00, wrote: + +External email: is it safe to open attachments and links? + +Gary, + +Thank you for your email of September 1, 2020. We would like to confirm our understanding of that correspondence, as informed by all of our communications over the past few months, as conveying that (1) your client will not participate in a voluntary interview—either in person or via videoconference—with our office, and (2) that your client will not voluntarily answer questions, even as part of a written statement, regarding events that took place outside of the period 1994 to 1997. Please let us know if our understanding is incorrect. + +Thank you, + +Assistant United States Attorney Southern District of New York I St. Andrew's Plaza + +From: ) 4:= + +Sent: Tuesday, September 1, 20201:35 PM + +To: Gary Bloxsome ; Daniel Cundy Jennifer + +Richardson + +Cc: (USANYS) + +Subject: RE: Reference materials further to our call + +Gary, + +We have received the below communication, and we will revert back as appropriate. + +thank you, + +Assistant U.S. Attorney Southern District of New York + +From: Gary Bloxsome + +Sent: Tuesday, September 01, 2020 13:04 + +To: < >; < >; Daniel Cundy ; Jennifer Richardson + +Subject: Re: Reference materials further to our call + +Dear + +We have found our recent conferences with you and your team (on 27 July, 3, 11 and 20 August 2020) helpful and informative and again I extend my thanks for your taking the time to discuss these matters at length. + +In the UK the provision of a signed witness statement - bearing a statement attesting as to its truth - is a commonly used approach when a witness provides evidence. Whilst we appreciate that such an approach differs from what is standard in the US, we do not consider such an approach would be unhelpful, or of no utility, to your case. Our client is willing to provide you with a witness statement, addressing any issues that he may be able to,in relation to Ghislaine Maxwell and Jeffrey Epstein, his association with them and his knowledge of them such as may be relevant to the prosecution of Ghislaine Maxwell. In addition - should you make written requests for clarification arising from that witness statement our client could provide written answers by way of a supplementary/addendum statement. Such an interaction could take place more than once if necessary. Providing written answers to either written questions or to questions previously put, is again a common practice in the UK. + +You have invited us to identify any areas or subject topics which we would consider to be inappropriate or irrelevant to be put to our client; we consider that questions put/topics raised should rightfully be limited to the indictment period in the current proceedings (i.e. US v Ghislaine Maxwell), being 1994-1997. + +We are of course aware that you have requested a witness interview in your request to the UKCA and to ourselves; you have confirmed to us however (in January this year, through your liaison officer immediately prior to our recent conferences, and then during our conferences) that you regard our client not as a witness but as a subject. We have ventilated at some length our concerns regarding our client being interviewed in those circumstances and we consider a witness statement and the offer of further engagement with written questioning to be a fair compromise and one which would be acceptable in the UK. + +To move forward with the above approach, we would continue to require your assurance that the content of any such witness statement and supplementary written responses be treated with the utmost confidentiality, not used for any purpose other than in relation to the criminal proceedings against Ms Maxwell, and not be shared with any parties outside of your department, including complainants and their representatives in your investigation and in civil matters outside of it. + +Kind regards + +Gary + +Gary Bloxsome I Partner + +Blackfords LLP 15 Old Bailey I London I EC4M 7EF DX 161400 Old Bailey 5 I 020 3427 3343 I www.blackfords.com + +COVID-19 - Please see our website here for our updated position in relation to Coronavirus. + +In the meantime if you need to speak to one of our lawyers, please leave a voicemail by dialling 020 8686 6232 where we will respond to the messages in the order they are received or by emailing your enquiry to covidPblackfords.com + +Blackfords LLP is a limited liability partnership registered in England & Wales with registered number OC325398 at Hill House, 1 Mint Walk, Croydon, CR0 lEA. 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 19 Aug 2020, at 18:19, ) wrote: + +External email: is it safe to open attachments and links? + +Received, thank you. We'll speak with you then. + +From: Gary Bloxsome Sent: Wednesday, August 19, 2020 12:39 To: ) Cc: ) < M>; >; Jennifer Richardson < ; Daniel Cundy Subject: Re: Reference materials further to our call + +Same dial in details as before. + +Regards + +Gary Bloxsome l Partner + +Blackfords LLP 115 Old Bailey I London I EC4M 7EF DX 161400 Old Bailey 5 I 020 3427 3343 I www.blackfords.com + +COVID-19 — Please see our website here for our updated position in relation to Coronavirus. + +In the meantime if you need to speak to one of our lawyers, please leave a voicemail by dialling 020 8686 6232 where we will respond to the messages in the order they are received or by emailing your enquiry to covidPblackfords.com + +Blackfords LLP is a limited liability partnership registered in England & Wales with registered number OC325398 at Hill House, 1 Mint Walk, Croydon, CR0 lEA. 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 19 Aug 2020, at 17:36, c > wrote: + +External email: is it safe to open attachments and links? + +Gary, + +Are we still planning to speak via phone tomorrow at 2:30 London time? + +Regards, + +From: Daniel Cundy Sent: Sunday, August 09, 2020 12:30 To: Cc: Bloxsome <1.1 .>; Jennifer Richardson Subject: Reference materials further to our call >; Gary + +DearM + +Apologies for the slight delay. + +Please find attached an extract from The Decision Procedure and Penalties manual (DEPP 7) from the Financial Conduct Authority handbook — drawing attention to 7.2.14. This practice and approach resonates with the law as set out in United States v. Allen, 864 F.3d (2d Cir.2017). We also attach an extract from the publication 'Montgomery and Ormerod on Fraud: Criminal Low and Procedure' (2008) which summarises the approach taken by the Serious Fraud + +Office (see A7-327) to the limitations and protections on use when their compulsory powers are used in MLAT requests, an approach which reflects such cases as Kastigar v. United States, 406 U.S. 441 (1972) as well as decisions in UK domestic law. We reiterate the protection at Article 7 (2) of the MLAT treaty although there is no need to attach it. + +Kind regards + +Daniel Cundy I Partner + +Blackfords LLP 15 Old Bailey I London I IC4M 7EF DX 161400 Old Bailey 5 I 020 3427 3343 I www.blackfords.com + +COVID-19 — Please see our website here for our updated position in relation to Coronavirus. + +In the meantime if you need to speak to one of our lawyers, please leave a voicemail by dialling 020 8686 6232 where we will respond to the messages in the order they are received or by emailing your enquiry to covid@blackfords.com + +Blackfords LLP is a limited liability partnership registered in England & Wales with registered number OC325398 at Hill House, 1 Mint Walk, Croydon, CR0 lEA. 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. + +Daniel Cundy I Partner + +Blackfords LLP 15 Old Bailey I London I EC4M 7EF DX 161400 Old Bailey 5 I 020 3427 3343 I www.blackfords.com + +COVID-19 — Please see our website here for our updated position in relation to Coronavirus. + +In the meantime if you need to speak to one of our lawyers, please leave a voicemail by dialling 020 8686 6232 where we will respond to the messages in the order they are received or by emailing your enquiry to covidPblackfords.com + +Blackfords LLP is a limited liability partnership registered in England & Wales with registered number OO25398 at Hill House, 1 Mint Walk, Croydon, CR0 lEA. 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Attached for your reference individuals identified by ); and email. + +Thank you! + +Best regards, + +From: [REDACTED] + +Sent: Tuesday, July 28, 2020 5:18 PM + +To: [REDACTED] + +[REDACTED] + +Cc: [REDACTED] + +Subject: [EXTERNAL EMAIL] - RE: [REDACTED] / [REDACTED] + +Of course, absolutely. We don't have anything scheduled, but we're hoping to talk with him in the coming weeks and we'll keep you in the loop. + +From: [REDACTED] + +Sent: Tuesday, July 28, 2020 08:27 + +To: [REDACTED] + +[REDACTED] + +Cc: [REDACTED] + +Subject: [REDACTED] / [REDACTED] + +Hi [REDACTED] – We talked internally here, and if not too much trouble, [REDACTED] + +[REDACTED] + +Thanks so much for the help. + +Best regards, + +[REDACTED] + +Special Agent + +FBI New York Office + +[REDACTED] \ No newline at end of file diff --git a/marker2/ds9/EFTA00087839/EFTA00087839.metadata.json b/marker2/ds9/EFTA00087839/EFTA00087839.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..c626ce57382ae873c920f6a4ce082de775d40ba1 --- /dev/null +++ b/marker2/ds9/EFTA00087839/EFTA00087839.metadata.json @@ -0,0 +1,88 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087839.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 1381, + "elapsed_seconds": 4.18, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 65 + ], + [ + "Line", + 32 + ], + [ + "Text", + 13 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 44 + ], + [ + "Span", + 37 + ], + [ + "Line", + 19 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087839" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087841/EFTA00087841.md b/marker2/ds9/EFTA00087841/EFTA00087841.md new file mode 100644 index 0000000000000000000000000000000000000000..e37d173b402949755101490d73e8381c3e595c50 --- /dev/null +++ b/marker2/ds9/EFTA00087841/EFTA00087841.md @@ -0,0 +1,37 @@ +From: + +To: + +Cc: + +Subject: Re: Subject: JEFFREY E EPSTEIN, 2020PR000426AMB + +Date: Mon, 14 Sep 2020 19:44:02 +0000 + +I don't believe it will include GJ materials, but I will confirm and work with my contact there to figure out how to get the GJ files. I'm hoping it will include SW materials, but if not, they can help us get it from the clerk's office (and we have a signed copy from the Reuter file). + +On Sep 14, 2020, at 3:36 PM, wrote: + +That's great! Will this include grand jury materials and the SW materials? + +Sent from my iPhone + +On Sep 14, 2020, at 3:32 PM, wrote: + +PBSA is giving us their entire Epstein file. + +when I get the email with the info about how to download the file, I'll forward it to you. Would you please + +---Original Message--- + +From• + +Sent: Monday, September 14, 2020 3:23 PM + +To: + +Subject: Subject: JEFFREY E EPSTEIN, 2020PR000426AMB + +The attached document is in regard to the above referenced case, to which you are a party of or have an interest in. If you have any questions, please contact our office at - + +FINAL LETTER.PDF> \ No newline at end of file diff --git a/marker2/ds9/EFTA00087841/EFTA00087841.metadata.json b/marker2/ds9/EFTA00087841/EFTA00087841.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..ee13bdffa7ad074ad53748cdb52ede2cde3e60a2 --- /dev/null +++ b/marker2/ds9/EFTA00087841/EFTA00087841.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087841.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1052, + "elapsed_seconds": 0.83, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 50 + ], + [ + "Line", + 25 + ], + [ + "Text", + 19 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087841" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087842/EFTA00087842.md b/marker2/ds9/EFTA00087842/EFTA00087842.md new file mode 100644 index 0000000000000000000000000000000000000000..8b7a226cdc567f4d7a741fe3f96914c7c421e6a4 --- /dev/null +++ b/marker2/ds9/EFTA00087842/EFTA00087842.md @@ -0,0 +1,41 @@ +**From:** + +[REDACTED] + +**To:** + +[REDACTED] + +**Cc:** + +[REDACTED] + +**Subject:** FW: Epstein Related Civilian Crime Report Submission ([REDACTED]) + +**Date:** Tue, 22 Sep 2020 14:46:58 +0000 + +**Attachments:** [REDACTED] Int'l\_re\_Epstein.pdf + +[REDACTED] + +Forwarding per our usual practice. + +Thanks, + +[REDACTED] + +--- + +**From:** [REDACTED] + +**Sent:** Tuesday, September 22, 2020 10:35 AM + +**To:** [REDACTED] + +[REDACTED] + +**Cc:** [REDACTED] + +**Subject:** Epstein Related Civilian Crime Report Submission ([REDACTED]) + +Attached is a submission from a civilian. It purports to relate to Epstein. Because it is from someone in a foreign country, we do not respond. In any event, there is nothing more for you to do if this is not of any use. If we get anything else, we will forward it along. [REDACTED], please make a note in the log. Thanks. \ No newline at end of file diff --git a/marker2/ds9/EFTA00087842/EFTA00087842.metadata.json b/marker2/ds9/EFTA00087842/EFTA00087842.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..88afb6b1fc9f0b7285752325094d26ac488451b7 --- /dev/null +++ b/marker2/ds9/EFTA00087842/EFTA00087842.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087842.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 834, + "elapsed_seconds": 4.35, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 41 + ], + [ + "Span", + 35 + ], + [ + "Line", + 18 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087842" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087843/EFTA00087843.md b/marker2/ds9/EFTA00087843/EFTA00087843.md new file mode 100644 index 0000000000000000000000000000000000000000..db8ce2e477edb46c08a556215345041c753a4422 --- /dev/null +++ b/marker2/ds9/EFTA00087843/EFTA00087843.md @@ -0,0 +1,55 @@ +From: To: Cc: a > " (USANYS)" + +Subject: RE: FW: Letter + +Date: Thu, 24 Sep 2020 18:43:57 +0000 + +Inline-Images: image001.png; image002.jpg + +Hi =, + +I'm going to be tied up until about 5pm. Can I call you after that? If not, would tomorrow early morning work? + +Thanks, + +From: Sent: Thursday, September 24, 2020 1:43 PM To: Cc: Subject: Re: FW: Letter >; (USANYS) < + +HI + +Do you have time for a quick call today? Either before 3 or after 4? Want to make sure I've got all the answers for you (or if I need to do any more following up, I can still do it tomorrow). + +>>>" "< Hi > 9/22/2020 11:15 AM >> > + +Please see the attached letter from Maxwell's counsel. Would you be available for a call to discuss this afternoon, please? + +Thanks, + +Assistant United States Attorney Southern District of New York I St. Andrew's Plaza New York, NY 10007 + +From: Christian Everdell < Sent: Monday, September 21, 2020 10:33 PM To: >; >; + +subject: Letter + +Alison, and Lara — + +Please see the attached letter regarding Ghislaine Maxwell. Thank you in advance for your attention to these matters. + +Regards, + +Chris + +Christian Everdell + +COHEN & GRESSER LLP + +800 Third Avenue NIP,Ar Vnrk MV + +www.cohengresser.com + +New York I Seoul I Paris I Washington DC I London + +![](_page_1_Picture_12.jpeg) + +CONFIDENTIALITY NOTICE: The information contained in this e-mail may be confidential and/or ptivileged. This e-mail is intended to be reviewed initially by only the individual named above. If the reader of this e-mail is not the intended recipient or a representative of the intended recipient. you are hereby notified that any review, dissemination or copying of this e-mail or the information contained herein is prohibited. If you have received this e-mail in error. please immediately notify the sender by telephone and permanently delete this e-mail. Thank you. + +PRIVACY: A complete copy of our privacy policy can be viewed ht(oslAvww.cohengresser.com/privacy-policy. \ No newline at end of file diff --git a/marker2/ds9/EFTA00087843/EFTA00087843.metadata.json b/marker2/ds9/EFTA00087843/EFTA00087843.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..8aeccc898233118c089a6b97d1e9093487db351a --- /dev/null +++ b/marker2/ds9/EFTA00087843/EFTA00087843.metadata.json @@ -0,0 +1,90 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087843.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 1937, + "elapsed_seconds": 0.86, + "image_assets": [ + "_page_1_Picture_12.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 71 + ], + [ + "Line", + 31 + ], + [ + "Text", + 16 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 38 + ], + [ + "Line", + 19 + ], + [ + "Text", + 14 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087843" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087843/_page_1_Picture_12.jpeg b/marker2/ds9/EFTA00087843/_page_1_Picture_12.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..fe6685e45984f8562ede7f632de73d463c55d89e --- /dev/null +++ b/marker2/ds9/EFTA00087843/_page_1_Picture_12.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:35704903de7c6385853051ed35d5b42c99350827be8e192849b7cc51d94cf4c1 +size 1239 diff --git a/marker2/ds9/EFTA00087845/EFTA00087845.md b/marker2/ds9/EFTA00087845/EFTA00087845.md new file mode 100644 index 0000000000000000000000000000000000000000..640946db64e98ac4b2fa2560ce2b690ff2e12521 --- /dev/null +++ b/marker2/ds9/EFTA00087845/EFTA00087845.md @@ -0,0 +1,59 @@ +To: + +Cc: + +Subject: Re: general Epstein update + +Date: Mon, 16 Mar 2020 19:47:26 +0000 + +How about 5 pm today? + +Sent from my iPhone + +On Mar 16, 2020, at 3:06 PM, > wrote: + +Me and are around today + +NYPD / FBI + +Child Exploitation Human Trafficking Task Force + +From: + +Sent: Monday, March 16, 2020 2:21 PM + +To: + +Cc: + +subject: Re: general tpstem up a e + +I'm free whenever works for everyone. Thanks. + +Sent from my iPhone + +On Mar 16, 2020, at 1:58 PM, > wrote: + +I'm available anytime (my trial has been adjourned indefinitely). + +From: + +Sent: Monday, March 16, 2020 1:49 PM + +Subject: RE: general Epstein update + +Team, + +I got in touch with attorney earlier today, and understandably they would like to postpone the meeting previously scheduled for tomorrow, which is also consistent with our office's recent direction to limit meetings to + +those that are mission critical. We'll circle back with them once things get back to normal (or normal-ish), which I guess may be some period of weeks or months. + +More generally, is there a time later this afternoon or tomorrow that would be convenient for a quick conference call to talk about status of the case in eneral? In some ways the current circumstances are very frustrating and will delay certain steps (meeting with ieeting wittiMin-person approaches, etc) but it will also provide time to do additional research and memos, 302s, reviewing search warrant results, etc. So whenever is good for everybody, would be great to chat for just like 10 minutes or so and figure out how to best make use of the time. + +Meanwhile, I hope everybody is healthy and safe, and talk soon. + +![](_page_1_Picture_3.jpeg) + +Assistant U.S. Attorney Southern District of New York + +![](_page_1_Picture_5.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00087845/EFTA00087845.metadata.json b/marker2/ds9/EFTA00087845/EFTA00087845.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..1c42126dbf0d28f72f6937806a6a469cf7971fb9 --- /dev/null +++ b/marker2/ds9/EFTA00087845/EFTA00087845.metadata.json @@ -0,0 +1,99 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087845.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 1725, + "elapsed_seconds": 1.44, + "image_assets": [ + "_page_1_Picture_3.jpeg", + "_page_1_Picture_5.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 55 + ], + [ + "Line", + 28 + ], + [ + "Text", + 25 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 21 + ], + [ + "Line", + 11 + ], + [ + "Text", + 3 + ], + [ + "Picture", + 2 + ], + [ + "Caption", + 1 + ], + [ + "PageFooter", + 1 + ], + [ + "PictureGroup", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087845" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087845/_page_1_Picture_3.jpeg b/marker2/ds9/EFTA00087845/_page_1_Picture_3.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..95042d3fed4f6b9150dc8e6fa84b47aba41a2f8e --- /dev/null +++ b/marker2/ds9/EFTA00087845/_page_1_Picture_3.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:a6cadb4cf799e47cb4df269e639335d2c563f9e11ad1a476e66f9f06cc8d4e81 +size 1823 diff --git a/marker2/ds9/EFTA00087845/_page_1_Picture_5.jpeg b/marker2/ds9/EFTA00087845/_page_1_Picture_5.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..82ca17a0765fb9181f7ed0811218106d84fba725 --- /dev/null +++ b/marker2/ds9/EFTA00087845/_page_1_Picture_5.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:0df03386052cc5f6300fbc30f94a37b23a2ddc58a6e4b7079a089942f0d49aed +size 993 diff --git a/marker2/ds9/EFTA00087847/EFTA00087847.md b/marker2/ds9/EFTA00087847/EFTA00087847.md new file mode 100644 index 0000000000000000000000000000000000000000..b9c420a450cd7d2aef5109efb94c2d21b78c81f3 --- /dev/null +++ b/marker2/ds9/EFTA00087847/EFTA00087847.md @@ -0,0 +1,47 @@ +From: + +[REDACTED] + +To: + +[REDACTED] + +**Subject:** Re: general Epstein update +**Date:** Mon, 16 Mar 2020 18:21:30 +0000 + +--- + +I'm free whenever works for everyone. Thanks. + +Sent from my iPhone + +On Mar 16, 2020, at 1:58 PM, [REDACTED] wrote: + +*I'm available anytime (my trial has been adjourned indefinitely).* + +--- + +**From:** [REDACTED] + +**Sent:** Monday, March 16, 2020 1:49 PM + +**To:** [REDACTED] + +[REDACTED] + +**Subject:** RE: general Epstein update + +Team, + +I got in touch with [REDACTED] attorney earlier today, and understandably they would like to postpone the meeting previously scheduled for tomorrow, which is also consistent with our office's recent direction to limit meetings to those that are mission critical. We'll circle back with them once things get back to normal (or normal-ish), which I guess may be some period of weeks or months. + +More generally, is there a time later this afternoon or tomorrow that would be convenient for a quick conference call to talk about status of the case in general? In some ways the current circumstances are very frustrating and will delay certain steps (meeting with [REDACTED], meeting with [REDACTED] in-person approaches, etc) but it will also provide time to do additional research and memos, 302s, reviewing search warrant results, etc. So whenever is good for everybody, would be great to chat for just like 10 minutes or so and figure out how to best make use of the time. + +Meanwhile, I hope everybody is healthy and safe, and talk soon. + +[REDACTED] + +Assistant U.S. Attorney +Southern District of New York + +[REDACTED] \ No newline at end of file diff --git a/marker2/ds9/EFTA00087847/EFTA00087847.metadata.json b/marker2/ds9/EFTA00087847/EFTA00087847.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..afe6b8f8bb3ee55c81daae6aa2b34cf3555b84ba --- /dev/null +++ b/marker2/ds9/EFTA00087847/EFTA00087847.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087847.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1577, + "elapsed_seconds": 6.46, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 62 + ], + [ + "Text", + 42 + ], + [ + "Line", + 28 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087847" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087848/EFTA00087848.md b/marker2/ds9/EFTA00087848/EFTA00087848.md new file mode 100644 index 0000000000000000000000000000000000000000..f4105d8fc29f739ae3a871604e0dc3fc4e1e845a --- /dev/null +++ b/marker2/ds9/EFTA00087848/EFTA00087848.md @@ -0,0 +1,127 @@ +From: "Kathleen E. Cassidy" Cc: Susan Necheles + +Subject: RE: Submission on behalf o' + +Date: Tue, 24 Mar 2020 19:03:39 +0000 + +Attachments: + +We share with you the attached draft submission in anticipation of our call. + +Thanks, + +From: + +Sent: Tuesday, March 24, 2020 12:51 PM + +To: Kathleen E. Cassidy + +Cc: Susan Necheles Susan Necheles + +Subject: RE: Submission on behalf ofElli + +That works for us, and thanks for sending the dial-in information. Talk with you then. + +From: Kathleen E. Cassidy + +Sent: Tuesday, March 24, 2020 10:30 + +To: + +Cc: Susan Necheles • Susan Necheles + +Subject: Re: Submission on behalf of + +Can we do 5:30? + +Passcode + +Sent from my iPhone + +On Mar 24, 2020, at 10:14 AM, wrote: + +Susan, + +We could talk anytime this afternoon between 12:00 and 2:00, if there's a time then that works? Or otherwise after 5:00. And if you're able to send a dial-in, that would be helpful, but let us know if not. + +Sent: Monday, March 23, 2020 21:28 + +To: > + +Cc: Susan Necheles + +Kathleen E. Cassidy + +Subject: Re: Submission on behalf + +Can we talk tomorrow afternoon? I hope to get you another draft in the morning. + +Susan R. Necheles + +Sent from my iPhone + +On Mar 23, 2020, at 4:20 PM wrote: + +Susan, + +We wanted to follow up on the below —we understand these are very unusual times but we're continuing to move ahead with our internal decision-making discussions, and it would be very helpful to be able to incorporate your client's proposal (if anything) in that process. It will be of particular use given the civil lawsuit Ms it is difficult for us to explain to our supervisors why she has been able to file a complaint but not to make a submission to our office. Would it be possible to schedule a call for tomorrow to discuss status? And separately we hope that you and your colleagues and families are weathering the current circumstances. + +thanks, + +From: + +Sent: Tuesday, March 17, 2020 16:16 + +To: Susan Necheles + +Cc: Susan Necheles + +Kathleen E. Cassidy + +Subject: Re: Submission on behalf ofil + +Susan totally understand, and we appreciate you letting us know. That's not a problem. + +thanks, + +On Mar 17, 2020, at 15:46, Susan Necheles wrote: + +I am working on the new draft of this submission but it is going slower than I expected. has been in an emotionally and psychologically fragile state, and because offigLaronavirus, we cannot get her the proper therapy which she needs. We have suggested she go back to so at least she can be in her home and not shut up in a stranger's apartment here in NYC. Additionally, we attorneys have all shut our offices and are working at home, leading to a great loss in productivity. + +Sent from my iPhone + +On Mar 12, 2020, at 8:49 PM, wrote: + +Confirming receipt, thanks. + +From: Susan Necheles (via Google Docs) + +Sent: Thursday, March 12, 2020 20:40 + +To: > + +Cc: + +Subject: Submission on behalf of + +has shared a link to the following document: + +<-WRD178.jpg>I + +Submission on behalf of + +Attached is a draft of the factual statement, just so that you can better understand the facts that we are presenting. + +We feel that giver abuse, and given the fact that we see her basically as a cog in Epstein's wheel, acting entirely at his direction and doing what she did at a time that she herself was a very vulnerable victim, a non-pros would be the appropriate disposition. But we want to discuss this with you before we finalize this and make a submission. + +Thanks Susan + +Open in Docs + +Google Docs: Create and edit documents online. + +Google LLC. 1600 Amphitheatre Parkway. Mountain View. CA 94043. USA + +You have received this email because someone shared a document with you from Google Docs. + +<-WRD178.jpgd \ No newline at end of file diff --git a/marker2/ds9/EFTA00087848/EFTA00087848.metadata.json b/marker2/ds9/EFTA00087848/EFTA00087848.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..a74a3f378884b808af06b0bf3bc4c896e145c5d9 --- /dev/null +++ b/marker2/ds9/EFTA00087848/EFTA00087848.metadata.json @@ -0,0 +1,114 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087848.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 3631, + "elapsed_seconds": 1.39, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 57 + ], + [ + "Line", + 29 + ], + [ + "Text", + 27 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 73 + ], + [ + "Line", + 35 + ], + [ + "Text", + 27 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 53 + ], + [ + "Line", + 27 + ], + [ + "Text", + 22 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087848" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087851/EFTA00087851.md b/marker2/ds9/EFTA00087851/EFTA00087851.md new file mode 100644 index 0000000000000000000000000000000000000000..2f8157879306354ef110ff47cb8f191786555e28 --- /dev/null +++ b/marker2/ds9/EFTA00087851/EFTA00087851.md @@ -0,0 +1,63 @@ +To: "' + +Cc: ' " + +Subject: RE: RE: follow-up + +Date: Mon, 23 Mar 2020 23:39:59 +0000 + +Free to speak now if you're around. + +Robert Glassman, Esq. + +Panish Shea & Boyle LLP + +11111 Santa Monica Boulevard, Suite 700 + +Los Angeles, CA 90025 + +## CONFIDENTIALITY NOTICE: + +This e-mail may contain confidential and privileged material for the sole use of the intended recipient(s). Any review, use, distribution or disclosure by others is strictly prohibited. If you are not the intended recipient (or authorized to receive for the recipient), please contact the sender by reply e-mail or telephone, and delete all copies of this message. + +If you are a potential client, the information you disclose to us by email will be kept in strict confidence and will be protected to the full extent of the law. Please be advised, however, that Panish Shea & Boyle LLP and its lawyers do not represent you until you have signed a retainer agreement with the firm. Until that time, you are responsible for any statutes of limitations or other deadlines for your case or potential case. + +From: ) + +Sent: Friday, March 20, 2020 1:28 PM + +To: Robert Glassman < + +Cc: + +Subject: RE: RE: follow-up + +Robert — got it, thank you. So that wouldn't have been her first trip, then, based on the flight records (and timeline), so we'll make that note. Thanks again. + +From: Robert Glassman + +Sent: Friday, March 20, 2020 16:26 + +To: + +Cc: + +Subject: Re: RE: follow-up + +Hey Hope you guys are staying safe. Here was her response about the lion king: + +Broadway play... Epstein bragged about being good friends with Julie Taymor, and we had amazing first row mezzanine seats they she had apparently given him. + +Cc + +Subject: RE: follow-up + +Robert, + +Wanted to quickly follow up on our conversation from a couple weeks ago — obviously it was before the world imploded, so understand if you haven't gotten a chance to connect on this yet, but we were wondering about the Lion King question? Just to briefly remind, the Lion King musical first came out in 1997, which we think would have been well after first trip to New York (based on her recollection as well as the flight records), while the movie came out in 1994 and was in theaters through approximately spring 1995. So entirely possible she was referencing the movie version, or that going to the play wasn't the first visit, or just doesn't have a specific memory, etc etc, but wanted to check for our records and our decision-making process. + +Thank you! And hope you and your family are healthy and safe in the midst of everything going on. + +thanks again, + +Assistant U.S. Attorney Southern District of New York \ No newline at end of file diff --git a/marker2/ds9/EFTA00087851/EFTA00087851.metadata.json b/marker2/ds9/EFTA00087851/EFTA00087851.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..88b77b89e6fc0aea42d1ebc69f705f3d5e209ac6 --- /dev/null +++ b/marker2/ds9/EFTA00087851/EFTA00087851.metadata.json @@ -0,0 +1,112 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087851.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2616, + "elapsed_seconds": 1.47, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "CONFIDENTIALITY NOTICE:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 310.23 + ], + [ + 144.14854431152344, + 310.23 + ], + [ + 144.14854431152344, + 323.1011657714844 + ], + [ + 30.6, + 323.1011657714844 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 73 + ], + [ + "Line", + 36 + ], + [ + "Text", + 31 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 31 + ], + [ + "Line", + 16 + ], + [ + "Text", + 8 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087851" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087853/EFTA00087853.md b/marker2/ds9/EFTA00087853/EFTA00087853.md new file mode 100644 index 0000000000000000000000000000000000000000..d3b790b8886b13aeb96b6b10031264af6cd8fa54 --- /dev/null +++ b/marker2/ds9/EFTA00087853/EFTA00087853.md @@ -0,0 +1,4157 @@ +UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA + +CASE NO.: 08-CV-80811-CIV-MARRAMOHNSON + +C.M.A., + +Plaintiff(s), + +VS. + +TEIN and + +Defendant(s). + +FIRST AMENDED COMPLAINT + +Parties, Jurisdiction and Venue + +COMES NOW the Plaintiff, C.M.A., and brings this First Amended Complaint + +against the Defendants, JEFFREY EPSTEIN an and states as + +follows: + +1. This is an action for damages in excess of \$75,000.00, exclusive of + +interest and costs. + +2. This Complaint is brought under a fictitious name in order to protect the + +identity of the Plaintiff, C.M.A., because this Complaint makes allegation of sexual + +assault and child abuse of a then minor. + +3. At all times material to this cause of action, the Plaintiff, C.M.A., was. + +A n EXHIBIT 3 a pn oonitblib\_ + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRA/JOHNSON + +First Amended Complaint + +4. At all times material to this cause of action, the Defendant, JEFFREY + +EPSTEIN, had a residence located in Palm Beach County, Florida. + +5. At all times material to this cause of action, the Defendant, JEFFREY + +EPSTEIN, was an adult male, born in 1953. + +6. This Court has jurisdiction of this action and the claim set forth herein + +pursuant to 18 U.S.C. §2255. + +7. This Court has venue of this action pursuant to 28 U.S.C. §1391(a) as a + +substantial part of the events or omissions giving rise to the claim occurred in this + +district. + +8. At all times material, the Defendant, JEFFREY EPSTEIN, owed a duty + +unto Plaintiff, C.M.A., to treat her in a non-negligent manner and to not commit + +intentional or tortious illegal acts against her. + +Factual Allegations + +9. Upon information and belief, the Defendant, JEFFREY EPSTEIN, has + +demonstrated a sexual preference and obsession for minor girls. He engaged in a plan, + +scheme, and enterprise in which he gained access to economically disadvantaged + +minor girls, such as Plaintiff, C.MA., sexually assaulted these girls, and/or coerced + +them to engage in prostitution, and in return gave these girls money. + +10. The Defendants plan, scheme and enterprise included an elaborate + +system wherein the then minor Plaintiff and other minor girls were brought to the + +2 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARFtA/JOHNSON + +First Amended Complaint + +Defendant, JEFFREY EPSTEIN'S, residence by the Defendant's employees and + +assistants. When the employees and assistants left the then minor Plaintiff and other + +minor girls alone in a room at the Defendant's mansion, the Defendant, JEFFREY + +EPSTEIN, himself would appear, remove his clothing, and direct the then minor Plaintiff + +to remove her clothing. He would then perform one or more lewd, lascivious, and + +sexual acts, including, but not limited to, masturbation, touching of the then minor + +Plaintiffs breasts and buttock, and solicitation and enticement of the then minor Plaintiff + +to engage in sexual acts with another female in JEFFREY EPSTEIN'S presence. + +11. The Plaintiff, C.M.A., was the first brought to the Defendant, JEFFREY + +EPSTEIN'S, mansion in late May or early June of 2002, when she was fifteen-years old + +and in middle school. + +12. The Defendant, JEFFREY EPSTEIN, a wealthy financier with a lavish + +home, significant wealth, anetwork of assistants and employees, used his resources + +and his influence over a vulnerable minor child to engage in asystematic pattern of + +sexually exploitive behavior. + +13. Beginning in approximately late May or early June of 2002, and continuing + +until approximately August of 2003, the Defendant coerced and enticed the + +impressionable, vulnerable, and economically deprived then minor Plaintiff to commit + +various acts of sexual misconduct. These acts occurred, on average, one to three times + +per week from late May or early June of 2002 until August of 2003. At a bare minimum, + +3 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80311-CIV-MARRA/JOHNSON + +First Amended Complaint + +these acts occurred twice a month from June 2002 until August of 2003. While the + +precise dates these acts occurred are unknown to Plaintiff, including those weeks in + +which no acts occurred, these dates are known by Defendant, JEFFREY EPSTEIN, as + +he is reported to have kept awritten log of each and every instance in which he + +engaged in these illegal acts with the then minor Plaintiff, C.M.A. and others. These + +acts included, but were not limited to, fondling and inappropriate and illegal sexual + +touching of the then minor Plaintiff, sexual misconduct and masturbation of the + +Defendant, JEFFREY EPSTEIN, in the presence of the then minor Plaintiff, soliciting + +and enticing the then minor Plaintiff to engage in sexual acts with another female in + +JEFFREY EPSTEIN'S presence, and encouraging the then minor Plaintiff to become + +involved in prostitution; Defendant, JEFFREY EPSTEIN, committed numerous criminal + +sexual offenses against the then minor Plaintiff including, but not limited to, sexual + +battery, solicitation of prostitution, procurement of a minor for the purpose of + +prostitution, and lewd and lascivious assaults upon the person of the then minor + +Plaintiff. + +14. Defendant, JEFFREY EPSTEIN, used his money, wealth and power to + +unduly and improperly manipulate and influence the then minor Plaintiff. + +15. The acts referenced in paragraphs 9 through 14, committed by Defendant, + +JEFFREY EPSTEIN, against the then minor Plaintiff, C.M.A., were committed in + +violation of numerous criminal State and Federal statutes condemning the sexual + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRA/JOHNSON + +First Amended Complaint + +exploitation of minor children, prostitution, sexual performance by a child, lewd and + +lascivious assaults, sexual battery, contributing the delinquency of a minor and other + +crimes, specifically including, but not limited to, those crimes designated in 18 USC + +§2241, §2242, §2243, §2421, and §2423, criminal offenses outlined In Chapter 800 of + +the Federal Codes, as well as those designated in Florida Statutes §796.03, §796.07, + +§796.045, §796.04, §39.01; and §827.04. + +16. The above-described acts took place in Palm Beach County, Florida, at + +the residence of the Defendant, JEFFREY EPSTEIN. Any assertions by the Defendant, + +JEFFREY EPSTEIN, that he was unaware of the age of the then minor Plaintiff are + +belied by his actions and rendered irrelevant by the provisions of applicable Florida + +Statutes concerning the sexual exploitation and abuse of a minor child. The Defendant, + +JEFFREY EPSTEIN, at all times material to this cause of action, knew and should have + +known of the Plaintiff, C.M.A.'s minority. + +17. In June 2008, in the Fifteenth Judicial Circuit in Palm Beach County, + +Florida, the Defendant, JEFFREY EPSTEIN, entered pleas of "guilty" to various Florida + +state crimes involving the solicitation of minors for prostitution and the procurement of + +minors for the purpose of prostitution. + +18. As a condition of that plea, and in exchange for the Federal Government + +not prosecuting the Defendant, JEFFREY EPSTEIN, for numerous federal offenses, + +Defendant, JEFFREY EPSTEIN, additionally entered into an agreement with the + +5 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRA/JOHNSON + +First Amended Complaint + +Federal Government to the following: "Any person, who while a minor, was a victim of + +an offense enumerated in Title 18, United States Code, Section 2255, will have the + +same rights to proceed under section 2255 as she would have had, if Mr. Epstein had + +been tried federally and convicted of an enumerated offense. For purposes of + +implementing this paragraph, the United States shall provide Mr. Epstein's attorneys + +with a list of individuals whom it was prepared to name in an indictment as victims of an + +enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, + +including any authority determining evidentiary burdens if any a Plaintiff must meet, + +shall consider that it is the intent of the parties to place these identified victims in the + +same position as they would have been had Mr. Epstein been convicted at trial. No + +more; no less". + +19. The Defendant, JEFFREY EPSTEIN, is thus estopped by his plea and + +agreement with the Federal Government from denying the acts alleged In this + +Complaint, and must effectively admit liability to the Plaintiff, C.M.A. + +COUNT I + +Cause of Action Pursuant to 18 USC §2255 + +May/June 2002 + +20. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 + +above. + +6 + +C.M.A. vs. Epstein, et at. + +Case No.: 08-CV-80811-CIV-MARRA/JOHNSON + +First Amended Complaint + +21. In late May or early June of 2002, C.M.A. was first introduced to + +Defendant, JEFFREY EPSTEIN. C.M.A. was brought to JEFFREY EPSTEIN'S + +residence by afemale friend of hers. C.M.A. sat on the couch while the female friend + +took off her own clothes, mounted JEFFREY EPSTEIN who was wearing only atowel + +and lying on atable, and performed asexual act upon JEFFREY EPSTEIN in the + +presence of C.M.A. In exchange for her participation as an observer of JEFFREY + +EPSTEIN'S lewd and lascivious conduct, C.M.A. was paid \$300 by JEFFREY + +EPSTEIN. + +22. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and + +in exchange for the Federal Government not prosecuting the Defendant for numerous + +federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an + +agreement with the Federal Government to the following: "Any person, who while a + +minor, was a victim of an offense enumerated in Title 18, United States Code, Section + +2255, will have the same rights to proceed under section 2255 as she would have had, + +if Mr. Epstein had been tried federally and convicted of an enumerated offense. For + +purposes of implementing this paragraph, the United States shall provide Mr. Epstein's + +attorneys with a list of individuals whom it was prepared to name in an indictment as + +victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this + +provision, including any authority determining evidentiary burdens if any a Plaintiff must + +meet, shall consider that it is the intent of the parties to place these identified victims in + +7 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRA/JOHNSON + +First Amended Complaint + +the same position as they would have been had Mr. Epstein been convicted at trial. No + +more; no less." + +23. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in + +Title 18, United States Code, Section 2255, and as such asserts a cause of action + +against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United + +States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the + +United States Government. + +24. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the + +same position as if he had been tried and convicted of the sexual offenses committed + +against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the + +Plaintiff, C.M.A. + +25. As a direct and proximate result of the offenses enumerated in Title 18, + +United States Code, Section 2255, being committed against the then minor Plaintiff, + +C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and + +suffering, emotional distress, psychological trauma, mental anguish, humiliation, + +embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other + +damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and + +coercing her into a perverse and unconventional way of life for a minor. The then minor + +Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in + +the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A., + +S + +C.MA. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRA/J0HNS0N + +First Amended Complaint + +has suffered a loss of income, aloss of the capacity to earn income in the future, and a + +loss of the capacity to enjoy life. These injuries are permanent In nature and the + +Plaintiff, C.M.A., will continue to suffer these losses in the future. + +WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, + +JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount + +provided by law, punitive damages, attorney's fees, costs, and such other and further + +relief as this Court deems just and proper, and hereby demands trial by jury on all + +issues triable as of right by a jury. + +COUNT II + +Cause of Action Pursuant to 18 USC §2255 + +June 2002- Incident 2 + +26. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 + +above. + +27. Approximately one week after the first incident, C.M.A. received a + +telephone call from AFFREY EPSTEIN requesting that she return to his residence. On + +this occasion, JEFFREY EPSTEIN directed C.M.A to undress to her brassiere and + +underwear and to provide him with a massage. At the conclusion of the massage, + +JEFFREY EPSTEIN masturbated himself in C.M.A.'s presence. JEFFREY EPSTEIN + +paid C.M.A. \$300 for this encounter. + +9 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRA/JOHNSON + +First Amended Complaint + +28. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and + +in exchange for the Federal Government not prosecuting the Defendant for numerous + +federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an + +agreement with the Federal Government to the following: "Any person, who while a + +minor, was a victim of an offense enumerated in Title 18, United States Code, Section + +2255, will have the same rights to proceed under section 2255 as she would have had, + +if Mr. Epstein had been tried federally and convicted of an enumerated offense. For + +purposes of implementing this paragraph, the United States shall provide Mr. Epstein's + +attorneys with a list of individuals whom it was prepared to name in an indictment as + +victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this + +provision, including any authority determining evidentiary burdens if any a Plaintiff must + +meet, shall consider that it is the intent of the parties to place these identified victims in + +the same position as they would have been had Mr. Epstein been convicted at trial. No + +more; no less? + +29. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in + +Title 18, United States Code, Section 2255, and as such asserts a cause of action + +against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United + +States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the + +United States Government. + +10 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRA/JOHNSON + +First Amended Complaint + +30. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the + +same position as if he had been tried and convicted of the sexual offenses committed + +against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the + +Plaintiff, C.M.A. + +31. As a direct and proximate result of the offenses enumerated in Title 18, + +United States Code, Section 2255, being committed against the then minor Plaintiff, + +C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and + +suffering, emotional distress, psychological trauma, mental anguish, humiliation, + +embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other + +damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and + +coercing her into a perverse and unconventional way of life for a minor. The then minor + +Plaintiff incurred medical and psychological expenses and the Plaintiff, C.MA" will in + +the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A., + +has suffered a loss of income, aloss of the capacity to earn income in the future, and a + +loss of the capacity to enjoy life. These injuries are permanent in nature and the + +Plaintiff, C.M.A., will continue to suffer these losses in the future. + +WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, + +JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount + +provided by law, punitive damages, attorney's fees, costs, and such other and further + +11 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRA/J0HNS0N + +First Amended Complaint + +relief as this Court deems just and proper, and hereby demands trial by jury on all + +issues triable as of right by a jury. + +COUNT III + +Cause of Action Pursuant to 18 USC 42255 + +July, 2002 — Incident 1 + +32. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 + +above. + +33. In July of 2002, C.M.A. again returned to JEFFREY EPSTEIN'S residence + +at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A to undress to her + +underwear and to provide him with a massage. At the conclusion of the massage, + +JEFFREY EPSTEIN masturbated himself in C.M.A.'s presence. JEFFREY EPSTEIN + +paid C.M.A. in excess of \$200 for this encounter. + +34. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and + +in exchange for the Federal Government not prosecuting the Defendant for numerous + +federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an + +agreement with the Federal Government to the following: "Any person, who while a + +minor, was a victim of an offense enumerated in Title 18, United States Code, Section + +2255, will have the same rights to proceed under section 2255 as she would have had, + +if Mr. Epstein had been tried federally and convicted of an enumerated offense. For + +12 + +C.M.A. vs. Epstein, et at + +Case No.: 08-CV-80811-CIV-MARRA/JOHNSON + +First Amended Complaint + +purposes of implementing this paragraph, the United States shall provide Mr. Epstein's + +attorneys with a list of individuals whom it was prepared to name in an indictment as + +victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this + +provision, including any authority determining evidentiary burdens if any a Plaintiff must + +meet, shall consider that it is the intent of the parties to place these identified victims in + +the same position as they would have been had Mr. Epstein been convicted at trial. No + +more; no less." + +35. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in + +Title 18, United States Code, Section 2255, and as such asserts a cause of action + +against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United + +States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the + +United States Government. + +36. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the + +same position as if he had been tried and convicted of the sexual offenses committed + +against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the + +Plaintiff, C.M.A. + +37. As a direct and proximate result of the offenses enumerated in Title 18, + +United States Code, Section 2255, being committed against the then minor Plaintiff, + +C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and + +suffering, emotional distress, psychological trauma, mental anguish, humiliation, + +13 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRA/JOHNSON + +First Amended Complaint + +embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other + +damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and + +coercing her into a perverse and unconventional way of life for a minor. The then minor + +Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in + +the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A., + +has suffered a loss of income, aloss of the capacity to earn income in the future, and a + +loss of the capacity to enjoy life. These injuries are permanent in nature and the + +Plaintiff, C.MA., will continue to suffer these losses in the future. + +WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, + +JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount + +provided by law, punitive damages, attorney's fees, costs, and such other and further + +relief as this Court deems just and proper, and hereby demands trial by jury on all + +issues triable as of right by a jury. + +COUNT IV + +Cause of Action Pursuant to 18 USC 42266 + +July 2002 — Incident 2 + +14 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARFUVJOHNSON + +First Amended Complaint + +38. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 + +above. + +39. For the second time in July of 2002, C.M.A. again returned to JEFFREY + +EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed + +C.M.A to fully undress and to provide him with a massage. Defendant, JEFFREY + +EPSTEIN, fondled the breasts and buttocks of the then minor C.M.A. At the conclusion + +of the massage, JEFFREY EPSTEIN masturbated himself in C.M.A.'s presence. + +JEFFREY EPSTEIN paid C.M.A. in excess of \$200 for this encounter. + +40. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and + +in exchange for the Federal Government not prosecuting the Defendant for numerous + +federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an + +agreement with the Federal Government to the following: "Any person, who while a + +minor, was a victim of an offense enumerated in Title 18, United States Code, Section + +2255, will have the same rights to proceed under section 2255 as she would have had, + +if Mr. Epstein had been tried federally and convicted of an enumerated offense. For + +purposes of implementing this paragraph, the United States shall provide Mr. Epstein's + +attorneys with a list of individuals whom it was prepared to name in an indictment as + +victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this + +provision, including any authority determining evidentiary burdens if any a Plaintiff must + +meet, shall consider that it is the intent of the parties to place these identified victims in + +15 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRA/JOHNSON + +First Amended Complaint + +the same position as they would have been had Mr. Epstein been convicted at trial. No + +more; no less? + +41. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in + +Title 18, United States Code, Section 2255, and as such asserts a cause of action + +against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United + +States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the + +United States Government. + +42. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the + +same position as if he had been tried and convicted of the sexual offenses committed + +against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the + +Plaintiff, C.M.A. + +43. As a direct and proximate result of the offenses enumerated in Title 18, + +United States Code, Section 2255, being committed against the then Minor Plaintiff, + +C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and + +suffering, emotional distress, psychological trauma, mental anguish, humiliation, + +embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other + +damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and + +coercing her into a perverse and unconventional way of life for a minor. The then minor + +Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in + +the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A., + +16 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRA/J0HNS0N + +First Amended Complaint + +has suffered a loss of income, aloss of the capacity to earn income in the future, and a + +loss of the capacity to enjoy life. These Injuries are permanent in nature and the + +Plaintiff, C.M.A., will continue to suffer these losses in the future. + +WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, + +JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount + +provided by law, punitive damages, attorney's fees, costs, and such other and further + +relief as this Court deems just and proper, and hereby demands trial by jury on all + +issues triable as of right by a jury. + +COUNT V + +Cause of Action Pursuant to 18 USC §2255 + +August of 2002 - Incident 1 + +44. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 + +above. + +45. In August of 2002, C.M.A. again returned to JEFFREY EPSTEIN'S + +residence at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A to fully + +undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled + +the breasts and buttocks of the then minor C.M.A. At the conclusion of the massage, + +JEFFREY EPSTEIN masturbated himself in C.M.A.'s presence. JEFFREY EPSTEIN + +paid C.M.A. in excess of \$200 for this encounter. + +17 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRA/JOHNSON + +First Amended Complaint + +46. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and + +in exchange for the Federal Government not prosecuting the Defendant for numerous + +federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an + +agreement with the Federal Government to the following: Any person, who while a + +minor, was a victim of an offense enumerated in Title 18, United States Code, Section + +2255, will have the same rights to proceed under section 2255 as she would have had, + +if Mr. Epstein had been tried federally and convicted of an enumerated offense. For + +purposes of implementing this paragraph, the United States shall provide Mr. Epstein's + +attorneys with a list of individuals whom it was prepared to name in an indictment as + +victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this + +provision, including any authority determining evidentiary burdens if any a Plaintiff must + +meet, shall consider that it is the intent of the parties to place these identified victims in + +the same position as they would have been had Mr. Epstein been convicted at trial. No + +more; no less? + +47. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in + +Title 18, United States Code, Section 2255, and as such asserts a cause of action + +against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United + +States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the + +United States Government. + +18 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRA/JOHNSON + +First Amended Complaint + +48. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the + +same position as if he had been tried and convicted of the sexual offenses committed + +against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the + +Plaintiff, C.M.A. + +49. As a direct and proximate result of the offenses enumerated in Title 18, + +United States Code, Section 2255, being committed against the then minor Plaintiff, + +C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and + +suffering, emotional distress, psychological trauma, mental anguish, humiliation, + +embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other + +damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and + +coercing her into a perverse and unconventional way of life for a minor. The then minor + +Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in + +the future suffer additional medical and psychological expenses. The Plaintiff, C.MA., + +has suffered a loss of income, a loss of the capacity to earn income in the future, and a + +loss of the capacity to enjoy life. These injuries are permanent in nature and the + +Plaintiff, C.M.A., will continue to suffer these losses in the future. + +WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, + +JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount + +provided by law, punitive damages, attorney's fees, costs, and such other and further + +19 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRA/JOHNSON + +First Amended Complaint + +relief as this Court deems just and proper, and hereby demands trial by jury on all + +issues triable as of right by a jury. + +COUNT VI + +Cause of Action Pursuant to 18 USC 42255 + +August of 2002 — Incident 2 + +50. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 + +above. + +51. For the second time in August of 2002, C.MA. again returned to + +JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN + +directed C.M.A to fully undress and to provide him with a massage. Defendant, + +JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor C.M.A. At the + +conclusion of the massage, JEFFREY EPSTEIN masturbated himself in C.M.A.'s + +presence. JEFFREY EPSTEIN paid C.M.A. in excess of \$200 for this encounter. + +52. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and + +in exchange for the Federal Government not prosecuting the Defendant for numerous + +federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an + +agreement with the Federal Govemment to the following: "Any person, who while a + +minor, was a victim of an offense enumerated in Title 18, United States Code, Section + +2255, will have the same rights to proceed under section 2255 as she would have had, + +20 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRA/JOHNSON + +First Amended Complaint + +if Mr. Epstein had been tried federally and convicted of an enumerated offense. For + +purposes of implementing this paragraph, the United States shall provide Mr. Epstein's + +attorneys with a list of individuals whom it was prepared to name in an indictment as + +victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this + +provision, including any authority determining evidentiary burdens if any a Plaintiff must + +meet, shall consider that it is the Intent of the parties to place these identified victims in + +the same position as they would have been had Mr. Epstein been convicted at trial. No + +more; no less." + +53. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated In + +Title 18, United States Code, Section 2255, and as such asserts a cause of action + +against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United + +States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the + +United States Government. + +54. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the + +same position as if he had been tried and convicted of the sexual offenses committed + +against the Plaintiff, C.M.R., and as such he must effectively admit liability unto the + +Plaintiff, C.M.A. + +55. As a direct and proximate result of the offenses enumerated in Title 18, + +United States Code, Section 2255, being committed against the then minor Plaintiff, + +C.M.A., has in the past suffered, and will in the future suffer, physical Injury, pain and + +21 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRA/J0HNS0N + +First Amended Complaint + +suffering, emotional distress, psychological trauma, mental anguish, humiliation, + +embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other + +damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and + +coercing her into a perverse and unconventional way of life for a minor. The then minor + +Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in + +the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A., + +has suffered a loss of income, aloss of the capacity to earn income in the future, and a + +loss of the capacity to enjoy life. These injuries aro permanent in nature and the + +Plaintiff, C.M.A., will continue to suffer these losses in the future. + +WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, + +JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount + +provided by law, punitive damages, attorney's fees, costs, and such other and further + +relief as this Court deems just and proper, and hereby demands trial by jury on all + +issues triable as of right by a jury. + +COUNT VII + +Cause of Action Pursuant to 18 USC §2255 + +September of 2002 — Incident 1 + +56. The. Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 + +above. + +22 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRA/JOHNSON + +First Amended Complaint + +57. In September of 2002, C.M.A. again returned to JEFFREY EPSTEIN'S + +residence at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A to fully + +undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled + +the breasts and buttocks of the then minor C.M.A. At the conclusion of the massage, + +JEFFREY EPSTEIN masturbated himself in C.M.A.'s presence. JEFFREY EPSTEIN + +paid C.M.A. in excess of \$200 for this encounter. + +58. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and + +in exchange for the Federal Government not prosecuting the Defendant for numerous + +federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an + +agreement with the Federal Government to the following: "Any person, who while a + +minor, was a victim of an offense enumerated in Title 18, United States Code, Section + +2255, will have the same rights to proceed under section 2255 as she would have had, + +if Mr. Epstein had been tried federally and convicted of an enumerated offense. For + +purposes of Implementing this paragraph, the United States shall provide Mr. Epstein's + +attorneys with a list of individuals whom it was prepared to name in an indictment as + +victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this + +provision, including any authority determining evidentiary burdens if any a Plaintiff must + +meet, shall consider that it is the intent of the parties to place these identified victims in + +the same position as they would have been had Mr. Epstein been convicted at trial. No + +more; no less? + +23 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRA/JOHNSON + +First Amended Complaint + +59. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in + +Title 18, United States Code, Section 2255, and as such asserts a cause of action + +against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United + +States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the + +United States Government. + +60. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the + +same position as if he had been tried and convicted of the sexual offenses committed + +against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the + +Plaintiff, C.M.A. + +61. As a direct and proximate result of the offenses enumerated in Tdle 18, + +United States Code, Section 2255, being committed against the then minor Plaintiff, + +C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and + +suffering, emotional distress, psychological trauma, mental anguish, humiliation, + +embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other + +damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and + +coercing her into a perverse and unconventional way of life for a minor. The then minor + +Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in + +the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A., + +has suffered a loss of income, aloss of the capacity to earn income in the future, and a + +24 + +C.MA. vs. Epstein, et at. + +Case No.: 08-CV-80811-CIV-MARFtA/JOHNSON + +First Amended Complaint + +loss of the capacity to enjoy life. These injuries are permanent in nature and the + +Plaintiff, C.M.A., will continue to suffer these losses in the future. + +WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, + +JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount + +provided by law, punitive damages, attorney's fees, costs, and such other and further + +relief as this Court deems just and proper, and hereby demands trial by Jury on all + +issues triable as of right by a jury. + +COUNT VIII + +Cause of Action Pursuant to 18 USC §2255 + +September of 2002 — Incident 2 + +62. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 + +above. + +63. For the second time in September of 2002, C.M.A. again returned to + +JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN + +directed C.M.A to fully undress and to provide him with a massage. Defendant, + +JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor C.MA. At the + +conclusion of the massage, JEFFREY EPSTEIN masturbated himself in C.M.A.'s + +presence. JEFFREY EPSTEIN paid C.M.A. in excess of \$200 for this encounter. + +25 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRA/JOHNSON + +First Amended Complaint + +64. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and + +in exchange for the Federal Government not prosecuting the Defendant for numerous + +federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an + +agreement with the Federal Government to the following: "Any person, who while a + +minor, was a victim of an offense enumerated in Title 18, United States Code, Section + +2255, will have the same rights to proceed under section 2255 as she would have had, + +if Mr. Epstein had been tried federally and convicted of an enumerated offense. For + +purposes of implementing this paragraph, the United States shall provide Mr. Epstein's + +attorneys with a list of individuals whom it was prepared to name in an indictment as + +victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this + +provision, including any authority determining evidentiary burdens if any a Plaintiff must + +meet, shall consider that it is the intent of the parties to place these identified victims in + +the same position as they would have been had Mr. Epstein been convicted at trial. No + +more; no less?" + +65. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in + +Title 18, United States Code, Section 2255, and as such asserts a cause of action + +against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United + +States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the + +United States Government. + +26 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARFtA/J0HNSON + +First Amended Complaint + +66. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the + +same position as if he had been tried and convicted of the sexual offenses committed + +against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the + +Plaintiff, C.MA. + +67. As a direct and proximate result of the offenses enumerated In Title 18, + +United States Code, Section 2255, being committed against the then minor Plaintiff, + +C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and + +suffering, emotional distress, psychological trauma, mental anguish, humiliation, + +embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other + +damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and + +coercing her into a perverse and unconventional way of life for a minor. The then minor + +Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in + +the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A., + +has suffered a loss of income, aloss of the capacity to earn income in the future, and a + +loss of the capacity to enjoy life. These injuries are permanent in nature and the + +Plaintiff, C.M.A., will continue to suffer these losses in the future. + +WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant + +JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount + +provided by law, punitive damages, attorney's fees, costs, and such other and further + +27 + +C.M.A. vs. Epstein, et at + +Case No.: 08-CV-80811-CIV-MARRA/JOHNSON + +First Amended Complaint + +relief as this Court deems just and proper, and hereby demands trial by jury on all + +issues triable as of right by a jury. + +COUNT IX + +Cause of Action Pursuant to 18 USC V255 + +October of 2002 — Incident 1 + +68. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 + +above. + +69. In October of 2002, C.M.A. again returned to JEFFREY EPSTEIN'S + +residence at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A to fully + +undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled + +the breasts and buttocks of the then minor C.M.A. At the conclusion of the massage, + +JEFFREY EPSTEIN masturbated himself in C.MA.'s presence. JEFFREY EPSTEIN + +paid C.M.A. In excess of \$200 for this encounter. + +70. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and + +in exchange for the Federal Government not prosecuting the Defendant for numerous + +federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an + +agreement with the Federal Government to the following: "Any person, who while a + +minor, was a victim of an offense enumerated in Title 18, United States Code, Section + +2255, will have the same rights to proceed under section 2255 as she would have had, + +28 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRA/JOHNSON + +First Amended Complaint + +if Mr. Epstein had been tried federally and convicted of an enumerated offense. For + +purposes of implementing this paragraph, the United States shall provide Mr: Epstein's + +attorneys with a list of individuals whom it was prepared to name in an indictment as + +victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this + +provision, including any authority determining evidentiary burdens if any a Plaintiff must + +meet, shall consider that it is the intent of the parties to place these identified victims in + +the same position as they would have been had Mr. Epstein been convicted at trial. No + +more; no less." + +71. The Plaintiff, C.MA., was a victim of one or more offenses enumerated in + +Title 18, United States Code, Section 2255, and as such asserts a cause of action + +against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United + +States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the + +United States Government. + +72. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the + +same position as if he had been tried and convicted of the sexual offenses committed + +against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the + +Plaintiff, C.M.A. + +73. As a direct and proximate result of the offenses enumerated in Title 18, + +United States Code, Section 2255, being committed against the then minor Plaintiff, + +C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and + +29 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRA/JOHNSON + +First Amended Complaint + +suffering, emotional distress, psychological trauma, mental anguish, humiliation, + +embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other + +damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and + +coercing her Into a perverse and unconventional way of life for a minor. The then minor + +Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in + +the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A., + +has suffered a loss of income, aloss of the capacity to earn income in the future, and a + +loss of the capacity to enjoy life. These injuries are permanent in nature and the + +Plaintiff, C.M.A., will continue to suffer these losses in the future. + +WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, + +JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount + +provided by law, punitive damages, attorney's fees, costs, and such other and further + +relief as this Court deems just and proper, and hereby demands trial by jury on all + +Issues triable as of right by a jury, + +COUNT X + +Cause of Action Pursuant to 18 USC 42255 + +October of 2002 - Incident 2 + +30 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRA/JOHNSON + +First Amended Complaint + +74. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 + +above. + +75. For the second time in October of 2002, C.M.A. again returned to + +JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN + +directed C.M.A to fully undress and to provide him with a massage. Defendant, + +JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor C.M.A. At the + +conclusion of the massage, JEFFREY EPSTEIN masturbated himself in C.M.A.'s + +presence. JEFFREY EPSTEIN paid C.M.A. in excess of \$200 for this encounter. + +76. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and + +in exchange for the Federal Government not prosecuting the Defendant for numerous + +federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an + +agreement with the Federal Government to the following: "Any person, who while a + +minor, was a victim of an offense enumerated in Title 18, United States Code, Section + +2255, will have the same rights to proceed under section 2255 as she would have had, + +if Mr. Epstein had been tried federally and convicted of an enumerated offense. For + +purposes of implementing this paragraph, the United States shall provide Mr. Epstein's + +attorneys with a list of Individuals whom it was prepared to name in an indictment as + +victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this + +provision, including any authority determining evidentiary burdens if any a Plaintiff must + +meet, shall consider that it is the intent of the parties to place these identified victims in + +31 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRNJOHNSON + +First Amended Complaint + +the same position as they would have been had Mr. Epstein been convicted at trial. No + +more; no less." + +77. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in + +Title 18, United States Code, Section 2255, and as such asserts a cause of action + +against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United + +States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the + +United States Government. + +78. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the + +same position as if he had been tried and convicted of the sexual offenses committed + +against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the + +Plaintiff, C.M.A. + +79. As a direct and proximate result of the offenses enumerated in Title 18, + +United States Code, Section 2255,. being committed against the then minor Plaintiff, + +C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and + +suffering, emotional distress, psychological trauma, mental anguish, humiliation, + +embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other + +damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and + +coercing her into a perverse and unconventional way of life for a minor. The then minor + +Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in + +the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A., + +32 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRA/JOHNSON + +First Amended Complaint + +has suffered a loss of income, aloss of the capacity to earn income in the future, and a + +loss of the capacity to enjoy life. These injuries are permanent in nature and the + +Plaintiff, C.M.A., will continue to suffer these losses in the future. + +WHEREFORE, the Plaintiff, C.MA., demands judgment against the Defendant, + +JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount + +provided by law, punitive damages, attorney's fees, costs, and such other and further + +relief as this Court deems just and proper, and hereby demands trial by jury on all + +issues triable as of right by a jury. + +COUNT XI + +Cause of Action Pursuant to 18 USC §22S5 + +November of 2002 — Incident 1 + +80. The Plaintiff, C.MA., adopts and realleges paragraphs 1 through 19 + +above. + +81. In November of 2002, C.M.A. again returned to JEFFREY EPSTEIN'S + +residence at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A to fully + +undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled + +the breasts and buttocks of the then minor C.M.A. At the conclusion of the massage, + +JEFFREY EPSTEIN masturbated himself In C.M.A.'s presence. JEFFREY EPSTEIN + +paid C.M.A. in excess of \$200 for this encounter. + +33 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRA/JOHNSON + +First Amended Complaint + +82. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and + +in exchange for the Federal Government not prosecuting the Defendant for numerous + +federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an + +agreement with the Federal Government to the following: Any person, who while a + +minor, was a victim of an offense enumerated in Title 18, United States Code, Section + +2255, will have the same rights to proceed under section 2255 as she would have had, + +if Mr. Epstein had been tried federally and convicted of an enumerated offense. For + +purposes of implementing this paragraph, the United Slates shall provide Mr. Epstein's + +attorneys with a list of individuals whom it was prepared to name in an Indictment as + +victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this + +provision, including any authority determining evidentiary burdens if any a Plaintiff must + +meet, shall consider that it is the intent of the parties to place these identified victims in + +the same position as they would have been had Mr. Epstein been convicted at trial. No + +more; no less.' + +83. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in + +Title 18, United States Code, Section 2255, and as such asserts a cause of action + +against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United + +States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the + +United States Government. + +34 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRA/JOHNSON + +First Amended Complaint + +84. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the + +same position as if he had been tried and convicted of the sexual offenses committed + +against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the + +Plaintiff, C.M.A. + +85. As a direct and proximate result of the offenses enumerated in Title 18, + +United States Code, Section 2255, being committed against the then minor Plaintiff, + +C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and + +suffering, emotional distress, psychological trauma, mental anguish, humiliation, + +embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other + +damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and + +coercing her into a perverse and unconventional way of life for a minor. The then minor + +Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in + +the future suffer additional medical and psychological expenses. The Plaintiff, C.MA., + +has suffered a loss of income, aloss of the capacity to earn income in the future, and a + +loss of the capacity to enjoy life. These injuries are permanent in nature and the + +Plaintiff, C.M.A., will continue to suffer these losses in the future. + +WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, + +JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount + +provided by law, punitive damages, attorney's fees, costs, and such other and further + +35 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRA/JOHNSON + +First Amended Complaint + +relief as this Court deems just and proper, and hereby demands trial by jury on all + +issues triable as of right by a jury. + +COUNT XII + +Cause of Action Pursuant to 18 USC §2255 + +November of 2002 — Incident 2 + +86. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 + +above. + +87. For the second time in November of 2002, C.M.A. again returned to + +JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN + +directed C.M.A to fully undress and to provide him with a massage. Defendant, + +JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor C.M.A. At the + +conclusion of the massage, JEFFREY EPSTEIN masturbated himself in C.M.A.'s + +presence. JEFFREY EPSTEIN paid C.M.A. in excess of \$200 for this encounter. + +88. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and + +in exchange for the Federal Government not prosecuting the Defendant for numerous + +federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an + +agreement with the Federal Government to the following: "Any person, who while a + +minor, was a victim of an offense enumerated In Title 18, United States Code, Section + +2255, will have the same rights to proceed under section 2255 as she would have had, + +36 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRA/JOHNSON + +First Amended Complaint + +if Mr. Epstein had been tried federally and convicted of an enumerated offense. For + +purposes of implementing this paragraph, the United States shall provide Mr. Epstein's + +attorneys with a list of individuals whom it was prepared to name in an indictment as + +victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this + +provision, including any authority determining evidentiary burdens if any a Plaintiff must + +meet, shall consider that it is the intent of the parties to place these identified victims in + +the same position as they would have been had Mr. Epstein been convicted at trial. No + +more; no less." + +89. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated In + +Title 18, United States Code, Section 2255, and as such asserts a cause of action + +against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United + +States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the + +United States Government. + +90. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the + +same position as if he had been tried and convicted of the sexual offenses committed + +against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the + +Plaintiff, C.M.A. + +91. As a direct and proximate result of the offenses enumerated in Title 18, + +United States Code, Section 2255, being committed against the then minor Plaintiff, + +C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and + +37 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRA/JOHNSON + +First Amended Complaint + +suffering, emotional distress, psychological trauma, mental anguish, humiliation, + +embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other + +damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and + +coercing her into a perverse and unconventional way of life for a minor. The then minor + +Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in + +the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A., + +has suffered a loss of income, aloss of the capacity to earn income in the future, and a + +loss of the capacity to enjoy life. These injuries are permanent in nature and the + +Plaintiff, C.M.A., will continue to suffer these losses in the future. + +WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, + +JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount + +provided by law, punitive damages, attorney's fees, costs, and such other and further + +relief as this Court deems just and proper, and hereby demands trial by jury on all + +issues triable as of right by a jury. + +COUNT XIII + +Cause of Action Pursuant to 18 USC \$2255 + +December of 2002 — Incident 1 + +92. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 + +above. + +38 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRA/JOHNSON + +First Amended Complaint + +93. In December of 2002, C.M.A. again returned to JEFFREY EPSTEIN'S + +residence at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A to fully + +undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled + +the breasts and buttocks of the then minor C.M.A. At the conclusion of the massage, + +JEFFREY EPSTEIN masturbated himself. in C.M.A.'s presence. JEFFREY EPSTEIN + +paid C.M.A. in excess of \$200 for this encounter. + +94. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and + +In exchange for the Federal Government not prosecuting the Defendant for numerous + +federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an + +agreement with the Federal Government to the following: "Any person, who while a + +minor, was a victim of an offense enumerated in Title 18, United States Code, Section + +2255, will have the same rights to proceed under section 2255 as she would have had, + +if Mr. Epstein had been tried federally and convicted of an enumerated offense. For + +purposes of Implementing this paragraph, the United States shall provide Mr. Epstein's + +attorneys with a list of individuals whom it was prepared to name in an indictment as + +victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this + +provision, including any authority determining evidentiary burdens if any a Plaintiff must + +meet, shall consider that it is the intent of the parties to place these identified victims in + +the same position as they would have been had Mr. Epstein been convicted at trial. No + +more; no less." + +39 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRA/JOHNSON + +First Amended Complaint + +95. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in + +Title 18, United States Code, Section 2255, and as such asserts a cause of action + +against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United + +States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the + +United States Government. + +96. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the + +same position as if he had been tried and convicted of the sexual offenses committed + +against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the + +Plaintiff, C.M.A. + +97. As a direct and proximate result of the offenses enumerated in Title 18, + +United States Code; Section 2255, being committed against the then minor Plaintiff, + +C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and + +suffering, emotional distress, psychological trauma, mental anguish, humiliation, + +embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other + +damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and + +coercing her into a perverse and unconventional way of life for a minor. The then minor + +Plaintiff incurred medical and psychological expenses and the Plaintiff, C.MA., will in + +the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A., + +has suffered a loss of income, a loss of the capacity to earn income in the future, and a + +40 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRA/JOHNSON + +First Amended Complaint + +loss of the capacity to enjoy life. These injuries are permanent in nature and the + +Plaintiff, C.M.A., will continue to suffer these losses in the future. + +WHEREFORE, the Plaintiff, C.MA., demands judgment against the Defendant, + +JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount + +provided by law, punitive damages, attorney's fees, costs, and such other and further + +relief as this Court deems just and proper, and hereby demands trial by jury on all + +issues triable as of right by a jury. + +COUNT XIV + +Cause of Action Pursuant to 18 USC §2255 + +December of 2002 — Incident 2 + +98. The Plaintiff, C.MA., adopts and realleges paragraphs 1 through 19 + +above. + +99. For the second time in December of 2002, C.M.A. again returned to + +JEFFREY EPSTEIN'S residence at his request On this occasion, JEFFREY EPSTEIN + +directed C.M.A to fully undress and to provide him with a massage. Defendant, + +JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor C.M.A. At the + +conclusion of the massage, JEFFREY EPSTEIN masturbated himself In C.M.A.'s + +presence. JEFFREY EPSTEIN paid C.M.A. in excess of \$200 for this encounter. + +41 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRA/JOHNSON + +First Amended Complaint + +100. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and + +in exchange for the Federal Government not prosecuting the Defendant for numerous + +federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an + +agreement with the Federal Government to the following: "Any person, who while a + +minor, was a victim of an offense enumerated in Title 18, United States Code, Section + +2255, will have the same rights to proceed under section 2255 as she would have had, + +if Mr. Epstein had been tried federally and convicted of an enumerated offense. For + +purposes of implementing this paragraph, the United States shall provide Mr. Epstein's + +attorneys with a list of individuals whom it was prepared to name in an indictment as + +victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this + +provision, including any authority determining evidentiary burdens if any a Plaintiff must + +meet, shall consider that it is the intent of the parties to place these identified victims in + +the same position as they would have been had Mr. Epstein been convicted at trial. No + +more; no less." + +101. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in + +Title 18, United States Code, Section 2255, and as such asserts a cause of action + +against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United + +States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the + +United States Government. + +42 + +C.M.A. vs. Epstein, et al, + +Case No.: 08-CV-80811-CIV-MARRA/JOHNSON + +First Amended Complaint + +102. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the + +same position as if he had been tried and convicted of the sexual offenses committed + +against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the + +Plaintiff, C.M.A. + +103. As a direct and proximate result of the offenses enumerated in Title 18, + +United States Code, Section 2255, being committed against the then minor Plaintiff, + +C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and + +suffering, emotional distress, psychological trauma, mental anguish, humiliation, + +embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other + +damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and + +coercing her into a perverse and unconventional way of life for a minor. The then minor + +Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in + +the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A., + +has suffered a loss of income, aloss of the capacity to earn income in the future, and a + +loss of the capacity to enjoy life. These injuries are permanent in nature and the + +Plaintiff, C.M.A., will continue to suffer these losses in the future. + +WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, + +JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount + +provided by law, punitive damages, attorney's fees, costs, and such other and further + +43 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRA/JOHNSON + +First Amended Complaint + +relief as this Court deems just and proper, and hereby demands trial by jury on all + +issues triable as of right by a jury. + +COUNT XV + +Cause of Action Pursuant to 18 USC 42255 + +January of 2003 — Incident 1 + +104. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 + +above. + +105. In January of 2003, C.M.A. again returned to JEFFREY EPSTEIN'S + +residence at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A to fully + +undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled + +the breasts arid buttocks of the then minor C.M.A. At the conclusion of the massage, + +JEFFREY EPSTEIN masturbated himself in C.M.A.'s presence. JEFFREY EPSTEIN + +paid C.M.A. in excess of \$200 for this encounter. + +106. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and + +in exchange for the Federal Government not prosecuting the Defendant for numerous + +federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an + +agreement with the Federal Government to the following: "Any person, who while a + +minor, was a victim of an offense enumerated in Title 18, United States Code, Section + +2255, will have the same rights to proceed under section 2255 as she would have had, + +44 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRA/JOHNSON + +First Amended Complaint + +if Mr. Epstein had been tried federally and convicted of an enumerated offense. For + +purposes of implementing this paragraph, the United States shall provide Mr. Epstein's + +attorneys with a list of individuals whom it was prepared to name in an indictment as + +victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this + +provision, including any authority determining evidentiary burdens if any a Plaintiff must + +meet, shall consider that it is the intent of the parties to place these identified victims in + +the same position as they would have been had Mr. Epstein been convicted at trial. No + +more; no less? + +107. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in + +Title 18, United States Code, Section 2255, and as such asserts a cause of action + +against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United + +States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the + +United States Government. + +108. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the + +same position as if he had been tried and convicted of the sexual offenses committed + +against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the + +Plaintiff, C.M.A. + +109. As a direct and proximate result of the offenses enumerated in Title 18, + +United States Code, Section 2255, being committed against the then minor Plaintiff, + +C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and + +45 + +C.M.A. vs. Epstein, et al. + +Case No.: 0B-CV-80811-CIV-MARRNJOHNSON + +First Amended Complaint + +suffering, emotional distress, psychological trauma, mental anguish, humiliation, + +embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other + +damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and + +coercing her Into a perverse and unconventional way of life for a minor. The then minor + +Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in + +the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A., + +has suffered a loss of income, aloss of the capacity to earn income in the future, and a + +loss of the capacity to enjoy life. These injuries are permanent in nature and the + +Plaintiff, C.M.A., will continue to suffer these losses in the future. + +WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, + +JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount + +provided by law, punitive damages, attorney's fees, costs, and such other and further + +relief as this Court deems just and proper, and hereby demands trial by Jury on all + +issues triable as of right by a jury. + +COUNT XVI + +Cause of Action Pursuant to 18 USC 42255 + +January of 2003 — Incident 2 + +110. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 + +above. + +46 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRA/JOHNSON + +First Amended Complaint + +111. For the second time in January of 2003, C.M.A. again returned to + +JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN + +directed C.M.A to fully undress and to provide him with a massage. Defendant, + +JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor C.M.A. At the + +conclusion of the massage, JEFFREY EPSTEIN masturbated himself In C.M.A.'s + +presence. JEFFREY EPSTEIN paid C.M.A. in excess of \$200 for this encounter. + +112. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and + +in exchange for the Federal Government not prosecuting the Defendant for numerous + +federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an + +agreement with the Federal Government to the following: "Any person, who while a + +minor, was a victim of an offense enumerated in Title 18, United States Code, Section + +2255, will have the same rights to proceed under section 2255 as she would have had, + +if Mr. Epstein had been tried federally and convicted of an enumerated offense. For + +purposes of implementing this paragraph, the United States shall provide Mr. Epstein's + +attorneys with a list of individuals whom it was prepared to name in an indictment as + +victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this + +provision, including any authority determining evidentiary burdens if any a Plaintiff must + +meet, shall consider that it is the intent of the parties to place these identified victims in + +the same position as they would have been had Mr. Epstein been convicted at trial. No + +more; no less." + +47 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRA/JOHNSON + +First Amended Complaint + +113. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in + +Title 18, United States Code, Section 2255, and as such asserts a cause of action + +against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United + +States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the + +United States Government. + +114. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the + +same position as if he had been tried and convicted of the sexual offenses committed + +against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the + +Plaintiff, C.M.A. + +115. As a direct and proximate result of the offenses enumerated in Title 18, + +United States Code, Section 2255, being committed against the then minor Plaintiff, + +C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and + +suffering, emotional distress, psychological trauma, mental anguish, humiliation, + +embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other + +damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and + +coercing her into a perverse and unconventional way of life for a minor. The then minor + +Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in + +the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A., + +has suffered a loss of income, aloss of the capacity to earn income in the future, and a + +48 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRAJJOHNSON + +First Amended Complaint + +loss of the capacity to enjoy life. These injuries are permanent in nature and the + +Plaintiff, C.MA., will continue to suffer these losses in the future. + +WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, + +JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount + +provided by law, punitive damages, attorney's fees, costs, and such other and further + +relief as this Court deems just and proper, and hereby demands trial by jury on all + +issues triable as of right by a jury. + +COUNT XVII + +Cause of Action Pursuant to 18 USC 42255 + +February of 2003 — Incident 1 + +116. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 + +above. + +117. In February of 2003, C.M.A. again returned to JEFFREY EPSTEIN'S + +residence at his request On this occasion, JEFFREY EPSTEIN directed C.M.A to fully + +undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled + +the breasts and buttocks of the then minor C.M.A. At the conclusion of the massage, + +JEFFREY EPSTEIN masturbated himself in C.M.A.'s presence. JEFFREY EPSTEIN + +paid C.M.A. in excess of \$200 for this encounter. + +49 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRA/JOHNSON + +First Amended Complaint + +118. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and + +in exchange for the Federal Government not prosecuting the Defendant for numerous + +federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an + +agreement with the Federal Government to the following: "Any person, who while a + +minor, was a victim of an offense enumerated in Title 18, United States Code, Section + +2255, will have the same rights to proceed under section 2255 as she would have had, + +if Mr. Epstein had been tried federally and convicted of an enumerated offense. For + +purposes of implementing this paragraph, the United States shall provide Mr. Epstein's + +attorneys with a list of individuals whom It was prepared to name in an indictment as + +victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this + +provision, including any authority determining evidentiary burdens If any a Plaintiff must + +meet, shall consider that it is the intent of the parties to place these identified victims in + +the same position as they would have been had Mr. Epstein been convicted at trial. No + +more; no less." + +119. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in + +Title 18, United States Code, Section 2255, and as such asserts a cause of action + +against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United + +States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the + +United States Government. + +50 + +C.M.A. vs. Epstein, etas. + +Case No.: 08-CV-80811-CIV-MARRA/JOHNSON + +First Amended Complaint + +120. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the + +same position as if he had been tried and convicted of the sexual offenses committed + +against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the + +Plaintiff, C.M.A. + +121. As a direct and proximate result of the offenses enumerated in Title 18, + +United States Code, Section 2255, being committed against the then minor Plaintiff, + +C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and + +suffering, emotional distress, psychological trauma, mental anguish, humiliation, + +embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other + +damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and + +coercing her into a perverse and unconventional way of life for a minor. The then minor + +Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in + +the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A., + +has suffered a loss of income, a loss of the capacity to earn income in the future, and a + +loss of the capacity to enjoy life. These injuries are permanent in nature and the + +Plaintiff, C.M.A., will continue to suffer these losses in the future. + +WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, + +JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount + +provided by law, punitive damages, attorney's fees, costs, and such other and further + +51 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRA/JOHNSON + +First Amended Complaint + +relief as this Court deems just and proper, and hereby demands trial by jury on all + +issues triable as of right by a jury. + +COUNT XVIII + +Cause of Action Pursuant to 18 USC 42255 + +February of 2003 — Incident 2 + +122. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 + +above. + +123. For the second time in February of 2003, C.M.A. again returned to + +JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN + +directed C.M.A to fully undress and to provide him with a massage. Defendant, + +JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor C.M.A. At the + +conclusion of the massage, JEFFREY EPSTEIN masturbated himself in C.M.A.'s + +presence. JEFFREY EPSTEIN paid C.M.A. in excess of \$200 for this encounter. + +124. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and + +in exchange for the Federal Government not prosecuting the Defendant for numerous + +federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an + +agreement with the Federal Government to the following: "Any person, who while a + +minor, was a victim of an offense enumerated In Title 18, United States Code, Section + +2255, will have the same rights to proceed under section 2255 as she would have had, + +52 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRA/JOHNSON + +First Amended Complaint + +if Mr. Epstein had been tried federally and convicted of an enumerated offense. For + +purposes of implementing this paragraph, the United States shall provide Mr. Epstein's + +attorneys with a list of individuals whom it was prepared to name in an indictment as + +victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this + +provision, including any authority determining evidentiary burdens if any a Plaintiff must + +meet, shall consider that it is the Intent of the parties to place these identified victims in + +the same position as they would have been had Mr. Epstein been convicted at trial. No + +more; no less." + +125. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in + +Title 18, United States Code, Section 2255, and as such asserts a cause of action + +against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United + +States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the + +United States Government. + +126. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the + +same position as if he had been tried and convicted of the sexual offenses committed + +against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the + +Plaintiff, C.M.A. + +127. As a direct and proximate result of the offenses enumerated in Title 18, + +United States Code, Section 2255, being committed against the then minor Plaintiff, + +C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and + +53 + +G.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRA/JOI•INSON + +First Amended Complaint + +suffering, emotional distress, psychological trauma, mental anguish, humiliation, + +embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other + +damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and + +coercing her into a perverse and unconventional way of life for a minor. The then minor + +Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in + +the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A., + +has suffered a loss of income, aloss of the capacity to earn income in the future, and a + +loss of the capacity to enjoy life. These injuries are permanent in nature and the + +Plaintiff, C.M.A., will continue to suffer these losses in the future. + +WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, + +JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount + +provided by law, punitive damages, attorney's fees, costs, and such other and further + +relief as this Court deems just and proper, and hereby demands trial by jury on all + +issues triable as of right by a jury. + +COUNT XIX + +Cause of Action Pursuant to 18 USC §2255 + +March of 2003 — Incident 1 + +128. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 + +above. + +54 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRA/JOHNSON + +First Amended Complaint + +129. In March of 2003, C.M.A. again returned to JEFFREY EPSTEIN'S + +residence at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A to fully + +undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled + +the breasts and buttocks of the then minor C.M.A. At the conclusion of the massage, + +JEFFREY EPSTEIN masturbated himself in C.M.A.'s presence. JEFFREY EPSTEIN + +paid C.M.A. in excess of \$200 for this encounter. + +130. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and + +in exchange for the Federal Government not prosecuting the Defendant for numerous + +federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an + +agreement with the Federal Govemment to the following: "Any person, who while a + +minor, was a victim of an offense enumerated in Title 18, United States Code, Section + +2255, will have the same rights to proceed under section 2255 as she would have had, + +if Mr. Epstein had been tried federally and convicted of an enumerated offense. For + +purposes of implementing this paragraph, the United States shall provide Mr. Epstein's + +attorneys with a list of individuals whom it was prepared to name in an indictment as + +victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this + +provision, including any authority determining evidentiary burdens if any a Plaintiff must + +meet, shall consider that it is the intent of the parties to place these identified victims in + +the same position as they would have been had Mr. Epstein been convicted at trial. No + +more; no less." + +55 + +C.M.A vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRAJJOHNSON + +First Amended Complaint + +131. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in + +Title 18, United States Code, Section 2255, and as such asserts a cause of action + +against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United + +States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the + +United States Government. + +132. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the + +same position as if he had been tried and convicted of the sexual offenses committed + +against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the + +Plaintiff, C.M.A. + +133. As a direct and proximate result of the offenses enumerated in Title 18, + +United States Code, Section 2255, being committed against the then minor Plaintiff, + +C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and + +suffering, emotional distress, psychological trauma, mental anguish, humiliation, + +embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other + +damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and + +coercing her into a perverse and unconventional way of life for a minor. The then minor + +Plaintiff incurred medical and psychological expenses and the Plaintiff, C.MA., will in + +the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A., + +has suffered a loss of income, a loss of the capacity to earn income in the future, and a + +56 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARFtA/JOHNSON + +First Amended Complaint + +loss of the capacity to enjoy life. These injuries are permanent in nature and the + +Plaintiff, C.M.A., will continue to suffer these losses in the future. + +WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, + +JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount + +provided by law, punitive damages, attorney's fees, costs, and such other and further + +relief as this Court deems just and proper, and hereby demands trial by jury on all + +issues triable as of right by a jury. + +COUNT XX + +Cause of Action Pursuant to 18 USC 42255 + +March of 2003 — Incident 2 + +134. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 + +above. + +135. For the second time in March of 2003, C.M.A. again returned to JEFFREY + +EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed + +C.M.A to fully undress and to provide him with a massage. Defendant, JEFFREY + +EPSTEIN, fondled the breasts and buttocks of the then minor C.M.A. At the conclusion + +of the massage, JEFFREY EPSTEIN masturbated himself in C.M.A.'s presence. + +JEFFREY EPSTEIN paid C.M.A. In excess of \$200 for this encounter. + +57 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRAIJOHNSON + +First Amended Complaint + +136. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and + +in exchange for the Federal Government not prosecuting the Defendant for numerous + +federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an + +agreement with the Federal Government to the following: "Any person, who while a + +minor, was a victim of an offense enumerated in Title 18, United States Code, Section + +2255, will have the same rights to proceed under section 2255 as she would have had, + +if Mr. Epstein had been tried federally and convicted of an enumerated offense. For + +purposes of implementing this paragraph, the United States shall provide Mr. Epstein's + +attorneys with a list of individuals whom it was prepared to name in an indictment as + +victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this + +provision, including any authority determining evidentiary burdens if any a Plaintiff must + +meet, shall consider that it is the intent of the parties to place these identified victims in + +the same position as they would have been had Mr. Epstein been convicted at trial. No + +more; no less." + +137. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in + +Title 18, United States Code, Section 2255, and as such asserts a cause of action + +against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United + +States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the + +United States Government. + +58 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRA/JOHNSON + +First Amended Complaint + +138. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the + +same position as if he had been tried and convicted of the sexual offenses committed + +against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the + +Plaintiff, + +139. As a direct and proximate result of the offenses enumerated in Title 18, + +United States Code, Section 2255, being committed against the then minor Plaintiff, + +C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and + +suffering, emotional distress, psychological trauma, mental anguish, humiliation, + +embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other + +damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and + +coercing her into a perverse and unconventional way of life for a minor. The then minor + +Plaintiff incurred medical arid psychological expenses and the Plaintiff, C.M.A., will in + +the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A., + +has suffered a loss of income, aloss of the capacity to earn income in the future, and a + +loss of the capacity to enjoy life. These injuries are permanent in nature and the + +Plaintiff, C.M.A., will continue to suffer these losses in the future. + +WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, + +JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount + +provided by law, punitive damages, attorney's fees, costs, and such other and further + +59 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRA/JOHNSON + +First Amended Complaint + +relief as this Court deems just and proper, and hereby demands trial by jury on all + +issues triable as of right by a Jury. + +COUNT XXI + +Cause of Action Pursuant to 18 USC 82255 + +April of 2003 — ncident 1 + +140. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 + +above. + +141. In April of 2003, C.M.A. again returned to JEFFREY EPSTEIN'S residence + +at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A to fully undress + +and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the + +breasts and buttocks of the then minor C.M.A. At the conclusion of the massage, + +JEFFREY EPSTEIN masturbated himself in C.M.A.'s presence. JEFFREY EPSTEIN + +paid C.M.A. in excess of \$200 for this encounter. + +142. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and + +in exchange for the Federal Government not prosecuting the Defendant for numerous + +federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an + +agreement with the Federal Government to the following: "Any person, who while a + +minor, was a victim of an offense enumerated in Title 18, United States Code, Section + +2255, will have the same rights to proceed under section 2255 as she would have had, + +60 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRA/JOHNSON + +First Amended Complaint + +if Mr. Epstein had been tried federally and convicted of an enumerated offense. For + +purposes of implementing this paragraph, the United States shall provide Mr. Epstein's + +attorneys with a list of individuals whom it was prepared to name in an indictment as + +victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this + +provision, including any authority determining evidentiary burdens if any a Plaintiff must + +meet, shall consider that It is the intent of the parties to place these identified victims in + +the same position as they would have been had Mr. Epstein been convicted at trial. No + +more; no less." + +143. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in + +Title 18, United States Code, Section 2255, and as such asserts a cause of action + +against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United + +States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the + +United States Government. + +144. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the + +same position as if he had been tried and convicted of the sexual offenses committed + +against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the + +Plaintiff, C.M.A. + +145. As a direct and proximate result of the offenses enumerated in Title 18, + +United States Code, Section 2255, being committed against the then minor Plaintiff, + +C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and + +61 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRA/JOHNSON + +First Amended Complaint + +suffering, emotional distress, psychological trauma, mental anguish, humiliation, + +embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other + +damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and + +coercing her into a perverse and unconventional way of life for a minor. The then minor + +Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in + +the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A., + +has suffered a loss of income, aloss of the capacity to earn income in the future, and a + +loss of the capacity to enjoy life. These injuries are permanent in nature and the + +Plaintiff, C.M.A., will continue to suffer these losses in the future. + +WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, + +JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount + +provided by law, punitive damages, attorney's fees, costs, and such other and further + +relief as this Court deems just and proper, and hereby demands trial by jury on all + +issues triable as of right by a jury. + +COUNT XXII + +Cause of Action Pursuant to 18 USC \$2255 + +April of 2003 — Incident 2 + +146. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 + +above. + +62 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRA/JOHNSON + +First Amended Complaint + +147. For the second time in April of 2003, C.M.A. again returned to JEFFREY + +EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed + +C.M.A to fully undress and to provide him with a massage. Defendant, JEFFREY + +EPSTEIN, fondled the breasts and buttocks of the then minor C.M.A. At the conclusion + +of the massage, JEFFREY EPSTEIN masturbated himself in C.M.A.'s presence. + +JEFFREY EPSTEIN paid C.M.A. In excess of \$200 for this encounter. + +148. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and + +in exchange for the Federal Government not prosecuting the Defendant for numerous + +federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an + +agreement with the Federal Government to the following: "Any person, who while a + +minor, was a victim of an offense enumerated in Title 18, United States Code, Section + +2255, will have the same rights to proceed tinder section 2255 as she would have had, + +if Mr. Epstein had been tried federally and convicted of an enumerated offense. For + +purposes of Implementing this paragraph, the United States shall provide Mr. Epstein's + +attorneys with a list of individuals whom it was prepared to name in an indictment as + +victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this + +provision, including any authority determining evidentiary burdens if any a Plaintiff must + +meet, shall consider that it is the intent of the parties to place these identified victims in + +the same position as they would have been had Mr. Epstein been convicted at trial. No + +more; no less." + +63 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-Cht-MARFtA/JOHNSON + +First Amended Complaint + +149. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in + +Title 18, United States Code, Section 2255, and as such asserts a cause of action + +against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United + +States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the + +United States Government. + +150. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the + +same position as if he had been tried and convicted of the sexual offenses committed + +against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the + +Plaintiff, C.M.A. + +151. As a direct and proximate result of the offenses enumerated in Title 18, + +United States Code, Section 2255, being committed against the then minor Plaintiff, + +C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and + +suffering, emotional distress, psychological trauma, mental anguish, humiliation, + +embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other + +damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and + +coercing her into a perverse and unconventional way of life for a minor. The then minor + +Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will In + +the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A., + +has suffered a loss of income, aloss of the capacity to earn income in the future, and a + +64 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRA/JOHNSON + +First Amended Complaint + +loss of the capacity to enjoy life. These injuries are permanent in nature and the + +Plaintiff, C.M.A., will continue to suffer these losses in the future. + +WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant + +JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount + +provided by law, punitive damages, attorney's fees, costs, and such other and further + +relief as this Court deems just and proper, and hereby demands trial by jury on all + +issues triable as of right by a jury. + +COUNT XXIII + +Cause of Action Pursuant to 18 USC §2255 + +May of 2003 — Incident 1 + +152. The Plaintiff, C.MA., adopts and realleges paragraphs 1 through 19 + +above. + +153. In May of 2003, C.M.A. again returned to JEFFREY EPSTEIN'S residence + +at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A to fully undress + +and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the + +breasts and buttocks of the then minor C.MA. At the conclusion of the massage, + +JEFFREY EPSTEIN masturbated himself in C.M.A.'s presence. JEFFREY EPSTEIN + +paid C.M.A. in excess of \$200 for this encounter. + +65 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRA/JOHNSON + +First Amended Complaint + +154. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and + +in exchange for the Federal Government not prosecuting the Defendant for numerous + +federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an + +agreement with the Federal Government to the following: "Any person, who while a + +minor, was a victim of an offense enumerated in Title 18, United States Code, Section + +2255, will have the same rights to proceed under section 2255 as she would have had, + +if Mr. Epstein had been tried federally and convicted of an enumerated offense. For + +purposes of implementing this paragraph, the United States shall provide Mr. Epstein's + +attorneys with a list of individuals whom it was prepared to name in an indictment as + +victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this + +provision, including any authority determining evidentiary burdens if any a Plaintiff must + +meet, shall consider that it Is the intent of the parties to place these identified victims in + +the same position as they would have been had Mr. Epstein been convicted at trial. No + +more; no less." + +155. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in + +Title 18, United States Code, Section 2255, and as such asserts a cause of action + +against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United + +States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the + +United States Government. + +66 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRA/JOHNSON + +First Amended Complaint + +156. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the + +same position as if he had been tried and convicted of the sexual offenses committed + +against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the + +Plaintiff, C.M\_A. + +157. As a direct and proximate result of the offenses enumerated in Title 18, + +United States Code, Section 2255, being committed against the then minor Plaintiff, + +C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and + +suffering, emotional distress, psychological trauma, mental anguish, humiliation, + +embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other + +damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and + +coercing her into a perverse and unconventional way of life for a minor. The then minor + +Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in + +the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A., + +has suffered a loss of income, aloss of the capacity to earn income in the future, and a + +loss of the capacity to enjoy life. These injuries are permanent in nature and the + +Plaintiff, C.M.A., will continue to suffer these losses in the future. + +WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, + +JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount + +provided by law, punitive damages, attorney's fees, costs, and such other and further + +67 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRA/JOHNSON + +First Amended Complaint + +relief as this Court deems just and proper, and hereby demands trial by jury on all + +issues triable as of right by a jury. + +COUNT XXIV + +Cause of Action Pursuant to 18 USC 42255 + +May of 2003 — Incident 2 + +158. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 + +above. + +159. For the second time in May of 2003, C.M.A. again returned to JEFFREY + +EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed + +C.M.A to fully undress and to provide him with a massage. Defendant, JEFFREY + +EPSTEIN, fondled the breasts and buttocks of the then minor C.M.A. At the conclusion + +of the massage, JEFFREY EPSTEIN masturbated himself in C.M.A.'s presence. + +JEFFREY EPSTEIN paid C.M.A. in excess of \$200 for this encounter. + +160. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and + +in exchange for the Federal Government not prosecuting the Defendant for numerous + +federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an + +agreement with the Federal Government to the following: "Any person, who while a + +minor, was a victim of an offense enumerated in Title 18, United States Code, Section + +2255, will have the same rights to proceed under section 2255 as she would have had, + +68 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRA/JOHNSON + +First Amended Complaint + +if Mr. Epstein had been tried federally and convicted of an enumerated offense. For + +purposes of implementing this paragraph, the United States shall provide Mr. Epstein's + +attorneys with a list of individuals whom it was prepared to name in an indictment as + +victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this + +provision, including any authority determining evidentiary burdens if any a Plaintiff must + +meet, shall consider that it is the intent of the parties to place these identified victims in + +the same position as they would have been had Mr. Epstein been convicted at trial. No + +more; no less." + +161. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in + +Title 18, United States Code, Section 2255, and as such asserts a cause of action + +against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United + +States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the + +United States Government. + +162. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the + +same position as if he had been tried and convicted of the sexual offenses committed + +against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the + +Plaintiff, C.M.A. + +163. As a direct and proximate result of the offenses enumerated in Title 18, + +United States Code, Section 2255, being committed against the then minor Plaintiff, + +C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and + +69 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRA/JOHNSON + +First Amended Complaint + +suffering, emotional distress, psychological trauma, mental anguish, humiliation, + +embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other + +damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and + +coercing her into a perverse and unconventional way of life for a minor. The then minor + +Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in + +the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A., + +has suffered a loss of income, a loss of the capacity to earn income In the future, and a + +loss of the capacity to enjoy life. These injuries are permanent in nature and the + +Plaintiff, C.M.A., will continue to suffer these losses in the future. + +WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, + +JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount + +provided by law, punitive damages, attorney's fees, costs, and such other and further + +relief as this Court deems just and proper, and hereby demands trial by jury on all + +issues triable as of right by a jury. + +COUNT XXV + +Cause of Action Pursuant to 18 USC 42255 + +June of 2003 — Incident 1 + +164. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 + +above. + +70 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRA/JOHNSON + +First Amended Complaint + +165. In June of 2003, C.M.A. again returned to JEFFREY EPSTEIN'S + +residence at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A to fully + +undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled + +the breasts and buttocks of the then minor C.M.A. At the conclusion of the massage, + +JEFFREY EPSTEIN masturbated himself in C.M.A.'s presence. JEFFREY EPSTEIN + +paid C.M.A. in excess of \$200 for this encounter. + +166. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and + +in exchange for the Federal Government not prosecuting the Defendant for numerous + +federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an + +agreement with the Federal Government to the following: 'Any person, who white a + +minor, was a victim of an offense enumerated in Title 18, United States Code, Section + +2255, will have the same rights to proceed under section 2255 as she would have had, + +if Mr. Epstein had been tried federally and convicted of an enumerated offense. For + +purposes of implementing this paragraph, the United States shall provide Mr. Epstein's + +attorneys with a list of individuals whom It was prepared to name in an indictment as + +victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this + +provision, including any authority determining evidentiary burdens if any a Plaintiff must + +meet, shall consider that it is the intent of the parties to place these identified victims In + +the same position as they would have been had Mr. Epstein been convicted at trial. No + +more; no less? + +71 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-C IV-MARRA/JOHNSON + +First Amended Complaint + +167. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in + +Title 18, United States Code, Section 2255, and as such asserts a cause of action + +against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United + +States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the + +United States Government. + +168. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the + +same position as if he had been tried and convicted of the sexual offenses committed + +against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the + +Plaintiff, C.M.A. + +169. As a direct and proximate result of the offenses enumerated in Title 18, + +United States Code, Section 2255, being committed against the then minor Plaintiff, + +C.M.A., has in the past suffered, and will In the future suffer, physical injury, pain and + +suffering, emotional distress, psychological trauma, mental anguish, humiliation, + +embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other + +damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and + +coercing her into a perverse and unconventional way of life for a minor. The then minor + +Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in + +the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A., + +has suffered a loss of income, a loss of the capacity to earn Income in the future, and a + +72 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRA/JOHNSON + +First Amended Complaint + +loss of the capacity to enjoy life. These injuries are permanent in nature and the + +Plaintiff, C.M.A., will continue to suffer these losses in the future. + +WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, + +JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount + +provided by law, punitive damages, attorney's fees, costs, and such other and further + +relief as this Court deems just and proper, and hereby demands trial by jury on all + +issues triable as of right by a jury. + +COUNT XXVI + +Cause of Action Pursuant to 18 USC §2255 + +June of 2003 — Incident 2 + +170. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 + +above. + +171. For the second time in June of 2003, C.M.A. again returned to JEFFREY + +EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed + +C.M.A to fully undress and to provide him with a massage. Defendant, JEFFREY + +EPSTEIN, fondled the breasts and buttocks of the then minor C.M.A. At the conclusion + +of the massage, JEFFREY EPSTEIN masturbated himself in C.M.A.'s presence. + +JEFFREY EPSTEIN paid C.M.A. in excess of \$200 for this encounter. + +73 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRAIJOHNSON + +First Amended Complaint + +172. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and + +in exchange for the Federal Government not prosecuting the Defendant for numerous + +federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an + +agreement with the Federal Government to the following: "Any person, who while a + +minor, was a victim of an offense enumerated in Title 18, United States Code, Section + +2255, will have the same rights to proceed under section 2255 as she would have had, + +if Mr. Epstein had been tried federally and convicted of an enumerated offense. For + +purposes of implementing this paragraph, the United States shall provide Mr. Epstein's + +attorneys with a list of individuals whom it was prepared to name in an indictment as + +victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this + +provision, including any authority determining evidentiary burdens if any a Plaintiff must + +meet, shall consider that it is the intent of the parties to place these identified victims in + +the same position as they would have been had Mr. Epstein been convicted at trial. No + +more; no less." + +173. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in + +Title 18, United States Code, Section 2255, and as such asserts a cause of action + +against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United + +States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the + +United States Government + +74 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRA/JOHNSON + +First Amended Complaint + +174. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the + +same position as if he had been tried and convicted of the sexual offenses committed + +against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the + +Plaintiff, C.M.A. + +175, As a direct and proximate result of the offenses enumerated in Title 18, + +United States Code, Section 2255, being committed against the then minor Plaintiff, + +C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and + +suffering, emotional distress, psychological trauma, mental anguish, humiliation, + +embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other + +damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and + +coercing her into a perverse and unconventional way of life for a minor. The then minor + +Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in + +the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A., + +has suffered a loss of income, aloss of the capacity to earn income in the future, and a + +loss of the capacity to enjoy life. These injuries are permanent in nature and the + +Plaintiff, C.M.A., will continue to suffer these losses in the future. + +WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, + +JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount + +provided by law, punitive damages, attorneys fees, costs, and such other and further + +75 + +C.M.A. vs. Epstein, et at + +Case No.: 08-CV-80811-CIV-MARRA/JOHNSON + +First Amended Complaint + +relief as this Court deems just and proper, and hereby demands trial + +issues triable as of right by a jury. + +COUNT XXVII + +Cause of Action Pursuant to 18 USC §2255 + +July of 2003 - Incident 1 + +by jury on all + +176. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 + +above. + +177. In July of 2003, C.M.A. again returned to JEFFREY EPSTEIN'S residence + +at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A to fully undress + +and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled the + +breasts and buttocks of the then minor C.M.A. At the conclusion of the massage, + +JEFFREY EPSTEIN masturbated himself in C.M.A.'s presence. JEFFREY EPSTEIN + +paid C.M.A. in excess of \$200 for this encounter. + +178. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and + +in exchange for the Federal Government not prosecuting the Defendant for numerous + +federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an + +agreement with the Federal Government to the following: "Any person, who while a + +minor, was a victim of an offense enumerated in Title 18, United States Code, Section + +2255, will have the same rights to proceed under section 2255 as she would have had, + +76 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRA/JOHNSON + +First Amended Complaint + +if Mr. Epstein had been tried federally and convicted of an enumerated offense. For + +purposes of implementing this paragraph, the United States shall provide Mr. Epstein's + +attorneys with a list of individuals whom it was prepared to name in an indictment as + +victims of an enumerated offense by Mr. Epstein. My judicial authority interpreting this + +provision, including any authority determining evidentiary burdens if any a Plaintiff must + +meet, shall consider that It is the intent of the parties to place these identified victims in + +the same position as they would have been had Mr. Epstein been convicted at trial. No + +more; no less." + +179. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in + +Title 18, United States Code, Section 2255, and as such asserts a cause of action + +against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United + +States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the + +United States Government + +180. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the + +same position as if he had been tried and convicted of the sexual offenses committed + +against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the + +Plaintiff, C.M.A. + +181. As a direct and proximate result of the offenses enumerated in Title 18, + +United States Code, Section 2255, being committed against the then minor Plaintiff, + +C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and + +77 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARR/VJOHNSON + +First Amended Complaint + +suffering, emotional distress, psychological trauma, mental anguish, humiliation, + +embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other + +damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and + +coercing her into a perverse and unconventional way of life for a minor. The then minor + +Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M,A., will in + +the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A., + +has suffered a loss of income, a loss of the capacity to earn income in the future, and a + +loss of the capacity to enjoy life. These injuries are permanent in nature and the + +Plaintiff, C.M.A., will continue to suffer these losses in the future. + +WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, + +JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount + +provided by law, punitive damages, attorney's fees, costs, and such other and further + +relief as this Court deems just and proper, and hereby demands trial by jury on all + +Issues triable as of right by a jury. + +COUNT XXVIII + +Cause of Action Pursuant to 18 USC §2255 + +July of 2003 — Incident 2 + +182. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 + +above. + +78 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRA/JOHNSON + +First Amended Complaint + +183. For the second time in July of 2003, C.M.A. again returned to JEFFREY + +EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN directed + +C.M.A to fully undress and to provide him with a massage. Defendant, JEFFREY + +EPSTEIN, fondled the breasts and buttocks of the then minor C.M.A. At the conclusion + +of the massage, JEFFREY EPSTEIN masturbated himself in C.MA.'s presence. + +JEFFREY EPSTEIN paid C.M.A. in excess of \$200 for this encounter. + +184. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and + +in exchange for the Federal Government not prosecuting the Defendant for numerous + +federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an + +agreement with the Federal Government to the following: °Any person, who while a + +minor, was a victim of an offense enumerated in Title 18, United States Code, Section + +2255, will have the same rights to proceed under section 2255 as she would have had, + +if Mr. Epstein had been tried federally and convicted of an enumerated offense. For + +purposes of implementing this paragraph, the United States shall provide Mr. Epstein's + +attorneys with a list of individuals whom it was prepared to name in an indictment as + +victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this + +provision, including any authority determining evidentiary burdens if any a Plaintiff must + +meet, shall consider that it is the intent of the parties to place these identified victims in + +the same position as they would have been had Mr. Epstein been convicted at trial. No + +more; no less." + +79 + +C.M.A. vs. Epstein, et at + +Case No.: 08-CV-80811-CIV-MARRA/JOHNSON + +First Amended Complaint + +185. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in + +Title 18, United States Code, Section 2255, and as such asserts a cause of action + +against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United + +States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the + +United States Government. + +186. Pursuant to the agreement the Defendant, JEFFREY EPSTEIN, is in the + +same position as if he had been tried and convicted of the sexual offenses committed + +against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the + +Plaintiff, C.M.A. + +187. As a direct and proximate result of the offenses enumerated in Title 18, + +United States Code, Section 2255, being committed against the then minor Plaintiff, + +C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and + +suffering, emotional distress, psychological trauma, mental anguish, humiliation, + +embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other + +damages associated with Defendant JEFFREY EPSTEIN, controlling, manipulating and + +coercing her into a perverse and unconventional way of life for a minor. The then minor + +Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in + +the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A., + +has suffered a loss of income, a loss of the capacity to earn income in the future, and a + +80 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRPJJOHNSON + +First Amended Complaint + +loss of the capacity to enjoy life. These injuries are permanent in nature and the + +Plaintiff, C.MA., will continue to suffer these losses in the future. + +WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, + +JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount + +provided by law, punitive damages, attorney's fees, costs, and such other and further + +relief as this Court deems just and proper, and hereby demands trial by jury on all + +issues triable as of right by a jury. + +COUNT XXIX + +Cause of Action Pursuant to 18 USC §2255 + +August of 2003 — Incident 1 + +188. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 + +above. + +189. In August of 2003, C.M.A. again returned to JEFFREY EPSTEIN'S + +residence at his request. On this occasion, JEFFREY EPSTEIN directed C.M.A to fully + +undress and to provide him with a massage. Defendant, JEFFREY EPSTEIN, fondled + +the breasts and buttocks of the then minor C.M.A. At the conclusion of the massage, + +JEFFREY EPSTEIN masturbated himself in C.M.A.'s presence. JEFFREY EPSTEIN + +paid C.M.A. in excess of \$200 for this encounter. + +81 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRA/JOHNSON + +First Amended Complaint + +190. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and + +in exchange for the Federal Government not prosecuting the Defendant for numerous + +federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an + +agreement with the Federal Government to the following: "Any person, who while a + +minor, was a victim of an offense enumerated in Title 18, United States Code, Section + +2255, will have the same rights to proceed under section 2255 as she would have had, + +if Mr. Epstein had been tried federally and convicted of an enumerated offense. For + +purposes of implementing this paragraph, the United States shall provide Mr. Epstein's + +attorneys with a list of individuals whom it was prepared to name in an indictment as + +victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this + +provision, including any authority determining evidentiary burdens If any a Plaintiff must + +meet, shall consider that it is the intent of the parties to place these identified victims in + +the same position as they would have been had Mr. Epstein been convicted at trial. No + +more; no less." + +191. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in + +Title 18, United States Code, Section 2255, and as such asserts a cause of action + +against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United + +States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the + +United States Government. + +82 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRAMOHNSON + +First Amended Complaint + +192. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the + +same position as if he had been tried and convicted of the sexual offenses committed + +against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the + +Plaintiff, C.M.A. + +193. As a direct and proximate result of the offenses enumerated in Title 18, + +United States Code, Section 2255, being committed against the then minor Plaintiff, + +C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and + +suffering, emotional distress, psychological trauma, mental anguish, humiliation, + +embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other + +damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and + +coercing her into a perverse and unconventional way of life for a minor. The then minor + +Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in + +the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A., + +has suffered a loss of income, a loss of the capacity to earn income in the future, and a + +loss of the capacity to enjoy life. These injuries are permanent in nature and the + +Plaintiff, C.M.A., will continue to suffer these losses in the future. + +WHEREFORE, the Plaintiff, C.MA, demands judgment against the Defendant, + +JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount + +provided by law, punitive damages, attorney's fees, costs, and such other and further + +83 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRNJOHNSON + +First Amended Complaint + +relief as this Court deems just and proper, and hereby demands trial by jury on all + +issues triable as of right by a jury. + +COUNT XXX + +Cause of Action Pursuant to 18 USC §2255 + +August of 2003 — Incident 2 + +194. The Plaintiff, C.M.A., adopts and realleges paragraphs 1 through 19 + +above. + +195. For the second time in August of 2003, C.M.A. again returned to + +JEFFREY EPSTEIN'S residence at his request. On this occasion, JEFFREY EPSTEIN + +directed C.M.A to fully undress and to provide him with a massage. Defendant, + +JEFFREY EPSTEIN, fondled the breasts and buttocks of the then minor C.M.A. At the + +conclusion of the massage, JEFFREY EPSTEIN masturbated himself in C.M.A.'s + +presence. JEFFREY EPSTEIN paid C.M.A. in excess of \$200 for this encounter. + +196. As a condition of the Defendant, JEFFREY EPSTEIN's criminal plea, and + +in exchange for the Federal Government not prosecuting the Defendant for numerous + +federal offenses, the Defendant, JEFFREY EPSTEIN, additionally entered into an + +agreement with the Federal Government to the following: 'Any person, who while a + +minor, was a victim of an offense enumerated in Title 18, United States Code, Section + +2255, will have the same rights to proceed under section 2255 as she would have had, + +84 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRA/JOHNSON + +First Amended Complaint + +if Mr. Epstein had been tried federally and convicted of an enumerated offense. For + +purposes of implementing this paragraph, the United States shall provide Mr. Epstein's + +attorneys with a list of individuals whom it was prepared to name in an indictment as + +victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this + +provision, including any authority determining evidentiary burdens if any a Plaintiff must + +meet, shall consider that it is the intent of the parties to place these identified victims in + +the same position as they would have been had Mr. Epstein been convicted at trial. No + +more; no less." + +197. The Plaintiff, C.M.A., was a victim of one or more offenses enumerated in + +Title 18, United States Code, Section 2255, and as such asserts a cause of action + +against the Defendant, JEFFREY EPSTEIN, pursuant to this Section of the United + +States Code and the agreement between the Defendant, JEFFREY EPSTEIN, and the + +United States Government. + +198. Pursuant to the agreement, the Defendant, JEFFREY EPSTEIN, is in the + +same position as if he had been tried and convicted of the sexual offenses committed + +against the Plaintiff, C.M.A., and as such he must effectively admit liability unto the + +Plaintiff, C.M.A. + +199. As a direct and proximate.result of the offenses enumerated in Title 18, + +United States Code, Section 2255, being committed against the then minor Plaintiff, + +C.M.A., has in the past suffered, and will in the future suffer, physical injury, pain and + +85 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRA/JOHNSON + +First Amended Complaint + +suffering, emotional distress, psychological trauma, mental anguish, humiliation, + +embarrassment, loss of self-esteem, loss of dignity, invasion of her privacy and other + +damages associated with Defendant, JEFFREY EPSTEIN, controlling, manipulating and + +coercing her into a perverse and unconventional way of life for a minor. The then minor + +Plaintiff incurred medical and psychological expenses and the Plaintiff, C.M.A., will in + +the future suffer additional medical and psychological expenses. The Plaintiff, C.M.A., + +has suffered a loss of income, aloss of the capacity to earn income in the future, and a + +loss of the capacity to enjoy life. These injuries are permanent in nature and the + +Plaintiff, C.M.A., will continue to suffer these losses in the future. + +WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, + +JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount + +provided by law, punitive damages, attorney's fees, costs, and such other and further + +relief as this Court deems just and proper, and hereby demands trial by jury on all + +issues triable as of right by a jury. + +COUNT XXXI + +Sexual Battery + +200. The Plaintiff, C.MA., adopts and realleges paragraphs 1 through 199 + +above. + +86 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRA/JOHNSON + +First Amended Complaint + +201. Between late May or early June of 2002 and August of 2003, Defendant, + +JEFFERY EPSTEIN, engaged in dozens of illegal and depraved sexual acts against + +Plaintiff, C.M.A. + +202. As described more fully in the above paragraphs, Defendant, JEFFERY + +EPSTEIN, intentionally inflicted harmful and/or offensive sexual contact on the person of + +C.M.A. + +203. Defendant, JEFFREY EPSTEIN'S, tortuous commission of sexual battery + +upon C.M.A. were done willfully and maliciously. + +204. As a direct and proximate result of JEFFREY EPSTEIN'S battery on + +C.M.A., she has suffered and will continue to suffer severe and permanent traumatic + +injuries, including mental, psychological and emotional damages. + +WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, + +JEFFREY EPSTEIN, for compensatory damages of at least the minimum amount + +provided by law, punitive damages, attorney's fees, costs, and such other and further + +relief as this Court deems just and proper, and hereby demands trial by jury on all + +issues triable as of right by a jury. + +COUNT XXXII + +Conspiracy to Commit Tortious Assault Against Defendant + +205. Plaintiff incorporates into this count the allegations of paragraphs 1 + +through 19. + +87 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRA/JOHNSON + +First Amended Complaint + +206. Defendant is one of Defendant, JEFFREY EPSTEIN'S, + +referenced in paragraph 12 above. Defendant, JEFFREY + +EPSTEIN, Defendant, and others reached an agreement between + +themselves for the purpose of allowing Defendant, JEFFREY EPSTEIN, to commit the + +illegal acts described above upon Plaintiff, C.M.A. + +207. Many of the instances of illegal sexual conduct committed by Defendant, + +JEFFREY EPSTEIN, described above were perpetrated with the assistance, support, + +and facilitation by Defendant, In fact, Defendant, + +aided, assisted, and/or abetted Defendant, JEFFREY EPSTEIN, in his organized + +scheme and plan to sexually assault, and/or coerce Plaintiff, C.M.A., to engage in + +prostitution. + +208. Defendant, would often arrange times for C.M.A. to + +come to Defendant, JEFFREY EPSTEIN'S, residence, would escort C.M.A. to the room + +where Defendant, JEFFREY EPSTEIN, was waiting, would deliver cash from + +Defendant, JEFFREY EPSTEIN, at the conclusion of a session, and took nude + +photographs of Plaintiffs, C.M.A., for Defendant, JEFFREY EPSTEIN. + +209. As a direct and proximate result of Defendant, + +participation in the aforementioned conspiracy, Plaintiff, C.M.A, has suffered and will + +continue to suffer damages, including, but not limited to, pain, suffering, emotional + +distress, psychological trauma, mental anguish, humiliation, embarrassment, loss of + +88 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRA/JOHNSON + +First Amended Complaint + +self-esteem, loss of dignity, invasion of personal privacy and other damages associated + +with JEFFREY EPSTEIN'S controlling , manipulating, and coercing C.M.A. into a + +perverse and unconventional way of life for a minor. The then minor Plaintiff incurred + +medical and psychological expenses and the Plaintiff, C.MA., will in the future suffer + +additional medical and psychological expenses. The Plaintiff, C.M.A., has suffered a + +loss of income, aloss of the capacity to earn income in the future, and a loss of the + +capacity to enjoy life. These injuries are permanent in nature and the Plaintiff, C.M.A., + +will continue to suffer these losses in the future. + +WHEREFORE, the Plaintiff, C.M.A., demands judgment against the Defendant, + +....or compensatory damages of at least the minimum amount provided + +by law, punitive damages, attorney's fees, costs, and such other and further relief as + +this Court deems just and proper, and hereby demands trial by jury on all issues triable + +as of right by a jury. + +CERTIFICATE OF SERVICE + +IHEREBY CERTIFY that on the 9th day of February, 2009, I electronically filed + +the foregoing with the Clerk of the Court by using CM/ECF system, which will send a + +notice of electronic filing to all counsel of record on the attached service list. + +89 + +C.M.A. vs. Epstein, et al. + +Case No.: 08-CV-80811-CIV-MARRA/JOHNSON + +First Amended Complaint + +Page 90 of 91 + +/s/Jack P Hill Jack Scarola + +Florida Bar No.: 169440 + +Jack P. Hill + +Florida Bar No.: 0547808 + +Shipley, P.A. + +Attorneys for s + +90 + +C.M.A. vs. Epstein, et al. + +case No.: 08-CV-80811-CIV-MARRNJOHNSON + +First Amended Complaint + +Page 91 of 91 + +COUNSEL LIST + +Richard H. Willits, Esquire Richard H. Willits, PA. + +Robert Critton, Esquire + +Burman Critton Luther & Coleman LLP + +Jack A. Goldberger, Esquire + +Bruce E. Reinhart, Esquire 11 . + +91 \ No newline at end of file diff --git a/marker2/ds9/EFTA00087853/EFTA00087853.metadata.json b/marker2/ds9/EFTA00087853/EFTA00087853.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..1b3c9d2bea5d8d0ed8a158b882b3c0ee36944640 --- /dev/null +++ b/marker2/ds9/EFTA00087853/EFTA00087853.metadata.json @@ -0,0 +1,2390 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087853.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 91, + "chars": 134892, + "elapsed_seconds": 48.62, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 49 + ], + [ + "Line", + 24 + ], + [ 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Please note that the FedEx will say it is from the White Plains office. The FedEx Tracking number is + +Thank you. + +From: + +Sent: Tuesday, August 04, 2020 1:48 PM + +To: + +Cc: >; + +Subject: RE: new materials for Maxwell upload to Relativity + +I know you're on vacation this week, but wanted to very briefly follow up on the below — I'm going to ask to mail you the thumb drive referenced below, which has folders for five devices (NYCO24332, NYCO24369, NYCO24369 1, NYCO24372, and NYCO24384) on this coming Monday, so that you'll be around when it arrives (and in case you have to sign for it). Per usual, if you could please take a look at it when you receive it, and then send on to PAE for processing and upload to Relativity, that would be great. Thank you!! + +From: + +Sent: Tuesday, August 04, 2020 13:44 + +To: + +Cc: >; + +Subject: RE: [EXTERNAL EMAIL] - RE: Epstein Evidence status + +Following up on the below, thanks for those responses, that's very useful. In terms of the one outstanding item, in the thumb drive I received from yesterday with CART materials, NYCO27913 is not included, so we are still missing that one. + +But I do see that each of the items with the "Included next round" label from the most recent spreadsheet (attached, with those items highlighted in red) are included, so that's helpful, thanks. + +In terms of any of the folders that have been produced so far, I know that you've sent supplemental materials on a handful of them (approximately seven total, I think) – do you currently expect to send any other supplemental materials for any of the devices we've received so far? Or are we fully complete? + +And then assuming those are all fully complete, or once they are, the only items pending will be the devices highlighted in gray in the attached, which we understand are being processed for hardware recovery. + +thanks, + +![A black rectangular bar with a small white circle on the right side.]()From: [REDACTED] > + +**Sent:** Monday, August 03, 2020 19:17 + +To: [REDACTED] <[REDACTED]> + +Cc: [REDACTED] >; [REDACTED] >; [REDACTED] >; [REDACTED] < [REDACTED] >; [REDACTED] < [REDACTED] >; [REDACTED] >; [REDACTED] < [REDACTED] >; [REDACTED] < [REDACTED] >; [REDACTED] ([REDACTED]) & + +**Subject:** RE: [EXTERNAL EMAIL] - RE: Epstein Evidence status + +Sorry I didn't get back sooner. It's been kinda crazy. I'll answer your questions in order, so match them up. I'm going off what I can see on my phone. + +The final items were given to ██████████. She should have them. Reach out to her for delivery. + +The 3 folders you mention contain supplemental files, do not ignore them. + +I am pretty sure NYC027913 is included with the items ██████████ has. If not, please let me know. + +As far as the old questions, you should have everything now. + +The zero byte files are just that. Sometimes the software will recover either file headers, or items off the directory listings, but no actual content. It lists them as zero length files. + +Need anything further, let me know. + +On Aug 3, 2020 3:33 PM, "[REDACTED]" <[REDACTED]> wrote: + +I know you may still be traveling, but I wanted to check in on a handful of outstanding issues. If you’re not available, perhaps Francesco can assist? + +1. 1. On this past Sunday and Monday, you had said you had you had additional materials you planned to get to us on Monday. I don't believe we ever received anything additional this past week. Are those still pending, and if so, when can we get those materials? +2. 2. There were three folders that were included in the first disc you provided to us, but then also provided again on the most recent disc. Those folders are: NYC024328, NYC024366, and NYC024392. Can you please let us know why those were provided twice? In particular, we need to know whether any supplemental information is in the new folders with those NYC numbers, or whether we can ignore them on the recent disc because we already received them. + +1. One item is listed on your spreadsheet as having been provided on 7/23, but it was not on the most recent disc you sent. That item is: NYC027913 (row 40 in your spreadsheet). + +In case it's useful, I'm attaching a version of the spreadsheet you put on the disc, but with all the items we received folders for on the most recent hard drive highlighted in yellow. + +Separately, we're still waiting on answers to the questions from Thursday and Friday, July 23 and 24. To refresh, those questions are: + +1. Comparing your most recent spreadsheet to the prior one, and leaving aside the "Nothing for Southern" designations as well as the NYC numbers that look like they're for the desktops that held the actual drives we're looking at (such as NYC024385, 387, 389, 391, and 393, and NYC027909), I think there are just three additional devices listed here that weren't on the spreadsheet you previously sent. I have those as: NYC024328 (row 10), NYC024367 (row 62), and NYC027910 (row 96). Please confirm that these were added, and also that we're not missing any? I believe those were all provided on the first disc. +2. As previously mentioned, the vendor has advised that in the initial seven devices provided, there were approximately 71,000 documents that are zero bytes (i.e., empty files). They are listed in the second attached spreadsheet. Is that accurate? Or does that reflect some issue with the extraction process? + +thanks, + +[REDACTED] + +[REDACTED] + +**From:** [REDACTED] > + +**Sent:** Friday, July 24, 2020 15:09 + +**To:** [REDACTED] <[REDACTED]> + +**Cc:** [REDACTED] >; [REDACTED] >; [REDACTED] <[REDACTED]>; [REDACTED] >; [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> + +**Subject:** [EXTERNAL EMAIL] - RE: Epstein Evidence status + +I don't have the evidence in front of me, but it is probably accurate. It is not unusual for the software to find such files. I will review Monday to make sure. As to your questions from last night, the sheet should be comprehensive. I only recall 1 addition, but I am sure that what I have is reflected in the sheet. As for the items in dark grey, there are 2 servers with multiple drives. Some of those drives have physically failed. We have to get them to one of our HQ specialists for recovery. Since they are physically broken, data recovery may or may not be possible. It can be a very long process. We will get that moving ASAP. Need anything else, let me know. + +[REDACTED] + +In addition to the pending questions below, we've been advised by the vendor that is reviewing the initial seven devices (that were provided on a per-device extraction basis, as previously discussed) that those materials include approximately 71,000 documents that are zero bytes (i.e., empty files). They are listed in the attached spreadsheet. + +Is that accurate? Or does that reflect some issue with the extraction process? + +thanks, + +From: + +Sent: Thursday, July 23, 2020 18:08 + +To: + +Cc: C >; + +Subject: RE: Epstein Evidence status + +This is very helpful, thank you. Comparing this to the prior spreadsheet, and leaving aside the "Nothing for Southern" designations as well as the NYC numbers that look like they're for the desktops that held the actual drives we're looking at (such as NYC024385, 387, 389, 391, and 393, and NYC027909), I think there are just three additional devices listed here that weren't on the spreadsheet you previously sent. I have those as: + +- 1. NYC024328 (row 10) +- 2. NYC024367 (row 62) +- 3. NYC027910 (row 96) + +Could you please confirm that I have those additions correct, and that I'm not missing any? And it looks like all of those were included in the drive you provided today. + +I also see there are some drives that are still being processed, including NYC024376 through 380 and several drives in NYC024395 — could you please let us know what that means? + +Thanks very much, and we'll circle back if any issues with anything we received today, which should get to in the next day or two. + +thanks again, + +Original Message + +From: + +Sent: Thursday, July 23, 2020 14:44 + +To: + +Cc: + +Subject: Epstein Evidence status + +Here is the up to date spreadsheet. I color coded things to hopefully make it easier. There are 5 items I have to get you (as we discussed this morning) Those should take another day or 2, so looking at Monday/Tuesday for that. 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I think downloaded these before, but not sure. + +From: + +Sent: Wednesday, August 19, 2020 10:32 AM + +To: %; ) + +Cc: (USANYS) [Contractor] 4 :,; (USANYS) + +Subject: FW: Invitation to view the folder "Epstein + +Hey guys, + +Do either of you have Amex credentials? I've never downloaded anything from Amex, so I can't log in to get the originals of this production. and I are working with to try to get the files from this production open, and we need to try logging back on to this link to do so. + +Thanks, + +From: + +Sent: Wednesday, August 19, 2020 10:23 AM + +To: (USANYS) + +Cc: (USANYS) [Contractor] 4 :2 + +Subject: FW: Invitation to view the folder "Epstein + +From: + +Sent: Saturday, July 13, 2019 1:57 PM + +To: + +Subject: Invitation to view the folder "Epstein + +![](_page_0_Picture_24.jpeg) + +EXPRESS AMEXDRIVE + +used AmexDrive to share a folder with you. To view the shared folder, click on the button below. + +Sharing expires on Jul 12, 2020 + +We be happy to answer any questions you may have. + +The AmexDrive Team + +htlps://square.americanexpress.com/communityltools-programsfamexdrive + +American Express made the following annotations + +"This message and any attachments are solely for the intended recipient and may contain confidential or privileged information. If you are not the intended recipient, any disclosure, copying, use, or distribution of the information + +included in this message and any attachments is prohibited. If you have received this communication in error, please notify us by reply e-mail and immediately and permanently delete this message and any attachments. Thank you." + +American Express a ajoute le commentaire suivant le + +Ce courrier et toute piece jointe qu'il contient sont reserves au seul destinataire indique et peuvent renfermer des renseignements confidentiels et privilegies. Si vous n'etes pas le destinataire prevu, toute divulgation, duplication, utilisation ou distribution du courtier ou de toute piece jointe est interdite. Si vous avez recu cette communication par erreur, veuillez nous en aviser par courrier et detruire immediatement le courrier et les pieces jointes. Merci. \ No newline at end of file diff --git a/marker2/ds9/EFTA00087950/EFTA00087950.metadata.json b/marker2/ds9/EFTA00087950/EFTA00087950.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..b4ab0c7f0c37598e7a4100834afd01923113558e --- /dev/null +++ b/marker2/ds9/EFTA00087950/EFTA00087950.metadata.json @@ -0,0 +1,90 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087950.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2322, + "elapsed_seconds": 1.3, + "image_assets": [ + "_page_0_Picture_24.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 72 + ], + [ + "Line", + 31 + ], + [ + "Text", + 26 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 39 + ], + [ + "Line", + 20 + ], + [ + "Text", + 11 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087950" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087950/_page_0_Picture_24.jpeg b/marker2/ds9/EFTA00087950/_page_0_Picture_24.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..3a0878c09636ad88360051b17dc53d859fc92974 --- /dev/null +++ b/marker2/ds9/EFTA00087950/_page_0_Picture_24.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:4656fcb590366a2380c64516f226f3f2491a320870cdfa26e027e3fb4efc911e +size 3589 diff --git a/marker2/ds9/EFTA00087952/EFTA00087952.md b/marker2/ds9/EFTA00087952/EFTA00087952.md new file mode 100644 index 0000000000000000000000000000000000000000..87f64ac20295c2c071a06017bbf064fbf995f0aa --- /dev/null +++ b/marker2/ds9/EFTA00087952/EFTA00087952.md @@ -0,0 +1,49 @@ +From: To: + +Subject: RE: draft letter re: unsealing + +Date: Thu, 20 Aug 2020 19:45:03 +0000 + +Attachments: Exhibit\_A \_to\_2020.08.21\_Govemment\_letter\_re\_proposed\_redactions\_and\_sealing.pdf; 2020-08- 21,\_GMJetter to\_Judge\_Nathan\_re\_proposed\_redactions\_&\_sealing\_of defense\_motion.d ocx + +Attached is a proposed letter to Judge Nathan regarding redactions/sealing. The portions highlighted in red are the portions I propose to redact when filing the letter on ECF. Please let me know if any of you guys have any edits, or would rather propose a different approach. before I send to the chiefs. + +From: + +Sent: Thursday, August 20, 2020 12:03 PM + +To: (USANYS) >; + +Subject: RE: draft letter re: unsealing + +Proposed redactions attached. + +In addition to these, I think we can propose that-affidavit be filed publicly without redactions and that all of the exhibits be filed under seal. + +From: + +Sent: Thursday, August 20, 2020 11:49 AM + +To: ) <->; (USANYS) + +Subject: RE: draft letter re: unsealing + +Thanks so much for putting this together. Some proposed edits in track. And I insist that your name be on this—even if it's the last thing you'll write in this case, you should have your name on your excellent work product. + +I'll circulate proposed redactions to letter motion in a bit. + +From: + +Sent: Thursday, August 20, 2020 1:56 AM cna + +To: (USANYS) + +Subject: draft letter re: unsealing + +Team — I hope this wasn't a disastrous instinct, but as I got into writing this tonight, it seemed more and more to me like I could do it without having to put anything under seal. See what you think?? I just don't know that it's necessary to get into every little accusation and innuendo; I feel like it should be straightforward — they're trying to get around the protective order that was entered less than a month ago, and there's no good cause. + +In particular, I don't know that it would be productive to get into a fight about whether or not the materials are likely to affect the civil cases, because realistically Judge Nathan likely won't be well positioned to evaluate those intricacies. And I + +All that said, of course let me know what you think — I can always rework tomorrow afternoon if necessary, and in particular if anybody thinks it's insufficient. And/or feel free to just make changes in it and take it from there—I have no pride of authorship and obviously one of you guys will ultimately sign. So whatever is preferable for y'all. + +many thanks, \ No newline at end of file diff --git a/marker2/ds9/EFTA00087952/EFTA00087952.metadata.json b/marker2/ds9/EFTA00087952/EFTA00087952.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..0d2f431dbd4598a7b23b77046e2b2973ecd41d0a --- /dev/null +++ b/marker2/ds9/EFTA00087952/EFTA00087952.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087952.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2462, + "elapsed_seconds": 1.08, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 81 + ], + [ + "Line", + 41 + ], + [ + "Text", + 24 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 13 + ], + [ + "Line", + 7 + ], + [ + "Text", + 4 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087952" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087954/EFTA00087954.md b/marker2/ds9/EFTA00087954/EFTA00087954.md new file mode 100644 index 0000000000000000000000000000000000000000..3b50299898cd546d5f95c80b48f7030fa52da2e4 --- /dev/null +++ b/marker2/ds9/EFTA00087954/EFTA00087954.md @@ -0,0 +1,26 @@ +• + +![](_page_1_Picture_13.jpeg) + +Charity · Philip Dioz, Alfurdo, Steve, Security #52 +Recipients + +Politicians · Peter Mandelson, Gov. Richardson, Cecille, +Sherill - New Mexico + +Business · Jess, Leon, Mont Zucerman, Glen D., + +House Staff · K+B, L+M, L+J, Rich, + +Barry · the Sherill Acasta, Governor, Stefanie's letter + +Religious People + +Academics · Henri Rosofski, Lawrence Kraus, Howard Gardner +Seth Loyd, Lee Swolin, Richard Axel, J. Adelman, +Murray Gillman, + +**Jeffrey E. Epstein** + +Phone +Ray Dannen \ No newline at end of file diff --git a/marker2/ds9/EFTA00087954/EFTA00087954.metadata.json b/marker2/ds9/EFTA00087954/EFTA00087954.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..5d2172fc6d4f0e06bcb0ebaec68f9d3365a32b11 --- /dev/null +++ b/marker2/ds9/EFTA00087954/EFTA00087954.metadata.json @@ -0,0 +1,86 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087954.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 510, + "elapsed_seconds": 3.31, + "image_assets": [ + "_page_1_Picture_13.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 3 + ], + [ + "Line", + 2 + ], + [ + "PageFooter", + 1 + ], + [ + "Text", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 19 + ], + [ + "Picture", + 2 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087954" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087954/_page_1_Picture_13.jpeg b/marker2/ds9/EFTA00087954/_page_1_Picture_13.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..d0900273988dd75785dc907053129f43a29dec53 --- /dev/null +++ b/marker2/ds9/EFTA00087954/_page_1_Picture_13.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:e508f89cdc6e52ee70c4e69121c122fb131d994bee10653bafdc9e06fe799b68 +size 15463 diff --git a/marker2/ds9/EFTA00087956/EFTA00087956.md b/marker2/ds9/EFTA00087956/EFTA00087956.md new file mode 100644 index 0000000000000000000000000000000000000000..490c8341969f490db5d43e9e2bed9a4e7e0a75df --- /dev/null +++ b/marker2/ds9/EFTA00087956/EFTA00087956.md @@ -0,0 +1,28 @@ +Laurent Louig Cuomo, Dave Christofer, Carol Montgomery +Enforcement Glovia Lambert, Richie STC STC STC Larry, Tommy's friend +ov L. Case + +Jim Pasca, + +Charity Philip Dioz, 4507 Alfredo, Steve, Security 452 ES2 +Recipients + +Politicians: Peter Mandeson, Gov. Richardson, Cecille, +Sherill - New Mexico + +Business: Jess, Leon, Mont Zucerman, Glen D., + +House Staff: K.B, L.+M, L.+J. Rich, + +Barry: the Sherill Acasta, Governor, Stefanie's letter + +Religious People + +Academics: Henri Rosofski, Lawrence Kraus, Howard Ganner +Seth Loyd, Lee Swolin, Richard Axel, J. Adelman, +Murray Gellman, + +**Jeffrey E. Epstein** + +*Phone +Roy Dalmon* \ No newline at end of file diff --git a/marker2/ds9/EFTA00087956/EFTA00087956.metadata.json b/marker2/ds9/EFTA00087956/EFTA00087956.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..07466fc26faa23712a08a59c6cad24e2dac833a7 --- /dev/null +++ b/marker2/ds9/EFTA00087956/EFTA00087956.metadata.json @@ -0,0 +1,46 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087956.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 710, + "elapsed_seconds": 4.02, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 21 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087956" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087957/EFTA00087957.md b/marker2/ds9/EFTA00087957/EFTA00087957.md new file mode 100644 index 0000000000000000000000000000000000000000..af057a083721ad4bdecbd35ceb73d07bdb877dcc --- /dev/null +++ b/marker2/ds9/EFTA00087957/EFTA00087957.md @@ -0,0 +1,19 @@ +From: WSANYSYI `t IMIE> + +To: Nathan NYSD Chambers •t: > + +Cc: + +Subject: RE: United States v. Maxwell, 20 Cr. 330 (MN) + +Date: Fri, 21 Aug 2020 16:13:57 +0000 + +Attachments: 2020-08-21,SEALED, \_letter to\_Judge\_Nathan\_re\_proposed\_redactions\_and\_sealing.pdf; 2020-08-21, \_letter toiudge\_Nathan\_re\_proposed\_redactions\_and\_sealint(docketed).pdf + +To the Chambers of Judge Nathan: + +In connection with the Court's Order of August 18, 2020, which directed the parties to propose redactions to the letter briefing regarding the defendant's letter motion seeking a modification of the Court's Protective Order in the abovecaptioned case, attached please find the Government's responsive letter, and attached Exhibit A, which the Government respectfully requests be filed under seal for the reasons set forth in the letter. Additionally, the Government has filed a redacted version of this letter on the public docket, which is also attached for the Court's convenience. Defense counsel is copied. + +Respectfully, + +Assistant U.S. Attorney Southern District of New York \ No newline at end of file diff --git a/marker2/ds9/EFTA00087957/EFTA00087957.metadata.json b/marker2/ds9/EFTA00087957/EFTA00087957.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..e43f838b4f7e921f254af82c876d6b4808f4a6eb --- /dev/null +++ b/marker2/ds9/EFTA00087957/EFTA00087957.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087957.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1067, + "elapsed_seconds": 0.65, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 40 + ], + [ + "Line", + 18 + ], + [ + "Text", + 13 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087957" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087958/EFTA00087958.md b/marker2/ds9/EFTA00087958/EFTA00087958.md new file mode 100644 index 0000000000000000000000000000000000000000..fa8f269e235a73c903e01033d10409ee145604b8 --- /dev/null +++ b/marker2/ds9/EFTA00087958/EFTA00087958.md @@ -0,0 +1,87 @@ +To:' + +Subject: RE: Envelopes in question + +Date: Mon, 28 Sep 2020 19:28:40 +0000 + +Good luck. + +From: + +Sent: Monday, September 28, 2020 3:28 PM + +To: + +Subject: RE: Envelopes in question + +Got it, thank you so much. + +From: + +Sent: Monday, September 28, 2020 3:18 PM + +To: + +Subject: RE: Envelopes in question + +You can open the envelopes. They are sealed pleadings that have the minor victim names in them. The law firm mailed copies to s and + +Sorry it took a little while to get back to you. + +From: + +Sent: Friday, September 25, 2020 11:12 AM + +To: + +Subject: RE: Envelopes in question + +No problem at all. Very sorry to be pestering you about this. Thanks very much and hope everything is ok. + +From: + +Sent: Friday, September 25, 2020 11:10 AM + +To: + +Subject: Re: Envelopes in question + +Sony It has been a tough week. Let me follow up today. + +Sent from my iPhone + +On Sep 25, 2020, at 11:08 AM, > wrote: + +Thanks, + +Assistant United States Attorney Southern District of New York I St. Andrew's Plaza New York, NY 10007 + +From: + +Sent: Tuesday, September 22, 2020 5:14 PM + +To: + +Subject: FW: Envelopes in question + +Hi + +The vendor sent me the attached photographs of two sealed envelopes contained in the SDFL Epstein files. One is marked "SEALED DOCUMENT" and the second is marked "CONFIDENTIAL." Each of the sealed envelopes was contained in an open envelope addressed to AUSA from the same law firm (photos of those two open envelopes are also attached). + +Is it alright for me to ask the vendor to open both envelopes and scan the contents for my office to review? I know your office indicated we could review the entire file, but I wanted to check before opening a sealed envelope. + +Thanks, + +Assistant United States Attorney Southern District of New York I St. Andrew's Plaza New York, NY 10007 + +From: Melanie Wheeler + +Sent: Tuesday, September 22, 2020 3:32 PM + +To: + +Subject: Envelopes in question + +Here they are. One is from a box marked US V Brodie et al. One is from a box labeled court documents, negotiations, statements, document production + +The content of this email is confidential and intended for the recipient specified in message only. It is strictly forbidden to share any part of this message with any third pany, without a written consent of the sender. If you received this message by mistake, please reply to this message and follow with its deletion, so that we can ensure such a mistake does not occur in the future. \ No newline at end of file diff --git a/marker2/ds9/EFTA00087958/EFTA00087958.metadata.json b/marker2/ds9/EFTA00087958/EFTA00087958.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..449ef6280133e37b6bffaa25522961e80298fcc4 --- /dev/null +++ b/marker2/ds9/EFTA00087958/EFTA00087958.metadata.json @@ -0,0 +1,114 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087958.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 2417, + "elapsed_seconds": 1.73, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 63 + ], + [ + "Text", + 32 + ], + [ + "Line", + 32 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 60 + ], + [ + "Line", + 30 + ], + [ + "Text", + 18 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 7 + ], + [ + "Line", + 4 + ], + [ + "Text", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087958" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087961/EFTA00087961.md b/marker2/ds9/EFTA00087961/EFTA00087961.md new file mode 100644 index 0000000000000000000000000000000000000000..4711d95b834e73baa76c1eba3769fea55660ffb0 --- /dev/null +++ b/marker2/ds9/EFTA00087961/EFTA00087961.md @@ -0,0 +1,69 @@ +U.S. Dept. of Justice Attaché - London + +UK Mobile: + +Sent from a mobile device + +From: ecl + +Sent: Tuesday, September 29, 2020 6:09:57 PM + +To: T (London) (CRM) < + +Cc: + +Subject: RE: SDNY investigation + +Hi M, + +Thanks again for taking the time to talk to us today. We can use this conference line + +From: (London) + +Sent: Monde , September 28, 2020 11:58 AM + +To: (CRM) + +Subject: Re: SDNY investigation + +I'll be in court much of the day tomorrow, so how about 1:30 pm EDT or later? Thx + +U.S. Dept. of Justice Attaché - London + +UK Mobile: + +Sent from a mobile device + +From: (CRM) + +Sent: y, Frida Se ber 25, 2020 8:14:17 PM + +To: (London) wrote: + +Hi - I will be out of the office on Monday, but could do it any other day of the week. If Monday is a critical day, I could do a call on Monday evening BST— which would be mid-afternoon your time. + +Let me know what works. + +Thx, + +U.S. Department of Justice Attaché United States Embassy — London + +U.K. Mobile: \ No newline at end of file diff --git a/marker2/ds9/EFTA00087961/EFTA00087961.metadata.json b/marker2/ds9/EFTA00087961/EFTA00087961.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..fa6edeef2e39f79c0e74c2c9a927510e4e7c68b7 --- /dev/null +++ b/marker2/ds9/EFTA00087961/EFTA00087961.metadata.json @@ -0,0 +1,106 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087961.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 1262, + "elapsed_seconds": 1.89, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "PageFooter", + 1 + ], + [ + "Line", + 1 + ], + [ + "Span", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 93 + ], + [ + "Line", + 45 + ], + [ + "Text", + 42 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "PageFooter", + 1 + ], + [ + "Line", + 1 + ], + [ + "Span", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087961" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087964/EFTA00087964.md b/marker2/ds9/EFTA00087964/EFTA00087964.md new file mode 100644 index 0000000000000000000000000000000000000000..b30af268a051d9787b98a54922b09117d9c11d39 --- /dev/null +++ b/marker2/ds9/EFTA00087964/EFTA00087964.md @@ -0,0 +1,123 @@ +Thanks very muchill. > 9/10/202010:36 AM > » + +From: ' )" U To Cc: a' )" < >, " (USANYS)" + +Subject: RE: DOJ Visit and Discovery + +Date: Thu, 10 Sep 2020 15:55:22 +0000 + +Got it, will do. Thanks very much. + +Fro Sent: Thursday, September 10, 202011:42 AM To: Cc: Subject: RE: DOJ Visit and Discovery (USANYS) < + +She should have it. If he tells you anything differently today or tomorrow, let me know. + +Fro SenrittMirbera7 AM To: Cc: Subject: Re: DOJ Visit and Discovery (USANYS) < + +It was delivered around 3 pm, which I believe was after her call with counsel. I will double check with my paralegal though. + +Thanks, + +>>>" "< Hi > 9/10/2020 12:01 AM >> > + +Maxwell's attorney just emailed me saying that his client still has not received this drive. Would you please confirm for us tomorrow that she has this drive? + +Thanks very much, + +On Sep 9, 2020, at 8:17 PM, wrote: + + Thank you so much Really appreciate you looking into that. + +Best, + +From: Holly Pratesi + +Sent: Wednesday, September 9, 2020 4:45 PM + +To: + +Cc: °: >; (USANYS) + +Subject: RE: FW: DOJ Visit and Discovery + +Drive was delivered today. + +Bes + +>» " " < > 9/8/2020 7:01 PM > » + +Thanks very much, Really appreciate the quick response. Please let us know if you learn of any planned visit from Dal. Our office is not aware of any planned visit either. + +And apologies for the oversight, we must have forgotten to email you about the drive. Our paralegal sent a new drive out for Maxwell on Thursday, September 3rd. Attached are the two accompanying letters. Would you please look into its status for us? + +Thanks again, + +Assistant United States Attorney + +Southern District of New York + +l St. Andrew's Plaza + +New York, NY 10007 + +From: Holly Pratesi + +Sent: Tuesday, September 8, 2020 6:44 PM + +To: + +Cc: ) (USANYS) c )a + +Subject: Re: FW: Dal Visit and Discovery + +Good evening + +I am unaware of any visit tomorrow by DOJ representatives. I will raise this early tomorrow with staff and see if I can get any further details about this. + +When was the drive sent last week? We have received two drives to date - are you saying another was sent? I do not recall seeing any emails about a third set (if I missed it while out of the office, I apologize). + +Thanks, + +> 9/8/2020 6:41 PM > » + +We just received the below email from Ghislaine Maxwell's attorney. Do you know what DOJ representatives they are referring to? Regardless, per counsel's instruction below, please ensure that no DOJ representatives speak with Maxwell without her counsel present. + +Also, would you please check on the status of the drive our office sent out last week? + +I can be reached on my cellphone at and am happy to have a call if that would be useful. + +Thank you, + +From: Christian Everdell + +Sent: Tuesday, September 8, 2020 6:37 PM + +To: + +(USANYS) + +Cc: Mark S. Cohen Laura Menninger c ; Jeff Pagliuca + +c->; + +ope you a a goo a or ay weekend. Our client has advised us that representatives from the Dal will be meeting with her in the MDC tomorrow. We are not clear who these representatives are or what they intend to meet with our client about. But it goes without saying that she is a represented party and that no representatives from DOJ should be speaking with her without her counsel present. We request that you notify the appropriate people at MDC about this as soon as possible. + +Also, our client has still not received the replacement hard drive you sent out on Thursday, September 3, at our request. As a result, it is now over two weeks past the August 21 deadline for completion of the initial tranche of discovery and Ms. Maxwell is still unable to review a substantial portion of the discovery produced to date. Ms. Maxwell cannot participate in her defense if she cannot review the discovery. Accordingly, we request that you expedite the delivery of the hard drive. + +Regards, + +Chris + +Christian Everdell + + + +800 Third Avenue New York, NY 10022 + +I view bio www.cohengresser.com + +New York I Seoul I Paris I Washington DC I London + +CONFIDENTIALITY NOTICE: The information contained in this e-mail may be confidential and/or privileged. This e-mail is intended fo be reviewed initially by only the individual named above. If the reader of this e-mail is not the intended recipient or a representative of the intended recipient. you are hereby notified that any review. dissemination or copying of this e-mail or the information contained herein is prohibited. If you have received this e-mail in error. please immediately notify the sender by telephone and permanently delete this e-mail. Thank yc::. + +PRIVACY: A complete copy of our privacy policy can be viewed al. Al pslAw.w.cohenoresser.com/privacL-policx \ No newline at end of file diff --git a/marker2/ds9/EFTA00087964/EFTA00087964.metadata.json b/marker2/ds9/EFTA00087964/EFTA00087964.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..e64b6973c5a2b7bd3bb0edaf7c64eacf9123dde1 --- /dev/null +++ b/marker2/ds9/EFTA00087964/EFTA00087964.metadata.json @@ -0,0 +1,114 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087964.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 4696, + "elapsed_seconds": 1.9, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 78 + ], + [ + "Line", + 37 + ], + [ + "Text", + 19 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 93 + ], + [ + "Line", + 43 + ], + [ + "Text", + 41 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 70 + ], + [ + "Line", + 33 + ], + [ + "Text", + 20 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087964" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087967/EFTA00087967.md b/marker2/ds9/EFTA00087967/EFTA00087967.md new file mode 100644 index 0000000000000000000000000000000000000000..7e889394af3dff4c26b51406bb03614719a53edf --- /dev/null +++ b/marker2/ds9/EFTA00087967/EFTA00087967.md @@ -0,0 +1,19 @@ +To: ' + +Subject: Scanning project for SDNY + +Date: Sat, 12 Sep 2020 00:23:00 +0000 + +Hi + +Our budget office has approved payment from SDNY to Melkin Solutions to complete the scanning of the 28 Epsteinrelated boxes in SDFL. How should I go about coordinating so that the vendor can get access to the boxes to scan them? + +The vendor indicated that it would be much faster if they could be permitted to take the boxes to their office for processing. Would your office be willing to permit that? We are hoping to get these scans completed as soon as possible, so we would be very grateful if there's any way to help expedite the process. + +Please feel free to call my cell at if it would be useful to discuss over the phone. + +Thanks so much for your help. + +Best, + +Assistant United States Attorney Southern District of New York \ No newline at end of file diff --git a/marker2/ds9/EFTA00087967/EFTA00087967.metadata.json b/marker2/ds9/EFTA00087967/EFTA00087967.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..d4c5c5b43fea7fcd3fbe0c45b2b4ddc00e835b28 --- /dev/null +++ b/marker2/ds9/EFTA00087967/EFTA00087967.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087967.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 818, + "elapsed_seconds": 0.77, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 30 + ], + [ + "Text", + 17 + ], + [ + "Line", + 16 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087967" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087968/EFTA00087968.md b/marker2/ds9/EFTA00087968/EFTA00087968.md new file mode 100644 index 0000000000000000000000000000000000000000..401b4613d8d21607d4e14e05bfb64038cbdde40c --- /dev/null +++ b/marker2/ds9/EFTA00087968/EFTA00087968.md @@ -0,0 +1,29 @@ +![](_page_0_Picture_3.jpeg) + +Date of entry 04/23/2020 + +, DOS , cellular number , was interviewed telephonically on April 10, 2020. After being advised of the identity of the interviewing Agent and the nature of the interview, provided the following information: + +was modeling when she met LEON BLACK in 2008. BLACK promised • drugs. BLACK manipulated and sexually abused . BLACK used a lot of threats towards ; she was scared of him. + +BLACK flew to JEFFREY EPSTEIN's home in Florida. BLACK told that if she talked to anyone he would tell her son that she was on drugs. was also at the house and wanted to have sex with EPSTEIN. It got to the point where they were yelling at , telling her that EPSTEIN had a sex addiction. told that EPSTEIN needed to have sex with multiple people and that if did not have sex with him then something terrible would happen to her and it would affect her life. did not have sex with EPSTEIN; she and BLACK left. + +BLACK ran a sex trafficking ring. constantly tried to run away. If fought BLACK, he hurt more. thought that every sexual encounter BLACK had with her was nonconsensual. BLACK told that if she stayed with him, he would let her stay in the country. BLACK told her she should not think about work. earned her bachelor's degree. + +BLACK told that he was friends with the police, EPSTEIN and HARVEY WEINSTEIN. There was a point where felt sick and felt like she had been poisoned. Around that time, BLACK forced his way into apartment and raped her. This was around 2014. was scared and left the country. While outside the United States, one of BLACK's associates contacted her. People that BLACK knew continued to approach her. + +In approximately 2015, BLACK told that he would pay people to destroy + +Investigation on 04/10/2020 at New York, New York, United States (Phone) + +This document contains neither recommendations nor conclusions of the FBI. It is the ',topiary of the FBI and is loaned to your agency; it and its contents arc no; to be distributed outside your agency. + +Continuation of FD-302 of (U) Interview of 04/10/2020 ,Pas, 2 of 2 + +her life. BLACK told her he had worked for the FBI. In the fall of 2015, signed a non-disclosure agreement with BLACK. + +BLACK transferred ten million dollars to EPSTEIN in or around 2015. met a lot of EPSTEIN's assistants. was introduced to GHISLAINE MAXWELL and PRINCE ANDREW, among others. + +Other women that EPSTEIN. knew had been abused by BLACK were , and . BLACK introduced to + +advised that she was willing to meet in person at a later date for a more in-depth interview. \ No newline at end of file diff --git a/marker2/ds9/EFTA00087968/EFTA00087968.metadata.json b/marker2/ds9/EFTA00087968/EFTA00087968.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..84d5a160ecf3b27357757e5ea913f44b4b609239 --- /dev/null +++ b/marker2/ds9/EFTA00087968/EFTA00087968.metadata.json @@ -0,0 +1,126 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087968.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2562, + "elapsed_seconds": 0.8, + "image_assets": [ + "_page_0_Picture_3.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "FEDERAL BUREAU OF INVESTIGATION", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 189.108, + 49.41 + ], + [ + 386.80224609375, + 49.41 + ], + [ + 386.80224609375, + 62.465087890625 + ], + [ + 189.108, + 62.465087890625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 85 + ], + [ + "Line", + 37 + ], + [ + "Text", + 11 + ], + [ + "PageHeader", + 2 + ], + [ + "SectionHeader", + 1 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 34 + ], + [ + "Line", + 15 + ], + [ + "Text", + 6 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087968" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087968/_page_0_Picture_3.jpeg b/marker2/ds9/EFTA00087968/_page_0_Picture_3.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..c07c0c62a9c29fee13f18268ebba1d5c33a5fcc3 --- /dev/null +++ b/marker2/ds9/EFTA00087968/_page_0_Picture_3.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:11ad1c04b5d138859ac4f9542a5d3d8979c23bf32504d7157c41dc2a4000bbf6 +size 4644 diff --git a/marker2/ds9/EFTA00087970/EFTA00087970.md b/marker2/ds9/EFTA00087970/EFTA00087970.md new file mode 100644 index 0000000000000000000000000000000000000000..4b5943b57cb7226285611b7997a38623cf1d10b8 --- /dev/null +++ b/marker2/ds9/EFTA00087970/EFTA00087970.md @@ -0,0 +1,31 @@ +Tol + +Subject: FW: 20-2413, v. Maxwell + +Date: Fri, 11 Sep 2020 21:45:11 +0000 + +Attachments: 20-2413 ORDER.pdf + +FYI, the court has now formally alerted us to the order in the appeal. + +From: + +Sent: Friday, September 11, 2020 5:43 PM + +To: + +Subject: 20-2413, v. Maxwell + +Enclosed please find the attached order filed in the above-referenced appeal. + +Thank you. + +Best regards, + +Executive Assistant to the Clerk + +U.S. Court of Appeals for the Second Circuit + +phone) + +fax) \ No newline at end of file diff --git a/marker2/ds9/EFTA00087970/EFTA00087970.metadata.json b/marker2/ds9/EFTA00087970/EFTA00087970.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..5011313918c2d97e846a0c2c18b71fa4edbef449 --- /dev/null +++ b/marker2/ds9/EFTA00087970/EFTA00087970.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087970.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 464, + "elapsed_seconds": 0.84, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 35 + ], + [ + "Text", + 19 + ], + [ + "Line", + 18 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087970" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087971/EFTA00087971.md b/marker2/ds9/EFTA00087971/EFTA00087971.md new file mode 100644 index 0000000000000000000000000000000000000000..9660d56ba327bb8c04582359ad8b0b0bdba3a862 --- /dev/null +++ b/marker2/ds9/EFTA00087971/EFTA00087971.md @@ -0,0 +1,33 @@ +S.D.N.Y. 20-2413 Loretta A. Preska, J. + +## United States Court of Appeals FOR THE SECOND CIRCUIT + +At a stated term of the United States Court of Appeals for the Second Circuit, held at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 11th day of September, two thousand twenty. + +Plaintiff-Appellee, ORDER + +v. 20-2413 + +Ghislaine Maxwell, + +Defendant-Appellant. + +Sharon Churcher, Jeffrey Epstein, + +Respondents, + +Julie Brown, Miami Herald Media Company, Alan M. Dershowitz, Michael Cemovich, DBA Cemovich Media, + +Intervenors. + +It is hereby ORDERED that the United States shall submit an amicus letter brief, not to exceed ten (10) double-spaced pages, regarding (I) arguments raised by Defendant-Appellant Ghislaine Maxwell and (2) Defendant-Appellant Ghislaine Maxwell's motion to consolidate this appeal with United States v. Maxwell, No. 20-3061. The United States shall submit its brief no later than Wednesday, September 16, 2020 at 3:00 pm. + +It is also hereby ORDERED that the parties to the appeal shall respond to the letter brief filed by the United States by Wednesday, September 23, 2020 at 3:00 pm. + +The hearing scheduled for Tuesday, September 22, 2020 at 2:00 pm is hereby ADJOURNED until further order of the court. + +For the Court: +Catherine O'Hagan Wolfe, +Clerk of Court + +![]() \ No newline at end of file diff --git a/marker2/ds9/EFTA00087971/EFTA00087971.metadata.json b/marker2/ds9/EFTA00087971/EFTA00087971.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..fd2758dae346a40f27dfd3ba835a7cc4bc1bba69 --- /dev/null +++ b/marker2/ds9/EFTA00087971/EFTA00087971.metadata.json @@ -0,0 +1,120 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087971.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 1341, + "elapsed_seconds": 2.18, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "United States Court of Appeals \nFOR THE \nSECOND CIRCUIT", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 178.09199999999998, + 135.6243896484375 + ], + [ + 435.9778137207031, + 135.6243896484375 + ], + [ + 435.9778137207031, + 180.63 + ], + [ + 178.09199999999998, + 180.63 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 54 + ], + [ + "Line", + 27 + ], + [ + "Text", + 15 + ], + [ + "PageHeader", + 1 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 13 + ], + [ + "Line", + 7 + ], + [ + "Text", + 6 + ], + [ + "PageFooter", + 4 + ], + [ + "PageHeader", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087971" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087973/EFTA00087973.md b/marker2/ds9/EFTA00087973/EFTA00087973.md new file mode 100644 index 0000000000000000000000000000000000000000..c4b626b0e76455528f0688d31a610573228de7ab --- /dev/null +++ b/marker2/ds9/EFTA00087973/EFTA00087973.md @@ -0,0 +1,95 @@ +From: (USANYS)" + +To:" )" ctl + +Cc: ' cti + +Subject: Re: Epstein [FFW-DOCS.FID6003375] + +Date: Wed, 16 Sep 2020 13:41:18 +0000 + +9/24 works for me, thanks + +On Sep 16, 2020, at 7:40 AM, < > wrote: + +How does 9/24 at 10 a.m sound? I could also do 10 this Friday (9/16). + +Sent from my iPhone + +Begin forwarded message: + +From: Jill Greenfield -I + +Date: September 16, 2020 at 4:04:13 AM EDT + +To: " + +Cc: ' (USANYS)" + +Subject: RE: Epstein [FFW-DOCS.FID6003375I + +I rather assumed thatyou were not able to travel given the inherent difficulties with that and how you would be able to meet with people without having to self-isolate first. + +Let me know when is good for you for a video conference call. + +Kind regards + +Jill + +Jill Greenfield + +Partner + +Click here for information relating to Covid-19 business impacts + +![](_page_0_Picture_25.jpeg) + +---itnatte30777e.PNG> + +Thanks very much for reaching out. We would be glad to schedule a videoconference with your client to discuss her questions and concerns. Are there particular dates and times that would work best for you and your client? + +We are in the process of looking into the current rules on travel for government employees, and will let you know as soon as we have more information. Our team is willing to travel if we are permitted to, but we're not yet certain whether that is possible. + +Thank you, + +Assistant United States Attorney Southern District of New York One Saint Andrew's Plaza New York, NY 10007 + +From: Sent: Tuesday, September 15, 2020 2:18 PM To: Jill Greenfield Cc: ) (USANYS) Subject: RE: Epstein [FFW-DOCS.FID600337S) + +We're very gratified to hear that your client is willing to speak with us, and we would be happy to answer her questions as best we can. + +In terms of logistics, I recently moved to a new position within our office and so the current team has been updated the investigation is now being handled by and , whom you've spoken with previously, as well as new addition , who also has extensive experience in these types of cases—they're all copied here. They'll follow up with you to schedule a time for the discussion, and they can let you know the latest status on any anticipated approvals for Government foreign travel (which I believe currently is prohibited for us, otherwise we would be happy to travel to meet in person). + +Thank you very much for your continued assistance in connection with our investigation, and I expect and will be in touch shortly as well. + +thanks again, + +Hi MI + +My client would like to speak to you to dis . This would be in the form of her asking how you would manage this. She did also ask if you were travellin at any point so. I said not but if I am wrong please do let me know. + +Thanks + +Jill + +Jill Greenfield + +Partner + +Click here for information relating to Covid-19 business impacts + +mage00 1 .jpej + + + +Fieldfisher, Riverbank House, 2 Swan Lane, London EC4R 3TT. + +www.fieldfishercom + +We do not intend to change our bank details. If you receive any communication that any of our bank details have changed. telephone us and speak to your contact at our office before transferring any funds. We do not accept responsibility for monies paid into a wrong bank account in any circumstances. + +This email and any attachments are confidential and may also be privileged. If you receive this message in error. please contact the sender immediately. destroy the email and any attachments and do not use, copy, store or disclose this email and any attachments for any purpose. Fieldfisher does not accept service of documents by electronic means without express prior agreement. + +For details about what personal information we collect and why. please see our Privacy Notice on our webile at www.lieldfishertom. + +Fieldfisher is the trading name of Fieldfisher LLP. a limited liability partnership registered in England and Wales (registered number OC318472) and is authorised and regulated by the Solicitors Regulation Authority. A list of its members and their professional qualifications is available at its registered office. Riverbank House. 2 Swan Lane. London EC4R 3TT. 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Cohen" "Laura + +k (USANYS)" + +Menninger" < >, Jeff Pagliuca + +Subject: Re: Letter + +Date: Tue, 22 Sep 2020 15:13:39 +0000 + +Inline-Images: image001.png; image004jpg + +Hi Chris, + +Are you available for a call today? Our team is free at 5:30 p.m. or later today, if that works. + +Thanks, + +Sent from my iPhone + +On Sep 21, 2020, at 10:34 PM, Christian Everdell wrote: + +Please see the attached letter regarding Ghislaine Maxwell. Thank you in advance for your attention to these matters. + +Regards, + +Chris + +Christian Everdell + + + +800 Third Avenue + +New Vrt rk NY 10022 + +www.cohengresser.com + +New York I Seoul I Paris I Washington DC I London + +CONFIDENTIALITY NOTICE: The information contained in this e-mail may be confidential and/or privileged. This e-mail is intended to be reviewed initially by only the individual named above. If the reader of this e-mail is not the intended recipient or a representative of the intended recipient. you are hereby notified that any review. dissemination or copying of this e-mail or the information contained herein is prohibited. If you have received this e-mail in error. please immediately notify the sender by telephone and permanently delete this e-mail. Thank you. + +PRIVACY: A complete copy of our privacy policy can be viewed at: https:/Annv.cohengresser.comiprivacy-policy. + +![](_page_1_Picture_1.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00087976/EFTA00087976.metadata.json b/marker2/ds9/EFTA00087976/EFTA00087976.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..b260a8aeaaa055f6fcbf0185b28b631b5daaaefd --- /dev/null +++ b/marker2/ds9/EFTA00087976/EFTA00087976.metadata.json @@ -0,0 +1,90 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087976.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 1423, + "elapsed_seconds": 1.23, + "image_assets": [ + "_page_1_Picture_1.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 66 + ], + [ + "Line", + 30 + ], + [ + "Text", + 26 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 3 + ], + [ + "Line", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087976" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087976/_page_1_Picture_1.jpeg b/marker2/ds9/EFTA00087976/_page_1_Picture_1.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..17b8010cbddcfee415d70e43cfb458a576356f89 --- /dev/null +++ b/marker2/ds9/EFTA00087976/_page_1_Picture_1.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:a86fb26e6f43345716c91196aa478b99aac476538d1fe3e90a984887f3f1f7fe +size 1171 diff --git a/marker2/ds9/EFTA00087978/EFTA00087978.md b/marker2/ds9/EFTA00087978/EFTA00087978.md new file mode 100644 index 0000000000000000000000000000000000000000..a73c0ccd55b821a6a68c07abe154642fdd80be12 --- /dev/null +++ b/marker2/ds9/EFTA00087978/EFTA00087978.md @@ -0,0 +1,43 @@ +From: To:I Cc: a)" >, " (USANYS)" + +Subject: FW: Letter + +Date: Tue, 22 Sep 2020 15:15:12 +0000 + +Attachments: 2020.09.21 Letter \_ to \_ Government \_ re \_ Discovery \_ and \_ Prison Conditions.PDF + +Inline-Images: image001.png; image004.jpg + +Please see the attached letter from Maxwell's counsel. Would you be available for a call to discuss this afternoon, please? + +Thanks, + +Assistant United States Attorney Southern District of New York 1 St. Andrew's Plaza New York, NY 10007 + +From: Christian Everdell + +Sent: Monday, September 21, 2020 10:33 PM + +To: (USANYS) >; >; + +Cc: Mark S. Cohen ; Laura Menninger k; Jeff Pagliuca + +Subject: Letter + +Maurene, Alison, and Lara — + +Please see the attached letter regarding Ghislaine Maxwell. Thank you in advance for your attention to these matters. + +Regards, + +Chris + +Christian Everdell + +COHEN & GRESSER LLP + +![](_page_1_Picture_2.jpeg) + +CONFIDENTIALITY NOTICE: The information contained in this e-mail may be confidential and/or privileged. This e-mail is intended robe reviewed initially by only the individual named above. If the reader of this e-mail is not the intended recipient or a representative of the intended recipient. you are hereby notified that any review. dissemination or copying of this e-mail or the information contained herein is prohibited. If you have received this e-mail in error. please immediately notify the sender by telephone and permanently delete this e-mail. Thank you. + +PRIVACY: A complete copy of our privacy policy can be viewed htlpslAvww.cohengressercomfprivacy-policy. \ No newline at end of file diff --git a/marker2/ds9/EFTA00087978/EFTA00087978.metadata.json b/marker2/ds9/EFTA00087978/EFTA00087978.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..10d8bc329f457736735380b92ffbc0ce1fb3cad1 --- /dev/null +++ b/marker2/ds9/EFTA00087978/EFTA00087978.metadata.json @@ -0,0 +1,94 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087978.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 1544, + "elapsed_seconds": 1.2, + "image_assets": [ + "_page_1_Picture_2.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 59 + ], + [ + "Line", + 30 + ], + [ + "Text", + 24 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 19 + ], + [ + "Line", + 9 + ], + [ + "PageHeader", + 2 + ], + [ + "Text", + 2 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087978" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087978/_page_1_Picture_2.jpeg b/marker2/ds9/EFTA00087978/_page_1_Picture_2.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..1709af48c0b94a6a8a1657dbfc112fc22652056a --- /dev/null +++ b/marker2/ds9/EFTA00087978/_page_1_Picture_2.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:66bb4aa4a3490aeaf2ab14479ecd15c0ac286c91cbd1967061dcd8ba83dc0cf5 +size 1218 diff --git a/marker2/ds9/EFTA00087980/EFTA00087980.md b/marker2/ds9/EFTA00087980/EFTA00087980.md new file mode 100644 index 0000000000000000000000000000000000000000..8671b3ad5d890cbc9e162f8952495373ed20f50f --- /dev/null +++ b/marker2/ds9/EFTA00087980/EFTA00087980.md @@ -0,0 +1,212 @@ +### BY EMAIL + +, Esq. Esq. Esq. United States Attorney's Office Southern District of New York 1 St. Andrew's Plaza New York, NY 10007 + +Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +De + +![](_page_0_Picture_10.jpeg) + +![](_page_0_Picture_4.jpeg) + +We write to address three issues. First, we write to express once again our dissatisfaction with the incomplete and inadequate production of discovery to Ms. Maxwell in the MDC, and to demand that the government find an immediate solution that will permit Ms. Maxwell to review all of the discovery materials produced to date. Second, we write to request that the government set up a time at the earliest convenience when Ms. Maxwell and defense counsel can review the documents marked as "Highly Confidential" in the discovery materials. Third, we write to register our objection to the onerous conditions of confinement to which Ms. Maxwell is subjected, which are entirely unique to Ms. Maxwell. We request that the government intercede directly with the BOP to improve these conditions, as set forth below. + +# 1. Ms. Maxwell Still Cannot Access All of the Discovery + +One full month has now passed since August 21, 2020, the date the government represented to the Court that it would complete production of the initial group of discovery materials, and Ms. Maxwell still cannot read a substantial portion of the discovery produced to date. The government further represented to the Court at the initial appearance on July 14, 2020 that this initial group of discovery materials represents "the core of the case" against Ms. Maxwell. (Tr. at 12, line 11). Ms. Maxwell has therefore been denied full access to the most critical evidence in this case for a month. This is unacceptable and inconsistent with the government's obligations and its representations to Judge Nathan; this must be fixed immediately. + +The government represented to the Court at the initial appearance that it was "prepared to make a substantial production of discovery" as soon as the protective order was entered. (Tr. 12- 13). However, the government was clearly not prepared to produce discovery, as each of the three subsequent productions contained numerous unreadable documents and were delivered to Ms. Maxwell in the MDC well after the dates on the cover letters. Ms. Maxwell did not receive the government's August 5'h production until August 11th and did not receive the August 13ih production until August 17'h. As you recall, Ms. Maxwell did not receive the hard drive with the government's third and final production in this first phase of discovery until August 25, 2020, several days after the August 21, 2020 deadline imposed by the Court. + +On a conference call on August 27, 2020, we advised you of the substantial number of documents in all three productions that Ms. Maxwell was unable to access, and even proposed possible technological solutions that we thought might alleviate the problem — namely, shortening the file paths to the documents and producing the documents on a hard drive with onboard encryption, as opposed to McAfee encryption. Later that same day, we sent you a follow-up letter listing the unreadable documents and requesting that the government immediately reproduce to Ms. Maxwell a new set of all of the discovery materials produced to date in a format that she could access on her computer at the MDC, and provide the appropriate software tools that will allow her to review all of the discovery files. That same day we also shipped to you two separate hard drives — one with onboard encryption and one without — to use to load the replacement production. + +The new hard drive was not made available to Ms. Maxwell at the MDC until the late afternoon of September 9, 2020, almost two weeks later. While some of the previously unreadable documents are now readable, Ms. Maxwell still cannot access a substantial portion of the discovery materials, including certain file types and extensions. For example, Ms. Maxwell cannot read any documents that have .XLS or .EML file extensions. Ms. Maxwell also still cannot access the following documents: + +| Production Number | Bates Numbers | +|-------------------|---------------| +| Production 1 | 967 | +| | 969 | +| | 971 | +| | 973-974 | +| | 976 | +| | 1014 | +| | 3699 | +| | 3700 | +| | 4511 | +| | 5417 | +| | 5431-5433 | +| | 5487-5491 | +| | 6007-6101 | +| | 6130-6132 | +| | 7087-7089 | + +| | 7521-7580 | +|---------------------|-------------| +| | 7620-7641 | +| | 7660 | +| | 7676-7677 | +| | 9087-9088 | +| | 11489-11490 | +| | 12217 | +| | 12305 | +| | 12359 | +| | 12376 | +| | 12382 | +| | 12405 | +| Production 2 | 20147 | +| | 20169 | +| | 20171 | +| | 20182 | +| | 20184 | +| | 20199 | +| | 20205 | +| | 20223 | +| | 20231 | +| | 20242 | +| | 20254 | +| | 20262 | +| | 20269 | +| | 20277 | +| | 20284 | +| | 20306 | +| | 20333 | +| | 20335 | +| | 20337 | +| | 20355 | +| | 20397 | +| | 65958-65960 | +| | 76863-76876 | +| | 76877-76884 | +| | 78667-78668 | +| | 78670-78671 | +| | 78710-78747 | +| | 87383 | + +| | 87407-87688 | +|---------------------|---------------| +| | 89471-89642 | +| | 90052 | +| | 90409 | +| | 90486 | +| | 91249 | +| | 91540-92418 | +| | 92994-93060 | +| | 93432-94279 | +| | 98846-101563 | +| | 101564-101631 | +| | 102101-102121 | +| | 105689-105866 | +| | 107072-107272 | +| | 110210-110266 | +| | 118735-118750 | +| | 164886-164887 | +| | 164920-165517 | +| Production 3 | 167914-168477 | +| | 169184-169504 | +| | 169505-169749 | +| | 169760-170396 | +| | 170398-170613 | +| | 170624-170635 | +| | 171442 | +| | 171447 | +| | 171449 | +| | 171455 | +| | 172140 | + +It is the responsibility of the government, not the defense, to ensure that Ms. Maxwell has a complete set of the discovery that she can review in the MDC. Defense counsel should not be in the position of having to suggest technological fixes to help the government satisfy its own Rule 16 obligations, which have not been met. Without access to the full discovery materials, Ms. Maxwell cannot participate in the preparation of her defense. Accordingly, we demand that the + +Page 5 + +government immediately fix all of the issues with Ms. Maxwell's discovery so that she can review all of the discovery materials produced to date.' + +Ms. Maxwell also does not have access to a table or a writing surface on which to take notes when she is reviewing the discovery. The desktop computer she uses to review discovery sits on a table that is only wide enough to accommodate the computer, leaving no room to take notes. Ms. Maxwell must attempt to write while the paper is on her lap or rest the paper sideways on the little available space next to the computer. Furthermore, the computer screen uses to view the discovery faces the prison guard station and the doorway to the rec room, where the phone is located. As a result, any time a guard answers the phone or enters or exits the rec room, which occurs as much as 40 times a day or more, Ms. Maxwell has to turn off the computer screen to prevent the guards from seeing what she is reviewing. + +These conditions severely impact Ms. Maxwell's ability to prepare her defense and provide written instructions to her legal team. We therefore request that you speak to the warden about providing Ms. Maxwell with a desk and reorienting the computer screen so that it is not visible to the prison guards. + +### 2. Ms. Maxwell and Defense Counsel Request Access to All Documents Designated as "Highly Confidential" + +According to the Protective Order in this case, Ms. Maxwell may only review the documents marked by the government as "Highly Confidential" in the presence of defense counsel and "under the protection of law enforcement officers or employees." (Dkt. 36 ¶ 14). Accordingly, we request that the government schedule a time at the earliest possible convenience for Ms. Maxwell and defense counsel to review all of the "Highly Confidential" documents produced to date, pursuant to the terms of the Protective Order. + +# 3. Ms. Maxwell's Conditions of Confinement Must Be Improved + +Ms. Maxwell's conditions of confinement are extraordinarily onerous and unlike those of any other inmate at the MDC (or in BOP custody, to our knowledge). In fact, in the time that Ms. Maxwell has been at the MDC, she has met with four separate wardens and interim wardens, and each has told her that they have never seen in their collective years of experience anything like her current regime. We have written to the current warden twice in the last three weeks — on August 28, 2020 and September 9, 2020 — making specific requests to improve the conditions of her + +We exclude from this any discovery materials marked "Highly Confidential" that she is not permitted to review in the MDC under the terms of the Protective Order in this case. The "Highly Confidential" documents are the subject of the defense's second request. + +Page 6 + +confinement, but have received no response. Accordingly, we now ask the government to intercede with the BOP to make the following improvements. + +### a. Living Conditions. Surveillance, and Searches + +Despite being housed on an entire floor by herself, Ms. Maxwell is forced to sleep and spend half of her time in a confined space ominously referred to as the "isolation cell," which is roughly 7x9 feet. While she is inside the isolation cell, Ms. Maxwell is constantly watched by 2-3 prison guards and has two cameras trained on her every second — one in the ceiling and a supplemental handheld camera that is usually positioned only about four feet away from her. She gets very little sleep, as she is woken up by flashing lights, loud discussions among the guards, and adjustments of the supplemental camera. Ms. Maxwell is effectively being kept in solitary confinement (she has now been housed alone for over 80 days) and treated as if she were on suicide watch even though she is not, and has never been suicidal. Moreover, she is being treated like a laboratory rat, with her every movement is recorded by the prison guards every 15 minutes. + +Ms. Maxwell is supposed to be allowed out of the isolation cell from 7am to 8pm each day and taken to a separate rec room on the same floor, where a desktop computer and a shower are located, so that she can review the discovery and maintain her personal hygiene. However, she is frequently picked up late and returned to the isolation cell early. For example, this past Friday, September 18, 2020, Ms. Maxwell had an in-person counsel visit that was supposed to begin at 11:00 a.m. Ms. Maxwell was not picked up from the isolation cell until after 8am and was not delivered to the visiting room until approximately 45 minutes after the meeting was supposed to begin. When Ms. Maxwell finally arrived, she then needed to be strip-searched before the meeting could begin, which meant that the visit was cut short by almost an hour.2 + +Ms. Maxwell is also searched more frequently and extensively than any other pretrial detainee of which we are aware. Each time Ms. Maxwell is moved from the isolation cell, she is searched and her cell is searched, and she is often searched again when she arrives at the rec room, all of which takes up time she could be using to review the discovery. Then process is repeated when Ms. Maxwell is brought back to the isolation cell. This past Friday, Ms. Maxwell was searched at least five separate times and strip-searched twice. Each time, Ms. Maxwell had her mouth searched by prison guards who put their hands inside her mouth, which exposes her to heightened risk of COVID-19 transmission. + +Given the disruption caused by moving Ms. Maxwell each day, we do not see why Ms. Maxwell could not be housed in the rec room where the computer and shower are located, instead of the isolation cell. In fact, Ms. Maxwell was told on several occasions by previous wardens and + +2 Ms. Maxwell was also not given approved legal calls with counsel on August 25, 2020 and August 27, 2020. + +Page 7 + +interim wardens that this was the plan. We ask that the government talk to the current warden about implementing this change. + +# b. Body Scans + +Ms. Maxwell is subjected to a body scan each week, and until recently, she received approximately three per week. We assume these are to see if Ms. Maxwell has secreted anything inside her body. We do not understand why it is necessary for the BOP to administer body scans on such a regular and frequent basis — and thereby repeatedly expose Ms. Maxwell to radiation especially when she is already under constant surveillance and the scans have all come up negative. We ask that these body scans be curtailed significantly or eliminated, if possible. + +#### c. Access to the Commissary + +Although the MDC nominally approved Ms. Maxwell's request for permission to purchase from the full prison commissary list in August 2020, in fact, her access to the commissary is still extremely limited. To name just one example, she has not been able to purchase sports bras that fit since she arrived at the MDC. Ms. Maxwell cannot be denied such a basic article of clothing. Among other things, it means that she cannot engage in aerobic exercise necessary to stay healthy. We are more than happy to send Ms. Maxwell whatever brand of underwear is approved by the MDC, but we cannot do so without the permission of the warden. We therefore ask the government to speak to the warden about granting defense counsel permission to send Ms. Maxwell approved commissary items, including underwear, and to give her access to the full commissary list. + +## d. Food/Care Packages + +Ms. Maxwell's meals have been a persistent problem and are entirely inadequate. She has been given non-vegetarian meals and has been denied food on the prison menu. For example, she often receives meals with no protein and was recently given only bread and butter for several meals with no additional food. It was not until Ms. Maxwell was given access to the menu for the first time on September 1, after she complained that she had been given a non-vegetarian meal, that she realized that she had not been receiving full meals with all of the nutritional components since arriving at MDC. + +Moreover, she has often has been given inedible food, such as frozen black bananas, and has not been fed at all for long stretches of time. For example, this past weekend she was not fed anything for a period of more than 20 hours from Saturday late afternoon until Sunday at midday. As a result of this inadequate nutrition, she has lost a great deal of weight since arriving at MDC. The MDC's response to this problem was to remove the scale from the rec room so that she can no longer weigh herself and keep track of how much weight she is losing. This is unconscionable + +Page 8 + +and unacceptable. This lack of food also severely affects her ability to concentrate and review discovery to prepare her defense. + +We therefore ask the government to speak to the warden about ensuring that Ms. Maxwell is given full access to the prison menu, that she be given complete meals on a timely basis, and that her food is, at the very least, edible and provides her with enough nutrition to stop her weight loss. We also ask that Ms. Maxwell, like other detainees, be given permission to receive care packages of approved food items to supplement her diet. + +#### e. Non-Delivery of Mail and Other Items + +Delivery of mail to Ms. Maxwell has also been a problem. Ms. Maxwell's friends and family members have mailed her numerous letters since she arrived at the MDC. However, as of yesterday, she has only received a handful of these letters, despite being correctly addressed. Several of these letters appear to have been rejected because they were written on colored paper, as opposed to white paper, even this prohibition appears nowhere in the prison regulations. It took six weeks for these letters to be rejected. And even though these letters were all resent on white paper, only one of the nine letters has been delivered to Ms. Maxwell thus far. At the same time, Ms. Maxwell has received hundreds of letters from people she does not know. We do not know why most of the letters that she cares about have not been delivered, while there seems to be no limit whatsoever on the number of letters she can receive from complete strangers. + +Ms. Maxwell has also not received shipments of approved items from Amazon. For example, on August 13, 2020, her counsel placed an Amazon order for a package of five BOPapproved flexible pens and eight BOP-approved legal pads. The legal pads were delivered to the MDC on August 18, 2020, and the pens were delivered on August 19, 2020. Both deliveries were rejected as undeliverable without reason. Similarly, the delivery of a book was rejected and returned for no apparent reason. And to our knowledge, none of the copies of The New York Times, which are approved and have been paid for since August I, 2020, have been delivered to Ms. Maxwell. We do not understand why these items were rejected or have not been delivered. + +We were also not permitted to deliver a new pair of reading glasses to Ms. Maxwell to replace the ones that BOP personnel broke in a search of her cell shortly after she arrived at the MDC. Instead, we had to wait until Ms. Maxwell received approval to receive the glasses and then had to mail them to her. As result, Ms. Maxwell was without her reading glasses for over two months from early July 2020 until September 16, 2020, when they finally were provided to her at the MDC. It therefore has been extremely difficult for Ms. Maxwell to review the discovery until now. + +We therefore ask the government to speak to the warden about ensuring that Ms. Maxwell's personal mail is delivered in a timely fashion, and that future deliveries of approved items are not rejected and are delivered to Ms. Maxwell. + +Page 9 + +In her August 25, 2020 Opinion and Order, Judge Nathan stated that if Ms. Maxwell is not being provided sufficient access to the discovery materials "so that she can meaningfully participate in the preparation of her defense," defense counsel may seek intervention by the Court. (Dkt. 49 at 2). Judge Nathan further stated that while she had not been presented any evidence that Ms. Maxwell's conditions of confinement were punitive or motivated by an improper purpose, she nevertheless ordered the government "to provide written status updates every 90 days detailing any material changes to conditions of Ms. Maxwell's confinement, with particular emphasis on her access to legal materials and ability to communicate with defense counsel." (Id.). + +For the reasons set forth above, the government and the BOP are not providing adequate conditions that allow Ms. Maxwell access to the discovery materials so that she can meaningfully participate in the preparation of her defense. Ms. Maxwell has been provided hard drives containing a substantial number of unreadable files and therefore still cannot review the entire discovery production, even though it is now one month after the discovery deadline has passed. + +Furthermore, the conditions of Ms. Maxwell's confinement have deteriorated since our last application to the Court for relief. She is not being fed a sufficient amount of food and is losing a great deal of weight, which makes it very difficult for her to review the discovery and prepare her defense. Ms. Maxwell is also subjected to a level of surveillance that is intrusive, aggressive, constant, unnecessary and unjustifiable on the grounds of safety and security. These measures are akin to punishment, which is inappropriate for any pretrial detainee, especially one who, like Ms. Maxwell, has never once received a disciplinary infraction. + +We seek your urgent intervention on these issues now, well before the November 25, 2020 deadline for the government's first written status update to the Court, because these matters simply cannot wait until then to be remedied. We further reserve all of our rights with regard to these issues, including the right to seek intervention from the Court, if these matters are not addressed expeditiously. + +Page 10 + +Thank you in advance for your attention to these matters. + +Sincerely, + +/s/ Christian Everdell + +Christian R. Everdell + +COHEN & GRESSER LLP + +800 Third Avenue, 21st Floor + +York 10022 + +cc: Mark S. Cohen, Esq. Jeff Pagliuca, Esq. 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0000000000000000000000000000000000000000..7305cae89d97935b56d9af2040e0064073499d3a --- /dev/null +++ b/marker2/ds9/EFTA00087980/_page_0_Picture_4.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:0cda9eeab0c790f539b84282ca5b724ffc7dbad934f8654c8c82dd4f34d2577c +size 2154 diff --git a/marker2/ds9/EFTA00087990/EFTA00087990.md b/marker2/ds9/EFTA00087990/EFTA00087990.md new file mode 100644 index 0000000000000000000000000000000000000000..16181d7101342ee920a3a4cf281af66301969b14 --- /dev/null +++ b/marker2/ds9/EFTA00087990/EFTA00087990.md @@ -0,0 +1,91 @@ +To: + +Cc: + +Subject: RE: Relativity Upload - Epstein Database + +Date: Mon, 21 Sep 2020 14:07:37 +0000 + +Hey IM + +I'm working on getting you replacements and will have an update for you soon. + +Thanks, + +From: + +Sent: Friday, September 18, 2020 1:23 PM + +Subject: RE: Relativity Upload - Epstein Database + +Hello, + +The following pst files are damaged and I was wondering if you are able to get replacement pst files for the following: + +\EOUSA-1\AVillafana\_030115To031119\_2\_PRpst + +\ EOUSA-2 \by dateffi070106To022819\_002.pst + +\ EOUSA-3 \ EOUSA 3=Proofpoint-SENT-01MAR15-20FE819\_0.pst + +\EOUSA-3\EOUSA 3 Proofpoint-SENT-01MAR15-20FEB19\_1.pst + +Please let me know if there are any questions. + +Thank you. + +From: + +Sent: Wednesday, Se tember 9, 2020 10:19 PM + +> + +Cc: (USANYS) < > `•. > + +Subject: RE: Relativity Upload - Epstein Database + +From: + +Sent: Wednesday, September 9, 2020 12:09 PM + +To: + +From: + +Sent: Wednesday, September 9, 2020 12:02 PM + +To: + +Cc: U ANY + +Subject: FW: Relativity Upload - Epstein Database + +Here is the information regarding the PST files from the NUIX PC (USANYSWSZ50856) which are to be uploaded to the Epstein Relativity database: + +Link/Materials: NUIX PC (USANYSWSZ50856) + +Folder/Subfolder in Relativity Emails + +Custodian: + +Thanks, + +From + +Sent: Wednesday, August 26, 2020 10:36 AM + +u•ject• Re ativity Up oa. - Epstein Data. + +We have received emails that we would like to upload to Relativity. + +Link: \\ Usa.doj.gov \cloud \ NYS \ StAndrews\Shared \ USvEpstein-2018R01618 Investip,ation OPR Materials Emails + +Folder/Subfolder in Relativity: mails + +Custodian: + +Additionally, I don't actually have access to the database. When you have the chance would you grant me access. + +Thanks, + +![](_page_2_Picture_0.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00087990/EFTA00087990.metadata.json b/marker2/ds9/EFTA00087990/EFTA00087990.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..eec2077caeebe39eb67a115ae31a8da05cda5df6 --- /dev/null +++ b/marker2/ds9/EFTA00087990/EFTA00087990.metadata.json @@ -0,0 +1,116 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087990.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 1722, + "elapsed_seconds": 1.35, + "image_assets": [ + "_page_2_Picture_0.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 62 + ], + [ + "Line", + 29 + ], + [ + "Text", + 28 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 55 + ], + [ + "Text", + 29 + ], + [ + "Line", + 27 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ], + [ + "Line", + 1 + ], + [ + "Span", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087990" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087990/_page_2_Picture_0.jpeg b/marker2/ds9/EFTA00087990/_page_2_Picture_0.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..336bc76d80c15e81709c2d7d2fe6c597df50cc3f --- /dev/null +++ b/marker2/ds9/EFTA00087990/_page_2_Picture_0.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:60e2cf567d94c2dce7b71fbfdde94130ea178f51b683676d8b48b3a8f3441ae7 +size 2569 diff --git a/marker2/ds9/EFTA00087993/EFTA00087993.md b/marker2/ds9/EFTA00087993/EFTA00087993.md new file mode 100644 index 0000000000000000000000000000000000000000..df24e15a1d7bd21df3f03ec01a81eb0f88e9741d --- /dev/null +++ b/marker2/ds9/EFTA00087993/EFTA00087993.md @@ -0,0 +1,39 @@ +**To:** "[REDACTED]" <[REDACTED]>, "[REDACTED]" + +<[REDACTED]>, "[REDACTED]" <[REDACTED]> + +**Subject:** RE: Draft Maxwell Indictment + +**Date:** Thu, 11 Jun 2020 23:28:35 +0000 + +--- + +Congratulations on having made it (this far) through the drafting gauntlet! With apologies for the intrusion, any chance once of you could send me a word version of the original Epstein complaint? Thanks very much. + +--- + +**From:** [REDACTED] <[REDACTED]> + +**Sent:** Thursday, June 11, 2020 6:13 PM + +**To:** [REDACTED] (USANYS) <[REDACTED]>; [REDACTED] (USANYS) <[REDACTED]>; [REDACTED] + +[REDACTED] (USANYS) <[REDACTED]>; [REDACTED] (USANYS) <[REDACTED]>; [REDACTED] (USANYS) + +<[REDACTED]> + +**Cc:** [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] + +[REDACTED] (USANYS) <[REDACTED]>; [REDACTED] (USANYS) <[REDACTED]> + +**Subject:** Draft Maxwell Indictment + +All, + +Attached please find draft of the Maxwell indictment. + +![](_page_0_Picture_98.jpeg) + +Thanks, + +![](_page_0_Picture_100.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00087993/EFTA00087993.metadata.json b/marker2/ds9/EFTA00087993/EFTA00087993.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..b052870d8c73fcd11b3e093931a1de2187e97078 --- /dev/null +++ b/marker2/ds9/EFTA00087993/EFTA00087993.metadata.json @@ -0,0 +1,61 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00087993.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 977, + "elapsed_seconds": 4.55, + "image_assets": [ + "_page_0_Picture_98.jpeg", + "_page_0_Picture_100.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 46 + ], + [ + "Text", + 31 + ], + [ + "Line", + 21 + ], + [ + "PageFooter", + 2 + ], + [ + "Picture", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00087993" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00087993/_page_0_Picture_100.jpeg b/marker2/ds9/EFTA00087993/_page_0_Picture_100.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..5a26a0f72c4b45460d2a610c4491949b47bf489b --- /dev/null +++ b/marker2/ds9/EFTA00087993/_page_0_Picture_100.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:765e947cbd9facdef8a7899349cb1c974ec1ed6c1ac495553f1ed922f2ad5b74 +size 1071 diff --git a/marker2/ds9/EFTA00087993/_page_0_Picture_98.jpeg b/marker2/ds9/EFTA00087993/_page_0_Picture_98.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..495a9f9ad72a50393fb40455e5bdfc1c06d77f1d --- /dev/null +++ b/marker2/ds9/EFTA00087993/_page_0_Picture_98.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:b4a43af14c2490b10a5b5b2a5474ca3982092029a6df084db06054062d1b5076 +size 10705 diff --git a/marker2/ds9/EFTA00087994/EFTA00087994.md b/marker2/ds9/EFTA00087994/EFTA00087994.md new file mode 100644 index 0000000000000000000000000000000000000000..0003404d1bd5823b00c4c6ec95aa973821699f13 --- /dev/null +++ b/marker2/ds9/EFTA00087994/EFTA00087994.md @@ -0,0 +1,359 @@ +![](_page_0_Picture_0.jpeg) + +## U.S. Department of Justice + +Criminal Division + +VAA:WHG:JEC:JTM DOJ No. CRM-182-73090 + +Office of International Affairs Washington, D.C. 20530 + +FROM: The Central Authority of the United States + +TO: The Central Authority of the United Kingdom + +SUBJECT: Request for Assistance in the Matter of Material Witness PA + +DATE: April 3, 2020 + +The Central Authority of the United States of America ("U.S.") requests the assistance of the Central Authority of the United Kingdom ("UK") under the 1994 Treaty of Mutual Legal Assistance in Criminal Matters between the U.S. and the UK, as amended by the 16 December 2004 Instrument and exchange of notes ("the Treaty"). The United States Attorney for the Southern District of New York and the Federal Bureau of Investigation (collectively the "U.S. authorities") seek to interview H.R.H. Prince Andrew Albert Christian Edward, the Duke of York, also known as Andrew Mountbatten-Windsor ("Prince Andrew" or "the witness"), relating to two ongoing criminal investigations. In addition, U.S. authorities seek records of certain communications and meetings between Prince Andrew and the subjects of one investigation. + +With regard to the interview, U.S. authorities request to conduct a voluntary interview of Prince Andrew and request the assistance of UK authorities in arranging for such an interview. In the event that the witness declines to participate in a voluntary interview, U.S. authorities request that UK authorities conduct a compelled interview of the witness under oath. + +The U.S. authorities may use the requested records and information in the U.S. criminal investigation and proceedings, as defined at Article 19 of the Treaty, and in other U.S. criminal investigations and proceedings, as well as non-criminal judicial or administrative proceedings directly related to the U.S. criminal investigations and proceedings, pursuant to Article 7 of the Treaty. + +## CONFIDENTIALITY + +The U.S. authorities are conducting ongoing criminal investigations. Notwithstanding that one or more of the persons referenced in this request is aware to some extent of the U.S. authorities' attention to this matter, this request also recounts specifics and evidentiary detail that may not be known, exposure of which could impede the investigation with regard to the integrity of evidence and witness accounts. Because the persons referenced in this request are generally aware of the U.S. authorities' investigations, U.S. authorities are not requesting that the existence of this legal assistance request be kept confidential. However, premature notification of the specific subject matter and the questions outlined in the attachments to this request could seriously jeopardize the investigations or compromise any trial, by prompting a witness to alter or prepare his/her answers to specific questions, by prompting others to destroy or tamper with evidence; change patterns of behavior; intimidate potential witnesses; or alert others who could do the same. Accordingly, and pursuant to articles 4(3)(j) and 7 of the Treaty, please keep the contents of this request, including the subject matter of questioning and the questions themselves, confidential and please ensure that they are not shared with any persons (including the witness, the witness's representatives, or subjects of the investigation), or with any government officials whose knowledge is not absolutely necessary for purposes of executing this request. In addition, please advise all who must be made aware of this request that the contents are to be kept confidential and should not be shared with any witness, potential subjects of the investigation or any other persons. If this request cannot be executed without breaching such confidentiality, please notify U.S. authorities through the U.S. Department of Justice, Office of International Affairs prior to taking any action. U.S. authorities also request that UK authorities keep a written log of all those individuals who have been made aware of the contents of this request, noting when those individuals were so made aware. + +# THE FACTS + +# Investigation I: The Jeffrey Epstein Investigation + +U.S. citizen Jeffrey Epstein is alleged to have engaged in the sexual abuse of minor girls during the period of approximately 1994 through 2005. On or about July 2, 2019, a grand jury in the Southern District of New York returned an Indictment charging Epstein with violations of U.S. criminal laws in connection with his sexual abuse of minors, including with engaging in a conspiracy to sexually traffic in minors. Epstein was arrested pursuant to the Indictment on or about July 6, 2019, and had been detained pending trial in New York. On or about August 10, 2019, Epstein committed suicide in his cell. Notwithstanding Epstein's death, the investigation that led to his indictment remains ongoing. That ongoing investigation has revealed evidence of additional criminal conduct by Epstein's associates, including Ghislaine Maxwell. + +The investigation to date has revealed that Prince Andrew may have been a witness to and/or participant in certain events of relevance to the ongoing investigation. For example, one victim has alleged that Maxwell introduced her to Prince Andrew who, according to this victim, was present for certain of the victim's interactions with Epstein and Maxwell. Additionally, documentary evidence uncovered during the course of this investigation has revealed information suggesting that Prince Andrew had knowledge that Maxwell recruited females to + +engage in sex acts with Epstein and other men. Finally, there is evidence that Prince Andrew engaged in sexual conduct involving one of Epstein's victims. Prince Andrew is not presently a target of the investigation, and U.S. authorities have not, to date, gathered evidence that he has committed any crime under U.S. law. + +# Investigation II: The Peter Nygard Investigation + +The U.S. authorities are investigating Peter Nygard, a Canadian citizen, and other coconspirators' involvement in an international sex trafficking ring victimizing adult women and minor girls. The investigation concerns, among other things, allegations of sex trafficking at various locations inside and outside the United States, including Nygard's estate in Lyford Cay, Bahamas, referred to as "Nygard Cay." Sex trafficking victims were transported internationally, including between the Bahamas and locations in the United States. + +The investigation of Peter Nygard and others is ongoing and no charges have been filed as of this date. The investigation has revealed that, on at least one occasion, Prince Andrew travelled to Nygard Cay in the Bahamas, a location where Nygard is believed to have trafficked minor and adult female victims. U.S. authorities seek to question Prince Andrew regarding his visit(s) to Nygard Cay during the time period under investigation, and other information he may have about Peter Nygard and related individuals. Prince Andrew is not presently a target of this investigation, and U.S. authorities have not, to date, collected evidence that he committed any crime under U.S. law. + +# THE OFFENSES + +The criminal conduct being investigated currently implicates the following offenses. Note that pursuant to Articles 7 and 19 of the Treaty, U.S. authorities may determine that additional or different offenses may also be implicated in this matter: + +### Title 18, United States Code, Section 1591 Sex Trafficking of Minors and by Force, Fraud, and Coercion + +- (a) Whoever knowingly + - (1) in or affecting interstate or foreign commerce, or within the special maritime and territorial jurisdiction of the United States, recruits, entices, harbors, transports, provides, obtains, advertises, maintains, patronizes, or solicits by any means a person; or + - (2) benefits, financially or by receiving anything of value, from participation in a venture which has engaged in an act described in violation of paragraph (1), knowing, or, except where the act constituting the violation of paragraph (1) is advertising, in reckless disregard of the fact, that means of force, threats of force, fraud, coercion described in subsection (e)(2), or any combination of such means will be used to cause the person to engage in a commercial sex act, or that the person has not attained the age of 18 years and will be caused to engage in a commercial sex act, shall [have committed a crime]. +- (b) The punishment for an offense under subsection (a) is + - (1) if the offense was effected by means of force, threats of force, fraud, or coercion ...or by any combination of such means, or if the person recruited, enticed, harbored, transported, provided, obtained, advertised, patronized, or solicited had not attained the age of 14 years at the time of such offense, by a fine under this title and imprisonment for any term of years not less than 15 or for life; or + - (2) if he offense was not so effected, and the person recruited, enticed, harbored, transported, provided, obtained, advertised, patronized, or solicited had attained the age of 14 years but had not attained the age of 18 years at the time of such offense, by a fine under this title and imprisonment for not less than 10 years or for life.' + +I The penalties stated herein apply to conduct that occurred after July 27, 2006. For conduct that occurred prior to that time, the penalties would be lower and may not include mandatory minimum sentences. + +### Title 18, United States Code, Section 2423 Transportation of Minors + +- (a) Transportation with intent to engage in criminal sexual activity + - (1) A person who knowingly transports an individual who has not attained the age of 18 years in interstate or foreign commerce, or in any commonwealth, territory or possession of the United States, with intent that the individual engage in prostitution, or in any sexual activity for which any person can be charged with a criminal offense, shall [have committed a crime and be] imprisoned not less than 10 years or for life.2 + +# Title 18 United States Code Section 2422 Coercion and Enticement + +- (1) (b) Whoever, using the mail or any facility or means of interstate or foreign commerce, or within the special maritime and territorial jurisdiction of the United States knowingly persuades, induces, entices, or coerces any individual who has not attained the age of 18 years, to engage in prostitution or any sexual activity for which any person can be charged with a criminal offense, or attempts to do so, shall [have committed a crime and be] imprisoned not less than 10 years or for life.; + +# Title 18, United States Code, Section 371 Conspiracy + +If two or more persons conspire ... to commit any offense against the United States ... and one or more of such persons do any act to effect the object of the conspiracy, each shall [have committed a crime and be] imprisoned not more than five years. + +## PERSONS INVOLVED + +Name: H.R.H. Prince Andrew Albert Christian Edward, Duke of York o known as Andrew Mountbatten-Windsor Date of birth: Place of birth: Citizenship: Address: UK + +2 The penalties stated herein apply to conduct that occurred after July 27, 2006. For conduct that occurred prior to that time, the penalties would be lower and may not include mandatory minimum sentences. + +3The penalties stated herein apply to conduct that occurred after July 27, 2006. For conduct that occurred prior to that time, the penalties would be lower and may not include mandatory minimum sentences. + +Name: hislaine Maxwell Date of Birth: Place of Birth: Maison-Laffitte, France Citizenship: U.S., UK, France + +Name: Peter N v ar Date of Birth: Place of Birth: Helsinki, Finland Citizenship: Canada, Finland + +#### ASSISTANCE NEEDED + +#### Voluntary Interview Conducted by U.S. Authorities + +U.S. authorities seek to conduct an investigative interview of Prince Andrew. U.S. authorities specifically request to conduct the questioning themselves in the presence of UK authorities to ensure that all necessary lines of inquiry are completed in the most efficient fashion. The specific subject matters of questioning are set forth in Attachment A. U.S. authorities further request that the interview be recorded using both video and audio recording equipment. U.S. authorities request that at least two members of each of the following investigatory teams be permitted to attend the questioning: + +For Investigation I (Epstein): + +- a. Assistant U.S. Attorney, Southern District of New York +- b. Assistant U.S. Attorney, Southern District of New York +- c. Assistant U. . Attorney, Southern District of New York + +- d. +- e. cial A n Federal Bureau of Investigation Detective N w York City Police Department' + +## For Investigation II (Nygard): + +- a. +- b. +- c. +- d. +- e. Assistant U.S. Attorney, Southern District of New York Assistant U.S. Attorney, Southern District of New York Assistant U.S. Attorney, Southern District of New York = Special A ent Federal Bureau of Investigation Detective. New York City Police Departments + +If the witness requests, U.S. authorities are prepared to conduct the interview pursuant to a "proffer letter" similar to that attached as Attachment B. The letter outlines the conditions under which U.S. authorities will not use the witness's statements against him. + +4 NYPD detective serving on the FBI task force, and assisting in the federal investigation. + +5 NYPD detective serving on the FBI task force, and assisting in the federal investigation. + +### Voluntary Interview Conducted by UK Authorities + +In the event that UK authorities decline to permit the U.S. case team to directly question the witness, U.S. authorities request that UK authorities question the witness about the subject matters set forth in Attachment C. As noted on that list, U.S. authorities request that additional follow-up questions be asked by UK authorities to clarify answers given or to follow relevant lines of inquiry. In the event it would assist UK authorities, U.S. authorities will produce a list of specific questions covering each of the topics outlined in Attachment C. + +U.S. authorities also request to be present during the questioning of the witness by UK authorities. Those observing would include at least two members of the teams listed above. U.S. authorities also request that they be permitted to propose, during or at the conclusion of the interview, additional questions to be asked by UK authorities of the witness after hearing the witness's initial responses. + +U.S. authorities request that UK authorities record the interview using audio and video recording equipment. U.S. authorities further request that the witness be cautioned in the event of a voluntary interview that if he were to provide false information to authorities in connection with this mutual legal assistance request, he could be prosecuted for perverting the course of justice in the UK, and he may be prosecuted for making a false statement, in violation of Title 18, United States Code. Section 1001, in the U.S. + +# Compelled Interview + +If the witness declines to participate in either type of voluntary interview requested above, U.S. authorities request that UK authorities conduct a compelled interview under oath employing the subject matters set out in Attachment C. As noted above, if it would assist UK authorities, U.S. authorities will produce a list of specific questions covering each of the topics outlined in + +Attachment C. U.S authorities also request that the compelled interview be audio- or videorecorded. If the witness declines to respond to questions by asserting his right to remain silent, U.S. authorities request that such a declination be to each question set forth in Exhibit C and that declination be on the audio or video recording under oath. + +Prior to conducting the compelled interview, U.S. authorities request that the witness be read the following caution on the record: + +- Pursuant to the 1994 Treaty of Mutual Legal Assistance in Criminal Matters between the United States of America and the United Kingdom, as amended by the 16 December 2004 Instrument and exchange of notes, and [relevant provisions of UK domestic law], you have been subpoenaed to answer questions under oath. +- Authorities in the United States are conducting an investigation of possible violations of Federal criminal laws including Sex Trafficking in violation of 18 United States Code Section 1591, Transportation of Minors to Engage in Sex in violation of 18 United States Code Section 2423, Coercion and Enticement of Minors to Engage in Sex in violation of 18 United States Code Section 2422, and related crimes. +- You may refuse to answer any question if a truthful answer to the question would tend to incriminate you. +- Anything you do say may be used against you. +- If you have retained counsel, you will be permitted a reasonable opportunity to consult with counsel if you so desire. +- Note that if you make any knowingly false statements you can be prosecuted for perverting the course of justice and other related crimes under the laws of the United Kingdom. + +# Future Testimony + +If the witness provides relevant information during the interview, the U.S. authorities request that the witness be asked if he is willing to testify in U.S. criminal proceedings in the Southern District of New York related to one or more of these investigation and any ensuing prosecutions at some future date. + +#### Documents + +U.S. authorities also seek certain records which are relevant to the Epstein Investigation. + +In particular, the U.S. authorities request production of the following categories of communication, including email, text, recorded or transcribed voicemail, and any other written correspondence or notes of oral communications, which is in the custody or control of the witness or his representatives: + +- a. Any notes or calendar entries reflecting communications or meetintwith the following individuals: Jeffrey Epstein; Ghislaine Maxwell; or +- b. Any documents reflecting travel to the following locations: residence located at 9 East 71st Street, New York, New York; "Zorro Ranch," located in Santa Fe, New Mexico; 358 El Brillo Way, Palm Beach, Florida; any other property owned or leased by Jeffrey Epstein or Ghislaine Maxwell. +- c. Any documents, such as receipts or tickets, reflecting events or meals at which the followin individuals were present: Jeffrey Epstein; Ghislaine Maxwell; or +- d. Any communication to, from, or copying Ghislaine Maxwell involving the followin to ics: + - i. + - ii. Any females Maxwell, Jeffrey Epstein or any associate or representative of Maxwell or Epstein arranged for Prince Andrew to meet; + - iii. Any females Maxwell, Epstein or any associate or representative of Maxwell or Epstein arranged for other adult men to meet. + - iv. Massage, massages, and/or masseuses. + - v. Any investigation into Epstein or is associates, including but not limited to any prosecutions brought by the U.S. authorities against Epstein. + - vi. Any civil lawsuits threatened or brought against Prince Andrew, Maxwell, Epstein, and/or their associates. + - vii. Any reference to or evidence of the destruction of evidence, the obstruction of investigations, or other efforts to conceal criminal activity by Epstein, Maxwell, or their associates. + - viii. Any payments made, in cash or in kind, to Maxwell, Epstein, or their representatives or associates. + - ix. Any sexual encounters and/or romantic relationships involving Prince Andrew and any female he met through Maxwell and/or Epstein. + - x. The involvement of Maxwell and/or any associate of Maxwell's in recruiting, enticing, transporting or trafficking minors for the purpose of engaging in unlawful sexual contact. + +- e. Any communication to, from, or copying Jeffrey Epstein involving the foll win to ic.: + - i. + - ii. Any females Epstein or his associates or representatives, including Maxwell, arranged for Prince Andrew to meet. + - iii. Any females Epstein or his associates or representatives, including Maxwell, arranged for other adult men to meet. + - iv. Massage, massages, and/or masseuses. + - v. Any investigation into Epstein or is associates or representatives, including but not limited to any prosecutions brought by the U.S. authorities against Epstein. + - vi. Any civil lawsuits threatened or brought against Prince Andrew, Maxwell, and/or their associates. + - vii. Any reference to or evidence of the destruction of evidence, the obstruction of investigations, or other efforts to conceal criminal activity by Epstein, Maxwell, or their associates. + - viii. Any payments made, in cash or in kind, to Maxwell, Epstein, or their representatives or associates. + - ix. Any sexual encounters and/or romantic relationships involving Prince Andrew and any female he met through Maxwell and/or Epstein. + - x. The involvement of Epstein and/or any associate of Epstein's in recruiting, enticing, transporting or trafficking minors for the purpose of engaging in unlawful sexual contact + +# CONCLUSION + +We thank you for your assistance with this matter of Material Witness PA and ask that you keep us apprised of all developments. + +3 April 2020 + +Date + +Associate Director Office of International Affairs Criminal Division U.S. Department of Justice + +### ATTACHMENT A + +## The Jeffrey Epstein Investigation + +The U.S. Authorities would seek to question Prince Andrew regarding the following topics during a voluntary interview: + +- I. The history and nature of Prince Andrew's relationship with Jeffrey Epstein. +- 2. The history and nature of Prince Andrew's relationship with Ghislaine Maxwell. +- 3. The history and nature of Prince Andrew's relationship with +- 4. The details regarding any trips Prince Andrew took with and/or to visit Maxwell and/or Epstein. +- 5. The details regarding any trips Maxwell and/or Epstein took to visit Prince Andrew. +- 6. The details regarding any payments Prince Andrew made to or received from Maxwell, Epstein, or any female associated with Maxwell and/or Epstein. +- 7. The names and identifying features of any females Prince Andrew met through Epstein and/or Maxwell. +- 8. The details of any conversations Prince Andrew participated in or witnessed during which anyone discussed Epstein's sexual preferences, practices or history; Maxwell's sexual preferences, practices, or history; and/or Maxwell's role assisting Epstein or other men in locating females with whom to engage in sexual activity. +- 9. The details of Prince Andrew's interactions with and/or conversations regarding +- 10. Communications, including email correspondence, between Prince Andrew and Maxwell regarding Maxwell's attempts to introduce Prince Andrew to females. +- II. Any knowledge Prince Andrew had or may have had of inappropriate relationships, including improper or unlawful sexual contact, involving Epstein and/or his associates with any minor. +- 12. Prince Andrew's involvement, if any, in any sexual contact and/or relationship with any person Prince Andrew met through or with Epstein and/or Maxwell. + +## The Peter Nygard Investigation + +- 1. The history and nature of Prince Andrew's relationship with Peter Nygard. +- 2. The details regarding any trips Prince Andrew took with and/or to visit Nygard. +- 3. The details of any trips Prince Andrew took to Nygard Cay, whether or not Nygard was present. +- 4. The names and/or descriptions of any females Prince Andrew met through Nygard or at Nygard Cay. + +#### ATTACHMENT B + +#### PROFFER AGREEMENT + +With respect to the meeting of ("Client") and his attorney, Esq., with Assistant United States Attorney to be held at the Office of the United States Attorney for the Southern District of New York on [Meeting Date] ("the meeting"), the following understandings exist: + +(1) THIS IS NOT A COOPERATION AGREEMENT. The Client has agreed to provide the Government with information, and to respond to questions, so that the Government may evaluate Client's information and responses in making prosecutive decisions. By receiving Client's proffer, the Government does not agree to make a motion on the Client's behalf or to enter into a cooperation agreement, plea agreement, immunity or non-prosecution agreement. The Government makes no representation about the likelihood that any such agreement will be reached in connection with this proffer. + +(2) In any prosecution brought against Client by this Office, except as provided below the Government will not offer in evidence on its case-in-chief, or in connection with any sentencing proceeding for the purpose of determining an appropriate sentence, any statements made by Client at the meeting, except (a) in a prosecution for false statements, obstruction of justice or perjury with respect to any acts committed or statements made during or after the meeting or testimony given after the meeting; or (b) if, at any time following the meeting, Client becomes a fugitive from justice. + +(3) Notwithstanding item (2) above: (a) the Government may use information derived directly or indirectly from the meeting for the purpose of obtaining leads to other evidence, which evidence may be used in any prosecution of Client by the Government; (b) in any prosecution brought against Client, the Government may use statements made by Client at the meeting and all evidence obtained directly or indirectly therefrom for the purpose of crossexamination should Client testify; and (c) the Government may also use statements made by Client at the meeting to rebut any evidence or arguments offered by or on behalf of Client (including arguments made or issues raised sua sponte by the District Court) at any stage of the criminal prosecution (including bail, all phases of trial, and sentencing) in any prosecution brought against Client. + +(4) The Client understands and agrees that in the event the Client seeks to qualify for a reduction in sentence under Title 18, United States Code, Section 3553(0, United States Sentencing Guidelines, Sections 2D1.1(b)(18) or 5C1.2, or Fed. R. Crim. P. 35(b), the Office may offer or use at any stage of the criminal proceeding any statement made by Client during the meeting, and all evidence obtained directly or indirectly therefrom, to the extent such use is consistent with Section 402 of the First Step Act of 2018. + +(5) To the extent that the Government is entitled under this Agreement to offer in evidence any statements made by Client or leads obtained therefrom, Client shall assert no claim under the United States Constitution, any statute, Rule 410 of the Federal Rules of Evidence, or + +any other federal rule that such statements or any leads therefrom should be suppressed. It is the intent of this Agreement to waive all rights in the foregoing respects. + +(6) If this Office receives a request from another prosecutor's office for access to information obtained pursuant to this Proffer Agreement, this Office may furnish such information but will do so only on the condition that the requesting office honor the provisions of this Agreement. + +(7) It is further understood that this Agreement is limited to the statements made by Client at the meeting and does not apply to any oral, written or recorded statements made by Client at any other time. No understandings, promises, agreements and/or conditions have been entered into with respect to the meeting other than those set forth in this Agreement and none will be entered into unless in writing and signed by all parties. + +(8) The understandings set forth in paragraphs 1 through 7 above extend to the continuation of this meeting on the dates that appear below. + +(9) Client and Attorney acknowledge that they have fully discussed and understand every paragraph and clause in this Agreement and the consequences thereof. + +Dated: New York, New York + +GEOFFREY S. BERMAN United States Attorney for the Southern District of New York + +by: Client Assistant United States Attorney + +Attorney for Client Witness + +### ATTACHMENT C + +## The Jeffrey Epstein Investigation + +- I. Please provide a list of all dates of travel or visits to any of the following locations: + - a. An Epstein-owned property located at 358 El Brillo Way, Palm Beach, Florida + - b. An Epstein-owned private island known as "Little St. James," located in the U.S. Virgin Islands + - c. An Epstein-owned mansion located at 9 East 71st Street, New York, New York + - d. An Epstein-owned property known as "Zorro Ranch," located in Santa Fe, New Mexico +- 2. For any dates provided for Question 1, please provide the following information: + - a. Length of visit; + - b. The names of any other individuals who were part of the visit, including family members and security detail; + - c. The names of any other individuals who were present at the property at the time; + - d. Any related itineraries or schedules; and + - e. Whether Prince Andrew observed any females who appeared to be, or stated that they were, under the age of 18 years old, the names of any of those females, any other observations Prince Andrew made of those females or conversations Prince Andrew had or witnessed involving those females, and whether Prince Andrew himself engaged in any sexual contact involving any of those females. +- 3. Please describe the history and nature of Prince Andrew's relationship with Ghislaine Maxwell, including but not limited to how they met, how frequently they were in contact during the general time period 1994-2005, how they communicated, and when they most recently communicated. +- 4. Please describe the history and nature of Prince Andrew's relationship with Jeffrey Epstein, including but not limited to how they met, how frequently they were in contact during the general time period 1994-2005, how they communicated, and when they most recently communicated. +- 5. Please describe the history and nature of Prince Andrew's relationship with + - including but not limited to any sexual interactions between Prince Andrew and a well as the history and nature of any relationship between and Maxwell, or and Epstein. +- 6. Please identify the approximate date(s) of any oral or written communications between Ghislaine Maxwell or any other individual acting as an agent, intermediary, and/or representative for Ghislaine Maxwell and any agent, intermediary, and/or representative for Prince Andrew at any time, regarding any of the following topics: + - a. Females associated with Ghislaine Maxwell; + - b. Females Ghislaine Maxwell or her representative arranged for Prince Andrew to meet; + +- c. Females Ghislaine Maxwell or her representative arranged for other adult men to +- d. +- e. The nature of Ghislaine Maxwell's relationship with Jeffrey Epstein; +- f. Massage, massages, and/or masseuses. +- g. Any investigation into Epstein or his associates, including but not limited to any prosecutions brought by the U.S. authorities against Epstein. +- h. Any civil lawsuits threatened or brought against Prince Andrew, Maxwell, and/or their associates. +- i. Any attempts to destroy evidence, obstruct or impede ongoing investigations, or otherwise cover up criminal activity by Epstein, Maxwell, or their associates. +- j. Any payments Maxwell received or expected to receive from Epstein for attorneys' fees or otherwise. +- 7. For any communications identified in response to Question 6, please provide the following information: + - a. Contact information, including phone numbers and email addresses for Ghislaine Maxwell and/or any other individual acting as an agent, intermediary, and/or representative for Ghislaine Maxwell; + - b. Contact information, including phone numbers and email addresses for any individual acting as an agent, intermediary, and/or representative for Prince Andrew; and + - c. Subject matter of the communications. Please be as detailed as possible. In particular, please describe any communications regarding the following topics: + - i. Females associated with Ghislaine Maxwell; + - ii. Females Ghislaine Maxwell or her representative arranged for Prince Andrew to meet; + - iii. Females Ghislaine Maxwell or her representative arranged for other adult men to meet• + - iv. + - v. The nature of Ghislaine Maxwell's relationship with Jeffrey Epstein; + - vi. Massage, massages, and/or masseuses. + - vii. Any investigation into Epstein or his associates, including but not limited to any prosecutions brought by the U.S. authorities against Epstein. + - viii. Any civil lawsuits threatened or brought against Prince Andrew, Maxwell, and/or their associates. + - ix. Any attempts to destroy evidence, obstruct or impede ongoing investigations, or otherwise cover up criminal activity by Epstein, Maxwell, or their associates. + - x. Any payments Maxwell received or expected to receive from Epstein for attorneys' fees or otherwise. +- 8. Please identify the approximate date(s) of any oral or written communications between Jeffrey Epstein or any other individual acting as an agent, intermediary, and/or representative for Jeffrey Epstein and any agent, intermediary, and/or representative for Prince Andrew at any time, regarding any of the following topics: + +- a. Females associated with Jeffrey Epstein; +- b. Females Jeffrey Epstein or his representative arranged for Prince Andrew to meet; +- c. Females Jeffrey Epstein or his representative arranged for other adult men to meet. +- d. +- e. The nature of Ghislaine Maxwell's relationship with Jeffrey Epstein; +- f. Massage, massages, and/or masseuses. +- g. Any investigation into Epstein or his associates, including but not limited to any prosecutions brought by the U.S. authorities against Epstein. +- h. Any civil lawsuits threatened or brought against Epstein and/or his associates. +- i. Any attempts to destroy evidence, obstruct or impede ongoing investigations, or otherwise cover up criminal activity by Epstein, Maxwell, or their associates. +- j. Any payments Epstein made or intended to make to Maxwell for attorneys' fees or otherwise. + +9. For any communications identified in response to Question 8, please provide the following information: + +- a. Contact information, including phone numbers and email addresses for Jeffrey Epstein and/or any other individual acting as an agent, intermediary, and/or representative for Jeffrey Epstein; +- b. Contact information, including phone numbers and email addresses for any individual acting as an agent, intermediary, and/or representative for Prince Andrew; and +- c. Subject matter of the communications. Please be as detailed as possible. In particular, please describe any communications regarding the following topics: + - i. Females associated with Jeffrey Epstein; + - ii. Females Jeffrey Epstein or his representative arranged for Prince Andrew to meet; + - iii. Females Jeffrey Epstein or his representative arranged for other adult men to meet- + - iv. • + - v. The nature of Ghislaine Maxwell's relationship with Jeffrey Epstein; + - vi. Massage, massages, and/or masseuses. + - vii. Any investigation into Epstein or his associates, including but not limited to any prosecutions brought by the U.S. authorities against Epstein. + - viii. Any civil lawsuits threatened or brought against Epstein and/or his associates. + - ix. Any attempts to destroy evidence, obstruct or impede ongoing investigations, or otherwise cover up criminal activity by Epstein, Maxwell, or their associates. + - x. Any payments Epstein made or intended to make to Maxwell for attorneys' fees or otherwise. + +10. Please identif the a roximate date(s) of any oral or written communications between or any other individual acting as an agent, intermediary, and/or representative for and any agent, intermediary, and/or representative for Prince Andrew + +- 11. For any communications identified in response to Question 10, please provide the following information: + - a. Contact information, including phone numbers and email addresses for and/or a h r individu as an agent, intermediary, and/or representative for + - b. Contact information, including phone numbers and email addresses for any individual acting as an agent, intermediary, and/or representative for Prince Andrew; and + - c. Subject matter of the communications. + - d. Nature of Prince Andrew's interactions with +- 12. Please identify the a roximatel dates and locations of any meetings or other interactions with including the nature and/or purpose of the meeting, the approximate duration of the meeting, the name(s) of any other persons present for the meeting, and a detailed account of what occurred at the meeting. +- 13. Please identify any payments made, in any form including by cash or in kind, to Prince Andrew by Ghislaine Maxwell or any other individual acting as an agent, intermediary, and/or representative for Ghislaine Maxwell. Please include travel, lodging, or other expenses paid in connection with any trip to visit Ghislaine Maxwell. +- 14. Please identify any payments made, in any form including by cash or in kind, to Ghislaine Maxwell or any other individual acting as an agent, intermediary, and/or representative for Ghislaine Maxwell from or on behalf of Prince Andrew. +- 15. Please identify any payments made, in any form including by cash or in kind, to Prince Andrew by Jeffrey Epstein or any other individual acting as an agent, intermediary, and/or representative for Jeffrey Epstein. Please include travel, lodging, or other expenses paid in connection with any trip to visit Jeffrey Epstein. +- 16. Please identify any payments made, in any form including by cash or in kind, to Jeffrey Epstein or any other individual acting as an agent, intermediary, and/or representative for Jeffrey Epstein well from or on behalf of Prince Andrew. +- 17. Please identif any payments made, in any form including by cash or in kind, to or an other individual acting as an agent, intermediary, and/or representative for well from or on behalf of Prince Andrew. +- 18. Please identify any payments made, in any form including by cash or in kind, to any female Prince Andrew met through Ghislaine Maxwell and/or Jeffrey Epstein, or any other individual acting as an agent, intermediary, and/or representative for any such female from or on behalf of Prince Andrew. + +- 19. Please identify any sexual encounters and/or romantic relationships involving Prince Andrew and any female he met through Maxwell and/or Epstein. In particular, please describe how Prince Andrew met any such female and detail any communications Prince Andrew had regarding any such female with Maxwell, Epstein, and/or any associates of Maxwell and/or Epstein. +- 20. Please provide any information, based on, among other things, any of the interactions or communications responsive to any question above, about the involvement of Jeffrey Epstein and/or any associate of Epstein's in recruiting, enticing, transporting or trafficking minors for the purpose of engaging in unlawful sexual contact. + +# The Peter Nygard Investigation + +- I. Please provide a list of all dates of travel or visits to any of the following locations: + - a. Nygard Cay, Bahamas + - b. Lyford Cay, Bahamas + - c. I Yawl Street, Marina Del Rey, CA + - d. 17 Yawl Street, Marina Del Rey, CA + - e. 1435 Broadway, New York, New York +- 2. For any dates provided for Question 1, please provide the following information: + - a. Length of visit; + - b. The names of any other individuals in party, including family members and security detail; + - c. The names of any other individuals who were present at the property at the time; + - d. Any related itineraries or schedules; and + - e. Whether Prince Andrew observed any females who appeared to be, or stated that they were, under the age of 18 years old, and the names of any of those females. +- 3. Please identify the approximate date(s) of any oral or written communications between Peter Nygard or any other individual acting as an agent, intermediary, and/or representative for Peter Nygard and any agent, intermediary, and/or representative for Prince Andrew. +- 4. For any communications identified in response to Question 3, please provide the following information: + - a. Contact information, including phone numbers and email addresses for Peter Nygard and/or any other individual acting as an agent, intermediary, and/or representative for Peter Nygard; + - b. Contact information, including phone numbers and email addresses for any individual acting as an agent, intermediary, and/or representative for Prince Andrew; and + - c. Subject matter of the communications. Please be as detailed as possible. +- 5. Please identify any payments made, in any form including by cash or in kind, to Prince Andrew by Peter Nygard or any other individual acting as an agent, intermediary, and/or + +representative for Peter Nygard. Please include travel, lodging, or other expenses paid in connection with any visit to Nygard Cay, Bahamas. + +- 6. 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b/marker2/ds9/EFTA00087994/_page_0_Picture_0.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:eb50c84a52c82fe77818b36c3c2757e3340ca1ef4b6cd59e36c29f3ecac788e1 +size 4390 diff --git a/marker2/ds9/EFTA00088016/EFTA00088016.md b/marker2/ds9/EFTA00088016/EFTA00088016.md new file mode 100644 index 0000000000000000000000000000000000000000..c1077264c1619e4f79a404d75070aca4f20bf75a --- /dev/null +++ b/marker2/ds9/EFTA00088016/EFTA00088016.md @@ -0,0 +1,79 @@ +From: " To:" "i Cc:" "C + +Subject: RE: Material Witness PA + +Date: Thu, 18 Jun 2020 14:04:17 +0000 + +Thanks, =. We will inquire of the Nygard team and report back. Since I know I will be asked here, is it standard protocol for the Home Office to demand more predication where, as here, we already plan to proceed with an interview on one subject for which the facts are not thin? Put differently, it would strike us as fairly common place to question a witness about anything and everything of interest if you're bringing him in, so assuming they agree (as they seem to) that we are predicated to question on Epstein, it seems unusual to not permit us to also ask a few questions about Nygard, even if our facts in that investigation are not as fully developed right now. + +From: Sent: Thursday, June 18, 2020 8:58 AM To: Cc: Subject: FW Material Witness PA + +Here is my email and the UKCA response. I also had a conversation with Dawn Browne about this to discuss the way forward. + +Just as a reminder, they are waiting on any additional information you have on If we have given them all we have, then we can just say this. They think the facts on that matter are pretty thin. + +With regard to the voluntary interview issue, Dawn explained in more detail why they have been looking for us to exhaust all avenues for voluntary cooperation. They expect that once they approve the MLA and refer it to the police that the Blackfords will file a judicial review action. In that action, they believe Blackfords will claim that the Home Office failed to follow its internal guidelines on reserving MLA assistance to those instances in which voluntary cooperation is not possible. Blackfords will argue that since they have offered voluntary cooperation as recently as early June, the Home Office failed to properly apply its internal guidelines, and the court should direct the Home Office to vacate its approval of the MLA request and send it back to the US to engage on a voluntary basis with the Prince's team. + +I pushed back quite hard on this, saying that while it might generally be Home Office practice and policy to provide assistance on police to police basis in the first instance, there is nothing in our MLA treaty which requires this. I also noted that the US routinely assists the UK via the MLA process with cooperative witnesses in the US - we do so by setting up witness testimony via video link, by obtaining witness statements of individuals who have never been approached by UK law enforcement, by seeking documents from individuals who may be fully cooperative, etc. + +I indicated to Dawn that if there is now a requirement that we exhaust all informal avenues before sending an MLA request, that conflicts with our treaty and would affect many UK and US cases going + +She responded by saying that they were just preparing for what they anticipate will be inevitable judicial review litigation in this matter, and wanted to eliminate any argument, even if not compelling, that there remains an avenue for voluntary cooperation. The Prince's team think this argument must have some purchase because they told the Home Office several months ago that they were willing to voluntarily assist, and then again sent a letter after learning of the MLA request. + +One thing we talked about was the back and forth between Blackfords and you in June. I said we were somewhat concerned about sharing that correspondence with them because of the inevitable claim that Blackfords would say we again breached their confidence. How do you feel about sharing that correspondence with the UKCA and/or informing Blackfords that you are doing so? + +Thx, + +From: Creffield Philomena Sent: Thursday, June 18, 202011:15 AM To: Margaret Cc: Chadwick, Amanda J (London) Subject: RE: Material Witness PA : Gibbs Julian ; Browne + +Thanks + +I appreciate you setting out the position regarding the merits of continuing down the non MIA route. + +As you know there is further work required and Dawn will continue to liaise with the US prosecution team. The next mile stone appears to be settling the position on the second investigation. Hopefully that can be reached relatively quickly. + +As the US Attorney General and the Home Secretary as keen to meet in person, we may yet see each other in person. + +All the best Philomena + +Philomena Creffield Deputy Director & Head of UK Central Authority International Directorate I BICS Policy & International Group Home Office I 2nd Floor, Peel Building, 2 Marsham Street I London SW1P 4DF I mob: + +Delivering Judicial Cooperation Globally + +From: Sent: 18 June 2020 10:59 To: Creffield Philomena Gibbs Julian Browne Margaret Cc: Chadwick, Amanda J (London) Subject: Material Witness PA + +Thank you for taking the time to speak with us about the status of our MLA request in the Material Witness PA matter. You asked that we confer and then get back to you on an appropriate timeline for the completion of any discussions with counsel for a voluntary interview. The case team and I have had an opportunity to discuss this, and I have now had an opportunity to review the correspondence between the team and Gary Bloxsome beginning in January 2020. + +Having reviewed this, it is plain to me that there has developed a significant mutual lack of trust between the case team and Blackfords. As a result, the possibility of a voluntary interview, done outside the context of the MLA request, is effectively nil. The case team believes, and I agree, that delaying the execution of the MLA request in the hope that Blackfords changes its position on a voluntary interview, will simply be an exercise in futility. + +That is not to say that the witness will continue to decline an interview once requested by UK law enforcement in connection with an MLA request. Mr. Bloxsome has repeatedly stated, although without committing to any particular step, that his client is willing to assist the investigation. While there is some reason to question whether these claims are simply posturing, it may be that offering an interview in the context of a more formal request provides a more agreeable forum and structure for the witness. Moreover, in that context, the UKCA and UK law enforcement will see whether the witness will in fact answer questions about the crimes under investigation. As you will recall, the MLA request suggests that the initial approach by UK law enforcement be one for a consensual interview rather than testimony before a UK court. Our hope is that your experience is better than the case team's. + +In short, efforts to obtain a truly voluntary interview have been exhausted. The case team has yet to see any commitment from Blackfords to making their client available to be questioned by law enforcement. We again request that the UKCA move forward without further delay. + +Finally, my intention was to share with you the written correspondence from Blackfords in February which states in no uncertain terms that, "there is no purpose to be served in continuing to try to assist further." However, Blackfords requested that communication to be "private and confidential," and if we were to share its entirety with you, I am certain that we would be criticized for breaching a requested confidence. + +Many thanks for your ongoing assistance in this matter. + +Best, + +![](_page_2_Picture_8.jpeg) + +![](_page_2_Picture_9.jpeg) + +U.S. Department of Justice Attaché United States Embassy - London + +![](_page_2_Picture_11.jpeg) + +![](_page_2_Picture_12.jpeg) + +![](_page_2_Picture_13.jpeg) + +This email has been scanned by the Symantec Email Security.cloud service. + +For more information please visit http://www.symanteccloud.com + +This email and any files transmitted with it are private and intended solely for the use of the individual or entity to whom they are addressed. + +If you have received this email in error please return it to the address it came from telling them it is not for you and then delete it from your system. + +This email message has been swept for 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b/marker2/ds9/EFTA00088020/EFTA00088020.md @@ -0,0 +1,97 @@ +From: + +Subject: RE: Material Witness PA Date: Thu, 18 Jun 2020 13:10:08 +0000 + +Can you discuss with the attache whether that is a normal approach (refusing to proceed because lack of predication)? All we want to do is ask some questions — do they really refuse to permit that, in an interview that would be happening regardless? Also, before doing that, someone should go back to the Nygaard team and confirm that there is nothing more to say. (I don't have the specifics of what we've already said, so I can't do it — but if you want me to handle let me know.) + +From: + +Sent: Thursday, June 18, 2020 9:02 AM + +To: + +Subject: FW: Material Witness PA + +See below on the MLAT. The only issue for you is the Nygard one I raised briefly earlier this week — the Home Office doesn't think we're predicated on Nygard, and unless we provide further specifics about Andrew's knowledge of or involvement in criminal conduct in that case, they are not going to process that aspect of the MLAT. I take it from our conversation that there is no more info to provide. If so, can we tell them we are withdrawing our request as it pertains to Nygard and only asking them to proceed on Epstein? + +From: + +Sent: Thursday, June 18, 2020 8:58 AM + +To: + +Cc: + +Subject: FW: Material Witness PA + +Here is my email and the UKCA response. I also had a conversation with Dawn Browne about this to discuss the way forward. + +Just as a reminder, they are waiting on any additional information you have on Nygard. If we have given them all we have, then we can just say this. They think the facts on that matter are pretty thin. + +With regard to the voluntary interview issue, Dawn explained in more detail why they have been looking for us to exhaust all avenues for voluntary cooperation. They expect that once they approve the MLA and refer it to the police that the Blackfords will file a judicial review action. In that action, they believe Blackfords will claim that the Home Office failed to follow its internal guidelines on reserving MLA assistance to those instances in which voluntary cooperation is not possible. Blackfords will argue that since they have offered voluntary cooperation as recently as early June, the Home Office failed to properly apply its internal guidelines, and the court should direct the Home Office to vacate its approval of the MLA request and send it back to the US to engage on a voluntary basis with the Prince's team. + +I pushed back quite hard on this, saying that while it might generally be Home Office practice and policy to provide assistance on police to police basis in the first instance, there is nothing in our MLA treaty which requires this. I also noted that the US routinely assists the UK via the MLA process with cooperative witnesses in the US - we do so by setting up witness testimony via video link, by obtaining witness statements of individuals who have never been approached by UK law enforcement, by seeking documents from individuals who may be fully cooperative, etc. + +I indicated to Dawn that if there is now a requirement that we exhaust all informal avenues before sending an MLA request, that conflicts with our treaty and would affect many UK and US cases going forward. I also indicated that this would get raised up the US and UK chains very quickly. + +She responded by saying that they were just preparing for what they anticipate will be inevitable judicial review litigation in this matter, and wanted to eliminate any argument, even if not compelling, that there remains an avenue for voluntary cooperation. The Prince's team think this argument must have some purchase because they told the Home Office several months ago that they were willing to voluntarily assist, and then again sent a letter after learning of the MLA request. + +One thing we talked about was the back and forth between Blackfords and you in June. I said we were somewhat concerned about sharing that correspondence with them because of the inevitable claim that Blackfords would say we again breathed their confidence. How do you feel about sharing that correspondence with the UKCA and/or informing Blackfords that you are doing so? + +Thx, + +From: Creffield Philomena + +Sent: Thursday, June 18, 2020 11:15 AM + +To: M=M 1'; Gibbs Julian ''t ; Browne Margaret ‹ &gt; + +Cc: Chadwick, Amanda J (London) + +Subject: RE: Material Witness PA + +Thanks MI + +I appreciate you setting out the position regarding the merits of continuing down the non MIA route. + +As you know there is further work required and Dawn will continue to liaise with the US prosecution team. The next mile stone appears to be settling the position on the second investigation. Hopefully that can be reached relatively quickly. + +As the US Attorney General and the Home Secretary as keen to meet in person, we may yet see each other in person. + +All the best + +Philomena + +Philomena Creffield I Deputy Director & Head of UK Central Authority I International Directorate I 8ICS Policy & International Group + +Home Office I I London SW1P 4DF I mob: + +From: Sent: 18 June 2020 10:59 To: Creffield Philomena < >; Gibbs Julian Browne Margaret ‹ > Cc: Chadwick, Amanda J (London) ‹ > Subject: Material Witness PA + +Dear Philomena, Julian, and Dawn: + +Thank you for taking the time to speak with us about the status of our MLA request in the Material Witness PA matter. You asked that we confer and then get back to you on an appropriate timeline for the completion of any discussions with counsel for a voluntary interview. The case team and I have had an opportunity to discuss this, and I have now had an opportunity to review the correspondence between the team and Gary Bloxsome beginning in January 2020. + +Having reviewed this, it is plain to me that there has developed a significant mutual lack of trust between the case team and Blackfords. As a result, the possibility of a voluntary interview, done outside the context of the MLA request, is effectively nil. The case team believes, and I agree, that delaying the execution of the MLA request in the hope that Blackfords changes its position on a voluntary interview, will simply be an exercise in futility. + +That is not to say that the witness will continue to decline an interview once requested by UK law enforcement in connection with an MLA request. Mr. Bloxsome has repeatedly stated, although without committing to any particular step, that his client is willing to assist the investigation. While there is some reason to question whether these claims are simply posturing, it may be that offering an interview in the context of a more formal request provides a more agreeable forum and structure for the witness. Moreover, in that context, the UKCA and UK law enforcement will see whether the witness will in fact answer questions about the crimes under investigation. As you will recall, the MLA request suggests that the initial approach by UK law enforcement be one for a consensual interview rather than testimony before a UK court. Our hope is that your experience is better than the case team's. + +In short, efforts to obtain a truly voluntary interview have been exhausted. The case team has yet to see any commitment from Blackfords to making their client available to be questioned by law enforcement. We again request that the UKCA move forward without further delay. + +Finally, my intention was to share with you the written correspondence from Blackfords in February which states in no uncertain terms that, "there is no purpose to be served in continuing to try to assist further." However, Blackfords requested that communication to be "private and confidential," and if we were to share its entirety with you, I am certain that we would be criticized for breaching a requested confidence. + +Many thanks for your ongoing assistance in this matter. + +![](_page_3_Picture_0.jpeg) + +U.S. Department of Justice Attaché United States Embassy - London + +This email has been scanned by the Symantec Email Security.cloud service. + +For more information please visit http://www.symanteccloud.com + +This email and any files transmitted with it are private and intended solely for the use of the individual or entity to whom they are addressed. + +If you have received this email in error please return it to the address it came from telling them it is not for you and then delete it from your system. + +This email message has been swept for computer viruses. \ No newline at end of file diff --git a/marker2/ds9/EFTA00088020/EFTA00088020.metadata.json b/marker2/ds9/EFTA00088020/EFTA00088020.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..dff29b175b50531e59281e4cffb837cba8308cde --- /dev/null +++ b/marker2/ds9/EFTA00088020/EFTA00088020.metadata.json @@ -0,0 +1,150 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00088020.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 4, + "chars": 8379, + "elapsed_seconds": 1.32, + "image_assets": [ + "_page_3_Picture_0.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 69 + ], + [ + "Line", + 35 + ], + [ + "Text", + 17 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 78 + ], + [ + "Line", + 36 + ], + [ + "Text", + 20 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 81 + ], + [ + "Line", + 38 + ], + [ + "Text", + 9 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 3, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 20 + ], + [ + "Text", + 13 + ], + [ + "Line", + 10 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00088020" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00088020/_page_3_Picture_0.jpeg b/marker2/ds9/EFTA00088020/_page_3_Picture_0.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..167d5d40bacb8137a8dc4860e004038dedbf2dac --- /dev/null +++ b/marker2/ds9/EFTA00088020/_page_3_Picture_0.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:24c908a7da300d40580bd02293ee2df2474fd524c6e8bce7ae24de861573b94f +size 1069 diff --git a/marker2/ds9/EFTA00088026/EFTA00088026.md b/marker2/ds9/EFTA00088026/EFTA00088026.md new file mode 100644 index 0000000000000000000000000000000000000000..13da20d532750e27699848d124c43542c6fa2366 --- /dev/null +++ b/marker2/ds9/EFTA00088026/EFTA00088026.md @@ -0,0 +1,43 @@ +**To:** Karas NYSD Chambers <[REDACTED]> + +**Cc:** Michael Bachrach <[REDACTED]>, Dawn Bordes + +<[REDACTED]>, <[REDACTED]>, <[REDACTED]>, + +<[REDACTED]>, John Diaz <[REDACTED]>, + +<[REDACTED]>, Aida Leisenring + +<[REDACTED]>, "[REDACTED]" + +<[REDACTED]>, + +**Subject:** Re: Scheduling Order (ex parte/under seal) + +**Date:** Wed, 22 Jul 2020 09:16:48 +0000 + +--- + +Received. Thank you. I hope everyone is healthy. + +Bruce A. Barket + +Barket, Epstein, Kearon, Aldea & LoTurco + +[REDACTED] + +Garden City, NY [REDACTED] + +Barketepstein.com + +[REDACTED] + +On Jul 21, 2020, at 6:16 PM, Karas NYSD Chambers <[REDACTED]> wrote: + +Dear Counsel, + +Attached, please find a scheduling order from Judge Karas concerning the *Curcio* proceeding that will take place on July 29, 2020. + +-Chambers of Judge Karas + + \ No newline at end of file diff --git a/marker2/ds9/EFTA00088026/EFTA00088026.metadata.json b/marker2/ds9/EFTA00088026/EFTA00088026.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..7e1660ce32068dbcfe6ac02214d7c90b04c2622c --- /dev/null +++ b/marker2/ds9/EFTA00088026/EFTA00088026.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00088026.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 803, + "elapsed_seconds": 4.83, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 45 + ], + [ + "Span", + 38 + ], + [ + "Line", + 19 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00088026" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00088027/EFTA00088027.md b/marker2/ds9/EFTA00088027/EFTA00088027.md new file mode 100644 index 0000000000000000000000000000000000000000..d1512c52f2d3b68565365e2d7465aae07f64d91e --- /dev/null +++ b/marker2/ds9/EFTA00088027/EFTA00088027.md @@ -0,0 +1,50 @@ +From: "[REDACTED] (USANYS)" <[REDACTED]> +To: "[REDACTED] (USANYS)" <[REDACTED]> +Subject: FW: PRESS CLIPS 7-24-2020 +Date: Fri, 24 Jul 2020 17:03:04 +0000 +Inline-Images: Press\_Clips\_Header\_7.24.20.png + +--- + +Also, any chance you can send me the Sadr article from Law.com? I'm not a subscriber. + +--- + +From: [REDACTED] (USANYS) <[REDACTED]> +Sent: Friday, July 24, 2020 12:51 PM +To: [REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +Subject: PRESS CLIPS 7-24-2020 + +![](_page_0_Picture_30.jpeg) + +## SDNY PRESS CLIPPINGS + +JULY 24, 2020 + +### GLOBAL ENTRY + +Yahoo: + +The Hill: + +### MICHAEL COHEN + + + +### WIRECARD + +Reuters: + +### MAXWELL + +ABC: + +The Hill: + +### MATTERS OF INTEREST + +LAW.COM: \ No newline at end of file diff --git a/marker2/ds9/EFTA00088027/EFTA00088027.metadata.json b/marker2/ds9/EFTA00088027/EFTA00088027.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..6c7cd04261660773abf492fb238d8300caf3a922 --- /dev/null +++ b/marker2/ds9/EFTA00088027/EFTA00088027.metadata.json @@ -0,0 +1,195 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00088027.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + 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[Contractor]" + +Subject: Law360 + +Date: Thu, 11 Feb 2021 12:27:36 +0000 + +## 3 Names To Watch As Biden Mulls Next SDNY Top Prosecutor + +By Pete Brush + +Sent from my iPhone + +Share us on: + +Law360, New York (February 10, 2021, 5:41 PM EST) -- President Joe Biden is ramping up the process of choosing new top federal prosecutors across the country, and while he may not rush to replace Manhattan U.S. Attorney Audrey Strauss, lawyers have their eye on a handful of her potential successors. + +The application process to helm the U.S. Attorney's Office for the Southern District of New York, a process that court-watchers say is active and includes a large pool of candidates, comes as the Biden administration begins the work of replacing U.S. attorneys appointed by former President Donald Trump, who have all been asked to step down. + +But the president may not hurry to replace Strauss, who in December was formally appointed as U.S. attorney by federal judges amid the chaos of the outgoing Trump administration. + +Strauss, who of late has brought high-profile cases including sex-abuse charges against + +Jeffrey Epstein associate Ghislaine Maxwelland ex-fashion executive Peter Nygard, is well-regarded, and her presence leaves the White House the luxury of taking its time on SDNY if it wishes to prioritize dozens of other districts across the country. + +"She has a stellar reputation inside and outside the office," Pace Law School professor Bennett L. Gershman said of Strauss. + +Nevertheless the application process is underway in the Southern District, sources said, with Senate Majority Leader Chuck Schumer, D-N.Y., holding powerful sway over the process. Asked to handicap top possible successors, lawyers named three people: + +Damian Williams + +Damian Williams is a veteran SDNY prosecutor who heads the district's Securities and Commodities Fraud Task Force. He prosecuted former politicians Sheldon Silver and Chris Collins in recent years, and is widely regarded as a steadying presence inside the halls at 1 St. Andrew's Plaza. + +Williams, who would be the first Black person to head the office, is a former law clerk for D.C. Circuit Judge Merrick B. Garland, Biden's nominee for attorney general who is slated for a Feb. 22 confirmation hearing in the Senate. + +The Garland clerk chain, dozens strong, could be fertile ground for possible picks, lawyers said, on the theory that a pre-existing relationship with the man who likely will lead Biden's Department of Justice could be valuable. + +Katherine Goldstein + +A white collar partner at Akin Gump Strauss Hauer & Feld LLP, Katherine Goldstein is a former SDNY Securities and Commodities Fraud Task Force chief with a sharp legal mindwho has worked on modernizing and improving insider trading enforcement. She has handled a number of high-profile white collar fraud cases. + +After Strauss and Mary Jo White, who held the post from 1993 until 2002, Goldstein would be the third woman to take the job in its more-than 200 year history, if confirmed. + +Anjan Sahni + +Like Williams and Goldstein, Anjan Sahni, a WilmerHale white collar partner, is a former SDNY Securities and Commodities Fraud Task Force chief. + +Sahni, who is of South Asian descent, also is noted for his work on a defense team that won acquittal for Citigroup trader Rohan Ramchandani in a closely-watched forexrigging criminal trial. + +Williams, Goldstein and Sahni are all said to be friendly with, and have professional ties to, former Manhattan U.S. Attorney Preet Bharara, who was fired by the Trump + +administration in 2017. Sources said Bharara has a direct line to Schumer as the application process unfolds. + +--Editing by Jill Coffey. \ No newline at end of file diff --git a/marker2/ds9/EFTA00088028/EFTA00088028.metadata.json b/marker2/ds9/EFTA00088028/EFTA00088028.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..89a24650865178821deb301c2987b75374dca428 --- /dev/null +++ b/marker2/ds9/EFTA00088028/EFTA00088028.metadata.json @@ -0,0 +1,172 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00088028.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 4, + "chars": 3708, + "elapsed_seconds": 0.93, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "3 Names To Watch As Biden Mulls Next SDNY Top Prosecutor", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 41.61600000000001, + 165.24 + ], + [ + 546.7833251953125, + 165.24 + ], + [ + 546.7833251953125, + 187.08349609375 + ], + [ + 41.61600000000001, + 187.08349609375 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 68 + ], + [ + "Line", + 33 + ], + [ + "Text", + 13 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 65 + ], + [ + "Line", + 33 + ], + [ + "Text", + 7 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 62 + ], + [ + "Line", + 32 + ], + [ + "Text", + 8 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 3, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 9 + ], + [ + "Line", + 5 + ], + [ + "Text", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00088028" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00088032/EFTA00088032.md b/marker2/ds9/EFTA00088032/EFTA00088032.md new file mode 100644 index 0000000000000000000000000000000000000000..60b9038deb1e136950f67654bab37fb8caaf5e3c --- /dev/null +++ b/marker2/ds9/EFTA00088032/EFTA00088032.md @@ -0,0 +1,93 @@ +UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA, + +-against- + +TOVA NOEL and MICHAEL THOMAS, + +Defendants. + +USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC #: DATE FILED: 6/9/2020 + +19 Cr. 830-2 (AT) + +#### ORDER + +ANALISA TORRES, District Judge: + +On November 19, 2019, Defendant Michael Thomas was charged with one count of conspiring to defraud the United States in violation of 18 U.S.C. § 371, and three counts of making false statements with the intent to impede, obstruct, or influence the investigation or proper administration of a matter within the jurisdiction of a department or agency of the United States in violation of 18 U.S.C. § 1001(aX3). ECF No. 1. The indictment alleges that Thomas, in his capacity as a correctional officer at the Metropolitan Correctional Center (the "MCC"), along with another officer, co-Defendant Tova Noel, submitted several false "count slips" on the night of August 9, 2019 and the morning of August 10, 2019, certifying that he conducted counts of the inmates he was supervising in the MCC's Special Housing Unit ("SHU"), even though he did not conduct those counts. Id. ¶¶ 16, 30, 36, 38, 40. During that time period, one of the inmates in the SHU—Jeffrey Epstein—hanged himself in his cell. Id. ¶q 1, 26-27. + +Thomas now moves to compel the Government to produce evidence in connection with the trial scheduled to begin on January 4, 2021. Motion, ECF No. 33. Thomas seeks three categories of information: (1) "[t]re report of the Inspector General" for the United States Department of Justice related to Epstein's death, and "any and all supplemental memorandums, written statements, photos, videos, and incident reports" obtained by the Inspector General's investigation, id, at 5; (2) "[a]ly and all internal investigative reports created by the [Bureau of + +Prisons (the "BOP")] as to both [D]efendants, including[] any and all supporting memorandums, written statements, photos, videos, and incident reports," id. at 6; and (3) "any and all reports, memorandums, written statements, photos, videos, and incident reports created, manufactured, or possessed by any investigative or disciplinary agencies[] participating in the investigation of the [D]efendants, allied with the prosecution, and to which the prosecution has access," id. at 7. + +For the reasons stated below, Thomas' motion is DENIED. + +## DISCUSSION + +The Government has already produced "surveillance video going back to July 5, 2019 ... ; count slips, thirty minute round forms, and staffing rosters for the three-week period surrounding Epstein's suicide; internal MCC phone records; employee files and staffing history for Noel and Thomas; and a wide range of written [BOP] policies and regulations," as well as "statements for all of the witnesses interviewed during the investigation." Gov't Opp. at 8-9, ECF No. 35. + +Thomas argues that he is entitled to additional discovery on two grounds: (1) Rule 16 of the Federal Rules of Criminal Procedure, and (2) the constitutional guarantee of due process as expressed by the Supreme Court's decisions in Brady v. Maryland, 373 U.S. 83 (1963), and Giglio v. United States, 405 U.S. 150 (1972). Motion at 1. + +## I. Legal Standards + +### A. Rule 16 + +Rule 16 requires the Government to "permit the defendant to inspect and to copy or photograph books, papers, documents, data, photographs, tangible objects, buildings or places, or copies or portions of any of these items, if the item is within the government's possession, + +custody, or control and: (i) the item is material to preparing the defense; (ii) the [G]ovemment intends to use the item in its case-in-chief at trial; or (iii) the item was obtained from or belongs to the defendant." Fed. R. Crim. P. 16(a)(1)(E). "Evidence is material if it could be used to counter the [G]overnment's case or to bolster a defense." United States v. Ulbricht, 858 F.3d 71, 109 (2d Cir. 2017) (internal quotation marks and citation omitted), abrogated on other grounds by Carpenter v. United States, 138 S. Ct. 2206 (2018). "In order to compel the Government to produce certain evidence, a defendant must make a prima facie showing of materiality, and must offer more than the conclusory allegation that the requested evidence is material." United States v. Abdalla, 317 F. Supp. 3d 786, 790 (S.D.N.Y. 2018) (internal quotation marks and citation omitted). "There must be some indication that the pretrial disclosure of the disputed evidence would enable the defendant significantly to alter the quantum of proof in his favor." United States v. Urena, 989 F. Supp. 2d 253, 261 (S.D.N.Y. 2013) (internal quotation marks, citation, and alterations omitted). + +Evidence is "within the [G]ovemment's possession, custody, or control" if "(1) it has actually reviewed [the evidence], or (2) [the evidence is] in the possession, custody, or control of a government agency so closely aligned with the prosecution so as to be considered part of the prosecution team." United States v. Finnerty, 411 F. Supp. 2d 428, 432 (S.D.N.Y. 2006). "Legal ownership of the requested documents or things is not determinative, nor is actual possession necessary if the party has control of the items. Control has been defined to include the legal right to obtain the documents requested upon demand. The term `control' is broadly construed." United States v. Stein, 488 F. Supp. 2d 350, 361 (S.D.N.Y. 2007) (internal quotation marks and citation omitted) (collecting cases). + +If the Government represents that it "it has fully complied with [its Rule 16] obligations and will continue to do so," the defendant must put forward some "compelling demonstration to the contrary" by pointing to a "specific failure by the Government to comply with its disclosure obligations" in order to justify a motion to compel. United States v. Minaya, 395 F. Supp. 2d 28, 34 (S.D.N.Y. 2005). + +#### B. BradylGiglio + +Under the Supreme Court's decision in Brady v. Maryland, the Government "has a constitutional duty to disclose evidence favorable to an accused when such evidence is material to guilt or punishment," and as elaborated in Giglio v. United States, that obligation extends to "not only exculpatory material, but also information that could be used to impeach a key [G]ovemment witness." United States v. Coppa, 267 F.3d 132, 135 (2d Cir. 2001). "Evidence is material within the meaning of Brady when there is a reasonable probability that, had the evidence been disclosed, the result of the proceeding would have been different." Turner v. United States, 137 S. Ct. 1885, 1893 (2017) (internal quotation marks, citations, and alteration omitted)); see also Coppa, 267 F.3d at 135 ("[T]he prosecutor must disclose evidence if, without such disclosure, a reasonable probability will exist that the outcome of a trial in which the evidence had been disclosed would have been different."). + +"The prosecution's obligation to disclose Brady material extends to any material in the possession of any entity that has acted as an `arm of the prosecutor' in a given case." United States v. Middendorf, No. 18 Cr. 36, 2018 WL 3956494, at '4 (S.D.N.Y. Aug. 17, 2018) (quoting United States v. Blaszczak, 308 F. Supp. 3d 736, 741 (S.D.N.Y. 2018)). "A prosecutor's duty to review documents in the possession, custody, or control of another agency + +arises where the Government conducts a joint investigation with another agency." United States v. Collins, 409 F. Supp. 3d 228, 239 (S.D.N.Y. 2019) (internal quotation marks and citation omitted). In determining whether the prosecution has conducted a joint investigation, courts in this district look to a number of non-exhaustive factors, "including whether the other agency: (1) participated in the prosecution's witness interviews, (2) was involved in presenting the case to the grand jury, (3) reviewed documents gathered by or shared documents with the prosecution, (4) played a role in the development of prosecutorial strategy, or (5) accompanied the prosecution to court proceedings." Id. (internal quotation marks and citation omitted). + +As under Rule 16, if the Government has represented that it is aware of and has complied with its Brady and Giglio obligations, a defendant must make a "particularized showing that materials exist requiring disclosure" in order to sustain a motion to compel. United States v. Juliano, No. 99 Cr. 1197, 2000 WL 640644, at \*2 (S.D.N.Y. May 18, 2000); see United States v. Evanclzik, 413 F.2d 950, 953 (2d Cir. 1969) ("[T]he assurance by the [G]overnment that it has in its possession no undisclosed evidence that would tend to exculpate defendant justifies the denial of a motion for inspection that does not make some particularized showing of materiality and usefulness.") + +## II. Inspector General Materials + +Thomas seeks disclosure of both the investigatory materials from the Department of Justice Office of the Inspector General's ("OIG") investigation regarding Epstein's death, and a draft of the Inspector General's report arising from that investigation. Motion at 5. The Government concedes that attorneys from OIG participated in the Government's investigation that led to the indictment of Thomas. Gov't Opp. at 3, 19. But, the Government represents that it has already delivered to Thomas all of the materials gathered by OIG personnel in the course of investigating this case, and that "it is the prosecution's understanding that [OIG] attorneys have not conducted any additional interviews or otherwise discovered any potential Brady material." Id. at 23-24. Thomas has not identified any specific material that might be in OIG's possession that has not been disclosed. + +The Court, therefore, has no basis to compel the Government to disclose additional evidence underlying the Inspector General's report. "[C]ourts in this circuit have repeatedly denied requests for discovery orders where the [G]overnment represents that it has produced discovery to defendants pursuant to Rule 16 and has made a good faith representation to the defense that it recognizes and has complied with its obligations under Brady and its progeny." United States v. Garcia-Pena, No. 17 Cr. 363, 2018 WL 6985220, at \*6 (S.D.N.Y. Dec. 19, 2018) (internal quotation marks, citation, and alterations omitted); see also, e.g., United States v. Blonde:, No. 16 Cr. 387, 2019 WL 5690711, at \*5 ("[T]o the extent that these motions seek evidence pursuant to Brady [], Giglio [], and their progeny, they are [denied] on the basis of the Government's good-faith representation that it has complied with its obligations and will continue to do so." (citations omitted)); United States v. Goode, No. 16 Cr. 529, 2018 WL 919928, at \*18 (S.D.N.Y. Feb. 15, 2018) ("The Government represents that it has complied with Rule 16 obligations; the Rule 16 requests are therefore moot." (citation omitted)). + +As for the draft Inspector General's report itself, the Government reports that "attorneys from [OIG] responsible for writing the [r]eport have not yet completed a draft, and do not anticipate completing the [r]eport in the near term," and so "there are no drafts of the [r]eport to disclose." Gov't Opp. at 21-22. The Court cannot grant a motion to compel the Government to produce a report that, at the time of this order, does not exist.' + +Accordingly, Thomas' motion to compel disclosure of materials related to the Inspector General's investigation is DENIED. + +## III. BOP Materials + +Thomas also seeks disclosure of "reports generated by investigators within the [BOP] regarding" Epstein's death, and "any and all documents, reports, witness statements and disciplinary records of any and all MCC employees who have engaged in conduct" similar to that alleged against Thomas. Motion at 6. However, Thomas has adduced no evidence that the Government reviewed information arising from a BOP investigation. Nor has he shown that BOP officials "participated in the prosecution's witness interviews," were "involved in presenting the case to the grand jury," "reviewed documents gathered by or shared documents with the prosecution," "played a role in the development of prosecutorial strategy," "accompanied the prosecution to court proceedings," or in any other way played a role in the investigation that led to the charges against him. Collins, 409 F. Supp. 3d at 239 (internal quotation marks, citation, and alteration omitted). There is, therefore, no evidence that BOP personnel participated in the criminal investigation that led to Thomas' indictment. Thus, the Court concludes that the BOP was not part of the prosecution team for purposes of Rule 16 and Brady. + +To be sure, the BOP is a component of the Department of Justice, but that fact standing alone is not sufficient to make the BOP an arm of the prosecution. "The court cannot find that + +I Because the Court denies Thomas' motion on the ground that no material exists to disclose, it does not address whether the Inspector General's report might contain information material to his defense, nor whether it is protected by the deliberative process privilege. See Gov't Opp. at 12-15,22-23. + +the government is in constructive possession of the materials where, as here, defendant has not presented any evidence suggesting that the BOP was involved in the investigation or prosecution of this case." United States v. Rivera, No. 13 Cr. 149, 2015 WL 1540517, at \*3 (E.D.N.Y. Apr. 7, 2015); see, e.g., United States v. Merlin, 349 F.3d 144, 155 (3d Cir. 2003) (holding that Government did not violate Brady obligation in failing to turn over tapes in BOP possession because "the BOP was not part of the prosecutorial arm of the federal government as it was not at all involved in either the investigation or the prosecution of the defendants"); United States v. Battle, 264 F. Supp. 2d 1088, 1201-02 (N.D. Ga. 2003) ("Defendant implies that because the BOP employees are connected with the Department of Justice that the prosecution team constructively possessed exculpatory information that could have been within the knowledge of BOP staff.... Even if the Court assumes that some members of the BOP staff did possess favorable information that alone does not impute knowledge to the prosecution team." (citing United States v. Avellino, 136 F.3d 249, 255 (2d Cir. 1998)). + +Accordingly, Thomas' motion to compel the Government to disclose evidence in the possession of the BOP is DENIED. + +## IV. Other Materials + +Finally, Thomas seeks disclosure of information that he argues will tend to show that the conduct for which he is being prosecuted was: "1) rampant throughout the BOP; 2) made with knowledge and acquiescence by the leadership of the BOP; 3) made as a result of BOP policies that forced the defendant to engage in conduct for which he is now being charged criminally, and; 4) made in a manner which contains a possible discriminatory application of BOP policies by [G]overnment prosecutors." Motion at 7. But Thomas has not provided support for his + +assertion that the Government, or any other agency that has operated as an arm of the prosecution, is in possession or control of evidence that relates to the prevalence of falsifying count slips in federal correctional facilities, or BOP leadership's tolerance of such practices. + +Moreover, to the extent that Thomas is seeking discovery in support of a selective prosecution defense, he has not met the "rigorous" standard that applies for obtaining discovery in aid of such a claim. United States v. Armstrong, 517 U.S. 456, 468 (1996). "[A] defendant who seeks discovery on a claim of selective prosecution must show some evidence of both discriminatory effect and discriminatory intent." United States v. Bass, 536 U.S. 862, 863 (2002). Though Thomas claims that BOP supervisors may have acquiesced in his submission of false count slips in this case, and that other BOP employees have submitted false documents in other circumstances, he has not presented any evidence that those officers differed from him in any protected characteristic-for example, that they were of a different race, sex, or ethnicity. See Motion at 10. Nor has Thomas put forward any evidence of a discriminatory motive for his prosecution. + +Accordingly, Thomas' motion to compel the Government to disclose evidence that the submission of false count slips was widespread and tolerated at the BOP, and for discovery related to selective prosecution, is DENIED. + +# CONCLUSION + +For the reasons stated, Thomas' motion to compel is DENIED. The Clerk of Court is directed to terminate the motion at ECF No. 33. + +SO ORDERED. + +Dated: June 9, 2020 New York, New York + +ANALISA TORRES United States District Judge \ No newline at end of file diff --git a/marker2/ds9/EFTA00088032/EFTA00088032.metadata.json b/marker2/ds9/EFTA00088032/EFTA00088032.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..17ac946e363d73bd6a9a1d71b8b4d4e4c99a89a0 --- /dev/null +++ b/marker2/ds9/EFTA00088032/EFTA00088032.metadata.json @@ -0,0 +1,570 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00088032.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 9, + "chars": 16675, + "elapsed_seconds": 1.21, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "ORDER", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 441.8639999999999, + 184.68 + ], + [ + 492.7633361816406, + 184.68 + ], + [ + 492.7633361816406, + 199.10302734375 + ], + [ + 441.8639999999999, + 199.10302734375 + ] + ] + }, + { + "title": "DISCUSSION", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 266.21999999999997, + 236.51999999999998 + ], + [ + 345.26641845703125, + 236.51999999999998 + ], + [ + 345.26641845703125, + 251.60302734375 + ], + [ + 266.21999999999997, + 251.60302734375 + ] + ] + }, + { + "title": "I. 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ATT00001.htm + +We do a poor job of marketing our work:) + +Begin forwarded message: + +From: + +Date: March 5. 2020 at 5:57:52 PM EST + +To: + +# Contents + +### Public Corruption + +Epstein + +MCC + +Akparanta + +#### Securities and Commodities Fraud + +Madoff + +#### Terrorism and International Narcotics + +Schulte + +### Violent and Organized Crime + +Ray. + +Akparanta + +### Civil Rights + +Akparanta + +#### White Plains + +Nikc + +### Matters of Interest + +Weinstein + +Barr + +# Public Corruption + +Epstein + +US Virgin Islands clears way for Jeffrey Epstein victims' fund + +NY Post + +By Priscilla DeGregory + +3/4/2020 + +The US Virgin Islands attorney general plans to stand aside and allow a Jeffrey Epstein victims compensation fund to proceed, according to new court papers. + +AG says her office has reached an agreement with victims to release liens she put on the dead pedophile's assets in January, so that they can be paid through a victim compensation fund. + +"The Attorney General intends to permit the release of Estate assets to allow for just compensation of victims of Mr. Epstein through the administration of the Fund assuming that certain enhancements to the claims program are implemented," Assistant AG wrote in papers filed Tuesday in Virgin Islands Superior Court. + +Last month, a lawyer on the estate blamed George for impeding the process of paying out the women who claim they were sexually assaulted or raped by the 66-year-old multi-millionaire financier — often when they were underage. + +George's office says before the fund can start paying out, certain measures need to be implemented "to ensure fairness to all victims." + +George asked a judge to hold off on ruling on the compensation fund until Monday so that negotiations can be finalized. + +Epstein left behind a \$634 million fortune when he hanged himself in a Lower Manhattan lockup as he was awaiting trial on federal charges of sex trafficking. + +William Blum, a lawyer for the estate, said co-executors Richard Kahn and Darren Indyke hope to reach an agreement with the AG's office. + +"The co-executors of the estate of Jeffrey Epstein look forward to meeting with the representatives of the office of the Attorney General of the Virgin Islands with regard to the Epstein Voluntary Claims Resolution Program," Blum said. + +MCC + +#### Lawyers Furious, Trying to 'Raise Hell' as MCC Lockdown Enters Day 8 + +NBC + +By Jonathan Dienst + +3/5/2020 + +Numerous pre-trial inmates have moved from Metropolitan Correctional Center to Otisville as the MCC facility lockdown reaches its eighth day -- all while the search for an alleged smuggled gun continues. + +The head of the Federal Defenders Office in Manhattan said many inmates from MCC have been moved to Otisville including some who are scheduled to be in court Thursday and Friday. + +David Patton, Chief of the Federal Defenders Office, said defense lawyers still have not been able to meet with most pretrial clients for the eight days the MCC has been on lockdown. + +"Let us in to see our clients," Patton said Thursday, adding that defense attorneys are trying to "raise hell" with the MCC and through the courts to gain access to their clients. + +Investigators are focusing on whether a corrections officer at MCC helped smuggle a gun to an inmate, sources previously told News 4. + +Defense lawyers representing MCC inmates that were questioned by authorities previously said the focus appears to be on that theory, and the subsequent investigation has left them unable to see their clients. + +The MCC issued a statement Thursday saying lawyers could begin meeting with clients again starting Friday on a floor-by floor-basis. Full attorney visits could resume next week, the Bureau of Prisons statement said. + +The BOP says their officials met with the Chief Judge of the Southern District of New York, federal defenders, the U.S. Marshals and the U.S. Attorney's office to explain the ongoing issues. + +The MCC says inmates are now receiving showers on a rotating basis -- a statement Patton said is inaccurate. He claims many clients have been locked down for 24 hours a days for the last eight days. + +Meanwhile, the BOP has said more time is needed to complete a thorough investigation. However, Patton claimed the time it has taken is a result of "pure incompetence and a total lack of concern for the constitutional rights and humane conditions" for the defendants. + +That hunt for the alleged weapon has forced an extensive search of the facility, both common areas and individual cells, and has prompted federal officials to bring in out-of-town teams to assist with the search. In the meantime, while the probe continues, inmates have said they have been denied access to phones, computers and showers, and are getting cold sandwiches shoved through doors for food. + +## AP Sources: Feds Investigate Contraband Flow at Epstein Jail + +AP By Michael Balsamo and Michael R. Sisak 3/5/2020 + +WASHINGTON — The Justice Department has opened a criminal investigation into potential misconduct by guards as officials keep inmates locked down at the federal jail in New York where financier Jeffrey Epstein killed himself over the summer, people familiar with the matter told The Associated Press. + +The investigation at the Metropolitan Correctional Center is focusing on the flow of contraband into one of the most secure jails in America and is being led by federal prosecutors from the U.S. attorney's office in Manhattan, the people said. They were not authorized to discuss the investigation publicly and spoke on condition of anonymity. + +The criminal investigation comes as inmates have remained locked in their cells without access to their lawyers a week after authorities began tossing cells in search of a possible gun that so far they've been unable to find. The investigation started after jail officials received information that a gun may have been smuggled into the Manhattan lockup. Since then, officials have canceled all visitation at the jail, which houses about 700 inmates. There are no signs of the lockdown ending anytime soon. + +The lockdown is just the latest crisis at the jail where Epstein died by suicide in August. Federal prosecutors allege that the two correctional officers assigned to watch Epstein's unit were snoozing and shopping on the internet, and later forged records to make it look like they checked in on him. + +All visitors and inmates are searched before entering the facility and go through metal detectors. They are supposed to leave personal belongings outside the jail. All mail is also screened by correctional staff. A gun smuggled inside would be a major security breach. + +In the past few days, officers have searched the facility and uncovered a sizable amount of contraband, including cellphones, but no gun has not been found, the people said. Investigators are trying to determine how the contraband has been entering into the facility. + +The Bureau of Prisons said the jail is on "modified operations" because of the investigation. The bureau provided no estimate for when normal operations could resume, raising legal concerns because the jail houses pretrial inmates while their cases are ongoing. + +In a statement to the AP, the agency said it must "take the time needed to complete a thorough investigation while actively working to return the facility to normal operations as soon as possible." + +David Patton, executive director and chief attorney of the Federal Defenders of New York, said it's a violation of inmates' constitutional rights to deny them visits with their lawyers. He also said it has affected legal proceedings. + +"Sentencings are being delayed. Hearings are being delayed," Patton said. "But the MCC acts as though it's perfectly fine for them to just shut down the entire institution to look for contraband. It's just not acceptable. They've got to be able to walk and chew gum at the same time." + +Patton said federal prison officials have refused to provide information about what has prompted the current lockdown, other than saying it is for "security concerns." They have not told the federal defenders that they are searching for a gun, he said. + +Patton said the chief judge in the Southern District of New York has been working with the U.S. Marshals Service to bring a small number of people to the courthouse for individual meetings with lawyers, but they're capped at just five per day. + +"It's just not nearly sufficient to deal with the need," he said. + +The agency said Thursday that it arranged for additional staff from other parts of the U.S. to assist in the investigation and ensure there is appropriate staffing at the jail. The agency said it "has maintained communication with stakeholders as needed" and held a meeting with the chief federal judge and public defender in Manhattan, along with prosecutors, the Marshals Service and probation officials. + +The agency also said it has discussed a plan to resume legal visits at the jail on Friday and expects to allow full legal visitation by next week. Visits with family members could resume as soon as this week, officials added. + +"The Bureau has been working closely with the stakeholders throughout this period to ensure those defendants with imminent court deadlines have the legal visits with their legal counsel as needed," the statement said. + +Inmates are being locked down for 24 hours a day and lawyers have been told that on some units the prisoners are being denied showers and being given cold meals in their cells. One inmate reported receiving peanut butter and jelly sandwiches for every meal since last Thursday. + +The bureau said inmates are on a periodic shower rotation, except for those in special housing units, who remain on a regular schedule. + +"All inmates have access to medical care and appointments and medical staff continue normal rounds on every floor," BOP said. + +## Akparanta + +### Federal correctional officer in Manhattan pleads guilty to sexually abusing female inmates + +NY Daily News + +By Stephen Rex Brown + +3/4/2020 + +A former Metropolitan Correctional Center officer pleaded guilty Wednesday to sexually abusing inmates as a lockdown at the troubled jail entered its seventh day. + +Cohn Akparanta, 43, copped to engaging in sexual acts with seven women at the federal jail. Prosecutors said one of the women was molested through the slot in the door of her solitary confinement cell. Akparanta pleaded guilty to abusive sexual contact and deprivation of civil rights. + +"As he has now admitted, Cohn Akparanta abused his position of authority as a correctional officer at the [the lockup] to sexually abuse at least seven inmates whose safety and security he was duty-bound to protect. This office has prosecuted, and will continue to prosecute, correctional officers who use their positions to engage in criminal conduct, and I encourage anyone with knowledge of this or similar criminal conduct involving correctional officers at the [the jail] to contact my office," Manhattan U.S. Attorney Geoffrey Berman said. + +Akparanta, of Irvington, NJ., asked victims for their contact information so he could reach them after they were released from custody, prosecutors said. + +He smuggled contraband, including feminine hygiene products, into the jail for at least one victim in exchange for sexual acts. The depraved officer, who abused his victims between 2012 and 2018, took advantage of Bureau of Prisons policy + +The guilty plea in Manhattan Federal Court occurred while the troubled jail next door remained on lockdown despite mounting public pressure. + +The ban on family and attorney visits is because of a tip that a gun was smuggled into the jail. A search of the 12-story jail where Jeffrey Epstein killed himself uncovered a large amount of contraband — but no gun, the Daily News previously reported. + +Federal defenders have criticized the Bureau of Prisons for not providing information about the lockdown, which they say violates inmates' constitutional rights to an attorney. + +# Securities and Commodities Fraud + +Madoff + +### Bernie Madoff should die in prison, US government says + +CNN By Jordan Valinsky 3/5/2020 + +New York (CNN Business) — Bernard Madoff should not be released early from his 150-year prison sentence, even though he has terminal kidney failure, federal prosecutors said Wednesday. + +The 81-year-old Madoff, who orchestrated the largest Ponzi scheme in history, asked for compassionate release from prison last month, saying he has less than 18 months to live. + +But the US Attorney's office for the southern district of New York said Madoff's crime was "unprecedented in scope and magnitude" and is "sufficient reason" to deny Madoff's request. + +"Since his sentencing, Madoff has demonstrated a wholesale lack of understanding of the seriousness of his crimes and a lack of compassion for his victims, underscoring that he is undeserving of compassionate release," the US Attorney's office wrote. + +Madoff was arrested in December 2008 on allegations that the prestigious asset management firm he ran in Manhattan was, in fact, a pyramid-type scheme that swindled billions of dollars from thousands of people. He pleaded guilty to 11 felony charges related to money laundering, perjury and falsifying financial documents. He began his prison term in July 2009. + +More than 500 victims wrote to the court about Madoff's early release request, with an "overwhelming" amount of them opposed. The court said the letters show "how deeply Madoff's crimes continue to affect his victims, many of whom, as one put it in a letter to the court, are iserv[ing] a kind of life sentence of [their) own.'" + +In one letter, a victim blamed her husband's death on the stress of losing money through Madoff's scheme. The woman acknowledged that Madoff is suffering with his condition, but she noted there are "many of his victims who are suffering and who will continue to suffer." + +The US Attorney's office also said it "clearly reckoned" with Madoffs medical condition and the fact that the sentence means he will die in prison. But because of his "continuing refusal to accept responsibility and show remorse," they stood by their decision. They acknowledged Madoff has kidney failure, and a doctor says he has about 18 months to live. But prosecutors also noted Madoff's condition has improved recently. + +Madoff has been serving his sentence at a federal prison in Butner, North Carolina. He initially submitted a compassionate release request in September to the Bureau of Prisons, which issued a denial in December. In a letter detailing the denial, the warden did not dispute Madoff's condition or his life expectancy, but noted that Madoff had refused dialysis. He re-started dialysis in November 2019, prosecutors said, and Madoff is able to care for himself. + +# Terrorism and International Narcotics + +## Schulte + +### Fate of ex-CIA employee charged with massive data leak in jury's hands + +CNN + +By Mark Morales + +3/4/2020 + +New York (CNN) — The fate of a former CIA employee charged with carrying out the largest leak of classified data in the agency's history, sits in the hands of a federal jury in New York. + +Attorneys have a painted different portrayals of Joshua Schulte, the 31-year-old computer coder who is accused of handing over reams of classified data to WikiLeaks in 2016. + +Prosecutors argued that Schulte was motivated by revenge for being denied access to computer systems and then took several measures to not only get this data, but to cover his tracks by erasing his record of having ever accessed the info. + +"Josh Schulte is no patriot. Far from it," said Assistant US Attorney Matthew Laroche in closing arguments on Monday. "He's vengeful and he's full of rage and he's committed crimes that have been devastating to our national security." + +Schutle's attorney, Sabrina Shroff, countered that prosecutors still have not made their case that it was definitely Schulte who stole the data. + +She argued that passwords were shared among CIA members who were each trained to grab data without leaving a trace and that another office worker could have easily taken the data instead of Schulte. She also argued that CIA and FBI investigators were more motivated to solve the case rather than find the real culprit. + +"The government still is not able to answer for you the very basic questions. In fact, quite weirdly, I tell you that there are more questions now than when this trial first began," Shroff said to jurors. + +Schulte faces several charges, including illegally gathering national defense information, illegal transmission of both lawfully and unlawfully possessed national defense information and even possession of child pornography. The jury in the case began deliberations on Tuesday. + +Schulte, who worked as a computer engineer within the CIA's Center for Cyber Intelligence, created cyber tools that could grab data undetected from computers. + +His issues at the CIA began in the summer of 2015 when he began to feud with management and a co-worker, ultimately filing a restraining order against the coworker in state court, court records show. Schulte and the co-worker were both transferred as a result of the feud. + +Investigators allege that Schulte became enraged when CIA officials wanted to hire a contractor to build a cyber tool similar to one he was building, prosecutors said. + +Then in April 2016, Schulte's administrative privileges on two projects were revoked. When Schulte's asked about the revoked privileges, an administrator told him that since he now worked in a different branch, he no longer had the + +Schulte then told the administrator that a branch supervisor said he should have his access reinstated. And while the administrator went to check with the branch manager, Schulte reinstated his own access, according to the records. + +Once he was caught, administrators denied Schulte's access to all computer systems. But during the deletion process, they missed a key, and Schulte still had access to a main system known as DELVAN. Schulte, who signed a memo stating that he wouldn't attempt to restore or give himself access to any other systems, signed in as an administrator to DEVLAN. + +On April 20, 2016, investigators say Schulte stole cyber tools and source code and transferred them to WikiLeaks, according to court records. He then went on to cover try and cover his tracks, erasing any and all traces of him accessing the computer system, prosecutors said. + +Schulte quit the CIA in November 2016. But in March 2017, WikiLeaks published the first installment of their Vault 7 leaks, which originated from two programs found on the DEVLAN system, court records show. + +WikiLeaks put out a press release to go with the information, saying that the data was provided anonymously by a source who wanted to raise policy questions, specifically about whether the CIA had overstepped its hacking capabilities exceeded its authority. + +Schulte, who also allegedly lied to CIA and FBI investigators to cover his tracks, was arrested in August 2017 on child pornography charges. He was indicted on the charges related to the data breach months later. + +While inside the Metropolitan Correctional Center where he was detained awaiting trial, Schulte was able to get access to a phone where he kept leaking information, this time to a Washington Post reporter, prosecutors said. + +He also created several social media accounts, including one under the name Jason Borne, a hat tip to the fictional Hollywood character that was a CIA operative who found himself on the run, prosecutors said. + +Prosecutors kept painting the picture of Schulte as an angry and vindictive former worker who wanted to get even with his managers using the data he allegedly stole. + +"And if there is one thing that is abundantly clear, it's that he felt like he was wronged. He was ready to retaliate, and he was ready to do anything -- anything -- to make it right in his mind," Laroche said in his closing statement. "That's exactly what he did at the CIA, and that's exactly what he tried to do again from prison, repeating that same pattern of anger, escalation, retaliation and lies." + +### WikiLeaks Trial Juror Booted For Looking Up Lawyer Online + +Law360 By Pete Brush 3/5/2020 + +Law360, New York (March 5, 2020, 5:27 PM EST) -- A Manhattan federal judge cut loose a juror from deliberations Thursday in the trial of Joshua Schulte, the former CIA coder accused of sending secrets to WikiLeaks, because she told fellow jurors she had looked up information online about a lawyer working on the trial. + +U.S. District Judge Paul A. Crotty cut the juror loose not long after the fourth day of deliberations began in a trial that opened Feb. 2. He then directed the remaining 11 jurors, nine women and two men, to continue their work. + +Schulte is charged with transmitting to WikiLeaks secrets he allegedly poached in 2016 from an elite CIA "digital weapons" team inside the agency's Center for Cyber Intelligence. The 31-year-old also allegedly attempted to transmit + +Judge Crotty had the option of pausing the trial to retrieve an alternate juror. That would have triggered a restart of deliberations. But he opted instead to move forward with a panel of 11, remarking that a restart could have delayed things even further. + +The excused juror, Sylwia Wiesenberg of Manhattan, disclosed her online searches in the course of deliberations, according to notes sent to Judge Crotty Wednesday afternoon and Thursday morning. She remarked that one lawyer, who was not named, "used to look so different" and also said she had "looked them up," the notes said. + +After getting the boot, Wiesenberg told reporters outside of the lower Manhattan courthouse where the trial is taking place she does not think Schulte is guilty of leaking national defense secrets, charges that could see him put away for decades. + +"I want solid proof," she said. "I don't think he did it — the most serious charges." + +Schulte's trial featured weeks of testimony from current and former CIA workers and from experts who probed the defendant's technological activities. The jury also saw Schulte's own writings, including a notebook that said he wanted to send secrets to WikiLeaks. But the defense argued it was all guesswork, asserting there was no smoking-gun exhibit. + +Prior to begin excused, Wiesenberg also remarked to her fellow jurors that she had read news articles about the case, jury notes said. The jury foreperson told Judge Crotty in a note that she "sternly" warned Wiesenberg not to discuss news articles. + +"She has to be excused," prosecutor Matthew Laroche of the Manhattan U.S. attorney's office said bluntly. Schulte's defense team asked for a mistrial but was denied. + +Judge Crotty also addressed a separate note, dated Wednesday, which complained that another juror was examining evidence on her own without deliberating. "She continues on her own path," that note read. + +To address that, the judge reread standard legal instructions, which essentially ask jurors to be open-minded. + +"You should consult with one another," he said. + +By the end of day Thursday, the jury had sent 22 notes, most asking for testimony and explanations of evidence. The jury was set to resume its deliberations Friday morning. + +Schulte is represented by the Law Offices of Sabrina Shroff, Edward Zas of the Federal Defenders of New York Inc. and the Law Office of James M. Branden. + +The government is represented by David Denton, Sidhardha Kamaraju and Matthew Laroche of the U.S. Attorney's Office for the Southern District of New York. + +The case is USA v. Schulte, case number 1:17-cr-00548, in the U.S. District Court for the Southern District of New York. WikiLeaks Trial Judge Cautious As Jury Signals Disharmony + +Law360 + +By Pete Brush + +3/4/2020 + +Law360, New York (March 4, 2020, 5:17 PM EST) -- The Manhattan federal judge presiding over the trial of a former CIA coder accused of sending secrets to WikiLeaks took a careful approach Wednesday as signs of discord, including a note complaining that one juror is not listening to others, emerged from the jury room. + +U.S. District Judge Paul A. Crotty, who is overseeing the trial of Joshua Schulte, fielded a morning note saying a female juror was doing her own examination of evidence and failing to engage with the group. Late in the day he also took a note saying a juror had "prior information" about the case. + +Judge Crotty planned to huddle with lawyers to assess how to instruct the jury of 10 women and two men to go forward. He likely will re-read a portion of instructions they already have received, which asks them to deliberate in good faith and to listen to each other's viewpoints. + +Schulte is charged with transmitting to WikiLeaks secrets he allegedly poached in 2016 from an elite CIA "digital weapons" team inside the agency's Center for Cyber Intelligence. The 31-year-old Texan also allegedly attempted to transmit secrets after he was jailed by Judge Crotty in December 2017 for violating bail conditions. The defense concedes Schulte was a difficult employee but says he did not betray the CIA. + +The jury has now deliberated without reaching a verdict for about 14 hours over three days, peppering Judge Crotty with questions all the while. + +Wednesday's afternoon note, sent to the judge just before 3 p.m. and marked "urgent," said a juror may have gotten outside information about the case. + +"It came up during the course of deliberations," the note said. The note was vague in its detail, but it prompted the judge to cut the jury loose early to give prosecutors from the Manhattan U.S. attorney's office and Schulte's defense team time to review it. + +"It could be nothing," defense counsel Sabrina Shroff said outside of the presence of the jury. "Maybe they remember reading a newspaper article. Nobody knows." + +"We don't know," Judge Crotty said. + +The morning note, meanwhile, said jurors are concerned about a female juror's "attitude" toward the group. It said the juror has been examining evidence on her own without actively deliberating. + +"She continues on her own path," the note read. + +It was unclear whether the juror who was the subject of the morning note was even aware that it had been sent. + +All in all, Wednesday's notes were signs that deliberations may not be going smoothly. They followed an unusual missive from Tuesday afternoon, which asked whether Schulte has been diagnosed with Asperger's syndrome. Jurors have also asked Judge Crotty if the defendant used drugs. + +It was all part of a higher-than-normal volume of questions in the wake of a trial that was heavy on technical evidence and conducted in part under secrecy to protect the names of active CIA agents. Jurors have asked for transcripts of testimony from at least five witnesses among many other questions related to trial evidence. + +"It seems to be a very inquisitive jury, Your Honor," defense co-counsel Edward Zas remarked early in the day out of the presence of the jury. + +"We can't satisfy them," Judge Crotty quipped. + +Schulte is represented by the Law Offices of Sabrina Shroff, Edward Zas of the Federal Defenders of New York Inc. and the Law Office of James M. Branden. + +The government is represented by David Denton, Sidhardha Kamaraju and Matthew Laroche of the U.S. Attorney's Office for the Southern District of New York. + +# Violent and Organized Crime + +Ray + +Accused Sarah Lawrence sex trafficker made nearly \$2m from victim: prosecutors Fox + +NY Post + +By Ben Feuerherd + +3/2/2020 + +Accused Sarah Lawrence sex trafficker Lawrence Ray made nearly \$2 million in just two years by forcing one of his victims into prostitution, federal prosecutors alleged in court Monday. + +Ray, who was ordered held without bail at the hearing in Manhattan federal court, kept records of the ill-gotten cash, a federal prosecutor said. + +One typed document shows that the unidentified woman handed over \$700,000 in 2017, according to prosecutors. In 2018, the same woman turned over more than \$1 million to the accused sex trafficker, a second ledger shows. Prosecutors believe the woman was seeing more and more clients to meet Ray's demands. + +The ledgers marked dates and amounts that prosecutors have matched to text messages sent by Ray and his associates. + +The cash payments were collected by a female associate of Ray's and deposited into bank accounts that he had access to, prosecutors said in court. + +The 60-year-old former friend of disgraced NYPD Commissioner Bernie Kerik allegedly created a Nxivm-like sex cult to prey on his daughter's classmates at Sarah Lawrence College — all while allegedly extorting the classmates. + +Ray's alleged conduct came to light in a 2019 New York magazine article, which sparked a federal investigation and led to his arrest in February. + +His defense attorney on Monday blasted the article as "salacious" reporting that led to sensationalized coverage of his case. + +It also emerged Monday that Ray was found in bed with another alleged female victim when federal agents arrested him in Piscataway, NJ, on Feb. 11. + +Ray, who was the legal "guardian" of that woman, had groomed her and subjected her to extreme physical and mental abuse, prosecutors charged. + +He forced that unidentified woman — a former college roommate of his daughter — to have sex with other men while he filmed, and berated her while he filmed her sobbing, prosecutors said. + +Authorities also recovered video of Ray grabbing her by the hair and physically throwing her out of the New Jersey house, prosecutors alleged. + +Prosecutors said Ray deprived that woman and another alleged victim who lived in the Piscataway house of sleep and food — abuse that "broke their spirits." + +At Monday's bail hearing, Ray's court-appointed defense attorney pleaded with the judge to release him on bail, arguing he had family to stay with in Staten Island and a friend who offered to put him up in New Jersey. + +Judge Kevin Fox sided with prosecutors, who highlighted the amount of evidence they had in the case and urged Ray to be kept behind bars. + +# Akparanta + +### Federal correctional officer in Manhattan pleads guilty to sexually abusing female inmates + +NY Daily News + +By Stephen Rex Brown + +3/4/2020 + +A former Metropolitan Correctional Center officer pleaded guilty Wednesday to sexually abusing inmates as a lockdown at the troubled jail entered its seventh day. + +Colin Akparanta, 43, copped to engaging in sexual acts with seven women at the federal jail. Prosecutors said one of the women was molested through the slot in the door of her solitary confinement cell. Akparanta pleaded guilty to abusive sexual contact and deprivation of civil rights. + +"As he has now admitted, Colin Akparanta abused his position of authority as a correctional officer at the [the lockup] to sexually abuse at least seven inmates whose safety and security he was duty-bound to protect. This office has prosecuted, and will continue to prosecute, correctional officers who use their positions to engage in criminal conduct, and I encourage anyone with knowledge of this or similar criminal conduct involving correctional officers at the [the jail] to contact my office," Manhattan U.S. Attorney Geoffrey Berman said. + +Akparanta, of Irvington, N.J., asked victims for their contact information so he could reach them after they were released from custody, prosecutors said. + +He smuggled contraband, including feminine hygiene products, into the jail for at least one victim in exchange for sexual acts. The depraved officer, who abused his victims between 2012 and 2018, took advantage of Bureau of Prisons policy that made feminine hygiene products available for purchase at the commissary. That policy was changed in 2017, making the products available free. + +The guilty plea in Manhattan Federal Court occurred while the troubled jail next door remained on lockdown despite mounting public pressure. + +The ban on family and attorney visits is because of a tip that a gun was smuggled into the jail. A search of the 12-story jail where Jeffrey Epstein killed himself uncovered a large amount of contraband — but no gun, the Daily News previously reported. + +Federal defenders have criticized the Bureau of Prisons for not providing information about the lockdown, which they say violates inmates' constitutional rights to an attorney. + +#### Federal correctional officer in Manhattan pleads guilty to sexually abusing female inmates + +NY Daily News + +By Stephen Rex Brown + +3/4/2020 + +A former Metropolitan Correctional Center officer pleaded guilty Wednesday to sexually abusing inmates as a lockdown at the troubled jail entered its seventh day. + +Colin Akparanta, 43, copped to engaging in sexual acts with seven women at the federal jail. Prosecutors said one of the women was molested through the slot in the door of her solitary confinement cell. Akparanta pleaded guilty to abusive sexual contact and deprivation of civil rights. + +"As he has now admitted, Colin Akparanta abused his position of authority as a correctional officer at the [the lockup] to sexually abuse at least seven inmates whose safety and security he was duty-bound to protect. This office has prosecuted, and will continue to prosecute, correctional officers who use their positions to engage in criminal conduct, and I encourage anyone with knowledge of this or similar criminal conduct involving correctional officers at the [the jail] to contact my office," Manhattan U.S. Attorney Geoffrey Berman said. + +Akparanta, of Irvington, N.J., asked victims for their contact information so he could reach them after they were released from custody, prosecutors said. + +He smuggled contraband, including feminine hygiene products, into the jail for at least one victim in exchange for sexual acts. The depraved officer, who abused his victims between 2012 and 2018, took advantage of Bureau of Prisons policy that made feminine hygiene products available for purchase at the commissary. That policy was changed in 2017, making the products available free. + +The guilty plea in Manhattan Federal Court occurred while the troubled jail next door remained on lockdown despite mounting public pressure. + +The ban on family and attorney visits is because of a tip that a gun was smuggled into the jail. A search of the 12-story jail where Jeffrey Epstein killed himself uncovered a large amount of contraband — but no gun, the Daily News previously reported. + +Federal defenders have criticized the Bureau of Prisons for not providing information about the lockdown, which they say violates inmates' constitutional rights to an attorney. + +# White Plains + +Nikc + +## Chappaqua Businessman Pleads In Tax Evasion Case + +Patch + +By Lanning Taliaferro + +3/5/2020 + +CHAPPAQUA, NY — A Chappaqua businessman will be paying \$395,745 to the Internal Revenue Service as restitution for evading taxes from 2010-14. Antonio Nikc managed a number of family businesses that operate large rental buildings in New York and Connecticut, prosecutors said, and treated their bank accounts as a slush fund for luxury personal expenses. + +Nikc used money from those businesses to pay for more than \$1.5 million in personal expenses, including ocean-side condominiums in Miami, marina fees for a boat docked in Miami, airline tickets, luxury car payments, college tuition and allowances for his children, and purchases at jewelry stores, clothing stores, and restaurants. + +However, he failed to file any personal federal income tax returns and failed to pay any taxes due and owing on the income he received. In fact, he took steps to evade the assessment of taxes on that income, including paying for personal expenses out of the family business accounts and intentionally maintaining few assets in his own name. + +By the time the feds caught up, he had evaded \$395,745 in federal income taxes, prosecutors said. + +"While using the business accounts to fund his extravagant lifestyle, Nikc failed to file any personal income tax returns," U.S. Attorney Geoffrey S. Berman said in announcing the plea. "Now Nikc awaits sentencing for his crime." + +On Tuesday, the 58-year-old pleaded guilty to one count of tax evasion, which carries a maximum sentence of five years in prison. The maximum potential sentence in this case is prescribed by Congress and is provided here for informational purposes only, as any sentence will be determined by the judge. He is scheduled to be sentenced June 5 by U.S. District Judge Nelson S. Roman. + +IRS-CI Special Agent in Charge Jonathan D. Larsen said: "Our tax system is based on voluntary compliance and we will hold those accountable who fail to report their income out of greed. IRS-CI special agents will continue to pursue those who take advantage of our tax system." + +This case is being handled by the Office's White Plains Division. Assistant U.S. Attorney Jim Ligtenberg is in charge of the prosecution. + +# Matters of Interest + +Weinstein + +### Weinstein Undergoes Heart Procedure Before Transfer to Jail + +NYT + +By Jan Ransom + +3/5/2020 + +Harvey Weinstein underwent a heart procedure and was expected to be moved on Thursday from a hospital to New York City's notorious Rikers Island jail complex, his spokesman said. + +Mr. Weinstein, the once powerful film producer, was convicted last week of rape and criminal sexual assault after a trial in Manhattan that many saw as a milestone in the #MeToo movement. A judge ordered him held in jail until his sentencing on March 11. + +But hours after the verdict, Mr. Weinstein, 67, experienced extremely high blood pressure and heart palpitations, his lawyers said. He was taken directly from State Supreme Court in Manhattan to Bellevue Hospital Center, where he was treated for several days in a ward for prisoners. + +Mr. Weinstein is expected to be housed in the jail's North Infirmary Command under protective custody, his spokesman said. The facility consists of two buildings, one of which was built in 1932 as a hospital for inmates. + +Martin Horn, a former Department of Correction commissioner, said the facility was not "luxurious," but not "draconian" either. It contains about 10 cells on each block, as opposed to the nearly 30 on a typical Rikers cell block, he said, and once housed people with acute conditions like tuberculosis. + +Mr. Weinstein — who, friends have said, is terrified of being behind bars — faces up to 29 years in prison. He has hired a prison consultant to help him navigate the journey from life on the outside to life in a cell. + +Barr + +### On immigration, Attorney General Barr is his own Supreme Court. Judges and lawyers say that's a problem. + +The Washington Post + +By Kim Bellware + +3/5/2020 + +Attorney General William P. Barr quietly intervened in an immigration asylum case last week when he issued a decision that narrowed the definition of torture for asylum seekers who invoke it as a grounds for staying in the United States. + +Barr used a process known as "certification," a historically little-used power of the attorney general that allows him to overrule decisions made by the Board of Immigration Appeals and set binding precedent. Immigration lawyers and judges say the Trump administration is using the power with greater frequency — to the point of abuse — as it seeks to severely limit the number of immigrants who can remain in the United States. The administration is also using it as a check on immigration judges whose decisions don't align with the administration's immigration agenda, experts say. + +The decision to intervene in a Mexican national's otherwise unremarkable asylum case is a warning to immigration board members that even their unpublished decisions are being scrutinized, former immigration judge Jeffrey Chase told The Washington Post via email. + +"In the past, such decisions flew under the radar," Chase wrote. + +Other critics said Barr's move should concern everyone — not just those in immigration. Half a dozen immigration experts who spoke to The Post said Barr's use of his certification power in this case erodes the neutrality and due process that should exist in immigration court. They also cited recent moves by Justice Department, such as creating an office to denaturalize immigrants or using an immigrant's confidential therapy notes in a deportation case against them, as evidence of the Trump administration's willingness to break norms to achieve its goals. + +"In American history, what happens to immigrants is a pretty good indication of what's going to happen to the rest of us," retired immigration judge J. Traci Hong told The Post. + +The Justice Department did not respond when asked to address concerns from immigration judges and lawyers about the recent decision to narrow the torture definition for asylum seekers. Nor did it respond to questions on whether it views the current remedies available to asylum seekers as overly broad. + +Hong, who retired as an immigration judge late last year amid what she described as pressure to speed up cases and deport more people, said the sheer number of times that attorneys general under President Trump have used the power to certify cases to themselves is cause for concern. + +"The power goes back decades, but in other administrations, it was used very rarely — kind of a nuclear option," Hong told The Post. "Certifying a case is a way for the attorney general to stamp his or her own views on immigration law and it's the quickest way to do it." + +The certification power was used just three times during President Bill Clinton's two terms, and four times during President Barack Obama's. President George W. Bush's attorneys general certified 16 cases over eight years, the highest of any administration since the 1950s, according to NBC News. + +By contrast, the Trump administration has used the power at least a dozen times in three years; in 2018, then-Attorney General Jeff Sessions certified eight cases to himself in an eight-month span. + +Proponents of the certification power argue that it's a necessary tool to correct erroneous immigration court decisions and quickly enact needed changes. Even immigration advocates who oppose the Trump administration's rate of certifying cases criticized the Obama administration for not invoking the power often enough over his two terms. + +Hong cited concern that certification could be used to circumvent the lengthy and detailed regulatory process, which can take years or even decades. Had Barr wanted to propose new standards for defining torture in asylum cases, she said, they would be subject to public notice, debate, revision and public comment. + +Holly Cooper, co-director of the Immigration Law Clinic at the University of California at Davis, points to other efforts by the Justice Department to change and speed up the immigration process to the point that, in her view, immigrants fighting their cases are not getting a fair shake. + +"The Trump administration's rhetoric has been 'the rule of law.' But one principle that has been recognized is whether you're a citizen or a noncitizen, you deserve due process," Cooper told The Post. "You're seeing a lot of really sloppy decision-making done expeditiously with no regard to the individual's rights. The Fifth Amendment — the due process clause — applies to immigration courts." + +Circuit courts under the judicial branch can check decisions made by immigration courts and the attorney general under the executive branch. Cooper said that while circuit courts like to give deference to executive branch departments, they will overturn decisions found to be made with flimsy justification. + +Dana Leigh Marks, president emeritus at the National Association of Immigration Judges who currently presides over immigration cases, said that can result in judges not knowing what guidance to follow. + +"The problem for those of us in the field right now is that we're being whipsawed between these radical departures in past precedent that aren't necessarily sustained long term," Marks said, speaking in her role as a NAIJ member. + +Hong described the resulting environment in even starker terms: "It was like trying to perform surgery on a dodgeball court." + +What's happening with immigration courts could produce ripple effects in the wider justice system, particularly if immigration court decisions put forth by the attorney general clash with the circuit courts, Marks warned. + +"What's happening now is that all the norms are breaking," she said. "All the wheels are coming off the car." + +Nicholas Biase + +Public Affairs + +United States Department of Justice + +U.S. Attorney's Office Southern District of New York + +Nicholas.Biase@usdoj.gov 'Mobile: (646) 261-2074 Press Office: (212) 637-1020 \ No newline at end of file diff --git a/marker2/ds9/EFTA00088041/EFTA00088041.metadata.json b/marker2/ds9/EFTA00088041/EFTA00088041.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..a8299b7bd6565789b067c7f3af5dfd1788504ff2 --- /dev/null +++ b/marker2/ds9/EFTA00088041/EFTA00088041.metadata.json @@ -0,0 +1,1243 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00088041.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 16, + "chars": 44679, + "elapsed_seconds": 3.46, 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Commodities Fraud | 7 | +| Madoff | 7 | +| Terrorism and International Narcotics | 8 | +| Schulte | 8 | +| Violent and Organized Crime | 14 | +| Ray | 14 | +| Akparanta | 16 | +| Civil Rights | 17 | +| Akparanta | 17 | +| White Plains | 18 | +| Nikc | 18 | +| Matters of Interest | 19 | +| Weinstein | 19 | +| Barr | 20 | + +# Public Corruption + +### Epstein + +#### US Virgin Islands clears way for Jeffrey Epstein victims' fund + +NY Post + +By Priscilla DeGregory + +3/4/2020 + +The US Virgin Islands attorney general plans to stand aside and allow a Jeffrey Epstein victims compensation fund to proceed, according to new court papers. + +AG Denise George says her office has reached an agreement with victims to release liens she put on the dead pedophile's assets in January, so that they can be paid through a victim compensation fund. + +"The Attorney General intends to permit the release of Estate assets to allow for just compensation of victims of Mr. Epstein through the administration of the Fund assuming that certain enhancements to the claims program are implemented," Assistant AG Carol Thomas-Jacobs wrote in papers filed Tuesday in Virgin Islands Superior Court. + +Last month, a lawyer on the estate blamed George for impeding the process of paying out the women who claim they were sexually assaulted or raped by the 66-year-old multi-millionaire financier — often when they were underage. + +Over two-dozen women have filed sexual-assault lawsuits against Epstein's estate seeking damages. + +George's office says before the fund can start paying out, certain measures need to be implemented "to ensure fairness to all victims." + +George asked a judge to hold off on ruling on the compensation fund until Monday so that negotiations can be finalized. + +Epstein left behind a \$634 million fortune when he hanged himself in a Lower Manhattan lockup as he was awaiting trial on federal charges of sex trafficking. + +William Blum, a lawyer for the estate, said co-executors Richard Kahn and Darren Indyke hope to reach an agreement with the AG's office. + +"The co-executors of the estate of Jeffrey Epstein look forward to meeting with the representatives of the office of the Attorney General of the Virgin Islands with regard to the Epstein Voluntary Claims Resolution Program," Blum said. + +#### Lawyers Furious, Trying to 'Raise Hell' as MCC Lockdown Enters Day 8 + +NBC By Jonathan Dienst 3/5/2020 + +Numerous pre-trial inmates have moved from Metropolitan Correctional Center to Otisville as the MCC facility lockdown reaches its eighth day -- all while the search for an alleged smuggled gun continues. + +The head of the Federal Defenders Office in Manhattan said many inmates from MCC have been moved to Otisville including some who are scheduled to be in court Thursday and Friday. + +David Patton, Chief of the Federal Defenders Office, said defense lawyers still have not been able to meet with most pretrial clients for the eight days the MCC has been on lockdown. + +"Let us in to see our clients," Patton said Thursday, adding that defense attorneys are trying to "raise hell" with the MCC and through the courts to gain access to their clients. + +Investigators are focusing on whether a corrections officer at MCC helped smuggle a gun to an inmate, sources previously told News 4. + +Defense lawyers representing MCC inmates that were questioned by authorities previously said the focus appears to be on that theory, and the subsequent investigation has left them unable to see their clients. + +The MCC issued a statement Thursday saying lawyers could begin meeting with clients again starting Friday on a floor-by floor-basis. Full attorney visits could resume next week, the Bureau of Prisons statement said. + +The BOP says their officials met with the Chief Judge of the Southern District of New York, federal defenders, the U.S. Marshals and the U.S. Attorney's office to explain the ongoing issues. + +The MCC says inmates are now receiving showers on a rotating basis -- a statement Patton said is inaccurate. He claims many clients have been locked down for 24 hours a days for the last eight days. + +Meanwhile, the BOP has said more time is needed to complete a thorough investigation. However, Patton claimed the time it has taken is a result of "pure incompetence and a total lack of concern for the constitutional rights and humane conditions" for the defendants. + +"It's worse than solitary confinement and the BOP just doesn't give a damn," Patton said in an email to News 4. + +That hunt for the alleged weapon has forced an extensive search of the facility, both common areas and individual cells, and has prompted federal officials to bring in out-of-town teams to assist with the search. In the meantime, while the probe continues, inmates have said they have been denied access to phones, computers and showers, and are getting cold sandwiches shoved through doors for food. + +AP Sources: Feds Investigate Contraband Flow at Epstein Jail + +AP By Michael Balsamo and Michael R. Sisak 3/5/2020 + +WASHINGTON — The Justice Department has opened a criminal investigation into potential misconduct by guards as officials keep inmates locked down at the federal jail in New York where financier Jeffrey Epstein killed himself over the summer, people familiar with the matter told The Associated Press. + +The investigation at the Metropolitan Correctional Center is focusing on the flow of contraband into one of the most secure jails in America and is being led by federal prosecutors from the U.S. attorney's office in Manhattan, the people said. They were not authorized to discuss the investigation publicly and spoke on condition of anonymity. + +The criminal investigation comes as inmates have remained locked in their cells without access to their lawyers a week after authorities began tossing cells in search of a possible gun that so far they've been unable to find. The investigation started after jail officials received information that a gun may have been smuggled into the Manhattan lockup. Since then, officials have canceled all visitation at the jail, which houses about 700 inmates. There are no signs of the lockdown ending anytime soon. + +The lockdown is just the latest crisis at the jail where Epstein died by suicide in August. Federal prosecutors allege that the two correctional officers assigned to watch Epstein's unit were snoozing and shopping on the internet, and later forged records to make it look like they checked in on him. + +All visitors and inmates are searched before entering the facility and go through metal detectors. They are supposed to leave personal belongings outside the jail. All mail is also screened by correctional staff. A gun smuggled inside would be a major security breach. + +In the past few days, officers have searched the facility and uncovered a sizable amount of contraband, including cellphones, but no gun has not been found, the people said. Investigators are trying to determine how the contraband has been entering into the facility. + +The Bureau of Prisons said the jail is on "modified operations" because of the investigation. The bureau provided no estimate for when normal operations could resume, raising legal concerns because the jail houses pretrial inmates while their cases are ongoing. + +In a statement to the AP, the agency said it must "take the time needed to complete a thorough investigation while actively working to return the facility to normal operations as soon as possible." + +David Patton, executive director and chief attorney of the Federal Defenders of New York, said it's a violation of inmates' constitutional rights to deny them visits with their lawyers. He also said it has affected legal proceedings. + +"Sentencings are being delayed. Hearings are being delayed," Patton said. "But the MCC acts as though it's perfectly fine for them to just shut down the entire institution to look for contraband. It's just not acceptable. They've got to be able to walk and chew gum at the same time." + +Patton said federal prison officials have refused to provide information about what has prompted the current lockdown, other than saying it is for "security concerns." They have not told the federal defenders that they are searching for a gun, he said. + +Patton said the chief judge in the Southern District of New York has been working with the U.S. Marshals Service to bring a small number of people to the courthouse for individual meetings with lawyers, but they're capped at just five per day. + +"It's just not nearly sufficient to deal with the need," he said. + +The agency said Thursday that it arranged for additional staff from other parts of the U.S. to assist in the investigation and ensure there is appropriate staffing at the jail. The agency said it "has maintained communication with stakeholders as needed" and held a meeting with the chief federal judge and public defender in Manhattan, along with prosecutors, the Marshals Service and probation officials. + +The agency also said it has discussed a plan to resume legal visits at the jail on Friday and expects to allow full legal visitation by next week. Visits with family members could resume as soon as this week, officials added. + +"The Bureau has been working closely with the stakeholders throughout this period to ensure those defendants with imminent court deadlines have the legal visits with their legal counsel as needed," the statement said. + +Inmates are being locked down for 24 hours a day and lawyers have been told that on some units the prisoners are being denied showers and being given cold meals in their cells. One inmate reported receiving peanut butter and jelly sandwiches for every meal since last Thursday. + +The bureau said inmates are on a periodic shower rotation, except for those in special housing units, who remain on a regular schedule. + +"All inmates have access to medical care and appointments and medical staff continue normal rounds on every floor," BOP said. + +#### Federal correctional officer in Manhattan pleads guilty to sexually abusing female inmates + +NY Daily News + +By Stephen Rex Brown + +3/4/2020 + +A former Metropolitan Correctional Center officer pleaded guilty Wednesday to sexually abusing inmates as a lockdown at the troubled jail entered its seventh day. + +Colin Akparanta, 43, copped to engaging in sexual acts with seven women at the federal jail. Prosecutors said one of the women was molested through the slot in the door of her solitary confinement cell. Akparanta pleaded guilty to abusive sexual contact and deprivation of civil rights. + +"As he has now admitted, Colin Akparanta abused his position of authority as a correctional officer at the [the lockup] to sexually abuse at least seven inmates whose safety and security he was duty-bound to protect. This office has prosecuted, and will continue to prosecute, correctional officers who use their positions to engage in criminal conduct, and I encourage anyone with knowledge of this or similar criminal conduct involving correctional officers at the [the jail] to contact my office," Manhattan U.S. Attorney Geoffrey Berman said. + +Akparanta, of Irvington, N.J., asked victims for their contact information so he could reach them after they were released from custody, prosecutors said. + +He smuggled contraband, including feminine hygiene products, into the jail for at least one victim in exchange for sexual acts. The depraved officer, who abused his victims between 2012 and 2018, took advantage of Bureau of Prisons policy that made feminine hygiene products available for purchase at the commissary. That policy was changed in 2017, making the products available free. + +The guilty plea in Manhattan Federal Court occurred while the troubled jail next door remained on lockdown despite mounting public pressure. + +The ban on family and attorney visits is because of a tip that a gun was smuggled into the jail. A search of the 12-story jail where Jeffrey Epstein killed himself uncovered a large amount of contraband — but no gun, the Daily News previously reported. + +Federal defenders have criticized the Bureau of Prisons for not providing information about the lockdown, which they say violates inmates' constitutional rights to an attorney. + +# Securities and Commodities Fraud + +Madoff + +Bernie Madoff should die in prison, US government says + +CNN By Jordan Valinsky 3/5/2020 + +New York (CNN Business) — Bernard Madoff should not be released early from his 150-year prison sentence, even though he has terminal kidney failure, federal prosecutors said Wednesday. + +The 81-year-old Madoff, who orchestrated the largest Ponzi scheme in history, asked for compassionate release from prison last month, saying he has less than 18 months to live. + +But the US Attorney's office for the southern district of New York said Madoff's crime was "unprecedented in scope and magnitude" and is "sufficient reason" to deny Madoff's request. + +"Since his sentencing, Madoff has demonstrated a wholesale lack of understanding of the seriousness of his crimes and a lack of compassion for his victims, underscoring that he is undeserving of compassionate release," the US Attorney's office wrote. + +Madoff was arrested in December 2008 on allegations that the prestigious asset management firm he ran in Manhattan was, in fact, a pyramid-type scheme that swindled billions of dollars from thousands of people. He pleaded guilty to 11 felony charges related to money laundering, perjury and falsifying financial documents. He began his prison term in July 2009. + +More than 500 victims wrote to the court about Madoff's early release request, with an "overwhelming" amount of them opposed. The court said the letters show "how deeply Madoff's crimes continue to affect his victims, many of whom, as one put it in a letter to the court, are 'serv[ing] a kind of life sentence of (their) own."' + +In one letter, a victim blamed her husband's death on the stress of losing money through Madoff's scheme. The woman acknowledged that Madoff is suffering with his condition, but she noted there are "many of his victims who are suffering and who will continue to suffer." + +The US Attorney's office also said it "clearly reckoned" with Madoff's medical condition and the fact that the sentence means he will die in prison. But because of his "continuing refusal to accept responsibility and show remorse," they stood by their decision. They acknowledged Madoff has kidney failure, and a doctor says he has about 18 months to live. But prosecutors also noted Madoff's condition has improved recently. + +Madoff has been serving his sentence at a federal prison in Butner, North Carolina. He initially submitted a compassionate release request in September to the Bureau of Prisons, which issued a denial in December. In a letter detailing the denial, the warden did not dispute Madoff's condition or his life expectancy, but noted that Madoff had refused dialysis. He re-started dialysis in November 2019, prosecutors said, and Madoff is able to care for himself. + +# Terrorism and International Narcotics + +### Schulte + +### Fate of ex-CIA employee charged with massive data leak in jury's hands + +CNN + +By Mark Morales + +3/4/2020 + +New York (CNN) — The fate of a former CIA employee charged with carrying out the largest leak of classified data in the agency's history, sits in the hands of a federal jury in New York. + +Attorneys have a painted different portrayals of Joshua Schulte, the 31-year-old computer coder who is accused of handing over reams of classified data to WikiLeaks in 2016. + +Prosecutors argued that Schulte was motivated by revenge for being denied access to computer systems and then took several measures to not only get this data, but to cover his tracks by erasing his record of having ever accessed the info. + +"Josh Schulte is no patriot. Far from it," said Assistant US Attorney Matthew Laroche in closing arguments on Monday. "He's vengeful and he's full of rage and he's committed crimes that have been devastating to our national security." + +Schutle's attorney, Sabrina Shroff, countered that prosecutors still have not made their case that it was definitely Schulte who stole the data. + +She argued that passwords were shared among CIA members who were each trained to grab data without leaving a trace and that another office worker could have easily taken the data instead of Schulte. She also argued that CIA and FBI investigators were more motivated to solve the case rather than find the real culprit. + +"The government still is not able to answer for you the very basic questions. In fact, quite weirdly, I tell you that there are more questions now than when this trial first began," Shroff said to jurors. + +Schulte faces several charges, including illegally gathering national defense information, illegal transmission of both lawfully and unlawfully possessed national defense information and even possession of child pornography. The jury in the case began deliberations on Tuesday. + +Schulte, who worked as a computer engineer within the CIA's Center for Cyber Intelligence, created cyber tools that could grab data undetected from computers. + +His issues at the CIA began in the summer of 2015 when he began to feud with management and a co-worker, ultimately filing a restraining order against the coworker in state court, court records show. Schulte and the co-worker were both transferred as a result of the feud. + +Investigators allege that Schulte became enraged when CIA officials wanted to hire a contractor to build a cyber tool similar to one he was building, prosecutors said. + +Then in April 2016, Schulte's administrative privileges on two projects were revoked. When Schulte's asked about the revoked privileges, an administrator told him that since he now worked in a different branch, he no longer had the clearance, prosecutors said. Schulte argued that he still needed access to keep working on his projects. + +Schulte then told the administrator that a branch supervisor said he should have his access reinstated. And while the administrator went to check with the branch manager, Schulte reinstated his own access, according to the records. + +Once he was caught, administrators denied Schulte's access to all computer systems. But during the deletion process, they missed a key, and Schulte still had access to a main system known as DELVAN. Schulte, who signed a memo stating that he wouldn't attempt to restore or give himself access to any other systems, signed in as an administrator to DEVLAN. + +On April 20, 2016, investigators say Schulte stole cyber tools and source code and transferred them to WikiLeaks, according to court records. He then went on to cover try and cover his tracks, erasing any and all traces of him accessing the computer system, prosecutors said. + +Schulte quit the CIA in November 2016. But in March 2017, WikiLeaks published the first installment of their Vault 7 leaks, which originated from two programs found on the DEVLAN system, court records show. + +WikiLeaks put out a press release to go with the information, saying that the data was provided anonymously by a source who wanted to raise policy questions, specifically about whether the CIA had overstepped its hacking capabilities exceeded its authority. + +Schulte, who also allegedly lied to CIA and FBI investigators to cover his tracks, was arrested in August 2017 on child pornography charges. He was indicted on the charges related to the data breach months later. + +While inside the Metropolitan Correctional Center where he was detained awaiting trial, Schulte was able to get access to a phone where he kept leaking information, this time to a Washington Post reporter, prosecutors said. + +He also created several social media accounts, including one under the name Jason Borne, a hat tip to the fictional Hollywood character that was a CIA operative who found himself on the run, prosecutors said. + +Prosecutors kept painting the picture of Schulte as an angry and vindictive former worker who wanted to get even with his managers using the data he allegedly stole. + +"And if there is one thing that is abundantly clear, it's that he felt like he was wronged. He was ready to retaliate, and he was ready to do anything -- anything -- to make it right in his mind," Laroche said in his closing statement. "That's exactly what he did at the CIA, and that's exactly what he tried to do again from prison, repeating that same pattern of anger, escalation, retaliation and lies." + +Law360 + +By Pete Brush + +3/5/2020 + +Law360, New York (March 5, 2020, 5:27 PM EST) -- A Manhattan federal judge cut loose a juror from deliberations Thursday in the trial of Joshua Schulte, the former CIA coder accused of sending secrets to WikiLeaks, because she told fellow jurors she had looked up information online about a lawyer working on the trial. + +U.S. District Judge Paul A. Crotty cut the juror loose not long after the fourth day of deliberations began in a trial that opened Feb. 2. He then directed the remaining 11 jurors, nine women and two men, to continue their work. + +Schulte is charged with transmitting to WikiLeaks secrets he allegedly poached in 2016 from an elite CIA "digital weapons" team inside the agency's Center for Cyber Intelligence. The 31-year-old also allegedly attempted to transmit secrets after he was jailed by Judge Crotty in December 2017 for violating bail conditions. Schulte denies being the leaker. + +Judge Crotty had the option of pausing the trial to retrieve an alternate juror. That would have triggered a restart of deliberations. But he opted instead to move forward with a panel of 11, remarking that a restart could have delayed things even further. + +The excused juror, Sylwia Wiesenberg of Manhattan, disclosed her online searches in the course of deliberations, according to notes sent to Judge Crotty Wednesday afternoon and Thursday morning. She remarked that one lawyer, who was not named, "used to look so different" and also said she had "looked them up," the notes said. + +After getting the boot, Wiesenberg told reporters outside of the lower Manhattan courthouse where the trial is taking place she does not think Schulte is guilty of leaking national defense secrets, charges that could see him put away for decades. + +"I want solid proof," she said. "I don't think he did it — the most serious charges." + +Schulte's trial featured weeks of testimony from current and former CIA workers and from experts who probed the defendant's technological activities. The jury also saw Schulte's own writings, including a notebook that said he wanted to send secrets to WikiLeaks. But the defense argued it was all guesswork, asserting there was no smoking-gun exhibit. + +Prior to begin excused, Wiesenberg also remarked to her fellow jurors that she had read news articles about the case, jury notes said. The jury foreperson told Judge Crotty in a note that she "sternly" warned Wiesenberg not to discuss news articles. + +"She has to be excused," prosecutor Matthew Laroche of the Manhattan U.S. attorney's office said bluntly. Schulte's defense team asked for a mistrial but was denied. + +Judge Crotty also addressed a separate note, dated Wednesday, which complained that another juror was examining evidence on her own without deliberating. "She continues on her own path," that note read. + +"You should consult with one another," he said. + +By the end of day Thursday, the jury had sent 22 notes, most asking for testimony and explanations of evidence. The jury was set to resume its deliberations Friday morning. + +Schulte is represented by the Law Offices of Sabrina Shroff, Edward Zas of the Federal Defenders of New York Inc. and the Law Office of James M. Branden. + +The government is represented by David Denton, Sidhardha Kamaraju and Matthew Laroche of the U.S. Attorney's Office for the Southern District of New York. + +The case is USA v. Schulte, case number 1:17-cr-00548, in the U.S. District Court for the Southern District of New York. + +Law360 + +By Pete Brush + +3/4/2020 + +Law360, New York (March 4, 2020, 5:17 PM EST) -- The Manhattan federal judge presiding over the trial of a former CIA coder accused of sending secrets to WikiLeaks took a careful approach Wednesday as signs of discord, including a note complaining that one juror is not listening to others, emerged from the jury room. + +U.S. District Judge Paul A. Crotty, who is overseeing the trial of Joshua Schulte, fielded a morning note saying a female juror was doing her own examination of evidence and failing to engage with the group. Late in the day he also took a note saying a juror had "prior information" about the case. + +Judge Crotty planned to huddle with lawyers to assess how to instruct the jury of 10 women and two men to go forward. He likely will re-read a portion of instructions they already have received, which asks them to deliberate in good faith and to listen to each other's viewpoints. + +Schulte is charged with transmitting to WikiLeaks secrets he allegedly poached in 2016 from an elite CIA "digital weapons" team inside the agency's Center for Cyber Intelligence. The 31-year-old Texan also allegedly attempted to transmit secrets after he was jailed by Judge Crotty in December 2017 for violating bail conditions. The defense concedes Schulte was a difficult employee but says he did not betray the CIA. + +The jury has now deliberated without reaching a verdict for about 14 hours over three days, peppering Judge Crotty with questions all the while. + +Wednesday's afternoon note, sent to the judge just before 3 p.m. and marked "urgent," said a juror may have gotten outside information about the case. + +"It came up during the course of deliberations," the note said. The note was vague in its detail, but it prompted the judge to cut the jury loose early to give prosecutors from the Manhattan U.S. attorney's office and Schulte's defense team time to review it. + +"It could be nothing," defense counsel Sabrina Shroff said outside of the presence of the jury. "Maybe they remember reading a newspaper article. Nobody knows." + +"We don't know," Judge Crotty said. + +The morning note, meanwhile, said jurors are concerned about a female juror's "attitude" toward the group. It said the juror has been examining evidence on her own without actively deliberating. + +"She continues on her own path," the note read. + +It was unclear whether the juror who was the subject of the morning note was even aware that it had been sent. + +SDNY News Clips, Thursday, March 5, 2020 + +All in all, Wednesday's notes were signs that deliberations may not be going smoothly. They followed an unusual missive from Tuesday afternoon, which asked whether Schulte has been diagnosed with Asperger's syndrome. Jurors have also asked Judge Crotty if the defendant used drugs. + +It was all part of a higher-than-normal volume of questions in the wake of a trial that was heavy on technical evidence and conducted in part under secrecy to protect the names of active CIA agents. Jurors have asked for transcripts of testimony from at least five witnesses among many other questions related to trial evidence. + +"It seems to be a very inquisitive jury, Your Honor," defense co-counsel Edward Zas remarked early in the day out of the presence of the jury. + +"We can't satisfy them," Judge Crotty quipped. + +Schulte is represented by the Law Offices of Sabrina Shroff, Edward Zas of the Federal Defenders of New York Inc. and the Law Office of James M. Branden. + +The government is represented by David Denton, Sidhardha Kamaraju and Matthew Laroche of the U.S. Attorney's Office for the Southern District of New York. + +The case is U.S. v. Schulte, case number 1:17-cr-00548, in the U.S. District Court for the Southern District of New York. + +# Violent and Organized Crime + +Ray + +#### Accused Sarah Lawrence sex trafficker made nearly \$2M from victim: prosecutors Fox + +NY Post + +By Ben Feuerherd + +3/2/2020 + +Accused Sarah Lawrence sex trafficker Lawrence Ray made nearly \$2 million in just two years by forcing one of his victims into prostitution, federal prosecutors alleged in court Monday. + +Ray, who was ordered held without bail at the hearing in Manhattan federal court, kept records of the ill-gotten cash, a federal prosecutor said. + +One typed document shows that the unidentified woman handed over \$700,000 in 2017, according to prosecutors. In 2018, the same woman turned over more than \$1 million to the accused sex trafficker, a second ledger shows. + +Prosecutors believe the woman was seeing more and more clients to meet Ray's demands. + +The ledgers marked dates and amounts that prosecutors have matched to text messages sent by Ray and his associates. + +The cash payments were collected by a female associate of Ray's and deposited into bank accounts that he had access to, prosecutors said in court. + +The 60-year-old former friend of disgraced NYPD Commissioner Bernie Kerik allegedly created a Nxivm-like sex cult to prey on his daughter's classmates at Sarah Lawrence College — all while allegedly extorting the classmates. + +Ray's alleged conduct came to light in a 2019 New York magazine article, which sparked a federal investigation and led to his arrest in February. + +His defense attorney on Monday blasted the article as "salacious" reporting that led to sensationalized coverage of his case. + +It also emerged Monday that Ray was found in bed with another alleged female victim when federal agents arrested him in Piscataway, NJ, on Feb. 11. + +Ray, who was the legal "guardian" of that woman, had groomed her and subjected her to extreme physical and mental abuse, prosecutors charged. + +He forced that unidentified woman — a former college roommate of his daughter — to have sex with other men while he filmed, and berated her while he filmed her sobbing, prosecutors said. + +Authorities also recovered video of Ray grabbing her by the hair and physically throwing her out of the New Jersey house, prosecutors alleged. + +SDNY News Clips, Thursday, March 5, 2020 + +Prosecutors said Ray deprived that woman and another alleged victim who lived in the Piscataway house of sleep and food — abuse that "broke their spirits." + +They noted the accused sicko had installed a lock on the house's refrigerator door and subjected them both to harsh verbal abuse. + +At Monday's bail hearing, Ray's court-appointed defense attorney pleaded with the judge to release him on bail, arguing he had family to stay with in Staten Island and a friend who offered to put him up in New Jersey. + +Judge Kevin Fox sided with prosecutors, who highlighted the amount of evidence they had in the case and urged Ray to be kept behind bars. + +#### Federal correctional officer in Manhattan pleads guilty to sexually abusing female inmates + +NY Daily News + +By Stephen Rex Brown + +3/4/2020 + +A former Metropolitan Correctional Center officer pleaded guilty Wednesday to sexually abusing inmates as a lockdown at the troubled jail entered its seventh day. + +Colin Akparanta, 43, copped to engaging in sexual acts with seven women at the federal jail. Prosecutors said one of the women was molested through the slot in the door of her solitary confinement cell. Akparanta pleaded guilty to abusive sexual contact and deprivation of civil rights. + +"As he has now admitted, Colin Akparanta abused his position of authority as a correctional officer at the [the lockup] to sexually abuse at least seven inmates whose safety and security he was duty-bound to protect. This office has prosecuted, and will continue to prosecute, correctional officers who use their positions to engage in criminal conduct, and I encourage anyone with knowledge of this or similar criminal conduct involving correctional officers at the [the jail] to contact my office," Manhattan U.S. Attorney Geoffrey Berman said. + +Akparanta, of Irvington, N.J., asked victims for their contact information so he could reach them after they were released from custody, prosecutors said. + +He smuggled contraband, including feminine hygiene products, into the jail for at least one victim in exchange for sexual acts. The depraved officer, who abused his victims between 2012 and 2018, took advantage of Bureau of Prisons policy that made feminine hygiene products available for purchase at the commissary. That policy was changed in 2017, making the products available free. + +The guilty plea in Manhattan Federal Court occurred while the troubled jail next door remained on lockdown despite mounting public pressure. + +The ban on family and attorney visits is because of a tip that a gun was smuggled into the jail. A search of the 12-story jail where Jeffrey Epstein killed himself uncovered a large amount of contraband — but no gun, the Daily News previously reported. + +Federal defenders have criticized the Bureau of Prisons for not providing information about the lockdown, which they say violates inmates' constitutional rights to an attorney. + +# Civil Rights + +Akparanta + +#### Federal correctional officer in Manhattan pleads guilty to sexually abusing female inmates + +NY Daily News + +By Stephen Rex Brown + +3/4/2020 + +A former Metropolitan Correctional Center officer pleaded guilty Wednesday to sexually abusing inmates as a lockdown at the troubled jail entered its seventh day. + +Colin Akparanta, 43, copped to engaging in sexual acts with seven women at the federal jail. Prosecutors said one of the women was molested through the slot in the door of her solitary confinement cell. Akparanta pleaded guilty to abusive sexual contact and deprivation of civil rights. + +"As he has now admitted, Colin Akparanta abused his position of authority as a correctional officer at the [the lockup] to sexually abuse at least seven inmates whose safety and security he was duty-bound to protect. This office has prosecuted, and will continue to prosecute, correctional officers who use their positions to engage in criminal conduct, and I encourage anyone with knowledge of this or similar criminal conduct involving correctional officers at the [the jail] to contact my office," Manhattan U.S. Attorney Geoffrey Berman said. + +Akparanta, of Irvington, N.J., asked victims for their contact information so he could reach them after they were released from custody, prosecutors said. + +He smuggled contraband, including feminine hygiene products, into the jail for at least one victim in exchange for sexual acts. The depraved officer, who abused his victims between 2012 and 2018, took advantage of Bureau of Prisons policy that made feminine hygiene products available for purchase at the commissary. That policy was changed in 2017, making the products available free. + +The guilty plea in Manhattan Federal Court occurred while the troubled jail next door remained on lockdown despite mounting public pressure. + +The ban on family and attorney visits is because of a tip that a gun was smuggled into the jail. A search of the 12-story jail where Jeffrey Epstein killed himself uncovered a large amount of contraband — but no gun, the Daily News previously reported. + +Federal defenders have criticized the Bureau of Prisons for not providing information about the lockdown, which they say violates inmates' constitutional rights to an attorney. + +# White Plains + +Nikc + +#### Chappaqua Businessman Pleads In Tax Evasion Case + +Patch + +By Lanning Taliaferro + +3/5/2020 + +CHAPPAQUA, NY — A Chappaqua businessman will be paying \$395,745 to the Internal Revenue Service as restitution for evading taxes from 2010-14. Antonio Nikc managed a number of family businesses that operate large rental buildings in New York and Connecticut, prosecutors said, and treated their bank accounts as a slush fund for luxury personal expenses. + +Nikc used money from those businesses to pay for more than \$1.5 million in personal expenses, including ocean-side condominiums in Miami, marina fees for a boat docked in Miami, airline tickets, luxury car payments, college tuition and allowances for his children, and purchases at jewelry stores, clothing stores, and restaurants. + +However, he failed to file any personal federal income tax returns and failed to pay any taxes due and owing on the income he received. In fact, he took steps to evade the assessment of taxes on that income, including paying for personal expenses out of the family business accounts and intentionally maintaining few assets in his own name. + +By the time the feds caught up, he had evaded \$395,745 in federal income taxes, prosecutors said. + +"While using the business accounts to fund his extravagant lifestyle, Nikc failed to file any personal income tax returns," U.S. Attorney Geoffrey S. Berman said in announcing the plea. "Now Nikc awaits sentencing for his crime." + +On Tuesday, the 58-year-old pleaded guilty to one count of tax evasion, which carries a maximum sentence of five years in prison. The maximum potential sentence in this case is prescribed by Congress and is provided here for informational purposes only, as any sentence will be determined by the judge. He is scheduled to be sentenced June 5 by U.S. District Judge Nelson S. Roman. + +IRS-CI Special Agent in Charge Jonathan D. Larsen said: "Our tax system is based on voluntary compliance and we will hold those accountable who fail to report their income out of greed. IRS-CI special agents will continue to pursue those who take advantage of our tax system." + +This case is being handled by the Office's White Plains Division. Assistant U.S. Attorney Jim Ligtenberg is in charge of the prosecution. + +# Matters of Interest + +Weinstein + +#### Weinstein Undergoes Heart Procedure Before Transfer to Jail + +NYT By Jan Ransom 3/5/2020 + +Harvey Weinstein underwent a heart procedure and was expected to be moved on Thursday from a hospital to New York City's notorious Rikers Island jail complex, his spokesman said. + +Mr. Weinstein, the once powerful film producer, was convicted last week of rape and criminal sexual assault after a trial in Manhattan that many saw as a milestone in the ttMeToo movement. A judge ordered him held in jail until his sentencing on March 11. + +But hours after the verdict, Mr. Weinstein, 67, experienced extremely high blood pressure and heart palpitations, his lawyers said. He was taken directly from State Supreme Court in Manhattan to Bellevue Hospital Center, where he was treated for several days in a ward for prisoners. + +On Wednesday, Mr. Weinstein had a stent implanted to alleviate a blockage, his spokesman, Juda Engelmayer, said. + +The city's Department of Correction did not immediately respond to questions about Mr. Weinstein's condition. + +Mr. Weinstein is expected to be housed in the jail's North Infirmary Command under protective custody, his spokesman said. The facility consists of two buildings, one of which was built in 1932 as a hospital for inmates. + +Martin Horn, a former Department of Correction commissioner, said the facility was not "luxurious," but not "draconian" either. It contains about 10 cells on each block, as opposed to the nearly 30 on a typical Rikers cell block, he said, and once housed people with acute conditions like tuberculosis. + +Mr. Weinstein — who, friends have said, is terrified of being behind bars — faces up to 29 years in prison. He has hired a prison consultant to help him navigate the journey from life on the outside to life in a cell. + +#### On immigration, Attorney General Barr is his own Supreme Court. Judges and lawyers say that's a problem. + +The Washington Post + +By Kim Bellware + +3/5/2020 + +Attorney General William P. Barr quietly intervened in an immigration asylum case last week when he issued a decision that narrowed the definition of torture for asylum seekers who invoke it as a grounds for staying in the United States. + +Barr used a process known as "certification," a historically little-used power of the attorney general that allows him to overrule decisions made by the Board of Immigration Appeals and set binding precedent. Immigration lawyers and judges say the Trump administration is using the power with greater frequency — to the point of abuse — as it seeks to severely limit the number of immigrants who can remain in the United States. The administration is also using it as a check on immigration judges whose decisions don't align with the administration's immigration agenda, experts say. + +The decision to intervene in a Mexican national's otherwise unremarkable asylum case is a warning to immigration board members that even their unpublished decisions are being scrutinized, former immigration judge Jeffrey Chase told The Washington Post via email. + +"In the past, such decisions flew under the radar," Chase wrote. + +Other critics said Barr's move should concern everyone — not just those in immigration. Half a dozen immigration experts who spoke to The Post said Barr's use of his certification power in this case erodes the neutrality and due process that should exist in immigration court. They also cited recent moves by Justice Department, such as creating an office to denaturalize immigrants or using an immigrant's confidential therapy notes in a deportation case against them, as evidence of the Trump administration's willingness to break norms to achieve its goals. + +"In American history, what happens to immigrants is a pretty good indication of what's going to happen to the rest of us," retired immigration judge J. Traci Hong told The Post. + +The Justice Department did not respond when asked to address concerns from immigration judges and lawyers about the recent decision to narrow the torture definition for asylum seekers. Nor did it respond to questions on whether it views the current remedies available to asylum seekers as overly broad. + +Hong, who retired as an immigration judge late last year amid what she described as pressure to speed up cases and deport more people, said the sheer number of times that attorneys general under President Trump have used the power to certify cases to themselves is cause for concern. + +"The power goes back decades, but in other administrations, it was used very rarely — kind of a nuclear option," Hong told The Post. "Certifying a case is a way for the attorney general to stamp his or her own views on immigration law and it's the quickest way to do it." + +The certification power was used just three times during President Bill Clinton's two terms, and four times during President Barack Obama's. President George W. Bush's attorneys general certified 16 cases over eight years, the highest of any administration since the 1950s, according to NBC News. + +By contrast, the Trump administration has used the power at least a dozen times in three years; in 2018, then-Attorney General Jeff Sessions certified eight cases to himself in an eight-month span. + +Proponents of the certification power argue that it's a necessary tool to correct erroneous immigration court decisions and quickly enact needed changes. Even immigration advocates who oppose the Trump administration's rate of certifying cases criticized the Obama administration for not invoking the power often enough over his two terms. + +Hong cited concern that certification could be used to circumvent the lengthy and detailed regulatory process, which can take years or even decades. Had Barr wanted to propose new standards for defining torture in asylum cases, she said, they would be subject to public notice, debate, revision and public comment. + +Holly Cooper, co-director of the Immigration Law Clinic at the University of California at Davis, points to other efforts by the Justice Department to change and speed up the immigration process to the point that, in her view, immigrants fighting their cases are not getting a fair shake. + +"The Trump administration's rhetoric has been 'the rule of law.' But one principle that has been recognized is whether you're a citizen or a noncitizen, you deserve due process," Cooper told The Post. "You're seeing a lot of really sloppy decision-making done expeditiously with no regard to the individual's rights. The Fifth Amendment — the due process clause — applies to immigration courts." + +Circuit courts under the judicial branch can check decisions made by immigration courts and the attorney general under the executive branch. Cooper said that while circuit courts like to give deference to executive branch departments, they will overturn decisions found to be made with flimsy justification. + +Dana Leigh Marks, president emeritus at the National Association of Immigration Judges who currently presides over immigration cases, said that can result in judges not knowing what guidance to follow. + +"The problem for those of us in the field right now is that we're being whipsawed between these radical departures in past precedent that aren't necessarily sustained long term," Marks said, speaking in her role as a NAIJ member. + +Hong described the resulting environment in even starker terms: "It was like trying to perform surgery on a dodgeball court." + +What's happening with immigration courts could produce ripple effects in the wider justice system, particularly if immigration court decisions put forth by the attorney general clash with the circuit courts, Marks warned. + +"What's happening now is that all the norms are breaking," she said. 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new file mode 100644 index 0000000000000000000000000000000000000000..162792f49042550f7422bbda4717dd1ed696c63a --- /dev/null +++ b/marker2/ds9/EFTA00088078/EFTA00088078.md @@ -0,0 +1,564 @@ +**From:** "[REDACTED] (USANYS)" <[REDACTED]> +**To:** "[REDACTED] (USANYS)" <[REDACTED]> +**Subject:** Re: SDNY News Clips, Thursday, March 5, 2020 +**Date:** Fri, 06 Mar 2020 11:36:09 +0000 + +--- + +Wow. + +On Mar 5, 2020, at 9:27 PM, [REDACTED] (USANYS) <[REDACTED]> wrote: + +We do a poor job of marketing our work:) + +Begin forwarded message: + +**From:** "[REDACTED]" +**Date:** March 5, 2020 at 5:57:52 PM EST +**To:** [REDACTED] + +[REDACTED] + +[Redacted] + +**Subject: SDNY News Clips, Thursday, March 5, 2020** + +## SDNY News Clips + +Thursday, March 5, 2020 + +## Contents + +### [Public Corruption](#) + +[Epstein](#) + +[MCC](#) + +[Akparanta](#) + +### [Securities and Commodities Fraud](#) + +[Madoff](#) + +### [Terrorism and International Narcotics](#) + +[Schulte](#) + +### [Violent and Organized Crime](#) + +[Ray](#) + +[Akparanta](#) + +### [Civil Rights](#) + +[Akparanta](#) + +### [White Plains](#) + +[Nikc](#) + +### [Matters of Interest](#) + +[Weinstein](#) + +[Barr](#) + +## Public Corruption + +Epstein + +### **US Virgin Islands clears way for Jeffrey Epstein victims' fund** + +NY Post + +By Priscilla DeGregory + +3/4/2020 + +The US Virgin Islands attorney general plans to stand aside and allow a Jeffrey Epstein victims compensation fund to proceed, according to new court papers. + +AG Denise George says her office has reached an agreement with victims to release liens she put on the dead pedophile's assets in January, so that they can be paid through a victim compensation fund. + +"The Attorney General intends to permit the release of Estate assets to allow for just compensation of victims of Mr. Epstein through the administration of the Fund assuming that certain enhancements to the claims program are + +Last month, a lawyer on the estate blamed George for impeding the process of paying out the women who claim they were sexually assaulted or raped by the 66-year-old multi-millionaire financier — often when they were underage. + +Over two-dozen women have filed sexual-assault lawsuits against Epstein's estate seeking damages. + +George's office says before the fund can start paying out, certain measures need to be implemented "to ensure fairness to all victims." + +George asked a judge to hold off on ruling on the compensation fund until Monday so that negotiations can be finalized. + +Epstein left behind a \$634 million fortune when he hanged himself in a Lower Manhattan lockup as he was awaiting trial on federal charges of sex trafficking. + +William Blum, a lawyer for the estate, said co-executors Richard Kahn and Darren Indyke hope to reach an agreement with the AG's office. + +"The co-executors of the estate of Jeffrey Epstein look forward to meeting with the representatives of the office of the Attorney General of the Virgin Islands with regard to the Epstein Voluntary Claims Resolution Program," Blum said. + +MCC + +### Lawyers Furious, Trying to 'Raise Hell' as MCC Lockdown Enters Day 8 + +NBC + +By Jonathan Dienst + +3/5/2020 + +Numerous pre-trial inmates have moved from Metropolitan Correctional Center to Otisville as the MCC facility lockdown reaches its eighth day -- all while the search for an alleged smuggled gun continues. + +The head of the Federal Defenders Office in Manhattan said many inmates from MCC have been moved to Otisville including some who are scheduled to be in court Thursday and Friday. + +David Patton, Chief of the Federal Defenders Office, said defense lawyers still have not been able to meet with most pre-trial clients for the eight days the MCC has been on lockdown. + +"Let us in to see our clients," Patton said Thursday, adding that defense attorneys are trying to "raise hell" with the MCC and through the courts to gain access to their clients. + +Investigators are focusing on whether a corrections officer at MCC helped smuggle a gun to an inmate, sources previously told News 4. + +Defense lawyers representing MCC inmates that were questioned by authorities previously said the focus appears to be on that theory, and the subsequent investigation has left them unable to see their clients. + +The MCC issued a statement Thursday saying lawyers could begin meeting with clients again starting Friday on a floorby floor-basis. Full attorney visits could resume next week, the Bureau of Prisons statement said. + +The BOP says their officials met with the Chief Judge of the Southern District of New York, federal defenders, the U.S. Marshals and the U.S. Attorney's office to explain the ongoing issues. + +The MCC says inmates are now receiving showers on a rotating basis -- a statement Patton said is inaccurate. He claims many clients have been locked down for 24 hours a days for the last eight days. + +Meanwhile, the BOP has said more time is needed to complete a thorough investigation. However, Patton claimed the time it has taken is a result of "pure incompetence and a total lack of concern for the constitutional rights and humane conditions" for the defendants. + +"It's worse than solitary confinement and the BOP just doesn't give a damn;' Patton said in an email to News 4. + +That hunt for the alleged weapon has forced an extensive search of the facility, both common areas and individual cells, and has prompted federal officials to bring in out-of-town teams to assist with the search. In the meantime, while the probe continues, inmates have said they have been denied access to phones, computers and showers, and are getting cold sandwiches shoved through doors for food. + +### AP Sources: Feds Investigate Contraband Flow at Epstein Jail + +AP By Michael Balsamo and Michael R. Sisak 3/5/2020 + +WASHINGTON — The Justice Department has opened a criminal investigation into potential misconduct by guards as officials keep inmates locked down at the federal jail in New York where financier Jeffrey Epstein killed himself over the summer, people familiar with the matter told The Associated Press. + +The investigation at the Metropolitan Correctional Center is focusing on the flow of contraband into one of the most secure jails in America and is being led by federal prosecutors from the U.S. attorney's office in Manhattan, the people said. They were not authorized to discuss the investigation publicly and spoke on condition of anonymity. + +The criminal investigation comes as inmates have remained locked in their cells without access to their lawyers a week after authorities began tossing cells in search of a possible gun that so far they've been unable to find. The investigation started after jail officials received information that a gun may have been smuggled into the Manhattan lockup. Since then, officials have canceled all visitation at the jail, which houses about 700 inmates. There are no signs of the lockdown ending anytime soon. + +The lockdown is just the latest crisis at the jail where Epstein died by suicide in August. Federal prosecutors allege that the two correctional officers assigned to watch Epstein's unit were snoozing and shopping on the internet, and later forged records to make it look like they checked in on him. + +All visitors and inmates are searched before entering the facility and go through metal detectors. They are supposed to leave personal belongings outside the jail. All mail is also screened by correctional staff. A gun smuggled inside would be a major security breach. + +In the past few days, officers have searched the facility and uncovered a sizable amount of contraband, including cellphones, but no gun has not been found, the people said. Investigators are trying to determine how the contraband has been entering into the facility. + +The Bureau of Prisons said the jail is on "modified operations" because of the investigation. The bureau provided no estimate for when normal operations could resume, raising legal concerns because the jail houses pretrial inmates while their cases are ongoing. + +In a statement to the AP, the agency said it must "take the time needed to complete a thorough investigation while actively working to return the facility to normal operations as soon as possible." + +David Patton, executive director and chief attorney of the Federal Defenders of New York, said it's a violation of inmates' constitutional rights to deny them visits with their lawyers. He also said it has affected legal proceedings. "Sentencings are being delayed. Hearings are being delayed," Patton said. "But the MCC acts as though it's perfectly fine for them to just shut down the entire institution to look for contraband. It's just not acceptable. They've got to be able to walk and chew gum at the same time." + +Patton said federal prison officials have refused to provide information about what has prompted the current lockdown, other than saying it is for "security concerns." They have not told the federal defenders that they are searching for a gun, he said. + +Patton said the chief judge in the Southern District of New York has been working with the U.S. Marshals Service to bring a small number of people to the courthouse for individual meetings with lawyers, but they're capped at just five per day. + +"It's just not nearly sufficient to deal with the need," he said. + +The agency said Thursday that it arranged for additional staff from other parts of the U.S. to assist in the investigation and ensure there is appropriate staffing at the jail. The agency said it "has maintained communication with stakeholders as needed" and held a meeting with the chief federal judge and public defender in Manhattan, along with prosecutors, the Marshals Service and probation officials. + +The agency also said it has discussed a plan to resume legal visits at the jail on Friday and expects to allow full legal visitation by next week. Visits with family members could resume as soon as this week, officials added. + +"The Bureau has been working closely with the stakeholders throughout this period to ensure those defendants with imminent court deadlines have the legal visits with their legal counsel as needed," the statement said. + +Inmates are being locked down for 24 hours a day and lawyers have been told that on some units the prisoners are being denied showers and being given cold meals in their cells. One inmate reported receiving peanut butter and jelly sandwiches for every meal since last Thursday. + +The bureau said inmates are on a periodic shower rotation, except for those in special housing units, who remain on a regular schedule. + +"All inmates have access to medical care and appointments and medical staff continue normal rounds on every floor," BOP said. + +## Akparanta + +### Federal correctional officer in Manhattan pleads guilty to sexually abusing female inmates + +NY Daily News + +By Stephen Rex Brown + +3/4/2020 + +A former Metropolitan Correctional Center officer pleaded guilty Wednesday to sexually abusing inmates as a lockdown at the troubled jail entered its seventh day. + +Cohn Akparanta, 43, copped to engaging in sexual acts with seven women at the federal jail. Prosecutors said one of the women was molested through the slot in the door of her solitary confinement cell. Akparanta pleaded guilty to abusive sexual contact and deprivation of civil rights. + +"As he has now admitted, Cohn Akparanta abused his position of authority as a correctional officer at the [the lockup] to sexually abuse at least seven inmates whose safety and security he was duty-bound to protect. This office has + +prosecuted, and will continue to prosecute, correctional officers who use their positions to engage in criminal conduct, and I encourage anyone with knowledge of this or similar criminal conduct involving correctional officers at the (the jail) to contact my office;' Manhattan U.S. Attorney Geoffrey Berman said. + +Akparanta, of Irvington, N.J., asked victims for their contact information so he could reach them after they were released from custody, prosecutors said. + +He smuggled contraband, including feminine hygiene products, into the jail for at least one victim in exchange for sexual acts. The depraved officer, who abused his victims between 2012 and 2018, took advantage of Bureau of Prisons policy that made feminine hygiene products available for purchase at the commissary. That policy was changed in 2017, making the products available free. + +The guilty plea in Manhattan Federal Court occurred while the troubled jail next door remained on lockdown despite mounting public pressure. + +The ban on family and attorney visits is because of a tip that a gun was smuggled into the jail. A search of the 12-story jail where Jeffrey Epstein killed himself uncovered a large amount of contraband — but no gun, the Daily News previously reported. + +Federal defenders have criticized the Bureau of Prisons for not providing information about the lockdown, which they say violates inmates' constitutional rights to an attorney. + +# Securities and Commodities Fraud + +Madoff + +Bernie Madoff should die in prison, US government says + +CNN By Jordan Valinsky 3/5/2020 + +New York (CNN Business) — Bernard Madoff should not be released early from his 150-year prison sentence, even though he has terminal kidney failure, federal prosecutors said Wednesday. + +The 81-year-old Madoff, who orchestrated the largest Ponzi scheme in history, asked for compassionate release from prison last month, saying he has less than 18 months to live. + +But the US Attorney's office for the southern district of New York said Madoff's crime was "unprecedented in scope and magnitude" and is "sufficient reason" to deny Madoff's request. + +"Since his sentencing, Madoff has demonstrated a wholesale lack of understanding of the seriousness of his crimes and a lack of compassion for his victims, underscoring that he is undeserving of compassionate release," the US Attorney's office wrote. + +Madoff was arrested in December 2008 on allegations that the prestigious asset management firm he ran in Manhattan was, in fact, a pyramid-type scheme that swindled billions of dollars from thousands of people. He pleaded guilty to 11 felony charges related to money laundering, perjury and falsifying financial documents. He began his prison term in July 2009. + +More than 500 victims wrote to the court about Madoff's early release request, with an "overwhelming" amount of them opposed. The court said the letters show "how deeply Madoff's crimes continue to affect his victims, many of whom, as one put it in a letter to the court, are iserv(ing) a kind of life sentence of [their) own." + +In one letter, a victim blamed her husband's death on the stress of losing money through Madoff's scheme. The woman acknowledged that Madoff is suffering with his condition, but she noted there are "many of his victims who are suffering and who will continue to suffer." + +The US Attorney's office also said it "clearly reckoned" with Madoffs medical condition and the fact that the sentence means he will die in prison. But because of his "continuing refusal to accept responsibility and show remorse," they stood by their decision. They acknowledged Madoff has kidney failure, and a doctor says he has about 18 months to live. But prosecutors also noted Madoff's condition has improved recently. + +Madoff has been serving his sentence at a federal prison in Butner, North Carolina. He initially submitted a compassionate release request in September to the Bureau of Prisons, which issued a denial in December. In a letter detailing the denial, the warden did not dispute Madoff's condition or his life expectancy, but noted that Madoff had refused dialysis. He re-started dialysis in November 2019, prosecutors said, and Madoff is able to care for himself. + +# Terrorism and International Narcotics + +## Schulte + +### Fate of ex-CIA employee charged with massive data leak in jury's hands + +CNN + +By Mark Morales + +3/4/2020 + +New York (CNN) — The fate of a former CIA employee charged with carrying out the largest leak of classified data in the agency's history, sits in the hands of a federal jury in New York. + +Attorneys have a painted different portrayals of Joshua Schulte, the 31-year-old computer coder who is accused of handing over reams of classified data to WikiLeaks in 2016. + +Prosecutors argued that Schulte was motivated by revenge for being denied access to computer systems and then took several measures to not only get this data, but to cover his tracks by erasing his record of having ever accessed the info. + +"Josh Schulte is no patriot. Far from it," said Assistant US Attorney Matthew Laroche in closing arguments on Monday. "He's vengeful and he's full of rage and he's committed crimes that have been devastating to our national security." + +Schutle's attorney, Sabrina Shroff, countered that prosecutors still have not made their case that it was definitely Schulte who stole the data. + +She argued that passwords were shared among CIA members who were each trained to grab data without leaving a trace and that another office worker could have easily taken the data instead of Schulte. She also argued that CIA and FBI investigators were more motivated to solve the case rather than find the real culprit. + +"The government still is not able to answer for you the very basic questions. In fact, quite weirdly, I tell you that there are more questions now than when this trial first began," Shroff said to jurors. + +Schulte faces several charges, including illegally gathering national defense information, illegal transmission of both lawfully and unlawfully possessed national defense information and even possession of child pornography. The jury in the case began deliberations on Tuesday. + +Schulte, who worked as a computer engineer within the CIA's Center for Cyber Intelligence, created cyber tools that could grab data undetected from computers. + +His issues at the CIA began in the summer of 2015 when he began to feud with management and a co-worker, ultimately filing a restraining order against the coworker in state court, court records show. Schulte and the co-worker were both transferred as a result of the feud. + +Investigators allege that Schulte became enraged when CIA officials wanted to hire a contractor to build a cyber tool similar to one he was building, prosecutors said. + +Then in April 2016, Schulte's administrative privileges on two projects were revoked. When Schulte's asked about the revoked privileges, an administrator told him that since he now worked in a different branch, he no longer had the clearance, prosecutors said. Schulte argued that he still needed access to keep working on his projects. + +Schulte then told the administrator that a branch supervisor said he should have his access reinstated. And while the administrator went to check with the branch manager, Schulte reinstated his own access, according to the records. + +Once he was caught, administrators denied Schulte's access to all computer systems. But during the deletion process, they missed a key, and Schulte still had access to a main system known as DELVAN. Schulte, who signed a memo stating that he wouldn't attempt to restore or give himself access to any other systems, signed in as an administrator to DEVLAN. + +On April 20, 2016, investigators say Schulte stole cyber tools and source code and transferred them to WikiLeaks, according to court records. He then went on to cover try and cover his tracks, erasing any and all traces of him accessing the computer system, prosecutors said. + +Schulte quit the CIA in November 2016. But in March 2017, WikiLeaks published the first installment of their Vault 7 leaks, which originated from two programs found on the DEVLAN system, court records show. + +WikiLeaks put out a press release to go with the information, saying that the data was provided anonymously by a source who wanted to raise policy questions, specifically about whether the CIA had overstepped its hacking capabilities exceeded its authority. + +Schulte, who also allegedly lied to CIA and FBI investigators to cover his tracks, was arrested in August 2017 on child pornography charges. He was indicted on the charges related to the data breach months later. + +While inside the Metropolitan Correctional Center where he was detained awaiting trial, Schulte was able to get access to a phone where he kept leaking information, this time to a Washington Post reporter, prosecutors said. + +He also created several social media accounts, including one under the name Jason Borne, a hat tip to the fictional Hollywood character that was a CIA operative who found himself on the run, prosecutors said. + +Prosecutors kept painting the picture of Schulte as an angry and vindictive former worker who wanted to get even with his managers using the data he allegedly stole. + +"And if there is one thing that is abundantly clear, it's that he felt like he was wronged. He was ready to retaliate, and he was ready to do anything -- anything -- to make it right in his mind," Laroche said in his closing statement. "That's exactly what he did at the CIA, and that's exactly what he tried to do again from prison, repeating that same pattern of anger, escalation, retaliation and lies." + +### Wikileaks Trial Juror Booted For Looking Up Lawyer Online + +Law360, New York (March 5, 2020, 5:27 PM EST) -- A Manhattan federal judge cut loose a juror from deliberations Thursday in the trial of Joshua Schulte, the former CIA coder accused of sending secrets to WikiLeaks, because she told fellow jurors she had looked up information online about a lawyer working on the trial. + +U.S. District Judge Paul A. Crotty cut the juror loose not long after the fourth day of deliberations began in a trial that opened Feb. 2. He then directed the remaining 11 jurors, nine women and two men, to continue their work. + +Schulte is charged with transmitting to WikiLeaks secrets he allegedly poached in 2016 from an elite CIA "digital weapons" team inside the agency's Center for Cyber Intelligence. The 31-year-old also allegedly attempted to transmit secrets after he was jailed by Judge Crotty in December 2017 for violating bail conditions. Schulte denies being the leaker. + +Judge Crotty had the option of pausing the trial to retrieve an alternate juror. That would have triggered a restart of deliberations. But he opted instead to move forward with a panel of 11, remarking that a restart could have delayed things even further. + +The excused juror, Sylwia Wiesenberg of Manhattan, disclosed her online searches in the course of deliberations, according to notes sent to Judge Crotty Wednesday afternoon and Thursday morning. She remarked that one lawyer, who was not named, "used to look so different" and also said she had "looked them up," the notes said. + +After getting the boot, Wiesenberg told reporters outside of the lower Manhattan courthouse where the trial is taking place she does not think Schulte is guilty of leaking national defense secrets, charges that could see him put away for decades. + +"I want solid proof," she said. "I don't think he did it — the most serious charges." + +Schulte's trial featured weeks of testimony from current and former CIA workers and from experts who probed the defendant's technological activities. The jury also saw Schulte's own writings, including a notebook that said he wanted to send secrets to WikiLeaks. But the defense argued it was all guesswork, asserting there was no smoking-gun exhibit. + +Prior to begin excused, Wiesenberg also remarked to her fellow jurors that she had read news articles about the case, jury notes said. The jury foreperson told Judge Crotty in a note that she "sternly" warned Wiesenberg not to discuss news articles. + +"She has to be excused," prosecutor Matthew Laroche of the Manhattan U.S. attorney's office said bluntly. Schulte's defense team asked for a mistrial but was denied. + +Judge Crotty also addressed a separate note, dated Wednesday, which complained that another juror was examining evidence on her own without deliberating. "She continues on her own path," that note read. + +To address that, the judge reread standard legal instructions, which essentially ask jurors to be open-minded. + +"You should consult with one another," he said. + +By the end of day Thursday, the jury had sent 22 notes, most asking for testimony and explanations of evidence. The jury was set to resume its deliberations Friday morning. + +Schulte is represented by the Law Offices of Sabrina Shroff, Edward Zas of the Federal Defenders of New York Inc. and the Law Office of James M. Branden. + +The government is represented by David Denton, Sidhardha Kamaraju and Matthew Laroche of the U.S. Attorney's Office for the Southern District of New York. + +The case is USA v. Schulte, case number 1:17-cr-00548, in the U.S. District Court for the Southern District of New York. WikiLeaks Trial Judge Cautious As Jury Signals Disharmony + +Law360 By Pete Brush 3/4/2020 + +Law360, New York (March 4, 2020, 5:17 PM EST) -- The Manhattan federal judge presiding over the trial of a former CIA coder accused of sending secrets to WikiLeaks took a careful approach Wednesday as signs of discord, including a note complaining that one juror is not listening to others, emerged from the jury room. + +U.S. District Judge Paul A. Crotty, who is overseeing the trial of Joshua Schulte, fielded a morning note saying a female juror was doing her own examination of evidence and failing to engage with the group. Late in the day he also took a note saying a juror had "prior information" about the case. + +Judge Crotty planned to huddle with lawyers to assess how to instruct the jury of 10 women and two men to go forward. He likely will re-read a portion of instructions they already have received, which asks them to deliberate in good faith and to listen to each other's viewpoints. + +Schulte is charged with transmitting to WikiLeaks secrets he allegedly poached in 2016 from an elite CIA "digital weapons" team inside the agency's Center for Cyber Intelligence. The 31-year-old Texan also allegedly attempted to transmit secrets after he was jailed by Judge Crotty in December 2017 for violating bail conditions. The defense concedes Schulte was a difficult employee but says he did not betray the CIA. + +The jury has now deliberated without reaching a verdict for about 14 hours over three days, peppering Judge Crotty with questions all the while. + +Wednesday's afternoon note, sent to the judge just before 3 p.m. and marked "urgent," said a juror may have gotten outside information about the case. + +"It came up during the course of deliberations," the note said. The note was vague in its detail, but it prompted the judge to cut the jury loose early to give prosecutors from the Manhattan U.S. attorney's office and Schulte's defense team time to review it. + +"It could be nothing," defense counsel Sabrina Shroff said outside of the presence of the jury. "Maybe they remember reading a newspaper article. Nobody knows." + +"We don't know," Judge Crotty said. + +The morning note, meanwhile, said jurors are concerned about a female juror's "attitude" toward the group. It said the juror has been examining evidence on her own without actively deliberating. + +"She continues on her own path," the note read. + +It was unclear whether the juror who was the subject of the morning note was even aware that it had been sent. + +All in all, Wednesday's notes were signs that deliberations may not be going smoothly. They followed an unusual missive from Tuesday afternoon, which asked whether Schulte has been diagnosed with Asperger's syndrome. Jurors have also asked Judge Crotty if the defendant used drugs. + +It was all part of a higher-than-normal volume of questions in the wake of a trial that was heavy on technical evidence and conducted in part under secrecy to protect the names of active CIA agents. Jurors have asked for transcripts of testimony from at least five witnesses among many other questions related to trial evidence. + +"It seems to be a very inquisitive jury, Your Honor," defense co-counsel Edward Zas remarked early in the day out of the presence of the jury. + +"We can't satisfy them," Judge Crotty quipped. + +Schulte is represented by the Law Offices of Sabrina Shroff, Edward Zas of the Federal Defenders of New York Inc. and the Law Office of James M. Branden. + +The government is represented by David Denton, Sidhardha Kamaraju and Matthew Laroche of the U.S. Attorney's Office for the Southern District of New York. + +The case is U.S. v. Schulte, case number 1:17-cr-00548, in the U.S. District Court for the Southern District of New York. + +# Violent and Organized Crime + +Ray + +### Accused Sarah Lawrence sex trafficker made nearly \$2m from victim: prosecutors Fox + +NY Post + +By Ben Feuerherd + +3/2/2020 + +Accused Sarah Lawrence sex trafficker Lawrence Ray made nearly \$2 million in just two years by forcing one of his victims into prostitution, federal prosecutors alleged in court Monday. + +Ray, who was ordered held without bail at the hearing in Manhattan federal court, kept records of the ill-gotten cash, a federal prosecutor said. + +One typed document shows that the unidentified woman handed over \$700,000 in 2017, according to prosecutors. In 2018, the same woman turned over more than \$1 million to the accused sex trafficker, a second ledger shows. Prosecutors believe the woman was seeing more and more clients to meet Ray's demands. + +The ledgers marked dates and amounts that prosecutors have matched to text messages sent by Ray and his associates. + +The cash payments were collected by a female associate of Ray's and deposited into bank accounts that he had access to, prosecutors said in court. + +The 60-year-old former friend of disgraced NYPD Commissioner Bernie Kerik allegedly created a Nxivm-like sex cult to prey on his daughter's classmates at Sarah Lawrence College — all while allegedly extorting the classmates. + +Ray's alleged conduct came to light in a 2019 New York magazine article, which sparked a federal investigation and led to his arrest in February. + +His defense attorney on Monday blasted the article as "salacious" reporting that led to sensationalized coverage of his case. + +It also emerged Monday that Ray was found in bed with another alleged female victim when federal agents arrested him in Piscataway, NJ, on Feb. 11. + +He forced that unidentified woman — a former college roommate of his daughter — to have sex with other men while he filmed, and berated her while he filmed her sobbing, prosecutors said. + +Authorities also recovered video of Ray grabbing her by the hair and physically throwing her out of the New Jersey house, prosecutors alleged. + +Prosecutors said Ray deprived that woman and another alleged victim who lived in the Piscataway house of sleep and food — abuse that "broke their spirits." + +They noted the accused sicko had installed a lock on the house's refrigerator door and subjected them both to harsh verbal abuse. + +At Monday's bail hearing, Ray's court-appointed defense attorney pleaded with the judge to release him on bail, arguing he had family to stay with in Staten Island and a friend who offered to put him up in New Jersey. + +Judge Kevin Fox sided with prosecutors, who highlighted the amount of evidence they had in the case and urged Ray to be kept behind bars. + +## Akparanta + +## Federal correctional officer in Manhattan pleads guilty to sexually abusing female inmates + +NY Daily News By Stephen Rex Brown 3/4/2020 + +A former Metropolitan Correctional Center officer pleaded guilty Wednesday to sexually abusing inmates as a lockdown at the troubled jail entered its seventh day. + +Colin Akparanta, 43, copped to engaging in sexual acts with seven women at the federal jail. Prosecutors said one of the women was molested through the slot in the door of her solitary confinement cell. Akparanta pleaded guilty to abusive sexual contact and deprivation of civil rights. + +"As he has now admitted, Colin Akparanta abused his position of authority as a correctional officer at the [the lockup] to sexually abuse at least seven inmates whose safety and security he was duty-bound to protect. This office has prosecuted, and will continue to prosecute, correctional officers who use their positions to engage in criminal conduct, and I encourage anyone with knowledge of this or similar criminal conduct involving correctional officers at the [the jail] to contact my office;' Manhattan U.S. Attorney Geoffrey Berman said. + +Akparanta, of Irvington, N.J., asked victims for their contact information so he could reach them after they were released from custody, prosecutors said. + +He smuggled contraband, including feminine hygiene products, into the jail for at least one victim in exchange for sexual acts. The depraved officer, who abused his victims between 2012 and 2018, took advantage of Bureau of Prisons policy that made feminine hygiene products available for purchase at the commissary. That policy was changed in 2017, making the products available free. + +The guilty plea in Manhattan Federal Court occurred while the troubled jail next door remained on lockdown despite mounting public pressure. + +The ban on family and attorney visits is because of a tip that a gun was smuggled into the jail. A search of the 12-story jail where Jeffrey Epstein killed himself uncovered a large amount of contraband — but no gun, the Daily News previously reported. + +Federal defenders have criticized the Bureau of Prisons for not providing information about the lockdown, which they say violates inmates' constitutional rights to an attorney. + +# Civil Rights + +## Akparanta + +### Federal correctional officer in Manhattan pleads guilty to sexually abusing female inmates + +NY Daily News + +By Stephen Rex Brown + +3/4/2020 + +A former Metropolitan Correctional Center officer pleaded guilty Wednesday to sexually abusing inmates as a lockdown at the troubled jail entered its seventh day. + +Cohn Akparanta, 43, copped to engaging in sexual acts with seven women at the federal jail. Prosecutors said one of the women was molested through the slot in the door of her solitary confinement cell. Akparanta pleaded guilty to abusive sexual contact and deprivation of civil rights. + +'As he has now admitted, Cohn Akparanta abused his position of authority as a correctional officer at the [the lockup] to sexually abuse at least seven inmates whose safety and security he was duty-bound to protect. This office has prosecuted, and will continue to prosecute, correctional officers who use their positions to engage in criminal conduct, and I encourage anyone with knowledge of this or similar criminal conduct involving correctional officers at the [the jail] to contact my office;' Manhattan U.S. Attorney Geoffrey Berman said. + +Akparanta, of Irvington, N.J., asked victims for their contact information so he could reach them after they were released from custody, prosecutors said. + +He smuggled contraband, including feminine hygiene products, into the jail for at least one victim in exchange for sexual acts. The depraved officer, who abused his victims between 2012 and 2018, took advantage of Bureau of Prisons policy that made feminine hygiene products available for purchase at the commissary. That policy was changed in 2017, making the products available free. + +The guilty plea in Manhattan Federal Court occurred while the troubled jail next door remained on lockdown despite mounting public pressure. + +The ban on family and attorney visits is because of a tip that a gun was smuggled into the jail. A search of the 12-story jail where Jeffrey Epstein killed himself uncovered a large amount of contraband — but no gun, the Daily News previously reported. + +Federal defenders have criticized the Bureau of Prisons for not providing information about the lockdown, which they say violates inmates' constitutional rights to an attorney. + +#### Chappaqua Businessman Pleads In Tax Evasion Case + +Patch + +By Lanning Taliaferro + +3/5/2020 + +CHAPPAQUA, NY - A Chappaqua businessman will be paying \$395,745 to the Internal Revenue Service as restitution for evading taxes from 2010-14. Antonio Nikc managed a number of family businesses that operate large rental buildings in New York and Connecticut, prosecutors said, and treated their bank accounts as a slush fund for luxury personal expenses. + +Nikc used money from those businesses to pay for more than \$1.5 million in personal expenses, including ocean-side condominiums in Miami, marina fees for a boat docked in Miami, airline tickets, luxury car payments, college tuition and allowances for his children, and purchases at jewelry stores, clothing stores, and restaurants. + +However, he failed to file any personal federal income tax returns and failed to pay any taxes due and owing on the income he received. In fact, he took steps to evade the assessment of taxes on that income, including paying for personal expenses out of the family business accounts and intentionally maintaining few assets in his own name. + +By the time the feds caught up, he had evaded \$395,745 in federal income taxes, prosecutors said. + +"While using the business accounts to fund his extravagant lifestyle, Nikc failed to file any personal income tax returns," U.S. Attorney Geoffrey S. Berman said in announcing the plea. "Now Nikc awaits sentencing for his crime." + +On Tuesday, the 58-year-old pleaded guilty to one count of tax evasion, which carries a maximum sentence of five years in prison. The maximum potential sentence in this case is prescribed by Congress and is provided here for informational purposes only, as any sentence will be determined by the judge. He is scheduled to be sentenced June 5 by U.S. District Judge Nelson S. Roman. + +IRS-CI Special Agent in Charge Jonathan D. Larsen said: "Our tax system is based on voluntary compliance and we will hold those accountable who fail to report their income out of greed. IRS-CI special agents will continue to pursue those who take advantage of our tax system." + +This case is being handled by the Office's White Plains Division. Assistant U.S. Attorney Jim Ligtenberg is in charge of the prosecution. + +# Matters of Interest + +Weinstein + +### Weinstein Undergoes Heart Procedure Before Transfer to Jail + +NYT + +By Jan Ransom + +3/5/2020 + +Harvey Weinstein underwent a heart procedure and was expected to be moved on Thursday from a hospital to New York City's notorious Rikers Island jail complex, his spokesman said. + +Mr. Weinstein, the once powerful film producer, was convicted last week of rape and criminal sexual assault after a trial in Manhattan that many saw as a milestone in the #MeToo movement. A judge ordered him held in jail until his sentencing on March 11. + +But hours after the verdict, Mr. Weinstein, 67, experienced extremely high blood pressure and heart palpitations, his lawyers said. He was taken directly from State Supreme Court in Manhattan to Bellevue Hospital Center, where he was treated for several days in a ward for prisoners. + +On Wednesday, Mr. Weinstein had a stent implanted to alleviate a blockage, his spokesman, Juda Engelmayer, said. + +The city's Department of Correction did not immediately respond to questions about Mr. Weinstein's condition. + +Mr. Weinstein is expected to be housed in the jail's North Infirmary Command under protective custody, his spokesman said. The facility consists of two buildings, one of which was built in 1932 as a hospital for inmates. + +Martin Horn, a former Department of Correction commissioner, said the facility was not "luxurious," but not "draconian" either. It contains about 10 cells on each block, as opposed to the nearly 30 on a typical Rikers cell block, he said, and once housed people with acute conditions like tuberculosis. + +Mr. Weinstein — who, friends have said, is terrified of being behind bars — faces up to 29 years in prison. He has hired a prison consultant to help him navigate the journey from life on the outside to life in a cell. + +Barr + +### On immigration, Attorney General Barr is his own Supreme Court. Judges and lawyers say that's a problem. + +The Washington Post + +By Kim Bellware + +3/5/2020 + +Attorney General William R Barr quietly intervened in an immigration asylum case last week when he issued a decision that narrowed the definition of torture for asylum seekers who invoke it as a grounds for staying in the United States. + +Barr used a process known as "certification," a historically little-used power of the attorney general that allows him to overrule decisions made by the Board of Immigration Appeals and set binding precedent. Immigration lawyers and judges say the Trump administration is using the power with greater frequency — to the point of abuse — as it seeks to severely limit the number of immigrants who can remain in the United States. The administration is also using it as a check on immigration judges whose decisions don't align with the administration's immigration agenda, experts say. + +The decision to intervene in a Mexican national's otherwise unremarkable asylum case is a warning to immigration board members that even their unpublished decisions are being scrutinized, former immigration judge Jeffrey Chase told The Washington Post via email. + +"In the past, such decisions flew under the radar," Chase wrote. + +Other critics said Barr's move should concern everyone — not just those in immigration. Half a dozen immigration experts who spoke to The Post said Barr's use of his certification power in this case erodes the neutrality and due process that should exist in immigration court. They also cited recent moves by Justice Department, such as creating an office to denaturalize immigrants or using an immigrant's confidential therapy notes in a deportation case against them, as evidence of the Trump administration's willingness to break norms to achieve its goals. + +"In American history, what happens to immigrants is a pretty good indication of what's going to happen to the rest of us," retired immigration judge J. Traci Hong told The Post. + +The Justice Department did not respond when asked to address concerns from immigration judges and lawyers about the recent decision to narrow the torture definition for asylum seekers. Nor did it respond to questions on whether it views the current remedies available to asylum seekers as overly broad. + +Hong, who retired as an immigration judge late last year amid what she described as pressure to speed up cases and deport more people, said the sheer number of times that attorneys general under President Trump have used the power to certify cases to themselves is cause for concern. + +"The power goes back decades, but in other administrations, it was used very rarely — kind of a nuclear option," Hong told The Post. "Certifying a case is a way for the attorney general to stamp his or her own views on immigration law and it's the quickest way to do it." + +The certification power was used just three times during President Bill Clinton's two terms, and four times during President Barack Obama's. President George W. Bush's attorneys general certified 16 cases over eight years, the highest of any administration since the 1950s, according to NBC News. + +By contrast, the Trump administration has used the power at least a dozen times in three years; in 2018, then-Attorney General Jeff Sessions certified eight cases to himself in an eight-month span. + +Proponents of the certification power argue that it's a necessary tool to correct erroneous immigration court decisions and quickly enact needed changes. Even immigration advocates who oppose the Trump administration's rate of certifying cases criticized the Obama administration for not invoking the power often enough over his two terms. + +Hong cited concern that certification could be used to circumvent the lengthy and detailed regulatory process, which can take years or even decades. Had Barr wanted to propose new standards for defining torture in asylum cases, she said, they would be subject to public notice, debate, revision and public comment. + +Holly Cooper, co-director of the Immigration Law Clinic at the University of California at Davis, points to other efforts by the Justice Department to change and speed up the immigration process to the point that, in her view, immigrants fighting their cases are not getting a fair shake. + +"The Trump administration's rhetoric has been 'the rule of law.' But one principle that has been recognized is whether you're a citizen or a noncitizen, you deserve due process," Cooper told The Post. "You're seeing a lot of really sloppy decision-making done expeditiously with no regard to the individual's rights. The Fifth Amendment — the due process clause — applies to immigration courts." + +Circuit courts under the judicial branch can check decisions made by immigration courts and the attorney general under the executive branch. Cooper said that while circuit courts like to give deference to executive branch departments, they will overturn decisions found to be made with flimsy justification. + +Dana Leigh Marks, president emeritus at the National Association of Immigration Judges who currently presides over immigration cases, said that can result in judges not knowing what guidance to follow. + +"The problem for those of us in the field right now is that we're being whipsawed between these radical departures in past precedent that aren't necessarily sustained long term," Marks said, speaking in her role as a NAIL member. + +Hong described the resulting environment in even starker terms: "It was like trying to perform surgery on a dodgeball court." + +What's happening with immigration courts could produce ripple effects in the wider justice system, particularly if immigration court decisions put forth by the attorney general clash with the circuit courts, Marks warned. + +Nicholas Biase + +Public Affairs + 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0000000000000000000000000000000000000000..e587074f11ac084df6c9ad0e078ec9bb27ac551e --- /dev/null +++ b/marker2/ds9/EFTA00088095/EFTA00088095.md @@ -0,0 +1,265 @@ +From: "Kochevar, Steven (USANYS)" To:' Co: " + +Subject: RE: Jeffrey Epstein-Related Touhy Requests + +Date: Fri, 31 Jul 2020 20:17:35 +0000 + +No, no response yet. I talked to McEnany this morning about the declaration in the Epstein FOIA case, and he said that he was very busy right now. I will ping him to make sure this doesn't drop, please feel free to follow up with him. Thanks. + +From: Sent: Friday, July 31, 2020 2:49 PM To: Kochevar, Steven (USANYS)‹ > Cc: Subject: FW: Jeffrey Epstein-Related Touhy Requests + +Steven, + +Did you get a response to this by any chance? We were hoping to have the materials go out by the end of this week, and I just realized I don't think I saw anything else on this since Tuesday, though apologies if I just missed it. + +thanks, Alex. + +From: Kochevar, Steven (USANYS) Sent: Tuesday, July 28, 2020 17:32 To: McEnany, John (USANYS) Cc: Jones, David (USANYS) >; (USANYS) cale>; I ca.; Subject: RE: Jeffrey Epstein-Related Touhy Requests + +John, + +Per our call yesterday, please find attached an updated letter responding to the Touhy request from the Epstein victim. The Maxwell team is okay with this version of the letter. Please let me know if this is what you had in mind, or happy to discuss/change things if not. + +Thanks, Steven + +From: Kochevar, Steven (USANYS) Sent: Sunday, July 26, 2020 10:10 PM To: McEnany, John (USANYS) Cc: Jones, David (USANYS) Subject: RE: Jeffrey Epstein-Related Touhy Requests (USANYS) < I>; + +Cc: (USANYS) (USANYS) ; aa; + +Subject: RE: Jeffrey Epstein-Related Touhy Requests + +Good by me + +From: Kochevar, Steven (USANYS) + +Sent: Monday, June 8, 2020 12:06 PM + +To: McEnany, John (USANYS) ‹ > + +Cc: (USANYS) (USANYS) ; I< >; + +Subject: RE: Jeffrey Epstein-Related Touhy Requests + +John, + +We have received another informal Touhy inquiry from an Epstein victim. Please find attached a letter to victim's counsel, outlining the Touhy process. This is basically the same letter we sent to Roberta Kaplan at the outset of the prior Touhy process. We intend to proceed along the same lines with this request as with the prior request. Please let me know if you have any edits or concerns. + +Thanks, Steven + +From: McEnany, John (USANYS) + +Sent: Friday, May 22, 2020 6:27 PM + +To: I < :>; Kochevar, Steven (USANYS) Cc: ) (USANYS) (USANYS) + +Subject: RE: Jeffrey Epstein-Related Touhy Requests + +Thanks for the further info. With apologies, I now think Steven was right in the first place: if plaintiffs ask us for the does and we don't have them then I guess it does make most sense for us to simply say, we don't have them, try SDFla and/or NDGA. SDFLa and NDGA may say, pound sand, and if plaintiffs subpoena one or the other of those districts, then we see if the subpoenaed district Touhy-refers the subpoena to Geoff as the "responsible" USA, and take it from there. So I am OK with Steven's plan for dealing with plaintiff's further requests as he outlines in his May 20 email. + +Sent: Friday, May 22, 2020 5:37 PM + +To: Kochevar, Steven (USANYS) < In; McEnany, John (USANYS) + +Cc: ) (USANYS) (USANYS) ‹ > + +Subject: RE: Jeffrey Epstein-Related Touhy Requests + +We do possess the FBI investigative files from the SDFL investigation. What we do not have, and avoided obtaining for a variety of reasons (including conflict issues, discovery issues, and a desire not to create even an appearance that we were stepping into the shoes of a district that was unable to prosecute due to the prior non-prosecution agreement) are any files specifically from the U.S. Attorney's Office in SDFL. As relevant here, for example, we do not have any materials relating to the purported immunity discussions relating te we have not identified any such materials in the FBI files, and we assume that any discussions or correspondence on that issue likely would have been between defense counsel and the SDFL USAO. + +On the civil side, I can't immediately think of a reason you guys shouldn't be able to make a request to either SDFL or NDGA, whichever is the right entity, for any such materials. We've just avoided literally any contact with SDFL on the criminal side. + +Let us know if any additional questions on this at all, we realize it's a little complex. + +From: Kochevar, Steven (USANYS) + +Sent: Friday, May 22, 2020 17:16 + +To: McEnany, John (USANYS) (USANYS) ‹ > (USANYS) + +Subject: RE: Jeffrey Epstein-Related Touhy Requests + +Cc: + +Understood. Thanks, John. David Jones thought this approach was reasonable, but I'll check with Sarah too. Overall, I don't think we have a ton of precedent for referring folks to another USAO on a Touhy, and certainly not to a third USAO in the referral context. + +Some information that might be useful in this that I don't have a complete understanding of—are the materials from the S.D. Fla. investigation available to us? As in, have we ever seen or used them? If not, is there a particular reason for that? We may be in the odd situation of technically having some purview over those materials by virtue of the Touhy regs, but without access to them. But please let me know if I'm overlooking some dimension of our cooperation (if any) with the other USAOs. + +Thanks, Steven + +From: McEnany, John (USANYS) + +Sent: Friday, May 22, 2020 4:34 PM + +To: Kochevar, Steven (USANYS)a; (USANYS) ‹ > (USANYS) + +Cc: + +Subject: RE: Jeffrey Epstein-Related Touhy Requests + +I have some hesitation on just referring them to NDGa for the SDFla investigative stuff. First, under Touhy section 16.22(6), the responsible USA is the USA for the district "where the issuing authority" is located. They + +actually have an action filed in this district, no? Like it or not, we may be stuck with dealing with their requests for does from the Florida investigation. Stephen, you might want to consult wiser Touhy heads in civ div, like Sarah for instance. Also, it is possible that Touhy does not fall within the scope of SDFla's recusal. I can't see NDGA racing to embrace doing Toukis on this. + +From: Kochevar, Steven (USANYS) + +Sent: Wednesday, May 20, 2020 7:24 PM + +To: IvicEnany, John (USANYS) (USANYS) (USANYS) + +Cc: + +Subject: RE: Jeffrey Epstein-Related Touhy Requests + +All, + +Closing the loop on this: we produced documents responsive to an Epstein victim's Touhy request about a month ago. The requesters got back to us (by phone) with a fairly lengthy list of follow-up questions about what we produced and additional/related demands. We don't have much responsive to many of their follow-ups, or do not think it would be appropriate to produce additional material they're seeking—for example, materials that are part of the ongoing investigation. Alex and I intend to have a call with requester's counsel to explain to them that we will not be producing anything further at this time. At this point, we don't plan to send them anything else in writing. + +One small wrinkle: they have asked us for materials from S.D. Fla.'s investigation (which we don't have) and asked whether they need to submit a separate request to that office. We intend to tell them that N.D. Ga. has stepped into the shoes of S.D. Fla. For Epstein purposes, that they can submit a request there (or to S.D. Fla.) for the materials they're seeking, and possibly provide them with a contact at N.D. Ga. if they ask. + +Please let us know if you have any concerns. We hope that this will be the last step on this request. + +Thanks, Steven + +From: McEnany, John (USANYS) + +Sent: Monday, April 20, 2020 5:52 PM + +To: Kochevar, Steven (USANYS) (USANYS) a> (USANYS) + +Cc: + +Subject: RE: Jeffrey Epstein-Related Touhy Requests + +I take it we fully know that Jane Doe i. + +I had a little pause on handing out the GJ subpoena, but since it's something previously disclosed to her, I can't see much of a problem disclosing it to her again. + +So I don't have a problem with you sending this out. Thanks for your work on this, Steven. + +-John + +From: Kochevar, Steven (USANYS) + +Sent: Thursday, April 16, 2020 7:07 PM + +To: McEnany, John (USANYS) (USANYS) (USANYS) + +Subject: RE: Jeffrey Epstein-Related Touhy Requests + +All, + +Please find attached a letter responding to the Touhy request for documents related to Jeffrey Epstein submitted by a victim who is a plaintiff in a civil suit against Epstein's estate. I am also attaching the documents to be produced in response to the request. Please let me know if you have any edits or concerns. If not, I plan to contact requester's counsel next week, let them know about the production, and send them the letter and the documents. I'm also attaching their request letter here. (Alex, Alison, and Maurene are signed off on the letter and gathered the documents.) + +Thanks, + +Steven + +From: + +Sent: Friday, January 3, 2020 8:49 PM + +To: Kochevar, Steven (USANYS) + +Cc: McEnany, John (USANYS) c: >; + +Subject: RE: Jeffrey Epstein-Related Touhy Requests + +Steven, + +(usANys)S; (USANYS) + +Thanks very much for drafting this, and I think generally it looks great. My only small thought would near the end, in the penultimate paragraph, where I'd suggest replacing the first two sentences with (something like): "My understanding is that you may intend to make a formal written request pursuant to the above-described regulations. [If you choose to submit . . .I" I say that only because the current language makes it sound like they were supposed to submit something in writing, or that they otherwise erred, when in fact what they actually asked for was just an explanation of the appropriate form in which to make a formal request—which they can do consistent with the regulations set forth in the letter. Does that sound alright? And of course on any of these I also entirely defer to John. + +thanks again, + +Alex. + +From: Kochevar, Steven (USANYS) + +Sent: Friday, January 03, 2020 12:55 + +To: + +Cc: McEnany, John (USANYS) <: >; sci l>: + +(USANYS) (USANYS) + +Subject: RE: Jeffrey Epstein-Related Touhy Requests + +All, + +Please find attached an initial letter to Kaplan Hecker re: the request for information related to Epstein. Please let me know if you have any edits or concerns. Once I have sign-off, I'll send to Robbie Kaplan (by mail and at rkaplanPkaplanhecker.com or let me know if I should use a different address). + +Alex, assuming there are not huge changes to be made here, I think the letter/email could just go out as the next contact with Robbie on this, but I leave it up to you if/how you want to separately give her notice that it's on the way. + +Thanks, Steven + +From: Kochevar, Steven (USANYS) + +Sent: Thursday, January 2, 2020 7:16 PM + +To: + +Cc: McEnany, John (USANYS) (USANYS) >. (USANYS) + +Subject: RE: Jeffrey Epstein-Related Touhy Requests + +Alex, + +All sounds good to me—thanks for the call and note. I'll circulate a draft of the initial letter. + +Thanks, Steven + +From: + +Sent: Thursday, January 2, 2020 7:10 PM + +To: Kochevar, Steven (USANYS) + +Cc: McEnany, John (USANYS) ; (USANYS) (USANYS) + +Subject: RE: Jeffrey Epstein-Related Touhy Requests + +Steven, + +Thanks for talking with me this evening about this, we appreciate it. To briefly memorialize our discussion, and to loop in everybody on the case on the criminal side, you'll be the point person for requests from civil plaintiffs / victims in connection with Epstein lawsuits, and we'll work with you on those requests given our knowledge of the relevant facts and materials. + +In terms of this first question from the plaintiff, which was essentially presented as a question of how they should go about making a request for certain materials possibly in the possession of the Government, we'll plan to take a look at the letter you draft that will essentially set forth the requirements for making a Touhy request (e.g., similar to, or including, the kind of information in John's example below), and separately sometime early next week I'll let plaintiff's counsel (Robbie Kaplan at Kaplan & Hecker) know that they can expect to hear from someone in our Civil Division, within approximately a week or so (of when that conversation occurs), and that we anticipate that communication will include the relevant requirements of making such a request. + +Please let me know if I'm forgetting anything, thanks again, and talk soon. + +Alex. + +From: McEnany, John (USANYS) + +Sent: Thursday, January 02, 2020 10:01 + +To: ‹ > Kochevar, Steven (USANYS) + +Subject: Jeffrey Epstein-Related Touhy Requests + +I spoke to Jeffrey O about continuing to use Steven as the POC to outsiders for Touhy requests for information relating to Jeffrey Epstein. (Thank you Steven!) Alex, please give Steven a call. Steven, FWIW, following is a markup of a "please give us a Touhy statement" email that I have used in the past. Alex anticipates that we will be getting additional requests stemming from civil litigation by alleged victims, so it would be useful to have some consistency here. Alex knows that the criminal AUSAs will have to do all the work digging for any pertinent information, but it will be useful to have another AUSA handle the actual communications, particularly since the criminal AUSAs may be dealing with the alleged victims as victim-witnesses in ongoing criminal matters. Thanks again, + +-John + +Here's some draft language you may or may not find useful: + +Dear XXX: + +I am the Assistant U.S. Attorney who will be handling the request that you made to AUSA Rossmiller for certain information relating to Jeffrey Epstein. To assist us in evaluating your request, we ask that you provide us with a detailed written statement of the litigation for which you seek this information; the pertinence of the information sought to your litigation; and the availability (or absence) of means in that litigation, including discovery, to obtain the information in question. This statement should be relatively thorough—Le, it should not assume that the persons reviewing your request will have any particular familiarity with the litigation in question. + +For your information, following are the general principles that govern disclosure, in unrelated litigation, of information obtained during the course of our official duties. Specifically, the response of federal agencies to subpoenas and other third-party discovery demands is largely governed by Department of Justice regulations, commonly referred to as Touhy regulations. See generally 5 U.S.C.A. § 301; United States ex rel. Touhy v. Ragen, 340 U.S. 462 (1951) (authorizing such regulations). These regulations dictate the procedure for obtaining a government employee's testimony or government records in state or federal proceedings. The Department of Justice has its own Touhy regulations that set out the procedure it follows in responding to demands for "production or disclosure" of information from the Department and its employees for use in state or federal court proceedings. See 28 C.F.R. §§ 16.21-16.29. These Touhy regulations channel review of such demands to the responsible United States Attorney, and then provide a set of procedures for the United States Attorney to follow when considering such demands. See id. §§ 16.22(b), 16.24. These regulations apply to both current and former Government employees. See id. §§ 16.21(a), 16.22(a), 16.28. The Department's Touhy regulations prohibit any Department employee from testifying or producing documents in a case in which the Government is not a party, even in response to a subpoena, "without prior approval of the proper Department official in accordance with §§ 16.24 and 16.25 of this part." Id. § 16.22(a). For matters concerning our Office, the proper official is the United States Attorney for the Southern District of New York. Id. § 16.22(b). To facilitate the process of determining whether such approval will be given, a party seeking such information must provide this Office with an affidavit or written statement setting forth the testimony sought and its relevance to the proceeding for which it is sought. See id. § 16.22(c), (d). We will then evaluate the request in light of governing rules of procedure in the case for which the information is sought, substantive law, and privilege; specific statutory prohibitions such as may apply to federal tax information, grand jury matters, or classified information; and the requirement of Deputy or Associate Attorney General approval where the disclosure would identify a confidential source over the objection of the agency or source, would interfere with enforcement proceedings or reveal sensitive investigative techniques, or would reveal trade secrets without the owner's consent. See 28 C.F.R. § 16.26. To the extent information sought derives from a criminal investigation, such information may be subject to, inter alia, the law enforcement privilege. The law enforcement privilege protects against the disclosure of information that would "reveal a confidential source or informant, . . reveal investigatory records compiled for law enforcement purposes . . . interfere with enforcement proceedings[,] or disclose investigative techniques and procedures . . .." Id. § 16.26(b)(4)-(5); see also In re City of New York, 607 F.3d 923 (2d Cir. 2010); In re Dept of Investigation of the City of New York, 856 F.2d 481, 484 (2d Cir. 1988); Tuite v. Henry, 181 F.R.D. 175, 176 (D.D.C. 1998) ("The federal law enforcement privilege is a qualified privilege designed to prevent disclosure of information that would be contrary to the public interest in the effective functioning of law enforcement"), aff'd, 203 F.3d 53 (D.C. Cir. 1999). The Government's privilege not to disclose material contained in the files of criminal + +investigations is well-recognized. *See In re Department of Investigation of the City of New York*, 856 F.2d at 483; *Friedman v. Bache Halsey Stuart Shields, Inc.*, 738 F.2d 1336, 1341 (D.C. Cir. 1984); *Kinoy v. Mitchell*, 67 F.R.D. 1, 11 (S.D.N.Y. 1975) (discussing privilege for files compiled in connection with a criminal investigation). To the extent documents are sought for use in state court proceedings, note that the Department's decision whether to authorize testimony or produce documents is not reviewable in state court. Review of the agency's decision may only be had pursuant to the federal Administrative Procedure Act in federal court. *See US. EPA v. Gen. Elec. Co.*, 197 F.3d 592, 598-99 (2d Cir. 1999) (review pursuant to Administrative Procedure Act), modified in part, 212 F.3d 689 (2d Cir. 2000); 5 U.S.C. § 702 (sovereign immunity waived to permit Administrative Procedure Act only in "a court of the United States"). Federal sovereign immunity bars any proceeding in state court to enforce a subpoena or otherwise compel testimony or production of documents. *See Louisiana v. Sparks*, 978 F.2d 226, 234-36 (5th Cir. 1992); *Boron Oil Co.*, 873 F.2d at 69-71; *see also*, e.g., *People v. Rodriguez*, 546 N.Y.S.2d 861, 862-63 (1st Dep't 1989) (holding that "state courts are without authority to compel production of such files without the federal government's consent"); *People v. Carbonaro*, 427 N.Y.S.2d 701, 702-03 (Kings Co. Sup. Ct. 1980) (quashing subpoena served on federal employee where Department of Justice ordered him not to comply); *Jacoby v. Delfiner*, 51 N.Y.S.2d 478, 479 (N.Y. Co. Sup. 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Fine with me if you reach out to McEnany also or instead of me. Is there any certain deadline we have or that we've communicated to their counsel? Thanks. + +--- + +**From:** Kochevar, Steven (USANYS) +**Sent:** Friday, July 31, 2020 4:18 PM +**To:** [REDACTED] <[REDACTED]> +**Cc:** [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> +**Subject:** RE: Jeffrey Epstein-Related Touhy Requests + +No, no response yet. I talked to McEnany this morning about the declaration in the Epstein FOIA case, and he said that he was very busy right now. I will ping him to make sure this doesn't drop, please feel free to follow up with him. Thanks. + +--- + +**From:** [REDACTED] <[REDACTED]> +**Sent:** Friday, July 31, 2020 2:49 PM +**To:** Kochevar, Steven (USANYS) <[REDACTED]> +**Cc:** [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> +**Subject:** FW: Jeffrey Epstein-Related Touhy Requests + +Steven, + +Did you get a response to this by any chance? We were hoping to have the materials go out by the end of this week, and I just realized I don't think I saw anything else on this since Tuesday, though apologies if I just missed it. + +thanks, +Alex. + +**From:** Kochevar, Steven (USANYS) <[REDACTED]> +**Sent:** Tuesday, July 28, 2020 17:32 +**To:** McEnany, John (USANYS) <[REDACTED]> +**Cc:** Jones, David (USANYS) <[REDACTED]>; [REDACTED] (USANYS) <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> +**Subject:** RE: Jeffrey Epstein-Related Touhy Requests + +John, + +Per our call yesterday, please find attached an updated letter responding to the Touhy request from the Epstein victim. The *Maxwell* team is okay with this version of the letter. Please let me know if this is what you had in mind, or happy to discuss/change things if not. + +Sent: Sunday, July 26, 2020 10:10 PM + +To: McEnany, John (USANYS) ‹ > + +Cc: Jones, David (USANYS) (USANYS) + +Subject: RE: Jeffrey Epstein-Related Touhy Requests + +John, + +Please find attached a letter responding to a Touhy request from an Epstein victim and the documents to be produced with it. The Maxwell team has signed off on this response. We anticipate that requester's counsel understands that the government has additional documents here and may press on why more are not being released. To attempt to address that issue up front, the letter notes that documents governed by 6(e) cannot be produced. + +Please let us know if you have any concerns. + +Thanks, Steven + +From: McEnany, John (USANYS) + +Sent: Monday, June 8, 2020 12:18 PM + +To: Kochevar, Steven (USANYS) ‹ > + +Cc: (USANYS) (USANYS) + +Subject: RE: Jeffrey Epstein-Related Touhy Requests + +Good by me + +From: Kochevar, Steven (USANYS) + +Sent: Monday, June 8, 2020 12:06 PM + +To: McEnany, John (USANYS) ‹ > + +Cc: (USANYS) (USANYS) + +Subject: RE: Jeffrey Epstein-Related Touhy Requests + +John, + +We have received another informal Touhy inquiry from an Epstein victim. Please find attached a letter to victim's counsel, outlining the Touhy process. This is basically the same letter we sent to Roberta Kaplan at the outset of the prior Touhy process. We intend to proceed along the same lines with this request as with the prior request. Please let me know if you have any edits or concerns. + +Thanks, Steven + +From: McEnany, John (USANYS) + +Sent: Friday, May 22, 2020 6:27 PM + +To: I •c >; Kochevar, Steven (USANYS) + +Thanks for the further info. With apologies, I now think Steven was right in the first place: if plaintiffs ask us for the does and we don't have them then I guess it does make most sense for us to simply say, we don't have them, try SDFla and/or NDGA. SDFLa and NDGA may say, pound sand, and if plaintiffs subpoena one or the other of those districts, then we see if the subpoenaed district Touhy-refers the subpoena to Geoff as the "responsible" USA, and take it from there. So I am OK with Steven's plan for dealing with plaintiff's further requests as he outlines in his May 20 email. + +From: + +Sent: Friday, May 22, 2020 5:37 PM + +To: Kochevar, Steven (USANYS) ca, McEnany, John (USANYS) + +Cc: I + +(USANYS) (USANYS) •fl• + +Subject: RE: Jeffrey Epstein-Related Touhy Requests + +We do possess the FBI investigative files from the SDFL investigation. What we do not have, and avoided obtaining for a variety of reasons (including conflict issues, discovery issues, and a desire not to create even an appearance that we were stepping into the shoes of a district that was unable to prosecute due to the prior non-prosecution agreement) are any files specifically from the U.S. Attorney's Office in SDFL. As relevant here, for example, we do not have any materials relating to the purported immunity discussions relating tc we have not identified any such materials in the FBI files, and we assume that any discussions or correspondence on that issue likely would have been between defense counsel and the SDFL USAO. + +On the civil side, I can't immediately think of a reason you guys shouldn't be able to make a request to either SDFL or NDGA, whichever is the right entity, for any such materials. We've just avoided literally any contact with SDFL on the criminal side. + +Let us know if any additional questions on this at all, we realize it's a little complex. + +From: Kochevar, Steven (USANYS) + +Sent: Friday, May 22, 2020 17:16 + +To: McEnany, John (USANYS) (USANYS) + +(USANYS) ‹ > + +Cc: (USANYS) >; + +Cc: + +Subject: RE: Jeffrey Epstein-Related Touhy Requests + +All, + +Please find attached a letter responding to the Touhy request for documents related to Jeffrey Epstein submitted by a victim who is a plaintiff in a civil suit against Epstein's estate. I am also attaching the documents to be produced in response to the request. Please let me know if you have any edits or concerns. If not, I plan to contact requester's counsel next week, let them know about the production, and send them the letter and the documents. I'm also attaching their request letter here. (Alex, Alison, and Maurene are signed off on the letter and gathered the documents.) + +Thanks, Steven + +From: + +Sent: Friday, January 3, 2020 8:49 PM + +To: Kochevar, Steven (USANYS) + +Cc: McEnany, John (USANYS) .>; (USANYS) ( USANYS) + +Subject: RE: Jeffrey Epstein-Related Touhy Requests + +Steven, + +Thanks very much for drafting this, and I think generally it looks great. My only small thought would near the end, in the penultimate paragraph, where I'd suggest replacing the first two sentences with (something like): "My understanding is that you may intend to make a formal written request pursuant to the above-described regulations. [If you choose to submit . .]" I say that only because the current language makes it sound like they were supposed to submit something in writing, or that they otherwise erred, when in fact what they actually asked for was just an explanation of the appropriate form in which to make a formal request—which they can do consistent with the regulations set forth in the letter. Does that sound alright? And of course on any of these I also entirely defer to John. + +thanks again, Alex. + +From: Kochevar, Steven (USANYS) + +Sent: Friday, January 03, 2020 12:55 + +To: + +Cc: McEnany, John (USANYS) (USANYS) >; (USANYS) + +All, + +Please find attached an initial letter to Kaplan Hecker re: the request for information related to Epstein. Please let me know if you have any edits or concerns. Once I have sign-off, I'll send to Robbie Kaplan (by mail and at rkaplan@kaplanhecker.com or let me know if I should use a different address). + +Alex, assuming there are not huge changes to be made here, I think the letter/email could just go out as the next contact with Robbie on this, but I leave it up to you if/how you want to separately give her notice that it's on the way. + +Thanks, Steven + +From: Kochevar, Steven (USANYS) + +Sent: Thursday, January 2, 2020 7:16 PM + +To: I + +Cc: McEnany, John (USANYS) (USANYS) (USANYS) + +Subject: RE: Jeffrey Epstein-Related Touhy Requests + +Alex, + +All sounds good to me—thanks for the call and note. I'll circulate a draft of the initial letter. + +Thanks, Steven + +From: + +Sent: Thursday, January 2, 2020 7:10 PM + +To: Kochevar, Steven (USANYS) + +Cc: McEnany, John (USANYS) c t'; (USANYS) (USANYS) + +Subject: RE: Jeffrey Epstein-Related Touhy Requests + +Steven, + +Thanks for talking with me this evening about this, we appreciate it. To briefly memorialize our discussion, and to loop in everybody on the case on the criminal side, you'll be the point person for requests from civil plaintiffs / victims in connection with Epstein lawsuits, and we'll work with you on those requests given our knowledge of the relevant facts and materials. + +In terms of this first question from the plaintiff, which was essentially presented as a question of how they should go about making a request for certain materials possibly in the possession of the Government, we'll plan to take a look at the letter you draft that will essentially set forth the requirements for making a Touhy request (e.g., similar to, or including, the kind of information in John's example below), and separately sometime early next week I'll let plaintiff's counsel (Robbie Kaplan at Kaplan & Hecker) know that they can expect to hear from someone in our Civil Division, within approximately a week or so (of when that conversation occurs), and that we anticipate that communication will include the relevant requirements of making such a request. + +From: McEnany, John (USANYS) + +Sent: Thursday, January 02, 2020 10:01 + +To: ; Kochevar, Steven (USANYS) + +Subject: Jeffrey Epstein-Related Touhy Requests + +Alex, Steven, + +I spoke to Jeffrey O about continuing to use Steven as the POC to outsiders for Touhy requests for information relating to Jeffrey Epstein. (Thank you Steven!) Alex, please give Steven a call. Steven, FWIW, following is a markup of a "please give us a Touhy statement" email that I have used in the past. Alex anticipates that we will be getting additional requests stemming from civil litigation by alleged victims, so it would be useful to have some consistency here. Alex knows that the criminal AUSAs will have to do all the work digging for any pertinent information, but it will be useful to have another AUSA handle the actual communications, particularly since the criminal AUSAs may be dealing with the alleged victims as victim-witnesses in ongoing criminal matters. Thanks again, + +-John + +Here's some draft language you may or may not find useful: + +Dear XXX: + +I am the Assistant U.S. Attorney who will be handling the request that you made to AUSA Rossmiller for certain information relating to Jeffrey Epstein. To assist us in evaluating your request, we ask that you provide us with a detailed written statement of the litigation for which you seek this information; the pertinence of the information sought to your litigation; and the availability (or absence) of means in that litigation, including discovery, to obtain the information in question. This statement should be relatively thorough—i.e., it should not assume that the persons reviewing your request will have any particular familiarity with the litigation in question. + +For your information, following are the general principles that govern disclosure, in unrelated litigation, of information obtained during the course of our official duties. Specifically, the response of federal agencies to subpoenas and other third-party discovery demands is largely governed by Department of Justice regulations, commonly referred to as Touhy regulations. See generally 5 U.S.C.A. § 301; United States a rel. Touhy v. Ragen, 340 U.S. 462 (1951) (authorizing such regulations). These regulations dictate the procedure for obtaining a government employee's testimony or government records in state or federal proceedings. The Department of Justice has its own Touhy regulations that set out the procedure it follows in responding to demands for "production or disclosure" of information from the Department and its employees for use in state or federal court proceedings. See 28 C.F.R. §§ 16.21-16.29. These Touhy regulations channel review of such demands to the responsible United States Attorney, and then provide a set of procedures for the United States Attorney to follow when considering such demands. See id. §§ 16.22(b), 16.24. These regulations apply to both current and former Government employees. See id. §§ 16.21(a), 16.22(a), 16.28. The Department's Touhy regulations prohibit any Department employee from testifying or producing documents in a case in which the Government is not a party, even in response to a subpoena, "without prior approval of the proper Department official in accordance with §§ 16.24 and 16.25 of this part." Id. § 16.22(a). For matters concerning our Office, the proper official is the United States Attorney for the Southern District of New York. Id. § 16.22(b). To facilitate the process of determining whether such approval will be given, a party seeking such information must provide this Office with an affidavit or written statement setting forth the testimony sought and its relevance to the proceeding for which it is sought. See id. § 16.22(c), (d). We will then evaluate the request in light of governing rules of procedure in the case for which the information is sought, substantive law, and privilege; specific statutory prohibitions such as may apply to federal tax information, grand jury matters, or classified information; and the requirement of Deputy or Associate Attorney General approval where the disclosure would identify a confidential source over the objection of the agency or source, would interfere with enforcement proceedings or reveal sensitive investigative + +techniques, or would reveal trade secrets without the owner's consent. See 28 C.F.R. § 16.26. To the extent information sought derives from a criminal investigation, such information may be subject to, *inter alia*, the law enforcement privilege. The law enforcement privilege protects against the disclosure of information that would “reveal a confidential source or informant, . . . reveal investigatory records compiled for law enforcement purposes . . . interfere with enforcement proceedings[,] or disclose investigative techniques and procedures . . . .” *Id.* § 16.26(b)(4)-(5); *see also In re City of New York*, 607 F.3d 923 (2d Cir. 2010); *In re Dep't of Investigation of the City of New York*, 856 F.2d 481, 484 (2d Cir. 1988); *Tuite v. Henry*, 181 F.R.D. 175, 176 (D.D.C. 1998) (“The federal law enforcement privilege is a qualified privilege designed to prevent disclosure of information that would be contrary to the public interest in the effective functioning of law enforcement”), *aff'd*, 203 F.3d 53 (D.C. Cir. 1999). The Government's privilege not to disclose material contained in the files of criminal investigations is well-recognized. *See In re Department of Investigation of the City of New York*, 856 F.2d at 483; *Friedman v. Bache Halsey Stuart Shields, Inc.*, 738 F.2d 1336, 1341 (D.C. Cir. 1984); *Kinoy v. Mitchell*, 67 F.R.D. 1, 11 (S.D.N.Y. 1975) (discussing privilege for files compiled in connection with a criminal investigation). To the extent documents are sought for use in state court proceedings, note that the Department's decision whether to authorize testimony or produce documents is not reviewable in state court. Review of the agency's decision may only be had pursuant to the federal Administrative Procedure Act in federal court. *See U.S. EPA v. Gen. Elec. Co.*, 197 F.3d 592, 598-99 (2d Cir. 1999) (review pursuant to Administrative Procedure Act), modified in part, 212 F.3d 689 (2d Cir. 2000); 5 U.S.C. § 702 (sovereign immunity waived to permit Administrative Procedure Act only in “a court of the United States”). Federal sovereign immunity bars any proceeding in state court to enforce a subpoena or otherwise compel testimony or production of documents. *See Louisiana v. Sparks*, 978 F.2d 226, 234-36 (5th Cir. 1992); *Boron Oil Co.*, 873 F.2d at 69-71; *see also*, e.g., *People v. Rodriguez*, 546 N.Y.S.2d 861, 862-63 (1st Dep't 1989) (holding that “state courts are without authority to compel production of such files without the federal government's consent”); *People v. Carbonaro*, 427 N.Y.S.2d 701, 702-03 (Kings Co. Sup. Ct. 1980) (quashing subpoena served on federal employee where Department of Justice ordered him not to comply); *Jacoby v. Delfiner*, 51 N.Y.S.2d 478, 479 (N.Y. Co. Sup. 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Same thing. + +Sent from my iPhone + +On Aug 4, 2020, at 4:28 PM, ) < wrote: + +Is the 3500 folder just the Witnesses & Cooperators folders, or is there another spot? Sorry if I'm missing / forgetting something. + +From: •c > Sent: Sunday, August 02, 2020 14:49 To: Subject: Fwd: Jeffrey Epstein-Related Touhy Requests + +With this in mind, could you please save the Touhy correspondence in the 3500 folder? Thanks. + +Sent from my iPhone + +Begin forwarded message: + +From: "a (USANYS)" • Date: Au ust 2 2020 at 2:30:39 PM EDT To: Cc: ' Subject: RE: Jeffrey Epstein-Related Touhy Requests SANYS)" (USANYS)" (USANYS)" + +Determinations under Touhy are somewhat discretionary and to the extent our Office exercised discretion to give the W something the W wanted, that could be construed as a benefit. Here, it's a benefit to her civil case. You can see how that might be developed on cross. + +From: Sent: Sunday, August 2, 2020 1:49 PM To: (USANYS) ; Cc: (USANYS) cc > (USANYS) (USANYS) Subject: RE: Jeffrey Epstein-Related Touhy Requests + +Curious about that view — it's not a benefit conferred upon her, in the sense that this avenue to obtain documents is available to literally any person. And the witness herself makes no statements whatsoever in the communications, nor are we providing anything that we aren't also providing to the defense in discovery. Is your view that the fact of production of materials is Giglio? Or that the substance of her attorney's request and the government's responsive letter is Giglio? Just want to make sure we understand the theory. + +thanks, + +From: S (USANYS) + +Sent: Sunday, August 02, 2020 13:44 + +To: ) < ;'; + +Cc: (USANYS) < (USANYS) >; (USANYS) < ; + +Subject: RE: Jeffrey Epstein-Related Touhy Requests + +BTW, I probably don't need to tell you, our Touhy communications with El are probably disclosable as Giglio info. + +From: (USANYS) < + +Sent: Tuesday, July 28, 2020 5:32 PM + +To: (USANYS) < + +Cc: (USANYS) < >; (USANYS) < + +Subject: RE: Jeffrey Epstein-Related Touhy Requests + +Per our call yesterday, please find attached an updated letter responding to the Touhy request from the Epstein victim. The Maxwell team is okay with this version of the letter. Please let me know if this is what you had in mind, or happy to discuss/change things if not. + +Thanks, + +From: (USANYS) + +Sent: Sunday, July 26, 2020 10:10 PM + +To: S (USANYS) < + +Cc: (USANYS) < >; >; (USANYS) < + +Subject: RE: Jeffrey Epstein-Related Touhy Requests + +Please find attached a letter responding to a Touhy request from an Epstein victim and the documents to be produced with it. The Maxwell team has signed off on this response. We anticipate that requester's counsel understands that the government has additional documents here and may press on why more are not being released. To attempt to address that issue up front, the letter notes that documents governed by 6(e) cannot be produced. + +Thanks, + +From: S (USANYS) •c > + +Sent: Monday, June 8, 2020 12:18 PM + +To: (USANYS) + +Cc: (USANYS) •< >; (USANYS) 1 S; + +Subject: RE: Jeffrey Epstein-Related Touhy Requests + +Good by me + +From: (USANYS) + +Sent: Monday, June 8, 202012:06 PM + +To: (USANYS)aa + +Cc: (USANYS) >; (USANYS) 'c >; + +Subject: RE: Jeffrey Epstein-Related Touhy Requests + +We have received another informal Touhy inquiry from an Epstein victim. Please find attached a letter to victim's counsel, outlining the Touhy process. This is basically the same letter we sent to Roberta Kaplan at the outset of the prior Touhy process. We intend to proceed along the same lines with this request as with the prior request. Please let me know if you have any edits or concerns. + +Thanks, + +From: (USANYS) + +Sent: Friday, May 22, 2020 6:27 PM + +To: cM > ; (USANYS) + +Cc: + +(USANYS) (USANYS) + +Subject: RE: Jeffrey Epstein-Related Touhy Requests + +Thanks for the further info. With apologies, I now think was right in the first place: if plaintiffs ask us for the docs and we don't have them then I guess it does make most sense for us to simply say, we don't have them, try SDFla and/or NDGA. SDFLa and NDGA may say, pound sand, and if plaintiffs subpoena one or the other of those districts, then we see if the subpoenaed district Touhy-refers the subpoena to Geoff as the "responsible" USA, and take it from there. So I am OK with plan for dealing with plaintiff's further requests as he outlines in his May 20 email. + +From: + +Sent: Friday, May 22, 2020 5:37 PM + +To: (USANYS) (USANYS) + +We do possess the FBI investigative files from the SDFL investigation. What we do not have, and avoided obtaining for a variety of reasons (including conflict issues, discovery issues, and a desire not to create even an appearance that we were stepping into the shoes of a district that was unable to prosecute due to the prior non-prosecution agreement) are any files specifically from the U.S. Attorney's Office in SDFL. As relevant here, for example, we do not have any materials relating to the purported immunity discussions relating to we have not identified any such materials in the FBI files, and we assume that any discussions or correspondence on that issue likely would have been between defense counsel and the SDFL USAO. + +On the civil side, I can't immediately think of a reason you guys shouldn't be able to make a request to either SDFL or NDGA, whichever is the right entity, for any such materials. We've just avoided literally any contact with SDFL on the criminal side. + +Let us know if any additional questions on this at all, we realize it's a little complex. + +From: (USANYS) + +Sent: Friday, May 22, 2020 17:16 + +To: S (USANYS) ; (USANYS) + +(USANYS) + +Cc: ) + +Subject: RE: Jeffrey Epstein-Related Touhy Requests + +Understood. Thanks, MI. thought this approach was reasonable, but I'll check with too. Overall, I don't think we have a ton of precedent for referring folks to another USAO on a Touhy, and certainly not to a third USAO in the referral context. + +Some information that might be useful in this that I don't have a complete understanding of—are the materials from the S.D. Fla. investigation available to us? As in, have we ever seen or used them? If not, is there a particular reason for that? We may be in the odd situation of technically having some purview over those materials by virtue of the Touhy regs, but without access to them. But please let me know if I'm overlooking some dimension of our cooperation (if any) with the other USAOs. + +Thanks, + +From: S (USANYS) + +Sent: Friday, May 22, 2020 4:34 PM + +To: (USANYS) >, (USANYS) + +(USANYS) + +Cc: ) + +Subject: RE: Jeffrey Epstein-Related Touhy Requests + +I have some hesitation on just referring them to NDGa for the SDFIa investigative stuff. First, under Touhy section 16.22(b), the responsible USA is the USA for the district "where the issuing authority" is located. They actually have an action filed in this district, no? Like it or not, we may be stuck with dealing with their requests for docs from the Florida investigation. Stephen, you might want to consult wiser Touhy heads in civ div, like for instance. Also, it is possible that Touhy does not fall within the scope of SDFla's recusal. I can't see NDGA racing to embrace doing Touhys on this. + +Sent: Wednesday, May 20, 2020 7:24 PM + +To: (USANYS) c (USANYS) + +(USANYS) < + +Cc: I >; + +Subject: RE: Jeffrey Epstein-Related Touhy Requests + +All, + +Closing the loop on this: we produced documents responsive to an Epstein victim's Touhy request about a month ago. The requesters got back to us (by phone) with a fairly lengthy list of follow-up questions about what we produced and additional/related demands. We don't have much responsive to many of their follow-ups, or do not think it would be appropriate to produce additional material they're seeking—for example, materials that are part of the ongoing investigation. and I intend to have a call with requester's counsel to explain to them that we will not be producing anything further at this time. At this point, we don't plan to send them anything else in writing. + +One small wrinkle: they have asked us for materials from S.D. Fla.'s investigation (which we don't have) and asked whether they need to submit a separate request to that office. We intend to tell them that N.D. Ga. has stepped into the shoes of S.D. Fla. For Epstein purposes, that they can submit a request there (or to S.D. Fla.) for the materials they're seeking, and possibly provide them with a contact at N.D. Ga. if they ask. + +Please let us know if you have any concerns. We hope that this will be the last step on this request. + +Thanks, + +From: S (USANYS) e M> + +Sent: Monday, April 20, 2020 5:52 PM + +To: (USANYS) (USANYS) c ; + +(USANYS) + +Cc: ) + +Subject: RE: Jeffrey Epstein-Related Touhy Requests + +I take it we fully know that Jane Doe is + +I had a little pause on handing out the GJ subpoena, but since it's something previously disclosed to her, I can't see much of a problem disclosing it to her again. + +So I don't have a problem with you sending this out. Thanks for your work on this, + +From: (USANYS) + +Sent: Thursday, April 16, 2020 7:07 PM + +To: S (USANYS) (USANYS) + +(USANYS) < + +Cc: I < ).; + +Please find attached a letter responding to the Touhy request for documents related to Jeffrey Epstein submitted by a victim who is a plaintiff in a civil suit against Epstein's estate. I am also attaching the documents to be produced in response to the request. Please let me know if you have any edits or concerns. If not, I plan to contact requester's counsel next week, let them know about the production, and send them the letter and the documents. I'm also attaching their request letter here. (M, and are signed off on the letter and gathered the documents.) + +Thanks, + +From: > + +Sent: Friday, January 3, 2020 8:49 PM + +To: (USANYS) + +Cc: S (USANYS) (USANYS) >; (USANYS) + +Subject: RE: Jeffrey Epstein-Related Touhy Requests + +1=, + +Thanks very much for drafting this, and I think generally it looks great. My only small thought would near the end, in the penultimate paragraph, where I'd suggest replacing the first two sentences with (something like): "My understanding is that you may intend to make a formal written request pursuant to the above-described regulations. [If you choose to submit . . .] 1 I say that only because the current language makes it sound like they were supposed to submit something in writing, or that they otherwise erred, when in fact what they actually asked for was just an explanation of the appropriate form in which to make a formal request—which they can do consistent with the regulations set forth in the letter. Does that sound alright? And of course on any of these I also entirely defer to + +thanks again, + +From: (USANYS) + +Cc: ' :/" < > + +Subject: RE: Jeffrey Epstein-Related Touhy Requests + +Date: Tue, 04 Aug 2020 20:28:04 +0000 + +Is the 3500 folder just the Witnesses & Cooperators folders, or is there another spot? Sorry if I'm missing / forgetting something. + +From: + +Sent: Sunday, August 02, 2020 14:49 + +To: + +Subject: Fwd: Jeffrey Epstein-Related Touhy Requests + +With this in mind, could you please save the Touhy correspondence in the 3500 folder? Thanks. + +Sent from my iPhone + +Begin forwarded message: + +From: "McEnany, John (USANYS)" < + +Date: August 2, 2020 at 2:30:39 PM EDT + +To: ' )11 + +Cc: "Jones, David (USANYS)" (USANYS)" , "Kochevar, Steven (USANYS)" + +Subject: RE: Jeffrey Epstein-Related Touhy Requests + +Determinations under Touhy are somewhat discretionary and to the extent our Office exercised discretion to give the W something the W wanted, that could be construed as a benefit. Here, it's a benefit to her civil case. You can see how that might be developed on cross. + +From: + +Sent: Sunday, August 2, 2020 1:49 PM + +To: McEnany, John (USANYS) ; + +Cc: Jones, David (USANYS) Steven (USANYS) (USANYS) Kochevar, + +Subject: RE: Jeffrey Epstein-Related Touhy Requests + +John, + +Curious about that view — it's not a benefit conferred upon her, in the sense that this avenue to obtain documents is available to literally any person. And the witness herself makes no statements whatsoever in the communications, nor are we providing anything that we aren't also providing to the defense in discovery. Is your view that the fact of production of materials is Giglio? Or that the substance of her attorney's request and the government's responsive letter is Giglio? Just want to make sure we understand the theory. + +From: McEnany, John (USANYS) + +Sent: Sunday, August 02, 2020 13:44 + +To: + +Cc: Jones, David (USANYS) ; (USANYS) Kochevar, Steven (USANYS) + +Subject: RE: Jeffrey Epstein-Related Touhy Requests + +BTW, I probably don't need to tell you, our Touhy communications with VB are probably disclosable as Giglio info. + +From: Kochevar, Steven (USANYS) + +Sent: Tuesday, July 28, 2020 5:32 PM + +To: McEnany, John (USANYS) + +Cc: Jones, David (USANYS) (USANYS) <= 1:•; ca; + +Subject: RE: Jeffrey Epstein-Related Touhy Requests + +John, + +Per our call yesterday, please find attached an updated letter responding to the Touhy request from the Epstein victim. The Maxwell team is okay with this version of the letter. Please let me know if this is what you had in mind, or happy to discuss/change things if not. + +Thanks, Steven + +From: Kochevar, Steven (USANYS) + +Sent: Sunday, July 26, 2020 10:10 PM + +To: McEnany, John (USANYS) ‹ > + +Cc: Jones, David (USANYS) (USANYS)Ifl; + +Subject: RE: Jeffrey Epstein-Related Touhy Requests + +John, + +Please find attached a letter responding to a Touhy request from an Epstein victim and the documents to be produced with it. The Maxwell team has signed off on this response. We anticipate that requester's counsel understands that the government has additional documents here and may press on why more are not being released. To attempt to address that issue up front, the letter notes that documents governed by 6(e) cannot be produced. + +Please let us know if you have any concerns. + +Thanks, Steven + +Cc: (USANYS) (USANYS) ; s'a; + +Subject: RE: Jeffrey Epstein-Related Touhy Requests + +Good by me + +From: Kochevar, Steven (USANYS) + +Sent: Monday, June 8, 2020 12:06 PM + +To: McEnany, John (USANYS) a> + +Cc: (USANYS) (USANYS) ; < >; + +Subject: RE: Jeffrey Epstein-Related Touhy Requests + +John, + +We have received another informal Touhy inquiry from an Epstein victim. Please find attached a letter to victim's counsel, outlining the Touhy process. This is basically the same letter we sent to Roberta Kaplan at the outset of the prior Touhy process. We intend to proceed along the same lines with this request as with the prior request. Please let me know if you have any edits or concerns. + +Thanks, + +Steven + +From: McEnany, John (USANYS) + +Sent: Friday, May 22, 2020 6:27 PM + +To: I a>; Kochevar, Steven (USANYS) Cc: (USANYS) < >;-(USANYS) + +Subject: RE: Jeffrey Epstein-Related Touhy Requests + +Thanks for the further info. With apologies, I now think Steven was right in the first place: if plaintiffs ask us for the docs and we don't have them then I guess it does make most sense for us to simply say, we don't have them, try SDFla and/or NDGA. SDFLa and NDGA may say, pound sand, and if plaintiffs subpoena one or the other of those districts, then we see if the subpoenaed district Touhy-refers the subpoena to Geoff as the "responsible" USA, and take it from there. So I am OK with Steven's plan for dealing with plaintiff's further requests as he outlines in his May 20 email. + +From: + +Sent: Friday, May 22, 2020 5:37 PM + +To: Kochevar, Steven (USANYS) McEnany, John (USANYS) Cc: ) (USANYS) (USANYS) + +Subject: RE: Jeffrey Epstein-Related Touhy Requests + +We do possess the FBI investigative files from the SDFL investigation. What we do not have, and avoided obtaining for a variety of reasons (including conflict issues, discovery issues, and a desire not to create even an appearance that we were stepping into the shoes of a district that was unable to prosecute due to the prior non-prosecution agreement) are any files specifically from the U.S. Attorney's Office in SDFL. As relevant here, for example, we do not have any materials relating to the purported immunity discussions relating to we have not identified any such materials in the FBI files, and we assume that any discussions or correspondence on that issue likely would have been between defense counsel and the SDFL USAO. + +On the civil side, I can't immediately think of a reason you guys shouldn't be able to make a request to either SDFL or NDGA, whichever is the right entity, for any such materials. We've just avoided literally any contact with SDFL on the criminal side. + +Let us know if any additional questions on this at all, we realize it's a little complex. + +From: Kochevar, Steven (USANYS) + +Sent: Friday, May 22, 2020 17:16 + +To: McEnany, John (USANYS) (USANYS) + +(USANYS) ‹ > + +Cc: + +Cc: se; + +Closing the loop on this: we produced documents responsive to an Epstein victim's Touhy request about a month ago. The requesters got back to us (by phone) with a fairly lengthy list of follow-up questions about what we produced and additional/related demands. We don't have much responsive to many of their follow-ups, or do not think it would be appropriate to produce additional material they're seeking—for example, materials that are part of the ongoing investigation. Alex and I intend to have a call with requester's counsel to explain to them that we will not be producing anything further at this time. At this point, we don't plan to send them anything else in writing. + +One small wrinkle: they have asked us for materials from S.D. Fla.'s investigation (which we don't have) and asked whether they need to submit a separate request to that office. We intend to tell them that N.D. Ga. has stepped into the shoes of S.D. Fla. For Epstein purposes, that they can submit a request there (or to S.D. Fla.) for the materials they're seeking, and possibly provide them with a contact at N.D. Ga. if they ask. + +Please let us know if you have any concerns. We hope that this will be the last step on this request. + +Thanks, Steven + +From: McEnany, John (USANYS) + +Sent: Monday, April 20, 2020 5:52 PM + +To: Kochevar, Steven (USANYS) (USANYS) (USANYS) + +Cc: + +Subject: RE: Jeffrey Epstein-Related Touhy Requests + +I take it we fully know that Jane Doe is + +I had a little pause on handing out the GJ subpoena, but since it's something previously disclosed to her, I can't see much of a problem disclosing it to her again. + +So I don't have a problem with you sending this out. Thanks for your work on this, Steven. + +-John + +From: Kochevar, Steven (USANYS) + +Sent: Thursday, April 16, 2020 7:07 PM + +To: McEnany, John (USANYS) (USANYS) (USANYS) + +Cc: + +Subject: RE: Jeffrey Epstein-Related Touhy Requests + +All, + +Please find attached a letter responding to the Touhy request for documents related to Jeffrey Epstein submitted by a victim who is a plaintiff in a civil suit against Epstein's estate. I am also attaching the documents to be produced in response to the request. Please let me know if you have any edits or concerns. If not, I plan to contact requester's counsel next week, let them know about the production, and send them the letter and the documents. I'm also attaching their request letter here. (Alex, Alison, and Maurene are signed off on the letter and gathered the documents.) + +Sent: Friday, January 3, 2020 8:49 PM + +To: Kochevar, Steven (USANYS) + +Cc: McEnany, John (USANYS) c: >; (usANys)S; (USANYS) + +Subject: RE: Jeffrey Epstein-Related Touhy Requests + +Steven, + +Thanks very much for drafting this, and I think generally it looks great. My only small thought would near the end, in the penultimate paragraph, where I'd suggest replacing the first two sentences with (something like): "My understanding is that you may intend to make a formal written request pursuant to the above-described regulations. [If you choose to submit .. .I" I say that only because the current language makes it sound like they were supposed to submit something in writing, or that they otherwise erred, when in fact what they actually asked for was just an explanation of the appropriate form in which to make a formal request—which they can do consistent with the regulations set forth in the letter. Does that sound alright? And of course on any of these I also entirely defer to John. + +thanks again, Alex. + +From: Kochevar, Steven (USANYS) + +Sent: Friday, January 03, 2020 12:55 + +To: + +Cc: McEnany, John (USANYS) I (USANYS) (USANYS) + +Subject: RE: Jeffrey Epstein-Related Touhy Requests + +All, + +Please find attached an initial letter to Kaplan Hecker re: the request for information related to Epstein. Please let me know if you have any edits or concerns. Once I have sign-off, I'll send to Robbie Kaplan (by mail and at rkaplanPkaplanhecker.com or let me know if I should use a different address). + +Alex, assuming there are not huge changes to be made here, I think the letter/email could just go out as the next contact with Robbie on this, but I leave it up to you if/how you want to separately give her notice that it's on the way. + +Thanks, Steven + +From: Kochevar, Steven (USANYS) + +Sent: Thursday, January 2, 2020 7:16 PM + +To: + +Cc: McEnany, John (USANYS) < fr; (USANYS) (USANYS) + +Subject: RE: Jeffrey Epstein-Related Touhy Requests + +Thanks, Steven + +From: + +Sent: Thursday, January 2, 2020 7:10 PM + +To: Kochevar, Steven (USANYS) + +Cc: McEnany, John (USANYS) ca›;
: (USANYS) (USANYS) + +Subject: RE: Jeffrey Epstein-Related Touhy Requests + +Steven, + +Thanks for talking with me this evening about this, we appreciate it. To briefly memorialize our discussion, and to loop in everybody on the case on the criminal side, you'll be the point person for requests from civil plaintiffs / victims in connection with Epstein lawsuits, and we'll work with you on those requests given our knowledge of the relevant facts and materials. + +In terms of this first question from the plaintiff, which was essentially presented as a question of how they should go about making a request for certain materials possibly in the possession of the Government, we'll plan to take a look at the letter you draft that will essentially set forth the requirements for making a Touhy request (e.g., similar to, or including, the kind of information in John's example below), and separately sometime early next week I'll let plaintiff's counsel (Robbie Kaplan at Kaplan & Hecker) know that they can expect to hear from someone in our Civil Division, within approximately a week or so (of when that conversation occurs), and that we anticipate that communication will include the relevant requirements of making such a request. + +Please let me know if I'm forgetting anything, thanks again, and talk soon. + +Alex. + +From: McEnany, John (USANYS) + +Sent: Thursday, January 02, 2020 10:01 + +To: ; Kochevar, Steven (USANYS) + +Subject: Jeffrey Epstein-Related Touhy Requests + +Alex, Steven, + +I spoke to Jeffrey 0 about continuing to use Steven as the POC to outsiders for Touhy requests for information relating to Jeffrey Epstein. (Thank you Steven!) Alex, please give Steven a call. Steven, FWIW, following is a markup of a "please give us a Touhy statement" email that I have used in the past. Alex anticipates that we will be getting additional requests stemming from civil litigation by alleged victims, so it would be useful to have some consistency here. Alex knows that the criminal AUSAs will have to do all the work digging for any pertinent information, but it will be useful to have another AUSA handle the actual communications, particularly since the criminal AUSAs may be dealing with the alleged victims as victim-witnesses in ongoing criminal matters. Thanks again, + +-John + +Here's some draft language you may or may not find useful: + +Dear XXX: + +I am the Assistant U.S. Attorney who will be handling the request that you made to AUSA Rossmiller for certain information relating to Jeffrey Epstein. To assist us in evaluating your request, we ask that you provide us with a detailed written statement of the litigation for which you seek this information; the pertinence of the information sought to your litigation; and the availability (or absence) of means in that litigation, including discovery, to obtain the information in question. This statement should be relatively thorough—i.e., it should not assume that the persons reviewing your request will have any particular familiarity with the litigation in question. + +For your information, following are the general principles that govern disclosure, in unrelated litigation, of information obtained during the course of our official duties. Specifically, the response of federal agencies to subpoenas and other third-party discovery demands is largely governed by Department of Justice regulations, commonly referred to as Touhy regulations. See generally 5 U.S.C.A. § 301; United States ex rel. Touhy v. Ragen, 340 U.S. 462 (1951) (authorizing such regulations). These regulations dictate the procedure for obtaining a government employee's testimony or government records in state or federal proceedings. The Department of Justice has its own Touhy regulations that set out the procedure it follows in responding to demands for "production or disclosure" of information from the Department and its employees for use in state or federal court proceedings. See 28 C.F.R. §§ 16.21-16.29. These Touhy regulations channel review of such demands to the responsible United States Attorney, and then provide a set of procedures for the United States Attorney to follow when considering such demands. See id. §§ 16.22(b), 16.24. These regulations apply to both current and former Government employees. See id. §§ 16.21(a), 16.22(a), 16.28. The Department's Touhy regulations prohibit any Department employee from testifying or producing documents in a case in which the Government is not a party, even in response to a subpoena, "without prior approval of the proper Department official in accordance with §§ 16.24 and 16.25 of this part." Id. § 16.22(a). For matters concerning our Office, the proper official is the United States Attorney for the Southern District of New York. Id. § 16.22(b). To facilitate the process of determining whether such approval will be given, a party seeking such information must provide this Office with an affidavit or written statement setting forth the testimony sought and its relevance to the proceeding for which it is sought. See id. § 16.22(c), (d). We will then evaluate the request in light of governing rules of procedure in the case for which the information is sought, substantive law, and privilege; specific statutory prohibitions such as may apply to federal tax information, grand jury matters, or classified information; and the requirement of Deputy or Associate Attorney General approval where the disclosure would identify a confidential source over the objection of the agency or source, would interfere with enforcement proceedings or reveal sensitive investigative techniques, or would reveal trade secrets without the owner's consent. See 28 C.F.R. § 16.26. To the extent information sought derives from a criminal investigation, such information may be subject to, inter alia, the law enforcement privilege. The law enforcement privilege protects against the disclosure of information that would "reveal a confidential source or informant, . . . reveal investigatory records compiled for law enforcement purposes . . . interfere with enforcement proceedings[,] or disclose investigative techniques and procedures . ." Id. § 16.26(b)(4)-(5); see also In re City of New York, 607 F.3d 923 (2d Cir. 2010); In re Dep't of Investigation of the City of New York 856 F.2d 481, 484 (2d Cir. 1988); Tuite v. Henry, 181 F.R.D. 175, 176 (D.D.C. 1998) ("The federal law enforcement privilege is a qualified privilege designed to prevent disclosure of information that would be contrary to the public interest in the effective functioning of law enforcement"), aff 'd, 203 F.3d 53 (D.C. Cir. 1999). The Government's privilege not to disclose material contained in the files of criminal investigations is well-recognized. See In re Department of Investigation of the City of New York, 856 F.2d at 483; Friedman v. Bache Halsey Stuart Shields, Inc., 738 F.2d 1336, 1341 (D.C. Cir. 1984); Kinoy v. Mitchell, 67 F.R.D. I, I1 (S.D.N.Y. 1975) (discussing privilege for files compiled in connection with a criminal investigation). To the extent documents are sought for use in state court proceedings, note that the Department's decision whether to authorize testimony or produce documents is not reviewable in state court. Review of the agency's decision may only be had pursuant to the federal Administrative Procedure Act in federal court. See US. EPA v. Gen. Elec. Co., 197 F.3d 592, 598-99 (2d Cir. 1999) (review pursuant to Administrative Procedure Act), modified in part, 212 F.3d 689 (2d Cir. 2000); 5 U.S.C. § 702 (sovereign immunity waived to permit Administrative Procedure Act only in "a court of the United States"). Federal sovereign immunity bars any proceeding in state court to enforce a subpoena or otherwise compel testimony or production of documents. See Louisiana v. Sparks, 978 F.2d 226, 234-36 (5th Cir. 1992); Boron Oil Co., 873 F.2d at 69-71; see also, e.g., People v. Rodriguez, 546 N.Y.S.2d 861, 862-63 (1st Dep't 1989) (holding that "state courts are without authority to compel production of such files without the + +federal government's consent"); People v. Carbonaro, 427 N.Y.S.2d 701, 702-03 (Kings Co. Sup. Ct. 1980) (quashing subpoena served on federal employee where Department of Justice ordered him not to comply); Jacoby v. De!finer, 51 N.Y.S.2d 478, 479 (N.Y. Co. Sup. 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It should get there tomorrow. + +From: Sent: Monday, August 10, 2020 3:30 PM To: Cc: >; + +Subject: RE: new materials for Maxwell upload to Relativity + +Hello, + +I was just checking to see if the hard drive was sent out to arrive today? + +Thank you. + +From: Sent: Tuesday, August 4, 2020 1:48 PM To: Cc: < )'; + +Subject: RE: new materials for Maxwell upload to Relativity + +I know you're on vacation this week, but wanted to very briefly follow up on the below — I'm going to ask to mail you the thumb drive referenced below, which has folders for five devices (NYCO24332, NYCO24369, NYCO24369 1, NYCO24372, and NYCO24384) on this coming Monday, so that you'll be around when it arrives (and in case you have to sign for it). Per usual, if you could please take a look at it when you receive it, and then send on to PAE for processing and upload to Relativity, that would be great. Thank you!! + +From: Sent: Tuesday, August 04, 2020 13:44 To: Cc: C + +![Black redacted area with a white border and a small white triangle in the top left corner.]()Following up on the below, thanks for those responses, that's very useful. In terms of the one outstanding item, in the thumb drive I received from ██████ yesterday with CART materials, NYC027913 is not included, so we are still missing that one. + +But I do see that each of the items with the “Included next round” label from the most recent spreadsheet (attached, with those items highlighted in red) are included, so that’s helpful, thanks. + +In terms of any of the folders that have been produced so far, I know that you've sent supplemental materials on a handful of them (approximately seven total, I think) – do you currently expect to send any other supplemental materials for any of the devices we've received so far? Or are we fully complete? + +And then assuming those are all fully complete, or once they are, the only items pending will be the devices highlighted in gray in the attached, which we understand are being processed for hardware recovery. + +thanks, + +[Redacted] + +From: [REDACTED] > + +Sent: Monday, August 03, 2020 19:17 + +To: [REDACTED] <[REDACTED]> + +Cc: [REDACTED] >; [REDACTED] >; + +[REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] + +[REDACTED] >; [REDACTED] < [REDACTED] >; [REDACTED] ([REDACTED]) + +[REDACTED] + +**Subject:** RE: [EXTERNAL EMAIL] - RE: Epstein Evidence status + +![A solid black rectangular bar on the right side of the page.]()Sorry I didn't get back sooner. It's been kinda crazy. I'll answer your questions in order, so match them up. I'm going off what I can see on my phone. + +The final items were given to ██████████. She should have them. Reach out to her for delivery. + +The 3 folders you mention contain supplemental files, do not ignore them. + +I am pretty sure NYC027913 is included with the items ██████████ has. If not, please let me know. + +As far as the old questions, you should have everything now. + +The zero byte files are just that. Sometimes the software will recover either file headers, or items off the directory listings, but no actual content. It lists them as zero length files. + +Need anything further, let me know. + +On Aug 3, 2020 3:33 PM, "[REDACTED]" <[REDACTED]> wrote: + +- 1. On this past Sunday and Monday, you had said you had you had additional materials you planned to get to us on Monday. I don't believe we ever received anything additional this past week. Are those still pending, and if so, when can we get those materials? +- 2. There were three folders that were included in the first disc you provided to us, but then also provided again on the most recent disc. Those folders are: NYC024328, NYC024366, and NYC024392. Can you please let us know why those were provided twice? In particular, we need to know whether any supplemental information is in the new folders with those NYC numbers, or whether we can ignore them on the recent disc because we already received them. +- 3. One item is listed on your spreadsheet as having been provided on 7/23, but it was not on the most recent disc you sent. That item is: NYC027913 (row 40 in your spreadsheet). + +In case it's useful, I'm attaching a version of the spreadsheet you put on the disc, but with all the items we received folders for on the most recent hard drive highlighted in yellow. + +Separately, we're still waiting on answers to the questions from Thursday and Friday, July 23 and 24. To refresh, those questions are: + +- 4. Comparing your most recent spreadsheet to the prior one, and leaving aside the "Nothing for Southern" designations as well as the NYC numbers that look like they're for the desktops that held the actual drives we're looking at (such as NYC024385, 387, 389, 391, and 393, and NYC027909), I think there are just three additional devices listed here that weren't on the spreadsheet you previously sent. I have those as: NYC024328 (row 10), NYC024367 (row 62), and NYC027910 (row 96). Please confirm that these were added, and also that we're not missing any? I believe those were all provided on the first disc. +- 5. As previously mentioned, the vendor has advised that in the initial seven devices provided, there were approximately 71,000 documents that are zero bytes (i.e., empty files). They are listed in the second attached spreadsheet. Is that accurate? Or does that reflect some issue with the extraction process? + +thanks, + +![](_page_2_Picture_6.jpeg) + +From: + +Sent: Friday, July 24, 2020 15:09 + +To: + +Cc: >; + +Subject: [EXTERNAL EMAIL] - RE: Epstein Evidence status + +I don't have the evidence in front of me, but it is probably accurate. It is not unusual for the software to find such files. I will review Monday to make sure. As to your questions from last night, the sheet should be comprehensive. I only recall 1 addition, but I am sure that what I have is reflected in the sheet. As for the items in dark grey, there are 2 servers with multiple drives. Some of those drives have physically failed. We have to get them to one of our HQ specialists for recovery. Since they are physically broken, data recovery may or may not be possible. It can be a very long process. We will get that moving ASAP. Need anything else, let me know. + +On Jul 24, 2020 2:20 PM, " )11 wrote: + +In addition to the pending questions below, we've been advised by the vendor that is reviewing the initial seven devices (that were provided on a per-device extraction basis, as previously discussed) that those materials include approximately 71,000 documents that are zero bytes (i.e., empty files). They are listed in the attached spreadsheet. + +Is that accurate? Or does that reflect some issue with the extraction process? + +thanks, + +From: + +Sent: Thursday, July 23, 2020 18:08 + +To: + +Cc: >; + +Subject: RE: Epstein Evidence status + +This is very helpful, thank you. Comparing this to the prior spreadsheet, and leaving aside the "Nothing for Southern" designations as well as the NYC numbers that look like they're for the desktops that held the actual drives we're looking at (such as NYC024385, 387, 389, 391, and 393, and NYC027909), I think there are just three additional devices listed here that weren't on the spreadsheet you previously sent. I have those as: + +- 1. NYC024328 (row 10) +- 2. NYC024367 (row 62) +- 3. NYC027910 (row 96) + +Could you please confirm that I have those additions correct, and that I'm not missing any? And it looks like all of those were included in the drive you provided today. + +I also see there are some drives that are still being processed, including NYC024376 through 380 and several drives in NYC024395 — could you please let us know what that means? + +Thanks very much, and we'll circle back if any issues with anything we received today, which should get to in the next day or two. + +thanks again, + +To: + +Cc: + +Subject: Epstein Evidence status + +Here is the up to date spreadsheet. I color coded things to hopefully make it easier. There are 5 items I have to get you (as we discussed this morning) Those should take another day or 2, so looking at Monday/Tuesday for that. Any questions, let me know. + +![](_page_4_Picture_5.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00088129/EFTA00088129.metadata.json b/marker2/ds9/EFTA00088129/EFTA00088129.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..a0dd9970cb3e5e04159bc2fe1212563ae3fe6e55 --- /dev/null +++ b/marker2/ds9/EFTA00088129/EFTA00088129.metadata.json @@ -0,0 +1,201 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00088129.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 5, + "chars": 8180, + "elapsed_seconds": 167.61, + "image_assets": [ + "_page_2_Picture_6.jpeg", + "_page_4_Picture_5.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 64 + ], + [ + "Line", + 30 + ], + [ + "Text", + 13 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 68 + ], + [ + "Text", + 54 + ], + [ + "Line", + 31 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 71 + ], + [ + "Line", + 35 + ], + [ + "Text", + 10 + ], + [ + "ListItem", + 5 + ], + [ + "ListGroup", + 2 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 3, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 63 + ], + [ + "Line", + 31 + ], + [ + "Text", + 17 + ], + [ + "ListItem", + 3 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 4, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 15 + ], + [ + "Line", + 8 + ], + [ + "Text", + 5 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00088129" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00088129/_page_2_Picture_6.jpeg b/marker2/ds9/EFTA00088129/_page_2_Picture_6.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..c6ec55c6aea0c5f9b930d2b24f39f79ffee8c694 --- /dev/null +++ b/marker2/ds9/EFTA00088129/_page_2_Picture_6.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:0548f8dfef50866eda94c87551323b15c883cab616d8be30dbc8d9c22c344b69 +size 3620 diff --git a/marker2/ds9/EFTA00088129/_page_4_Picture_5.jpeg b/marker2/ds9/EFTA00088129/_page_4_Picture_5.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..0d411d5a7ecc3bbe4d8077235727401b2c645796 --- /dev/null +++ b/marker2/ds9/EFTA00088129/_page_4_Picture_5.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:0ac3998afe52faf34aca17b0b8396281b4f064da130e9a0a3243c3435633285c +size 4634 diff --git a/marker2/ds9/EFTA00088134/EFTA00088134.md b/marker2/ds9/EFTA00088134/EFTA00088134.md new file mode 100644 index 0000000000000000000000000000000000000000..5e650b69e653dcf10e041f4b6ba4e88faf4eb284 --- /dev/null +++ b/marker2/ds9/EFTA00088134/EFTA00088134.md @@ -0,0 +1,145 @@ +From: ' To: " r Cc: "I + +Subject: RE: new materials for Maxwell upload to Relativity + +Date: Mon, 10 Aug 2020 19:29:43 +0000 + +Hello, + +I was just checking to see if the hard drive was sent out to arrive today? + +Thank you. + +From: + +Sent: Tuesday, August 4, 2020 1:48 PM + +To: Cc: >; >; + +Subject: RE: new materials for Maxwell upload to Relativity + +I know you're on vacation this week, but wanted to very briefly follow up on the below — I'm going to ask to mail you the thumb drive referenced below, which has folders for five devices (NYCO24332, NYCO24369, NYCO24369\_1, NYCO24372, and NYCO24384) on this coming Monday, so that you'll be around when it arrives (and in case you have to sign for it). Per usual, if you could please take a look at it when you receive it, and then send on to PAE for processing and upload to Relativity, that would be great. Thank you!! + +From: + +Sent: Tuesday, August 04, 2020 13:44 + +To: Cc: >; C )< >; + +Subject: RE: [EXTERNAL EMAIL] - RE: Epstein Evidence status + +Following up on the below, thanks for those responses, that's very useful. In terms of the one outstanding item, in the thumb drive I received from yesterday with CART materials, NYCO27913 is not included, so we are still missing that one. + +But I do see that each of the items with the "Included next round" label from the most recent spreadsheet (attached, with those items highlighted in red) are included, so that's helpful, thanks. + +In terms of any of the folders that have been produced so far, I know that you've sent supplemental materials on a handful of them (approximately seven total, I think) – do you currently expect to send any other supplemental materials for any of the devices we've received so far? Or are we fully complete? + +And then assuming those are all fully complete, or once they are, the only items pending will be the devices highlighted in gray in the attached, which we understand are being processed for hardware recovery. + +thanks, + +![A black rectangular bar with a small blue arrow pointing to its right edge.]()From: ██████████ > + +**Sent:** Monday, August 03, 2020 19:17 + +To: [REDACTED] <[REDACTED]> + +Cc: [REDACTED] >; [REDACTED] >; [REDACTED] >; [REDACTED] < [REDACTED] >; [REDACTED] < [REDACTED] >; [REDACTED] >; [REDACTED] ( [REDACTED] < [REDACTED] >; [REDACTED] ( [REDACTED] < [REDACTED] >; [REDACTED] >; [REDACTED] >; [REDA + +**Subject:** RE: [EXTERNAL EMAIL] - RE: Epstein Evidence status + +![A solid black rectangular bar on the right side of the page.]()Sorry I didn't get back sooner. It's been kinda crazy. I'll answer your questions in order, so match them up. I'm going off what I can see on my phone. + +The final items were given to ██████████. She should have them. Reach out to her for delivery. + +The 3 folders you mention contain supplemental files, do not ignore them. + +I am pretty sure NYC027913 is included with the items ██████████ has. If not, please let me know. + +As far as the old questions, you should have everything now. + +The zero byte files are just that. Sometimes the software will recover either file headers, or items off the directory listings, but no actual content. It lists them as zero length files. + +Need anything further, let me know. + +On Aug 3, 2020 3:33 PM, "[REDACTED]" <[REDACTED]> wrote: + +I know you may still be traveling, but I wanted to check in on a handful of outstanding issues. If you’re not available, perhaps ██████ can assist? + +1. 1. On this past Sunday and Monday, you had said you had you had additional materials you planned to get to us on Monday. I don't believe we ever received anything additional this past week. Are those still pending, and if so, when can we get those materials? +2. 2. There were three folders that were included in the first disc you provided to us, but then also provided again on the most recent disc. Those folders are: NYC024328, NYC024366, and NYC024392. Can you please let us know why those were provided twice? In particular, we need to know whether any supplemental information is in the new folders with those NYC numbers, or whether we can ignore them on the recent disc because we already received them. + +1. One item is listed on your spreadsheet as having been provided on 7/23, but it was not on the most recent disc you sent. That item is: NYC027913 (row 40 in your spreadsheet). + +In case it's useful, I'm attaching a version of the spreadsheet you put on the disc, but with all the items we received folders for on the most recent hard drive highlighted in yellow. + +Separately, we're still waiting on answers to the questions from Thursday and Friday, July 23 and 24. To refresh, those questions are: + +1. Comparing your most recent spreadsheet to the prior one, and leaving aside the "Nothing for Southern" designations as well as the NYC numbers that look like they're for the desktops that held the actual drives we're looking at (such as NYC024385, 387, 389, 391, and 393, and NYC027909), I think there are just three additional devices listed here that weren't on the spreadsheet you previously sent. I have those as: NYC024328 (row 10), NYC024367 (row 62), and NYC027910 (row 96). Please confirm that these were added, and also that we're not missing any? I believe those were all provided on the first disc. +2. As previously mentioned, the vendor has advised that in the initial seven devices provided, there were approximately 71,000 documents that are zero bytes (i.e., empty files). They are listed in the second attached spreadsheet. Is that accurate? Or does that reflect some issue with the extraction process? + +thanks, + +[REDACTED] + +[REDACTED] + +From: [REDACTED] + +Sent: Friday, July 24, 2020 15:09 + +To: [REDACTED] <[REDACTED]> + +Cc: [REDACTED] >; [REDACTED] >; [REDACTED] <[REDACTED]>; [REDACTED] >; [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] ([REDACTED]) <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] ([REDACTED]) <[REDACTED]>; [REDACTED] <[REDACTED]> + +Subject: [EXTERNAL EMAIL] - RE: Epstein Evidence status + +I don't have the evidence in front of me, but it is probably accurate. It is not unusual for the software to find such files. I will review Monday to make sure. As to your questions from last night, the sheet should be comprehensive. I only recall 1 addition, but I am sure that what I have is reflected in the sheet. As for the items in dark grey, there are 2 servers with multiple drives. Some of those drives have physically failed. We have to get them to one of our HQ specialists for recovery. Since they are physically broken, data recovery may or may not be possible. It can be a very long process. We will get that moving ASAP. Need anything else, let me know. + +[REDACTED] + +In addition to the pending questions below, we've been advised by the vendor that is reviewing the initial seven devices (that were provided on a per-device extraction basis, as previously discussed) that those materials include approximately 71,000 documents that are zero bytes (i.e., empty files). They are listed in the attached spreadsheet. + +Is that accurate? Or does that reflect some issue with the extraction process? + +thanks, + +From: + +Sent: Thursday, July 23, 2020 18:08 + +To: + +Cc: MM) + +Subject: RE: Epstein Evidence status + +This is very helpful, thank you. Comparing this to the prior spreadsheet, and leaving aside the "Nothing for Southern" designations as well as the NYC numbers that look like they're for the desktops that held the actual drives we're looking at (such as NYC024385, 387, 389, 391, and 393, and NYC027909), I think there are just three additional devices listed here that weren't on the spreadsheet you previously sent. I have those as: + +- 1. NYC024328 (row 10) +- 2. NYC024367 (row 62) +- 3. NYC027910 (row 96) + +Could you please confirm that I have those additions correct, and that I'm not missing any? And it looks like all of those were included in the drive you provided today. + +I also see there are some drives that are still being processed, including NYC024376 through 380 and several drives in NYC024395 — could you please let us know what that means? + +Thanks very much, and we'll circle back if any issues with anything we received today, which should get to in the next day or two. + +thanks again, + +Original Message + +From: + +Sent: Thursday, July 23, 2020 14:44 + +To: + +Cc: + +Subject: Epstein Evidence status + +Here is the up to date spreadsheet. I color coded things to hopefully make it easier. There are 5 items I have to get you (as we discussed this morning) Those should take another day or 2, so looking at Monday/Tuesday for that. 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See Epstein Records (containing message which states "haat [sic] of roses to =High School for [redacted text.] Give the flowers at 8:30 to sb to give it to her at the stage after performance" and "re[-]rent the car — contract up on 2nd of February ... Blue Dodge Neon"). + +Their submission defines "Epstein Records" as: Office of State Attorney Epstein Public Records Request, http://sa15.orgistateattomey/NewsRoom/indexPR.htm + +Assistant United States Attorney United States Attorney's Office Southern District of New York \ No newline at end of file diff --git a/marker2/ds9/EFTA00088139/EFTA00088139.metadata.json b/marker2/ds9/EFTA00088139/EFTA00088139.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..f178ad7dde31b0e2d33ef33025b7660b092af9de --- /dev/null +++ b/marker2/ds9/EFTA00088139/EFTA00088139.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00088139.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 821, + "elapsed_seconds": 0.45, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 29 + ], + [ + "Line", + 15 + ], + [ + "Text", + 8 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00088139" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00088140/EFTA00088140.md b/marker2/ds9/EFTA00088140/EFTA00088140.md new file mode 100644 index 0000000000000000000000000000000000000000..bcc568d4cd405ed786927049f81b3d552243da5d --- /dev/null +++ b/marker2/ds9/EFTA00088140/EFTA00088140.md @@ -0,0 +1,116 @@ +From: (USANYS)" To: CRM " Cc:l== CRM)" + +Subject: RE: Independent: Prince Andrew: Refusal to talk to Epstein investigators 'straining relations between UK and America' + +Date: Tue, 24 Aug 2021 15:06:25 +0000 + +Embedded: RE: + +Inline-Images: image001.png + +Please see attached written consent fro attorney. + +Best, + +From:W(CRM) + +Sent: urs ay, ugust 12, 2021 5:49 AM + +To: (USANYS) + +Cc: + +Subject: RE: Independent: Prince Andrew: Refusal to talk to Epstein investigators 'straining relations between UK and America' + +We also just got the following questions on the new MLA request. I have given preliminary responses (as noted), but want to confirm with you. + +- 1. Has the witness consented to the release of the information requested? If so, please a copy of the written consent. + +The witness has not been asked for written consent. However, counsel for the witness has encouraged the prosecutors to seek this information. In can be inferred from the state ants of counsel that the witness has consented. + +- 2. did the witness apply to and what was the year of her application/attendance? + +The team was uncertain of which college (I had asked this). Is there a central office at which can be queried for all colleges? + +- 3. How, if at all does this request relate to/impact the material witness MLA request? + +This request relates to the charged Maxwell case going to trial. The material witness MIA requests relates to a broader investigation. + +- 4. What were the sentences which applied at the date of the offences (1994 2004), as the penalties provided with the request apply to conduct that occurred after 27 July 2006? + +I will check with the case team to confirm specific periods. The sentences will he greater than one year and less than life (with no death penalty involved), so is there a need to he more precise? + +![](_page_1_Picture_116.jpeg) + +United States Embassy + +[REDACTED] +London SW11 7US + +**From:** [REDACTED] (CRM) + +**Sent:** Thursday, August 12, 2021 9:03 AM + +**To:** [REDACTED] ([REDACTED]) [REDACTED] [REDACTED] (USANYS) [REDACTED] + +**Cc:** [REDACTED] (CRM) [REDACTED] (CRM) [REDACTED] + +**Subject:** FW: Independent: Prince Andrew: Refusal to talk to Epstein investigators 'straining relations between UK and America' + +You guys have a moment for a brief call this morning? The Ambassador is concerned about the attached story, and I wanted to see if you have any sense of where this is coming from. Is this coming from victims' counsel? Anyone in your shop decided to push this? + +The quote from the State Department yesterday in the NY Times was unhelpful (and I let them know it – I think it came from someone spouting off on the European Desk). + +I also had the following email from the UKCA yesterday: + +We are aware that a civil case has been filed in New York concerning the Epstein investigation with the material witness as the defendant. Please can you let us know what impact this has on the material witness's current status, as a witness, in the criminal investigation and in relation to the MLA request. + +I think they are asking whether, in light of the recent allegations, [REDACTED] is now a suspect instead of a witness (in British parlance). I was going to respond with one word "none" but thought I should check first. + +I am around today whenever you can chat. The earlier the better because the Amb is keen to sort this out. + +Thanks, + +[REDACTED] + +![](_page_2_Picture_0.jpeg) + +United States Embassy + +London SW 11 7US + +Desk: + +From this morning's independent + +## Fears issue over Duke of York could affect wider efforts to collaborate on high-profile legal cases. + +US authorities are growing increasingly frustrated with Prince Andrew's failure to cooperate into their probe into the network surrounding convicted sex offender Jeffrey Epstein, exacerbating tensions between Washington and London, The Independent understands. + +People familiar with authorities' investigations into Mr Epstein's business affairs told The Independent that the lack of information-sharing had caused diplomatic strain, with US law enforcement and diplomats raising the matter with their British counterparts. + +They said a new civil case brought by alleging the Duke of York had sexually abused her, will add further strain over the issue, along with the prosecution of Esptein's former girlfriend Ghislaine Maxwell, who is set to go on trial for sex trafficking charges later this year. + +There are fears that the issue could sour broader efforts to collaborate on high profile legal cases. + +The prince has consistently denied the allegations, while Ms Maxwell denies the charges against her. + +The lack of cooperation now spans three years of reported attempts by the US authorities to gather facts from the royal who, in a statement from 2019, said he would be willing to help US law-enforcement with investigations. However, in January last year, Manhattan US attorney Geoffrey Berman said the country's authorities had received "zero cooperation" from the prince, who no longer carries out royal duties. + +In June 2020, The Wall Street Journal reported that an application had been made by the Department of Justice (Dal) under a US-UK mutual legal assistance treaty in order to win cooperation from the Duke of York. + +This avenue has not been effective, according to sources. They contend that Prince Andrew has failed to share details of the extent of his ties to Mr Epstein, whose death in a Manhattan prison in 2019 was ruled a suicide. The extent and nature of Mr Epstein's financial network is still being explored in several jurisdictions, including the US. + +Of particular interest to the US authorities is how money transfers may be linked to the movement of young women and girls. The various interested bodies, including the FBI, believe these may offer insights into ongoing organised criminal operations. + +These probes are significant not only for legal proceedings related to Epstein, but also to ongoing investigations surrounding Ms Maxwell, who is currently in prison awaiting trial on sex-trafficking charges. + +It is also alleged that multiple authorities are seeking details of flights that the Duke of York used to visit Epstein in a range of locations, so that they can better understand how people may have travelled into and out of the disgraced financier's orbit. The authorities' interests are understood to include multiple trips by the royal to Epstein's Caribbean island, Little St James, as well as Florida and New York. + +Last year, prosecutors in the US Virgin Islands, which includes Little St James, alleged Mr Epstein abused hundreds of young women and girls up until 2018. + +The frustration over the Duke of York's lack of cooperation is said to be amplified by the fact that it appears unlikely that the royal would be extradited. His cooperation would therefore be a matter of bolstering diplomatic relations and sharing any information which could help avoid future trafficking of young women and girls. + +The lawyer representing Ms has accused the prince, who is facing the Queen after arriving at Balmoral on Tuesday, of "stonewalling" appeals for information after the 15-page lawsuit was filed in New York. The prince is the only defendant in the suit, which alleges she was "lent out for sexual purposes" by Epstein. David Boies said his client ultimately wanted "vindication" from the legal action. + +In 2019, Prince Andrew told the BBC that he had not had sex with . "It didn't happen," he said. 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KCG\_TCR\_3-20-13-penultimate\_draft.pdf; KCG\_TCR\_3-20-13-penultimate\_draft.docx; KCG\_Appendix\_3-20\_13\_penultimate.pdf; Cifu.jpg; Blosteinjpg; KCGMarch2017.jpg + +Judge Preska et al: + +This is NOTHING and I mean NOTHING compared to the naked shorting going on in the OTCM and clearly evident on the NITE/VIRT balance sheet TODAY + +As a DIRECT result of SEC corruption and criminal obstruction, the investing public has been placed at risk for the last almost 8 years. + +AND: Knight/KCG/VIRT: NITE is again/always/continuously INSOLVENT + +SEC Data Show \$359 Million of GameStop Shares Failed to Deliver - Bloomberg + +![](_page_1_Picture_6.jpeg) + +## SEC Data Show \$359 Million of GameStop Shares Failed to Deliver - Bloomberg + +On Jan. 28, the day after GameStop Corp. mania hit its crescendo on the back of a short squeeze for the record books, about \$359 million worth of shares were caught in limbo. + +www.bloomberg.com + +Here Glitchy Glitchy + +Cheers! + +Christopher J Dilorio + +Whistleblower Extraordinaire + +From: Chris Dilorio + +Sent: Friday, February 12, 2021 2:31 PM + +![](_page_1_Picture_17.jpeg) + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +Well, + +The Sell side got close to asking a few questions regarding the exploding balance sheet at NITE/VIRT. + +When asking about capital, HOW is it possible that tangible book isn't a topic???? + +How about TANGIBLE working capital if the per share tangible book value is too complex a calculation? AND WHY would VIRT hold as "assets" ANYTHING related to settlement on its balance sheet?? Can VIRT convert these "assets" to cash for its own use? WHY are failed trades booked as "assets":receivable? Just because VIRT is self clearing does NOT mean they are legitimate "assets". More accurately: LIABILITIES + +But a GREAT admission came on the earnings call by Cifu himself: + +Tip toeing around the payment for orderflow issue. + +In response to question by perma pumper Reppetto: + +Dougie "we're not gonna publish KCG 2Q2017 financials" Cifu said: + +"Like really who is NOT benefitting from that system. AND we're putting risk capital up to provide that service." + +"Service"???? what happens BEFORE and AFTER the retail customer gets his/her "price improvement" is the REAL question. because as ALL the Sell Siders Know: NITE/VIRT is a non profit. To f'n funny + +I have hard copies as usual + +Virtu Financial Inc (VIRT) O4 2020 Earnings Call Transcript i The Motley Fool + +![](_page_2_Picture_13.jpeg) + +Virtu Financial Inc (VIRT) Q4 2020 Earnings Call Transcript I The Motley Fool + +Virtu Financial Inc (NASDAQ:VIRT) Q4 2020 Earnings Call Feb 11, 2021, 8:30 a.m. EE Contents: Prepared Remarks; Questions and Answers; Call Participants; Prepared Remarks: Operator. Good day, and ... + +www.fool.com + +Christopher J Dilorio Whistleblower Extraordinaire + +From: Chris Dilorio Sent: Thursday, February 11, 2021 6:14 AM + +>; + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +Judge Nathan et al, + +There is NO REAL INVESTIGATION OF MY ALLEGATIONS. The information I have provided resulted in a VERY nice plea deal for Mr Kamensky. Yet, the very same information has amounted to no real investigation by the SEC whatsoever. + +Today, VIRT/NITE reported Q4 2020 and full year 2020 results. The balance sheet fraud is abundantly evident STILL. + +WHY won't the Sell side analysts ask any questions on the balance sheet? + +So, while Mr Kamensky is virtually a free man as the direct result of my contacting the SONY Courts, the criminal enterprise NITE/VIRT continues to operate UNINTERRUPTED. + +No Doubt the third NITE/VIRT CFO in just over a year Sean Galvin is keeping the fraud up and running. + +There is NO SEC investigation. + +Chris + +From: Chris Ditorio + +Sent: Friday. November 6. 2020 7:09 AM + +![](_page_4_Picture_9.jpeg) + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +Janey et al, + +NITE/VIRT just released 3Q2020 earnings. A direct result of a massive, ongoing, SEC facilitated fraud on the public the SEC is mandated to protect + +The Balance sheet fraud shell game continues. + +https://www.sec.gov/Archives/edgar/data/1592386/000110465920122134/tm2034848d1 ex99-1.htm + +for the sell siders to ask on the earnings Call: + +Tangible book BEFORE we get into mechanics of the massive, ongoing accounting fraud as a direct result of illegal naked shorting OTCM (and other) shells: + +I get les than \$2/sh. Tell me where I'm wrong. + +But, it's MUCH MUCH MUCH worse than that; + +Account receivable : \$1.88 billion + +AR is where NITE books naked short fails as a result of self clearing. No intention/can't deliver. More accurately: a liability + +Further: prior commitment on this "asset": settlement. Nothing NITE/VIRT can convert to cash for company use. Also: + +Trading assets: the old securities owned + +Trading liabilities: the old securities sold not yet purchased + +Structural liability as a result of naked shorting. Propped up/off set by securities owned. + +NITE/VIRT is grossly insolvent STILL/AGAIN/CONSTANTLY. + +And, no breakdown of the vast driver of trading revenue: US equity market Making + +Did NITE/VIRT exit the extremely low tech/cash OTCM trading business? NOPE + +This illegal activity is extremely profitable. Virtually riskless in fact. AND is the driver of trading revenue. WHY the VIRT/KCG merger was done . + +Abusive naked shorting OTCM/other shells to facilitate money laundering is and always has been the core business at NITE. The SEC knows this. Where are disclosures in SEC filings of this high AML risk business? You won't find any. Cifu stopped reporting post merger. Not in Sell Side models either. INTENTIONALLY misleading the investing public as to the true nature of the NITE/VIRT business model. + +In short: absolutely NOTHING has changed since the so called "glitch" as a direct result of SEC corruption/obstruction. With help from the SDNY and Sell Side analists covering NITE/VIRT + +Cheers! + +Christopher.' Dilorio + +Whistleblower + +From: Chris Dilorio + +Sent: Wednesday. October 14.2020 9:00 AM + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +The corrupt, criminal relationship with Handler/Jefferies as I have stated is NOT the only corrupt,criminal relationship the SEC/SDNY have with members of their respective "do not investigate lists". AQR, Blackstone as well as Jay Clayton good fried Glenn Hutchins. Hutchins also worked at Blackstone with Schwarzman prior to + +founding Silver Lake. Hutchins bought SunGard. Then sold it to FIS. This transaction was the basis of the formation of North Island with former NASDAQ CEO Greifeld. North Island is a top shareholder of the criminal enterprise NITE/VIRT. More context: Greifeld was a Director UK/NI company called Automated Securities Clearance Ltd + +https://find-and-update.company-information.service.gov.uk/company/03385409/officers + +## AUTOMATED SECURITIES CLEARANCE (EUROPE) LIMITED - Officers (free information from Companies House) + +AUTOMATED SECURITIES CLEARANCE (EUROPE) LIMITED - Free company information from Companies House including registered office address, filing history, accounts, annual return, officers, charges, business activity + +find-and-update.company-information.service.gov.uk + +Sold to SunGard. Greifeld then became CEO at SunGard. He wasn't at SunGard very long. Then made the jump to CEO of NASDAQ. Curious to say the least. Shortly after becoming NASDAQ CEO, NASDAQ bought the BRUT ECN from SunGard. Self dealing? MUCH WORSE + +http://innasdaq.comIstatic-files/fiblca278-75f0-4259-9372-5b3351126a8b + +ir.nasdaq.com + +121 e< 2 h- 21 e< 16\$ 8;1‹ 76 .23\$54 -:;2((1 -&22 + +ir.nasdaq.com + +As you can see, current NASDAQ CEO Adena Friedman signed off on this transaction. + +SunGard was then sold to FIS. AFTER it had developed a very interesting product converting Russian Rubles to dollars in real time. + +hups://www.finextra.com/pressarticle/49357/otkritie-capital-taps-sungard-for-automated-ruble-conversion + +![](_page_6_Picture_13.jpeg) + +# 1;2, Otkritie Capital taps SunGard for automated Ruble conversion + +Otkritie Capital (Otkritie), one of the leading financial services providers in Russia, has selected SunGard to help launch a new direct market access (DMA) service allowing for automatic real ... I'll say that again: FROM Russian rubles TO dollars in real time. Providing DMA to WHICH markets???? + +So, the marriage of Blackstone Alum Hutchins and Greifeld to form N Island and become a top investor in the criminal enterprise NITE was a natural fit. Money laundering on a MASSIVE scale. Algos and OTCM shells are very complimentary money laundering vehicles. Not to mention: Russian Mirror trades: RU ADR's trade OTCM Pinks as well. The KCG 1Q2014 astronomical increase in OTCM volumes. Expunged from SEC reviewed filings. Attached on previous emails as part of the OWB record. NASDAQ is also the repository of the vast AQR blank check money laundering shells. FULLY SEC reporting for credibility. As with many OTCM shells. The only real difference between a NASDAQ/AQR blank check shell and an OTCM shell is the amount of money being laundered. Clayton should have been investigated and barred from SEC business pending a full and thorough investigation. So, that precludes the corrupt SEC IG Hoecker from any involvement. + +Cheers! Christopher J Dilorio Whistleblower + +From: Chris Dilorio •z: > + +Sent: Thursday, September 17, 2020 5:56 PM + +To: + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +Judge Nathan, + +I applaud your reproof of the SONY. + +Now, I urge you to look at the Dan Kamensky case. I have never met Kamensky. When I saw the joint SEC/SDNY complaint I became physically ill. I am an SEC whistleblower. The SEC/SDNY have actively and continuously obstructed a thorough investigation of my extremely serious allegations. In favor of Rich Handler/Jefferies. The IB in the Kamensky case. Based on my experience with the SEC/SDNY I believe they both are withholding exculpatory evidence which impeaches the credibility of the SEC/SDNY/Handler/Jefferies. A corrupt relationship exists between the SEC/SDNY and Handler/Jefferies. In addition to others in my claims. I have contacted Judge Cave as well as Kamensky counsel. Disclosure of this corrupt relationship puts the Neiman Marcus "sting" in a whole different context. The motives of which should be investigated. + +Respectfully, + +Christopher J Dilorio + +Whistleblower + +From: Chris Dilorio + +Sent: Thursday, September 17, 2020 9:17 AM + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +Please see the new photos attached: + +Mr Blostein's Eureka moment and Cifu admission that the NITE/VIRT revenue model is driven by the "retail participation" rate: + +Cifu: "The retail segment of what we do is a SIGNIFICANT portion of our overall American equity segment..." + +So, are institutions trading .0001 OTCM money laundering shells? Mr Blostein: what are you modeling for NITE/VIRT OTCM share volumes when you KNOW and Cifu admits the importance of these share volumes on the NITE/VIRT revenue model? Does ANY Sell side analyst model this NITE/VIRT revenue driver? WHY doesn't Cifu disclose these share volumes in SEC filings? He used to. Knight/KCG used to as well. See photo. So why did he stop? Did NITE exit OTCM trading? ABSOLUTELY NOT. So the Goldman Analist Blostein KNOWS these share volumes drive revenue at NITE. Blostein doesn't disclose these volumes in his model. Fraud is also an OMISSION of material fact. Time to ask Cifu WHY he doesn't tell you to model OTCM share volumes fellas. This is WHY the SEC/Handler/Jefferies/VIRT/KCG acquisition took place. As Cifu admits: Retail:OTCM drives NITE/VIRT earnings. + +Cheers! + +Christopher J Dilorio + +Whistleblower + +From: Chris Dilorio Sent: Wednesday, September 16, 2020 3:01 PM + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +First Sell Sider, SEC,Dal who can get me a current NITE/VIRT tangible book value calculation wins a prize: Mr Kamensky's freedom. That's BEFORE properly classification of Naked short fails NITE/VIRT KNOWINGLY books as fraud assets: receivable. + +Mr Blostein, I remember a NITE/VIRT earnings call not to long ago where you made a direct correlation between NITE OTCM share volumes and NITE trading profits. Remember the 1? I have hard copies of that too. Did Cifu threaten you if you bring it up again? Please forward your model including these share volumes so we + +can compare notes. Who else has been threatened with retaliation by Cifu/Handler? Who has been promised business? Mr Repetto/Fannon? Who has BUY ratings on NITE/VIRT currently? + +Cheers! + +Christopher J Dilorio + +Whistleblower + +[REDACTED] + +--- + +**From:** Chris Dilorio <[REDACTED]> + +**Sent:** Wednesday, September 16, 2020 9:20 AM + +[REDACTED] + +**Subject:** Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +Judge Cave, + +The criminal, corrupt relationship between the SEC/Handler/NITE goes further. + +Doesn't it Mr Repetto? + +For the Sell Siders on this e mail: + +Please tell Judge Cave, The SEC/DoJ, Mr Kamensky's counsel the following: + +1. 1) how many red flags in NITE 3 CFO's in a year? +2. 2) What you're modeling for NITE OTCM share volumes +3. 3) WHY none of you question the once again ballooning balance sheet on earnings calls + +The other questions below can be answered by Mr Repetto and Jefferies Mr Fannon + +Cheers! + +Christopher J Dilorio + +Whistleblower + +[REDACTED] + +--- + +**From:** Chris Dilorio <[REDACTED]> + +**Sent:** Monday, September 14, 2020 9:22 AM + +**To:** [REDACTED] <[REDACTED]> + +**Subject:** Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +I look forward to speaking with you + +Regards, + +Chris + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +Judge Jones, Judge Cave + +Straight forward, irrefutable proof of SEC corrupt relationship with Handler Jefferies: + +KCG was engaged in abusive naked shorting in months leading up to the SEC/Handler/Jefferies VIRT acquisition closing 7/31/2017 + +SEC/Handler/Jefferies KNEW the core business at KCG is and always has been abusive naked shorting OTCM and other shells to facilitate money laundering. + +SEC/Handler/Jefferies knew KCG was insolvent in 2012 as well as 2017 as a direct result of this illegal activity Handler/Jefferies were the largest shareholder of KCG in 2017 when the SEC/Handler/Jefferies/Cifu orchestrated VIRT/KCG merger was consumated + +https://www.clearygottlieb.com/news-and-insights/news-listing/14-billion-merger-of-kcg-holdings-and-virtufinancial + +#### \$1.4 Billion Merger of KCG Holdings and Virtu Financial I Cleary Gottlieb + +Cleary Gottlieb is representing Goldman, Sachs & Co., as financial advisor to KCG Holdings in its sale to Virtu Financial in an all-cash transaction valued at 51.4 billion. + +www.clearygottlieb.com + +SEC/Handler/Jefferies/Cifu used known fraud "assets" on the KCG balance sheet to determine the grossly inflated tangible book value calculation used to value the KCG acquisition price. + +Immediately prior to the transaction closing on 7/31/2017 the SEC/Cifu wrote down more than \$4 billion in leverage from the KCG balance sheet. INCLUDING fraud assets used to calculate the grossly inflated acquisition price of KCG. + +SEC/Handler/Jefferies KNEW KCG was insolvent in 2012 AND July 2017 + +The SEC has known about the Knight/KCG/VIRT accounting fraud and securities fraud for years. I TOLD THEM. + +The SEC has engaged in a massive criminal obstruction scheme that is ongoing to protect NITE/VIRT. + +As a direct result of this corrupt, criminal scheme the investing public is put at risk, NITE/VIRT is insolvent again/always, Handler/Jefferies benefit, my rights as a whistleblower have been egregiously abused, Kamensky's life is ruined. + +The SEC/SDNY is making a mockery of your respective courts. Worse: the SEC and SDNY are committing a massive and well known FRAUD on your respective courts. + +The true character of Handler/ Jefferies as well as the corrupt relationship the SEC has with Handler/Jefferies must be disclosed to Mr Kamensky. Any verdict without these disclosures is a known miscarriage of justice. + +https://www.lexology.com/library/detaiLaspx?g=9e2b4e49-See2-48f6-b8c7-03d39d02b5ca + +![](_page_11_Picture_0.jpeg) + +# 2 SEC ordered to produce Brady and Giglio materials due to joint investigation with U.S. Attorney's office - Lexology + +A district court ordered the SEC to produce material solely in its possession to a defendant in a parallel criminal prosecution by the U.S. Attorney... + +www.lexology.com + +Mr Kamensky WILL have my information. Mr Kamensky WILL have justice. The SEC/Handler/Jefferies/Cifu corrupt criminal relationship and ongoing frauds on the public will be exposed and ENDED. + +Regards, + +Christopher J Dilorio + +Whistleblower + +From: Chris Dilorio + +Sent: Saturday, September 12, 2020 8:23 AM + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +Judges Cave and Jones, + +The SEC corruption goes well beyond just Handler/Jefferies/NITE. + +My research: I developed a template. I would search NITE top traded OTCM shells. From there: Derivatives. I have filed several separate but related TCR's based on that information. + +The SEC has brought several actions related to my 2013 Knight TCR with Berger: Hanover/Magna, JMJ,Keener, Hicks, Fife,UBSS, and FINRA's NITE Nov 2016 Rule 204 complaint. ALL my information. In addition: FINRA brought a complaint against Brown Brothers Harriman AFTER the SEC was in possession of my information for almost a year. That complaint IS also my information. New SEC NY Richard Best brought that FINRA complaint. ALL of the entities are un named. WHY? Per the complaint: BBH delivered 80%+ of the trades to executing BD's/MM's. NITE as the #1 trader in the space would most certainly have executed BBH trades converting worthless certs to real money. The BBH complaint also cites un named Swiss Banks and FFI's. As a result of exposing these frauds the SEC/FINRA no longer allow searches of OTCM share volume by Market Maker. Further, Cifu,Handler,the SEC have allowed the post VIRT/KCG: NITE to no longer disclose these share volumes in any SEC filings NOR SEC reviewed investor presentations. Has NITE exited this business? ABSOLUTELY not. It is and always has been the DRIVER of NITE trading profits. Virtually riskless albeit illegal. The investing public is intentionally misled as to the true, core business of NITE. + +The August 1 2012 "glitch" proved my allegations that Knight was insolvent. Knight had to raise virtually the entire "glitch" loss despite claiming to have a "highly liquid balance sheet". The accounting fraud is a result of the illegal naked shorting. The SEC,Handler,Jefferies et al "glitch" and bailout wasn't JUST a cover up of a massive SEC failure to protect the investing public however. The 2012 "glitch" was the first of many cover ups so that this massive fraud on the public can continue. Per previous correspondence and the extensive record with the SEC: As with the "glitch" ALL participants KNEW exactly the NITE core business and accounting fraud at NITE in 2017 had not changed. As the record clearly shows: NITE was engaged in abusive naked shorting OTCM (and other) money laundering shells immediately prior to the VIRT/KCG merger closing. Many of the same players in the 2017 "glitch" as the 2012 "glitch". JPM,GS,JEF/Handler, and Jay Clayton Sull Crom colleague Jared Fishman. How did the VIRT/KCG merger get approved in the face of the overwhelming evidence I provided? The same way the 2013 Knight/Getco reverse merger got approved: SEC criminal obstruction. + +In 2017 the SEC,Cifu,Handler wrote down 4 billion+ Naked short fails immediately prior to the VIRT/KCG deal closing. These fraud "assets" were sitting on the KCG balance sheet and used to calculate the grossly inflated tangible book value used in the KCG acquisition price. KCG was grossly insolvent. ALL participants and the SEC knew this. The primary beneficiary of this fraud: Handler/Jefferies. + +In 1Q2020 I alerted the SEC that absolutely nothing had changed. NITE reported a receivable of 2.5 BILLION+. This was up 90% sequentially. HUGE red flags. No investigation. In 2Q2020 the receivable had fallen by just \$100 mil from 1Q. Meaning: The 1Q receivable would have zeroed out within days of March 31 2020 as is required: settlement Then, the receivable at June 30 was within 100 mil of the March 31 balance. Inconceivable. The March 31 receivable was NEVER zeroed out as is required by law. Further, the fails listed as "assets" are a fraud. More accurately: liability. AND there is nothing in the receivable that can be converted into cash for company use. There are prior commitments: settlement. Combine this with the THIRD CFO in a year and you have the makings of ANOTHER "glitch" + +As I've told the SEC: H FT holdings:seconds. No receivable there. DMM? KCG sold theirs in 2016. So that leaves the VIRT DMM. Even AFTER the massive 2Q2017 Cifu/Handler/SEC write down, the receivable is up more than 6X from the last VIRT stand alone 2Q2017. AGAIN the effects of the core NITE illegal activity. + +So, what has changed since August 1 2012? Absolutely nothing. This is an ongoing, massive fraud perpetrated on the American people. Well orchestrated by the SEC,Handler/Jefferies,Sull Crom et al. + +Did Clayton recuse himself from my Award denial? Did Clayton recuse himself from the VIRT/KCG approval? Did Clayton EVER disclose his Sull Crom NITE conflicts? + +The answer can be found in the very carefully structured complaints against several entities in my 2013 and derivative TCR's: NONE of the activity in these SEC/FINRA complaints takes place without a willing, executing BD/MM converting worthless certs into real money. The #1 trader in the space: NITE. Yet, you won't find NITE in ANY of these complaints. As far as the SEC is concerned: :"penny stock trading fairies". The corrupt, criminal SEC/Handler/Jefferies relationship explained. + +I offer AGAIN to fly to SEC DC HQ or NY Office on my own dime to have the best and brightest at the SEC rip me apart and refute my extremely serious allegations 1 by 1. Bring the SDNY too. Better yet: RE forward my information to Handler,Cifu et al. I know they have already seen it from the SEC. I still have yet to be sued by ANYONE related to my information. The Opco Denial Award is also further evidence of SEC criminal obstruction. A gross mishandling of my information to both bring strategic complaints while protecting the criminal entity NITE. Ms Norberg has created some of the most extraordinary reasons for denying my award. The best so far: "SEC investigators never saw my information". An acknowledgement of SEC criminal Obstruction. It is the job of the OWB exclusively and explicitly to distribute whistleblower information within the SEC. A whistleblower has no way of knowing WHO at the SEC is working on a case. Further, despite my request for Norberg to produce the entirety of my extensive record with the SEC, she failed to do so. + +What was the denial in Opco based on? The SEC, Clayton, Handler, Jefferies, NITE et al ongoing massive fraud on the public must continue. So it does. + +Mr Kamensky must have my information. + +Per the extensive record and my derivative TCR's: It isn't just NITE,Cifu,Handler,Jefferies et al the SEC is protecting. Is it Jane? + +Regards, Christopher J Dilorio Whistleblower + +From: Chris Dilorio ‹ > + +Sent: Tuesda Jul 7.2020 6:09 AM + +![](_page_13_Picture_4.jpeg) + +u •ject: Fw: Forma appea or pre iminary .eni • g t Capita R : Appenox + +Janey, + +MORE EXTRAORDINARY SEC corruption and criminal obstruction designed to protect criminals and screw whistleblowers like me. Despite my very generous 4 day offer to produce the entire record which is the basis of my award application/denial/appeal AND REQUIRED by the statute I have referenced: + +240.21F-12 "Materials that may form the basis of an award determination and that may comprise the record on appeal", The several hundred e mails I have sent you, Hoecker et al MUST be part of this record. Janey, you failed to produce this record. As I made clear: my 6/23/2020 emails to you Hoecker, SEC commissioners were merely re re re sent previously sent e mails: the record. Further, my 6/23/2020 e mail: Formal appeal for preliminary denial covered action 2015-016 Knight Capital & Appendix was merely a summary of several hundred e mails sent to you, Hoecker et al. These e mails SHOULD be the record. You failed to produce the record. Which begs the question: WHAT "record" was used to determine the SEC preliminary denial exactly IF the SEC can't produce the record? The preliminary denial was completely fabricated and must be reversed. But, it doesn't end there: per my 6/23/2020 summary based on several hundred e mails sent to the SEC, the RECORD of EXTRAORDINARY corrupt obstruction designed to protect criminals and screw whistleblowers is not confined to Opco,NITE,UBSS,Sason,Keener etc etc etc. I have filed 2 TCR's with the OWB related to the money laundering/transaction + +laundering/Putin/Rakishev/Trump/Kushner/Alfa/Crede/Peizer/Milken/Hapoalim/SBNY/CardWorks/ESQ/WireCa rd/AQR etc etc etc fraud known as Net Element. For YEARS the SEC has been in possession of not just my TCR's but HUNDREDS of e mails supporting my TCR's comprising the extensive record. Here again, the SEC is covering up a MASSIVE fraud perpetrated on the public and well within even the grossly corrupt SEC ability to shut down + +the fraud IF they had used my information to execute its mandate to do so. Instead, the SEC obstructed a thorough investigation. Per my previous e mails: the record: NETE claimed to be a payment processing entity. Claiming further to process BILLIONS of dollars worth of transactions every year. Its subsidiary Pay Online is linked to the massive fraud Wire Card. How's the SEC Wire Card investigation coming along? For years, based on my extensive financials research and other research, I pleaded and pleaded with the SEC to shut down this massive fraud. They did not. email after email. Year after year I wrote the SEC "NETE is a money laundering/transaction laundering fraud". Rather than shut it down, the SEC with the help of NASDAQ allowed fraud public offerings by Crede/Peizer/Milken related entities: Esousa and Cobblestone and a reverse split so NETE could keep its NASDAQ listing. The balance sheet has been grossly insolvent for years: goodwill. + +ALL of my allegations were confirmed when NETE decided to "unlock value in its payment processing" business by doing a reverse merger with a CA EV "manufacturer" started by a musician. This fraud transaction is quite common in money laundering shell land dominated by NITE/VIRT. The SEC cover up of criminal activity while screwing whistleblowers:ME: The "payment processing business" is to be "sold". Related of course was the SEC cover up of criminal activity while screwing whistleblowers: ME: The Goldman/Sull Cromm advised purchase by ALLY of CardWorks: Merrick Bank: NETE and then the recent unwinding of this fraud transaction. No doubt the brain child of Chair Clayton and his SuII Cromm colleague Jared Fishman who has played a key role in keeping the criminal entity NITE/VIRT up and running. + +NETE/Mullen: "here glitchy glitchy" cover up. But, who the hell would EVER touch the massive fraud: NETE? Only another fraud: Mullen. + +Mullen doesn't "manufacture" ANYTHING. Mullen is simply a car dealership. + +The K50 EV is manufactured in China by Qiantu a subsidiary of CH-Auto. Qiantu/CH have a production facility in China. There will be no Mullen "production" of EV vehicles in Washington or anywhere else in the US. + +But, the SEC facilitated fraud doesn't end at protecting criminals and screwing whistleblowers: ME. Per my TCR attached, there is a well orchestrated eco system of fraud. Including "issuer/bag man funded research" that facilitates P&D. In fact, on 11/8/2018 the SEC brought a complaint against an entity I cited in 1 of my emails to the SEC: the record: known as SeeThroughEquity + +https://www.sec.gov/litigation/complaints/2018/comp-pr2018-259 pdf + +# Seethruequity, LLC, Ajay Tandon, and Amit Tandon + +THE DEFENDANTS 6. SeeThruEquity, LLC is a Delaware limited liability company that was co-founded in 2011 by brothers Ajay Tandon and Amit Tandon. + +www.sec.gov + +SeeThroughEquity was engaged in a Pump and Dump promotion of NETE in April and August 2018 + +https://www.netelement.com/press-releases/release-content/1062906#.XwRXEOWSnIV + +![](_page_15_Picture_0.jpeg) + +NEW YORK, NY / ACCESSWIRE / April 10, 2018 / SeeThruEquity, a leading independent equity research and corporate access firm focused on smallcap and microcap public companies, today announced that it has issued an update on Net Element, Inc. 0. The note is available here: NETE April 2018 Update Note. Net Element Inc. (NASDAQ: NETE, "Net Element") is a global financial + +www.netelement.com + +https://www.netelement.com/press-releases/release-content/10734671/1.XwRXGuWSnIV + +![](_page_15_Picture_5.jpeg) + +#### SeeThruEquity Issues Update on Net Element, Inc. + +NEW YORK, NY / ACCESSWIRE / August 6, 2018 / SeeThruEquity, a leading independent equity research and corporate access firm focused on smallcap and microcap public companies, today announced that it has issued an update on Net Element, Inc. 0. The note is available here: NETE August 2018 Update Note. Net Element Inc. (Nasdaq CM: NETE, "Net Element") is a global financial + +www.netelement.com + +So, the SEC SeeThroughEquity complaint acknowledges the fraud associated with NETE. Well orchestrated. This P&D campaign was part of the 2 fraud offerings : Esousa and Cobblestone: I alerted the SEC to. Who PAID for the SeeThrough P&D? Crede/Peizer/Esousa/Cobblestone? + +The cherry on top of the SEC corrupt obstruction: NETE was still in business in 2020 to receive taxpayer Cares Act money. + +A summary of the record. + +Janey, Hoecker et al, + +Please update my Net Element and AQR TCR's + +Cheers! + +Christopher J Dilorio + +Whistleblower + +Not just irony but a massive fraud on the + +From: Chris Dilorio + +Sent: Tuesday, June 30, 2020 1:01 PM + +![](_page_15_Picture_20.jpeg) + +S; + +![]()Janey, + +the purpose of your 5 years in the waiting PRELIMINARY denial of my OpCo Award application could not be any more clear: run the clock out and protect NITE,UBSS,Magna et al while denying me rightful compensation. But, As I have repeatedly told you, Hoecker, your colleagues: the last overt act of this vast conspiracy has not yet occurred: + +NITE/VIRT is insolvent today 6/30/2020 as a direct result of the SEC facilitated fraud on the public which is and always has been the core business at NITE/VIRT: Abusive naked shorting publicly traded shells to facilitate money laundering. The public is STILL at risk. The SEC has facilitated NITE intentionally misleading the public as to the true nature of its business. The SEC still facilitates this massive fraud on the public while it intentionally misleads the public there is no naked shorting because the SEC authorized the DTCC to create the illegal, shadow clear mechanism Obligation Warehouse (OW) so NITE's criminal activity can continue and it can circumvent close out REQUIREMENTS of Rule 204 of Reg SHO. ALL very much ongoing in June 2020 as a direct result of the SEC (OWB/Hoecker/Enforcement etc etc) criminal obstruction and ACTIVE facilitation of the criminal enterprise known as Knight/KCG/VIRT: NITE. + +Clayton never disclosed his Sull Crom/Fishman/NITE conflicts. He must step down from the SEC IMMEDIATELY until a criminal investigation can be concluded. NITE must be halted IMMEDIATELY as it still poses a monumental risk to the investing public. FINRA should go back to being a cheerleader as it is just another enabler of this criminal activity. It has NO business enforcing SECURITIES LAWS. It should not be overseeing the OTCM. FINRA fines are a joke and not meant to be a deterrent. INTENTIONALLY siding with criminals over the investing public the SEC is mandated to protect. The cesspool known as the OTCM MUST be shut down. It exists SOLEY for the purpose of facilitating a massive fraud on the public. The OW must be shut down IMMEDIATELY so the public can see just how pervasive naked short selling: MANIPULATION really is. EVERYONE at the SEC who has had contact with my information MUST resign/be terminated IMMEDIATELY. ALL of the AQR blank check shells must be shut down IMMEDIATELY as they pose a serious national security risk. AQR MUST be shut down IMMEDIATELY. + +Certainly not exhaustive BUT a good start + +Cheers! + +Christopher J Dilorio + +Whistleblower + +![]()![]()Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +Janey, please add the following info to my appeal of your preliminary denial of my Opco award. + +More evidence the SEC is using/has used my information to both bring complaints and protect/obstruct complaints. Again, you, McKessy, Hoecker have been in possession of my 2013 TCR filed with Berger for several years. In addition to hundreds of e mails continuing into 2020 showing irrefutable and overwhelming evidence to support my allegations. + +Highlighted in my attached TCR and related to my Opco Award application: Joshie Sason/Hanover/Magna: CGFIA, IMDS,NewLead,FreeSeas, PRTH etc etc etc. The SEC Sason/NewLead complaint is also my information as I filed separate but related NewLead, and FreeSeas TCR's with your office. The SEC complaint: Sason assignments: bogus notes. NO SHIT? Really? detailed by me. In addition to Bag Man Sason/Hanover/Magna, I detailed the illegal activity of Bag Man Justin Keener/JMJ in my 2013 TCR. Keener was the customer in the FINRA World Trade Financial complaint. + +https://www.finra.org/media-center/news-releases/2013/finra-fines-three-firms-900000-inadequate-antimoney-laundering + +## FINRA Fines Three Firms \$900,000 for Inadequate Anti-Money Laundering Programs I FINRA.org + +WASHINGTON - The Financial Industry Regulatory Authority (FINRA) announced today that it has fined three firms a total of \$900,000 for failing to establish and implement adequate anti-money laundering (AML) programs and other supervisory systems to detect suspicious transactions. + +www.finra.org + +Related to the billions of OTCM money laundering shells traded through World Trade, the BD SRO FINRA requested information from Keener related to his assignments and acquisition of bogus convertible notes including bank statements to prove the notes weren't bogus. Keener told FINRA to 'F Off" + +https://www.finra.org/sites/default/files/OHODecision/p182993 0 0.pdf + +### FINANCIAL INDUSTRY REGULATORY AUTHORITY OFFICE OF HEARING OFFICERS + +5 distributions of securities in violation of Section 5 of the Securities Act of 1933. Tr. 158, 179-180.6 On September 22, 2011, FINRA staff served a request on Keener, pursuant to FINRA + +FINRA barred Keener/JMJ in 2013 as a "Bad Actor" + +The SEC was certainly aware of the FINRA action + +https://www.sec.gov/litigation/opinions/2012/34-68014.pdf + +As recently as 2019 Bag Man Keener/JMJ was involved in ANOTHER money laundering shell called Blink Charging fka New Image Concepts + +https://www.sec.gov/cgi-bin/browse-edgar? + +action=getcompany&CIK=0001429764&owner=exclude&count=40&hidefilings=0 + +https://www.sec.gov/Archives/edgar/data/1429764/000114420419004046/0001144204-19-004046-index.htm + +### EDGAR Filing Documents for 0001144204-19-004046 + +Blink Charging Co. (Subject) CIK: 0001429764 (see all company filings) IRS No.: 030608147 I State of Incorp.:NV I Fiscal Year End: 1231 Type: SC 13G/A I Act: 34 ... + +WW W. See (1, 0 V + +New Image Concepts was detailed by the SEC in their Jaclin et al "Shell factory" complaint in 2016. PRIOR to Keener involvement. + +https://www.sec.gov/litigation/complaints/2016/comp-pr2016-86.pdf + +#### Case No. 2:16-cv-03250 + +1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Case 2:16-cv-03250 Document 1 Filed 05/12/16 Page 1 of 45 Page ID #:1 AMY JANE LONGO, Cal ... + +www. sec .g ov + +But Keener not the only 1 involved who knew New Concept was a money laundering shell. + +CEO of Blink is Michael Farkas. SEC knows him well from his Skyway Communications days. + +The SEC revoked the registration of Farkas/Skyway in 2007 + +https://www.sec.gov/cgi-bin/browse-edgar? + +action=getcompany&CIK=0001128723&owner=exclude&count=40&hidefilings=0 + +The CFO of Blink is Jonathan New. Formerly CFO of the AQR/Crede: Milken money laundering/Transaction laundering blank check shell: Cazador/Arco: Net Element + +A director of Blink is a guy named Donald Engel who worked at Drexel with Milken. + +New Concepts was HQ'd in Santa Monica: Milken + +But it gets better + +![](_page_19_Picture_0.jpeg) + +## Honig's Shell Factory Attorney Gregg Jaclin Barred as SEC lawyer - TERI BUHL + +Your Voice. High Times Admits SEC Filing is Wrong: Stormy Simon off the Board - L.A. Cannabis News on Text messages show Cannabis investors Defrancesco & Serruya allegedly Colluded with Clarus Securities' Christodoulis in Multiple Stocks; High Times Admits SEC Filing is Wrong: Stormy Simon off the Board - + +www.teribuhl.com + +Where the SEC said multi billionaire Frost risked ALL to make a few million. NO, Frost,Alpha (also in my attached TCR), Stetson, Honig were LAUNDERING. Frost bought Ladenburg from Milken flunkie Icahn AFTER Icahn rolled Gruntal int Ladenburg. Gruntal: Icahn,Sater,SAC,Feinberg et al: Milken + +The SEC intentionally omitted a Honig/Stetson shell from this complaint: + +Millenium Bio/lnergetics + +linked to Trump Cleveland fundraiser and healthcare fraud felon: Brian Colleran + +In typical SEC "cover up", revoked the Millenium/Inergetics registration in 2019. + +https://www.sec.gov/cgi-bin/browse-edgar? + +action=getcompany&CIK=0000072170&owner=exclude&count=40&hidefilings=0 + +Finally, + +SEVEN F'n Years AFTER FINRA barred (not exactly) Keener/JMJ and my Berger TCR filed with your office Janey, The SEC is going after Keener/JMJ related to my information AGAIN + +17.5 BILLION shares of money laundering penny stocks. + +https://www.sec.gov/litigation/litreleases/2020/Ir24779.htm + +Justin W. Keener d/b/a JMJ Financial (Release No. LR-24779; Mar. 24, 2020) + +SEC Charges Unregistered Penny Stock Dealer Litigation Release No. 24779 / March 24, 2020 Securities and Exchange Commission v. Justin W. Keener d/b/a JMJ Financial, No. 20-cv-21254 (S.D. Fla. March 24, 2020) + +wwwsecgov + +WHO was/were executing BD's/MM's in these billions of shares of worthless Keener/JMJ money laundering shells???? + +What are odds that bogus note/worthless certs/assignments Sason/Magna would be involved with bogus notes/worthless certs/assignments Keener/JMJ in money laundering shells like IMDS and CGFIA etc) AND CGFIA was detailed by me to the SEC/FINRA AND CGFIA was 1 of the shells in the FINRA Opco AML complaint AND where NITE and UBSS traded billions of shares of CGFIA + +AND where NITE and UBSS traded billions of shares of IMDS also + +Now, what are the odds of all of that? + +Christopher J Dilorio Whistleblower + +From: Chris Dilorio ‹ > + +Sent: Tuesday, June 23, 2020 4:11 PM + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +small typos/corrections: + +Mirror trade activity peaked in 1H2014 not 2H2014 and this coincides with OTCM astronomical share volume data in 1Q2014 and 2Q2014 that were expunged from KCG 10Q SEC filings. Not 2Q2014 and 3Q2014 SEC reviewed 10Q's as I previously stated + +corrected below + +Chris + +From: Chris Dilorio + +Sent: Tuesday, June 23, 2020 9:48 AM + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +Ms Norberg, + +I am in receipt of the SEC OWB correspondence allowing me more time to respond to the preliminary denial of my award application for the Oppenheimer 2015 covered action. This e mail was the last 1 I sent to your office related to my appeal. It will serve as the basis of my appeal. Including the attachments of my 2013 TCR submitted with Berger Montague to the SEC. I will also forward correspondence from 2012 and following detailing my extensive correspondence with Robin Traxler at FINRA as well as Sean McKessy in the OWB. Even though, I have previously forwarded your office as well as the SEC IG office the exact same corroborating + +evidence. My response to you will be lengthy and detailed. However, given that it took your office FIVE YEARS to send me a preliminary denial notice, that is understandable and in fact a result of YOUR lengthy delay in notifying me. ALL of my response pertains to the denial appeal at hand. + +In 2011, I filed my first Whistleblower complaint with the SEC. Detailing a massive fraud on the public directly implicating dozens of entities. The center of my claims: Knight/KCG/VIRT: collectively NITE and the Swiss banking giant UBS:UBSS. By far, NITE was and still is today the largest MM/executing BD in the OTCM space. I was shocked to find the Swiss banking Giant UBSS was trading many of the same stocks as NITE and to the extent they were. This came on the heels of the FINRA UBSS Reg SHO complaint where the extent of the UBSS activity "threatened to undermine the integrity of our markets" while the SEC analysis of this activity was simply a case of "sloppy record keeping". My experience as an Institutional Sales trader: executing multi million share equity trades for the largest institutions in the world like Fidelity and Putnam. In addition, as a Research Sales person: analyzing financial statements and making investment recommendations formed the basis of my expertise. In fact, the SEC OWB has paid out awards for information just like mine. In August of 2011, I informed the SEC that NITE was insolvent having reported just \$105 mil in working capital at June 30, 2011. AND, for the resaons cited in my TCR detailing massive accounting fraud as a direct result of illegal naked shorting/self clearing/reverse splits/cusip changes etc. The SEC had a choice: investigate these extremely serious allegations and shut down this massive fraud on the public OR cover up their failure and allow this massive fraud on the public to continue. Unfortunately for the American public the SEC is mandated to protect, the SEC chose the latter. As a direct result, ALL of the activity detailed by me in this TCR and other TCR's filed with the SEC as well as 9 years of additional correspondence with the SEC, this is very much an ongoing, massive scheme. One that the SEC actively facilitates. Countless losses have been incurred as a result. NITE as I detailed is in a constant state of insolvency. The SEC has time and again intentionally misled the investing public that there is no abusive naked shorting. NITE is still in business TODAY. + +The core business at NITE is and always has been: abusive naked shorting OTCM shells to facilitate money laundering. Not DMM, FCM, reverse mortgages, or even HFT. This illegal business is EXTREMELY profitable and virtually riskless. AND, both the SEC and FINRA know this. In 2016, FINRA brought a Rule 204 complaint against NITE. The fine was pathetic and not meant to be a deterrent. This is WHY the OTCM exists. But it's not JUST OTCM as my AQR TCR filed with the SEC clearly proves: NASDAQ Blank check shells as well. I have also filed separate TCR's related to NewLead and FreeSeas: 2 massive money laundering shells which began on NASDAQ,de listed to the OTCM. NONE of the activity detailed in the Opco/Gibraltar complaint takes place without a willing executing BD/MM who ultimately turns worthless certs into real money. That #1 trader is NITE. As you read in my Knight TCR CGFIA is at the heart and, because it was based in Colorado, became a template of sorts for my extensive research. See Ms Norberg, unlike the SEC "investigators" on the Opco/Gibraltar complaint, I've actually seen first hand the CGFIA "world HQ" as well as the rented Littleton home of CGFIA CEO Guyer. I've done extensive research on Properties claimed to be owned and M&A transactions done for the sole purpose of cert printing and distribution (Aurelio AMNP) where the ultimate acquisition amounted to a distributor of Ukrainian folk music. I've also done extensive research on domestic and foreign financial institutions claiming to "invest" in these scam companies like Josh Sason/Hanover/Magna also cited in my 2013 Berger/Knight TCR linked. So, as I detailed to Ms Traxler, I followed Guyer to Neuchatel Switzerland and his previous endeavor: Antelope Technologies also with an office in Highlands Ranch CO. Where I discovered a connection to Swiss/German individuals/entities that were also related to another OTCM shell in the OpCo/Gibraltar complaint as well as my Knight TCR: AppTech. Offices in the Woodlands TX and Boca Raton. AND very much up and running today. SHOCKING. The SEC OpCo/Gibraltar complaint is based on the FINRA complaint. That is absolutely irrefutable. As the Gibraltar complaint alleges just 1 OTCM shell and just a million shares while Commissioners Stein and Aguilar referenced BILLIONS of shares in their OpCo waiver dissent. Who executed those BILLIONS of shares? Was OpCo even a MM? If I ask a question it's typically a rhetorical: I know the answer. The SEC knows the answer also. The SEC OpCo complaint does not mention the executing BD/MM. The SEC complaint doesn't mention Sason/Hanover/Magna either. The SEC complaint makes no mention of illegal naked shorting which is clearly evident in the CGFIA 10Q referenced below. THIS IS MY + +INFORMATION. So, why aren't NITE, Hanover/Magna and UBSS implicated in the SEC OpCo/Gibraltar complaint? What my TCR clearly and irrefutably proves: NITE was engaged in illegal activity both BEFORE and AFTER the SEC et al orchestrated August 1 2012 "trading glitch". So, the SEC bailed out a KNOWN criminal entity. Unfortunately for the investing public, the SEC has doubled downed on facilitating this illegal activity into 2020. The "glitch". Knight was insolvent in August 2011. 1 told the SEC this. The "glitch" proved my allegations. Key point in my TCR: NITE inadvertently sent 4000 worthless securities to JPM to secure an emergency bridge financing as collateral. These were open, naked short fails that could not be covered/closed due to a cusip change (SEC/FINRA approved rev split) booked as an "asset"(receivable) due to self clearing: MASSIVE accounting fraud. Ironically, the "glitch" proved my allegations: despite claiming to have a "highly liquid balance sheet" NITE had to raise the entire amount of the "glitch". AND the ultimate "financing" was not collateral based. Rather a 50% discounted convert when the stock had already been crushed to \$3 OR \$1.50. ALL of the financing participants knew the NITE balance sheet was complete fraud. NITE also committed securities fraud in pledging those 4000 worthless securities as collateral to JPM: SCOTUS Rubin: pledging collateral to secure financing is an offer to sell. JPM looked the other way. As did the SEC. Further, I submitted my amended TCR with Berger in March 2013, In August of 2013, FINRA brought a penny stock AML complaint against OpCo. Sale of unregistered penny stocks. WHO ultimately executed the trades? 2008-2010. In July 2013, the "glitch" financing Gen Atlantic/Getco reverse merger with Knight to form KCG closed. The new CEO of KCG was Dan Coleman who ran Equities at UBSS during their Reg Sho and cross border activity. For UBSS, the DOJ (Acosta Downing et al) dropped their DPA in 2010. My claims: the FINRA OpCo/Gibraltar complaint clearly implicates UBSS criminal activity AFTER the DoJ dropped its UBSS x border DPA. This is what the SEC is protecting in the OpCo/Gibraltar complaint: NITE/UBSS/Hanover/Magna illegal activity. + +Also in my Knight/Berger 2013 TCR: IMDS. A multi year money laundering shell kept up and running by the SEC. Also NITE,UBSS, and Hanover Magna. In addition to other entities like JMJ, Southridge, and Alpha Capital Anstalt. Alpha Capital Anstalt is very much in business today as a result of SEC obstruction while the SEC recently brought a complaint against JMJ for activity like that in IMDS even AFTER he was barred by FINRA. In IMDS, the SEC allowed 2 barred individuals (CEO/CFO) to do an offering that created 37 BILLION shares of IMDS at .0001 with Chinese Nationals before revoking the IMDS registration. What do you do with 37 billion shares of IMDS at .0001 when there are no bids below that? NOTHING. The stock never traded. The SEC orchestrated a NITE/UBSS/Hanover/Magna/JMJ/Alpha etc MASSIVE naked shorting to facilitate money laundering scheme bailout so that the MASSIVE naked short position didn't need to be covered in the open market as is mandated by Rule 204. Thus insuring profits and not MASSIVE losses for NITE and UBSS. + +I also filed separate TCR's for NewLead and FreeSeas. 2 "Greek shipping" money laundering shells started on NASDAQ and delisted to OTCM. NITE top trader in BOTH. Hanover/Magna in both. I contacted the KY Div of Mines and notified the SEC that these "transactions" were complete fraud. The SEC Feb 2019 complaint against Hanover/Magna is my information: Bogus obligations, assigned, converted to worthless certs. Then dumped on the public and converted to REAL money by the executing BD/MM:NITE. Who generates illegal trading profits by abusive naked shorting. Very symbiotic relationship. 1 of the Hanover/Magna entities was Gibraltar/Hanover. Somehow omitted from the SEC OpCo/Gibraltar complaint. In NewLead, then SEC White and Ceresney firm Debevoise did a "fairness opinion" of a Russian Nickel wire transaction where the NewLead CEO had back dated documents. That has been expunged from SEC reviewed filings. FreeSeas: a structured tax evasion/money laundering shell. Also involved Credit Suisse and Deutsche Bank. Both Debevoise clients. Both involved in the tens of billions Russian Mirror trade scheme. In addition to Hanover/Magna a Milken related entity Crede: Run by Milken/Drexel/Obstruction of justice/Parking: Terren Peizer and his felon partner Michael Wachs. This led me to Net Element NETE. Peizer again. This time with more AML red flags than be counted. Well known to the SEC through TWO of my separate TCR's. CEO is Oleg Firer. Firer former money laundering shell Acies shut down by the SEC while NETE was left up and running. Acies very much up and running also in MA. In NETE: NASDAQ. AQR Blank check shell. SEC allowed 2 offerings so that NETE could keep its NASDAQ listing. 1 was with entity Esousa: felon Wachs ex wife. 2nd was with Cobblestone: felon Wachs sister. I told the SEC. They still approved + +the offerings. I discovered AQR money laundering blank check shell activity doing research on NITE and Hanover/Magna. A top traded NITE OTCM shell was Cereplast. Another AQR blank check shell. Hanover/Magna/NITE/ and Alpha Capital Anstalt. Alpha is Liechtenstein based and controlled by Martin Schlaff: Austria/Israel. AlsolMDS (w/Schlaff controlled Balmore) and the Frost/Honing/Stetson et al complaint. Schlaff also LH Financial/Wolfson/Sulphco and Bawag: Sedona/Scan Graphics: Refco: Naked shorting. NITE is Refco on steroids. Cereplast ended in bankruptcy. + +NETE claims to be a "payment processor". BILLIONS in transactions processed. Never break even let alone profitable. Balance sheet complete fraud. AML red Flags: Firer is Grenada Amb to Russia living in Miami, Apockinas/Grinshpun/Antonov/RakisheviTrump/Kushner/SBNY/CardWorks/Merrick Bank/ESCt/Cohen etc etc etc money laundering/transaction laundering BILLIONS shell. Kept up and running for years since filing my NETE/AQR SEC TCR's. ALL of my allegations proved accurate in 2020 when NETE received Cares Act taxpayer money then announcing it was "unlocking the value in its misunderstood payment processing business" by doing a reverse merger with a CA electric car company started by a former musician. The payment processing business to be "sold" and the new company (Mullen) will own 80-90%. All made possible by SEC obstruction and ACTIVELY facilitating illegal activity. Another AQR blank check shell is Astra/Phunware. More Greek shippers related to massive swindler Economou originally intended to do an "energy logistics company" acquisition and somehow settled on "mobile app developer" Austin TX: Phunware. PHUN CEO is well known to the SEC with shells going back 15 years. I alerted the DoJ and SEC that PHUN was a money laundering shell. In addition to the "genius quant" AQR, AIPAC: Gerber/Hudson Bay, Nordlicht: Ari Glass/Boothbay, 1MDB: Khazanah Nasional, Global Crown/Rani Jarkas/EFG/BSI/Optima/Max Fang. AG Barr 1MDB waivers: Kirkland also AQR. Broidy: Trump: 1MDB money laundering. PHUN also received Cares Act money. AND PHUN is Trump/Kushner/Parscale campaign mobile App. PHUN should have also been shut down long ago. AQR too. OTHER AQR blank check shells: CIS/Delta/Urban Tea, Ability/Cambridge, Hunter Maritime, and MI Acquisition/Priority Tech Holdings. Ability/Cambridge: Israeli cellular intercept/surveillance. Israel sent employees to jail. In the US it was "securities fraud". The SEC Ability/Cambridge complaint was handled by Ansu Banerjee in the SECLA office. Milken/Mogilevich/BoNY money laundering entity Sinex: Debasish Banerjee. WHY did SECLA have jurisdiction over ABILF/Cambridge? Result: ABILF is very much up and running today. I believe this is the PHUN/Trump/Kushner/Parscale mobile app technology. + +Hunter Maritime:HUNTF: Never consummated an acquisition. Just cert printing/dumping. Also involved: Milken family office: Silver Rock. MI/Priority:PRTH. CEO Tom Priore: well known fraudster to the SEC. Also transaction/money laundering like NETE. Also involved: Hanover/Magna. + +ALL AQR money laundering shells up and running today thanks to the SEC. Only recently did the SEC revoke CGFIA and NewLead. well after going dark and the massive fraud on the public had already been perpetrated. In NewLead, FreeSeas, etc etc etc a common tool used is reverse splits to perpetuate and facilitate illegal activity. SEC/FINRA approved. The result is the massive accounting fraud at NITE. WHEN not IF there is an open naked short fail when a rev split takes place, a new CUSIP/security is issued. Trades in the old cusip/security cease. This creates a structural liability. The fail/short can NOT be closed. Like covering a short in AAPL with MSFT. Because NITE is self clearing it books a prop naked short as a receivable. An asset. But, because NITE won't or CAN'T deliver, massive accounting fraud. Literally a liability booked as an asset. This is how "glitches" are born. But the SEC facilitated fraud doesn't end there. The definition of a failed trade: 1 that hasn't settled. The SEC/DTCC issue new securities where trades in the old haven't settled yet AND not authorized by the issuer. Settlement: buyer brings cash/seller brings securities. The DTCC simply makes journal entries. But there are still "IOU's" in the system. The SEC authorized the DTCC to create a shadow clear,non guaranteed, ILLEGAL (clearly contrary to 34' Act "prompt and accurate settlement) Obligation Warehouse so criminals like NITE et al can circumvent close out REQUIREMENS of Rule 204. The OW is just what it sounds like. Per my Knight TCR, DTCC suspends services (Chill/Lock) and trades are deemed "ex clearing". In a FOIA request made with POGO,Berger and I asked the SEC fails data on dozens of NITE/UBSS top traded stocks like CGFIA,APCX and IM0S. The SEC response: see our website. The SEC fails data is for DTCC cleared trades only. The SEC knows exactly the level of fails sitting in the OW. They don't disclose. Intentionally misleading the public there is no naked shorting. In + +1Q2020, the receivable at NITE/VIRT increased \$1.2 BILLION sequentially. Up almost 90%. AND the tangible book value is grossly insolvent. When it comes down to it, there really isn't ANYTHING in the receivable that NITE can convert into cash for its own use. There are prior commitments on those "assets": SETTLEMENT of transactions. Because the SEC has never shut down this activity, NITE is in a constant state of insolvency. + +Other examples of SEC attempts to cover up NITE illegal activity so that it can continue include: + +Cerberus/Feinberg/VIRT bidding on NITE post "glitch". Wasn't their turn. First, Gen Atlantic needed to monetize its GETCO "investment". The HFT business at GETCO was in a death spiral when the rev merger took place. So + +what was the attraction to NITE? The business that had absolutely ZERO overlap/synergies: OTCM. As low tech + +as it gets. Literally a trader sitting in a chair. As I have asked the SEC on hundreds of occasions over the years: what would happen to NITE trading profits if their OTCM share volumes went to ZERO? Cerberus is Feinberg: + +Gruntal/Milken. Also bailed out Bawag:Refco, HSH, and Deutsche Bank (\$50 bil Bad Bank to Goldman). Another Milken/NITE connection is Rich Handler: Jefferies. Also a Milken/Drexel protege. Milken was Gruntal: + +Feinberg,SAC,Icahn, Sater etc. Gruntal was "sold" to Ladenburg. Controlled by + +Vector/NewValley:Icahn/Lorber/Elliman etc. And, was sold to multi billionaire Frost. Who, according to the SEC risked it all trying to "make" a few million when he, Honig, Stetson, Alpha et al were really LAUNDERING. Milken + +also Whiterock ,D H Blair (Morty Davis) and AR Baron (Bressman/D H Blair) which was the precursor to Bear + +Stearns collapse . So, Milken and his merry crew of flunkies are really at the nexus of JUNK. They own Trump and his White House (Trump casino junk) and they own the SEC. It was Milken, Leon Black, Handler, Moelis, + +Virtue: Drexel that caused the S&L taxpayer bailout stuffing them with junk like Trump's. It is no coincidence that these same flunkies are also the largest CLO originators/managers. CLO's: Junk on steroids. AGAIN Bailed + +out by taxpayers in Cares Act HY. There also connections to Epstein. Treasury Sec Mnuchin and Black: HY/Junk/S&L's and Epstein. Black: Money laundering shell ESWW kept up and running by the SEC was/is an + +Epstein money laundering vehicle: JUNK IS JUNK. THIS EXPLAINS the Handler/Jefferies/Milken repeated bailouts of NITE. It also explains the SEC criminal + +obstruction. + +SEC Chair Clayton is also directly linked to this criminal obstruction. His firm Sullivan Cromwell and Jared Fishman are ACTIVELY facilitating this massive fraud on the public. Clayton did not disclose these conflicts in his + +disclosures. Sull Crom/Fishman have advised Knight/KCG/VIRT and several transactions designed to facilitate + +this ongoing and ongoing fraud on the public. Many of the same players involved in the "glitch" were involved in the VIRT acquisition of KCG in July 2017. In addition to Sull Crom/Fishman and Handler/Jefferies: JPM and + +Goldman. The SEC facilitated fraud in the NITE/VIRT transaction is egregious illegal activity. The transaction NEVER should have happened. KCG was an SEC reporting company until the deal closed on July 31 2017. + +Despite this FACT, VIRT CEO Cifo refused to "publish" KCG 2Q2017 financials. I estimate Cifu/Coleman/Handler/GS/JPM wrote down more than \$4 billion in open naked short fails: "leverage". The SEC + +let him. Meaning: "assets" used to determine the take out/ tangible book of KCG was complete fraud. VIRT + +grossly OVER paid for insolvent KCG. Prior to the NITE/VIRT transaction closing in July 2017, NITE would report its trading stats monthly. Including + +OTCM share volumes. Cifu stopped this post merger. The SEC let him. In fact, you will find NO reference to NITE/VIRT OTCM share volumes in any SEC reviewed filing, sell side research or investor presentation. A well + +orchestrated fraud on the public. Omissions to Intentionally mislead the public as to the true representation of the NITE/VIRT business model. These share volumes are also at the center of my 2013 Berger TCR. There are no + +affirmative disclosures in any SEC filings to this day as to the AML risks posed in trading these OTCM and other shells. In a 2014 letter to the SEC, I detailed the first 2 months of NITE OTCM share volumes. When the 1Q2014 + +10Q was filed, these volumes were confirmed: An ASTRONOMICAL increase sequentially as well as year over + +year. These share volumes/my letter/TCR SHOULD have triggered an immediate SEC investigation. It did not. This portion of the KCG 1Q2014 10O was expunged as well as 2Q2014 OTCM share volumes. I have detailed this + +to the SEC/OWB/Enforcement/IG. In the months leading up to the NITE/VIRT closing in July 2017, KCG put out monthly trade stat pr's showing KCG trading more volume than the overall market. Also indicative of naked + +The SEC has essentially outsourced the ENTIRE OTCM market to the Broker Dealer SRO FINRA. Including: management of the OTCM share volume website fka OtcBB.com. Today, there is very little transparency into trading activity by MM as a result. Also: ISSUER corporate actions: rev splits, Short interest reporting: an absolute farce given there is still no CAT. AND BD compliance with the BSA. Per my TCR: WHY did NITE and UBSS trade Billions of shares of CGFIA and IMDS AFTER a Chill or Lock was placed (ex clear/OW)? CLEAR AML red flags. Because they had an open naked short position. Why not pull a market? Because they had an open naked short position. SAR's? WHEN? BEFORE OR AFTER THEY TRADED BILLIONS OF SHARES? There were no SAR's either. NITE can not outsource its compliance responsibilities to 3rd parties (like OpCo) when executing trades as MM. In 2015 at a SIFMA conference, Ceresney was "shocked" by the number of BD's under his supervision filing 1 or ZERO SAR's. NITE SHOULD have been investigated for egregious BSA violations long ago based on my TCR. Knight/KCG/VIRT:NITE is and always has been a criminal enterprise. Spitzer Russian/US mob bust: "worthless paper". Ashton Tech became VIE became Optimark became Knight/Trimark NITE literally "made by the mob". The SEC has known this for years. ALL of the "worthless paper" shells were SEC reporting companies. Today, Trump PA Campaign Mgr David Urban sits on the NITE BoD. AND is also on the BoD of his very own money laundering shell: Canadian/Pakastani/pot/COVID: FSD Parma: HUGE. Trump advisers/campaign staff Bannon and Parscale also involved in OTCM money laundering shells.Parscale Cloudcommerce fka Roaming Messenger also receiving taxpayer Cares Act money. Madoff: more money laundering than Ponzi. HOW THE HELL did the SEC let that scam go on for as long as it did? Criminal obstruction. The former SEC IG Kotz actually investigated his "bosses" at the SEC unlike current IG Hoecker. Years of SEC obstruction. Bullshit "investigations" into "running ahead" meant to distract. Similar to the SEC "glitch" "market access complaint" where former SEC "glitch" Enforcement Dir Khuzami/Kirkland(Barr) also rep'd NITE. Can't make this up. The center of IG Kotz scathing failure of the SEC in Madoff: SEC NY and Mr John McCarthy who ended up being Knight/KCG Chief Counsel. As I said: can't make this up. And, as we know Madoff started his career in NASDAQ penny stocks exactly like the l's in the Spitzer/Mob complaint. OTCM: This is WHY the OTCM exists: abusive naked shorting publicly traded shells to facilitate money laundering. CEO Cromwell Coulson CHAIRED the FINRA market Regulation Cmte. Say it with me: Can't make this shit up: CMTSU. A founding OTCM Board member is former NITE trader Andrew Wimpfheimer:CMTSU. This is a very well orchestrated and ongoing fraud on the public. Russian mirror trades: no SEC OR DOJ investigation HOW? According to stories: activity peaked in 1H2014. Coinciding with NITE astronomical OTCM 1Q2014 share volume increase. In additional to money laundering penny stock shells, the OTCM is also home to many ADR's. Including Russian ADR's cited in the NYDFS/DBTCA/mirror trade complaint. Little/no disclosures. Also in my TCR: P&D is just a tool used to facilitate the fraud and NOT a stand alone fraud. The SEC intentionally stops short of thorough investigations into much bigger frauds. The same way it has the public believe the "penny stock trading fairies" convert worthless certs to real money. NO! willing executing BD's and MM's like NITE do that. Less than a year after filing my Knight TCR with Berger, FINRA (not the SEC) brought the BBH AML complaint. This was my information. Swiss banks, foreign/domestic institutions, executing BD's/MM's/ penny stock shells: \$850 mil in proceeds. Did BBH implicate NITE and other entities in my claims? WHY are all of the entities in the complaint UN NAMED? In the interest of transparency for the investing public? In 2019, I also filed an award application for the UBS x border/AML complaint. This is BLATANTLY my information. SEC/FINRA/ AND the SEC. I filed an IRS TCR based on my SEC TCR attached. In April 2016, 2 IRS CI Agents: VIKAS Arora and Nathan Sarnacki flew to Denver from Chicago to meet with me. I believe they were blown away. Then came the UBS complaint. As a follow up to our meeting, they wanted to know WHO at the SEC I shared my information with. I told them. That was the last I heard from them although I continued to send them my information. To the SEC IG Carl Hoecker: In 2015 I parted ways with Berger as I was convinced the SEC was using my information in an unethical/illegal manner to both bring and obstruct complaints. Berger was not willing to file an IG complaint. After parting ways, I almost immediately did just that. Prior to retaining Berger I had filed an award application for the UBS Reg Sho complaint. In my submission and my correspondence with Mckessy/OWB I made the claim based on OWB permissible rules to "open a new line of inquiry". One that would link the trading activity detailed in my ultimate TCR by NITE and UBSS. That link: Abusive naked shorting + +publicly traded shells and money laundering. My application was denied and there was no investigation into this link. The SEC had just bailed out a "known criminal enterprise":NITE "glitch" was not a forthcoming admission. Neither was the blatantly and knowingly false pretext for the DOJ dropping its UBSS x border DPA because "UBSS was in full compliance" in 2010. So, rather than open a new line of inquiry, the SEC chose to obstruct. + +I made clear to Hoecker the egregious conflicts by Khuzami,White and Ceresney with clients UBS,JPM,CS, and DB. Hoecker claims to have conducted a "thorough" investigation of my very serious allegations and found nothing. Despite MJW waivers received to "investigate" her Swiss bank client CS. Then in 2019, Hoecker arrogantly told me I could file a FOIA request on his findings. Then, came 2019 and absolutely nothing had changed. NITE was still trading billions of shares of OTCM shells like ELTZ. There were still no risk disclosures. Cifu refused to publish KCG 2O2017 financials, Hanover/Magna/AQR/Alpha/IMDS etc etc etc were still up and running . I filed ANOTHER complaint with IG Hoecker. Despite the fact that Hoecker himself wroth the IG handbook on "thorough investigations" mandating complainant interviews, I have never been interviewed by Hoecker. In addition, the IG Hoecker is mandated to inform Congress as to serious allegations like mine. He did not. In doing so, obstructed Congress from executing its oversight of the SEC/OWB. And despite hundreds of offers to fly to SEC HQ to have the best and brightest at the SEC rip apart my allegations 1 by 1 I have never been taken up on my offer. Why is that? The SEC OWB has gone to great lengths in other cases to explain the OWB process etc to whistleblowers. I have never been told "no thanks" for my information. In fact, McKessy has solicited MORE information from me after submitting my Berger TCR. In Madoff, an intern could have verified/shut down in weeks NOT years. No contra parties. Only a well orchestrated obstruction by SECNY/McCarthy et al kept it up and running. As I have also repeatedly told the SEC: My claims could be verified in weeks also. NITE has a P&L for every stock they trade. These, aggregated, are basis for quarterly trading profits. These P&L's, combined with OW data, and balance sheet data will validate ALL of my claims. I've offered my service to do exactly that. 2 weeks max. Afterall, proprietary trading strategies are NOT proprietary if they're illegal. For the reasons I have listed in this summary, NITE/VIRT is on the SEC "do not investigate list". And yes, there most definitely is such a thing. Especially when it comes to illegal activity facilitated by the SEC. So, the SEC denial of my OpCo award claim which was 5 years in the making is just another example of my very serious allegations: The SEC solicits and uses whistleblower information like mine to both bring and obstruct complaints. Unethical. Illegal. To deny my award application because the "investigators" didn't see my information is further affirmation of my allegations. They saw it. They used it. They denied my compensation for it. Again Ms Norberg, I will forward my 2012 etc emails with Robin Traxler at FINRA as well as McKessy as further evidence that my Award application denial should be overturned. Further affirmation from 2 dissenting SEC Commissioners and the judge in the Gibraltar case makes this denial both egregious and bizarre. Bizarre ONLY if you believe that there is no SEC obstruction that is. BTW, crazy stuff going on with the firing of Mr Berman/Clayton nomination to take his place/Rabbitt to DoJ/Carpenito replacing Audrey Strauss/Trump/Barr don't you think? The SEC needs some fixers. Wonder why. I'm cc'ing some our mutual friends on this email Jane. The last overt act of this massive ongoing, SEC facilitated conspiracy has not occurred yet. + +Cheers! + +Christopher J Dilorio + +Wistleblower + +![](_page_26_Picture_5.jpeg) + +Sent: Wednesday, June 10, 2020 2:30 PM + +To + +Sulect: w: orma or pre "'nary .IIMMI ei 15-016/ Knight Capital TCR & Appendix + +Mr Roach, + +The SEC is irrefutably using my information in unethical and illegal manner. My information is being used to BOTH Bring complaints AND obstruct/protect investigations into entities detailed in my various TCR's. Denying me rightful compensation. This is the latest example + +Chris + +From: Chris Dilorio ‹ > + +Sent: Monday, May 18, 2020 10:36 AM + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +As straightforward as it gets: + +The SEC OWB dragged its feet for 5 years in issuing its preliminary denial notice. + +The SEC knows this is my information. The SEC committed fraud on the court in Gibraltar. The judge corrected them. The SEC was omitting information that implicated NITE, UBSS and customers like Sason/Hanover/Magna. The SEC was obstructing a thorough investigation of my claims. The naked shorting cited in the CGFIA 10O in 2013 PROVES my allegations. The SEC's "targeted investigation" stops short of a full accounting. The SEC Gibraltar complaint does NOT explain the totality of the Oppenheimer complaint. The SEC Gibralter complaint cites 1 OTCM shell and less than 1 million shares traded by Opco. 2 dissenting Opco waiver SEC Commissioners proved that also citing "BILLIONS" of shares in their dissent. The SEC/Opco AML complaint was based on the FINRA complaint and my information. The SEC OWB concocted a completely fabricated reason for denying my Award: "The SEC investigators involved never saw claimants information". The responsibility to distribute Whistleblower information within the SEC is the exclusive and explicit responsibility of the OWB. As a result, the massive fraud taking place continued well into 2020. The 1Q2020 10O proves this. + +The SEC IG Hoecker is guilty of violating specific IG requirements in keeping Congress informed of serious matters like mine. The SEC IG Hoecker has never interviewed me despite my filing 2 separate complaints with his office. The SEC IG Hoecker is guilty of criminal obstruction. SEC Chair Clayton and Co Enforcement Peikin worked at Sullivan Cromwell with Jared Fishman. Fishman has played a key role in the SEC facilitated criminal obstruction. Peikin and Clayton should have recused themselves from ANY pending NITE/VIRT matter before the SEC: My information. Clayton and Peikin should have recused themselves from the SEC facilitated KCG/VIRT merger. My information, including the Opco AML complaint SHOULD have stopped the merger from ever happening. 2 former SEC Commissioners agree with that analysis. The SEC is actively facilitating a massive ,ongoing fraud on the American people they are mandated to protect. NITE/VIRT is a criminal entity. The SEC MUST invoke emergency powers and halt trading in VIRT IMMEDIATELY. + +In short Mr Arp, the criminal activity actively perpetrated by the SEC OWB/IG must be referred to law enforcement as well as Congress. Separate but related: SEC facilitated criminal activity and my claims. The criminality is a matter for law enforcement. My pending matters with the SEC have no bearing on a criminal investigation OR a GAO investigation. + +You are incorrect in your analysis. + +Christopher J Dilorio + +Whistleblower + +--- + +**From:** Chris Dilorio <[REDACTED]> + +**Sent:** Tuesday, May 12, 2020 8:54 AM + +**To:** [REDACTED] <[REDACTED]> + +**Subject:** Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +Almost immediately I filed a formal appeal to the SEC OWB fabricated denial of my award application. In this appeal I show irrefutable proof of my allegations: The SEC OWB used/ is using my information to both bring complaints AND obstruct complaints while denying me compensation. In short: My information exposes an ongoing, massive in scope, SEC facilitated fraud on the American people. Rather than shut it down, the SEC has chosen to cover up so that the illegal activity can continue. It does in 2020 + +Chris + +--- + +**From:** Chris Dilorio <[REDACTED]> + +**Sent:** Monday, May 11, 2020 7:16 PM + +--- + +**Subject:** Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +--- + +**From:** Chris Dilorio <[REDACTED]> + +**Sent:** Wednesday, April 29, 2020 8:03 AM + +--- + +**Subject:** Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +The SMOKING GUN in my allegations: + +Naked shorting in CGFIA (My TCR/FINRA complaint) by "un named third party BD" in 2013. Well known to the SEC. This is why there was no investigation into the ENTIRETY of the FINRA trading activity. The SEC issued waivers to Opco within days of its AML complaint. WHO was the SEC protecting? WHO were the customers and executing BD's/MM's in the Opco complaint? ALSO well known to the SEC: + +MY INFORMATION. 5 years to get a preliminary denial: statute of limitations. BUT the last overt act of this ongoing conspiracy has not yet occurred. + +Chris + +--- + +**From:** Chris Dilorio <[REDACTED]> + +--- + +[REDACTED] >; +[REDACTED] + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +Still more evidence of a well orchestrated scheme to cover up and obstruct a FULL SEC investigation into Opco/Gibraltar/NITE/UBSS trading activity in billions of shares of OTCM money laundering shells. The SEC used my information to bring AND obstruct complaints. + +The 2 SEC Commissioners dissent in granting Oppenheimer waivers after this egregious activity + +https://www.sec.gov/news/statement/dissenting-statement-oppenheimer-inc.html + +## SEC.gov I Dissenting Statement In the Matter of Oppenheimer & Co., Inc. + +Dissenting Statement In the Matter of Oppenheimer & Co., Inc., by Commissioner Luis A. Aguilar and Commissioner Kara M. Stein, February 4, 2015 + +www.sec.gov + +In fact, the SEC waivers came within days of their complaint. Here, these 2 Commissioners cite Oppenheimer trading "BILLIONS of shares of penny stocks". Clearly, they were not JUST referencing the SEC Gibraltar complaint. WHO was the SEC protecting with its complaint then waivers? + +The smoking gun which I have provided to the SEC on several e mails: + +Which came in an SEC reviewed CGFIA 10O + +hups://www.sec.gov/Archives/edgar/data/1344394/000135448814000425/cgfi 10q.htm + +## cgfi\_10q.htm - SEC + +Indicate by check mark whether the registrant (1) has filed all reports required to be filed by Section 13 or 15(d) of the Securities Exchange Act of 1934 during the preceding 12 months (or for such shorter period that the registrant was required to file such reports), and (2) has been subject to such filing requirements for the past 90 days. + +www.sec.gov + +pg 27 + +"Our stock is subject to a "Global Lock" imposed by the Depository Trust and Clearing Corporation (DTCC)" "On September 24, 2013, we were notified that the DTCC would be placing a 'Global Lock" on the Company's Class A stock as a result of actions by a third-party broker dealer. On November 11 2013, DTCC imposed the "Global Lock". Since less than 0.02% of the Company's Class A common stock shares were held within DTCC, Management chose to not undertake the expense of challenging the Global Lock. Nevertheless, shares that are held in street name (CEDE & CO), will not be able to be withdrawn from DTCC without further action." + +Of Course, I have hard copies if you prefer. + +This is CLEAR,IREEFUTABLE,INCONTROVETIBLE evidence of naked shorting by executing BD's in CGFIA. This activity took place per my Knight/UBSS TCR submitted to the SEC. So, WHY did the SEC obstruct an investigation into the ENTIRETY of the trading activity in the FINRA (and FINCEN) complaints? WHO were the executing BD's/MM's? WHO were the customers? + +The veracity of my information is also irrefutable and incontrovertible. + +Game. Set. Match. The SEC is a grossly corrupt, criminal enterprise facilitating illegal activity detailed by me so that this activity can continue. It does in 2020. The SEC solicits then uses Whistleblower information (MINE) to bring complaints AND obstruct other illegal activity while denying proper compensation to whistleblowers (ME). The SEC KNEW who the "third party BD" was in the CGFIA filing long before it filed its Opco complaint in 2015. It had my TCR in its possession in March 2013. So why did it take 5 years for the SEC to issue its preliminary denial? I would remind the SEC that this is very much an ONGOING conspiracy on the part of the SEC et al. IN FURTHERANCE OF THE CONSPIRACY + +Cheers! + +Christopher \_I Dilorio + +Whistleblower + +From: Chris Dilorio + +Sent: Tuesday, April 28, 2020 7:24 AM + +![](_page_30_Picture_8.jpeg) + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +Per my extensive SEC TCR's: Josh Sason/Emanuel/Abitebol/Hanover/Magna extensive overlap with NITE/VIRT (and AQR) money laundering shells. + +The SEC Sason/Magna/NewLead Feb 2019 complaint: also my information + +https://www.sec.gov/litigation/complaints/2019/comp24403.pdf + +Marc P Berger SECURITIES AND EXCHANGE COMMISSION Brookfield Place 200 Vesey Street, Suite 400 New York, NY 10281-1022 SOUTHERN DISTRICT OF NEW YORK JOSHUA SASON, MARC MANUEL, + +3 S. In addition, Pallas acted as an underwriter for a primary offering of NewLead stock, which NewLead attempted to disguise as an asset sale transaction. + +VONW. sec. q ov + +(i) Sole power to vote or to direct the vote . The information required by Item 4(c)(i) is set forth in Row 5 of the cover page for each Reporting Person hereto and is incorporated by reference for each such Reporting Person. + +www.sec.gov + +MG Partners Ltd: Abitebol + +But not in the complaint: MAGNA GIBRALTAR INVESTMENTS LLC: also Abitebol + +As with Opco/GIBRALTAR, who is the SEC protecting? + +AND, per my extensive correspondence with the SEC re my TCR's: The SEC is ALSO grossly under estimating the criminal activity in NITE/Magna/NewLead + +SEC: Criminals bailing out/actively facilitating criminals/criminal activity. + +soliciting/using whistleblower information in unethical/illegal manner to bring complaints/obstruct complaints/deny whistleblower rightful compensation. + +Cheers! + +Christopher Dilorio + +Whistleblower + +From: Chris Dilorio + +Sent: Tuesday, April 28, 2020 6:43 AM + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +More evidence of SEC fraud on the court in Gibraltar. + +It is CLEAR that the Opco AML Covered Action 2015-016 was NOT ENTIRELY based on the SEC Gibraltar Action. The SEC Gibraltar action covered trading activity in just 1 OTCM Money laundering shell: Magnum d'Or where Opco traded less than 1 million shares. CLEARLY the SEC Opco complaint was based on the trading activity in the FINRA Opco AML complaint: my information. However, the SEC Opco complaint even stops short of a thorough investigation of the ENTIRETY of the FINRA trading activity. WHY? WHY didn't the SEC Opco/Gibraltar complaint go into trading activity in the FINRA AML OTCM shells through 2014 as FINCEN did? WHY did the SEC omit MATERIAL information to the court in Gibraltar causing a "significant under estimating" of criminal activity? The SEC knows who the accounts were. The SEC knows who the executing BD's/MM's were. The SEC committed a fraud on the court in Gibraltar. + +Gibraltar was ROLLING OUT NEW OTCM services into the end of 2011. + +https://www.pr.com/press-release/355246 + +Gibraltar Global Securities Now Offering Offshore Brokerage Accounts - PR.com + +Nassau, Bahamas, The, September 22, 2011 Gibraltar Global Securities is now offering offshore brokerage accounts in addition to their broad array of financial services.Gibraltar Global ... + +vo.m.pr.corn + +https://www.pr.com/press-release/355247 + +### GGSI Bahamas is Now Offering Pink Sheet Clearance + +Offshore Broker Adds to Buying and Selling Services + +NW. pr.corn + +https://www.pr.com/press-release/369649 + +## GGSI Bahamas Provides State-of-the-Art Security for OTC PINK Transactions and Communication + +GGSI (Gibraltar Global Securities Inc.) has just announced the release of their latest security measures designed to protect their client's personal data, and to secure electronic communication. + +VAYW. prcorn + +The SEC KNEW the Gibraltar/Opco trading activity went well beyond 2011 YET cut off its investigation at "well into 2010". Thus, KNOWINGLY omitting material information in Gibraltar: FRAUD ON THE COURT. Confirming my allegations of SEC criminal activity in handling my information. WHY? to protect NITE and UBSS. 2 criminal entities bailed out by the SEC. + +Now, the SEC is using the completely fabricated reason for denying my award claim for covered action 2015- 016: "The investigators never saw the claimants information". + +WHEN the explicit and exclusive responsibility to distribute whistleblower information within the SEC falls on the OWB itself. + +More criminal activity. + +Criminals bailing out criminals while denying Whistleblowers due process and compensation. + +Cheers! + +Christopher J Dilorio + +Whistleblower + +From: Chris Dilorio + +Sent: Sunday, April 26, 2020 9:36 AM + +To: + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +Sent: Frida Aril 24 2020 8:18 AM + +< ="; + +u ject: orma appea or pre iminary enia covere action 1 - 1 / Knight Capital TCR & Appendix + +I am in receipt of the SEC preliminary denial of my award claim for the Oppenheimer AML covered action 2015- 016 + +This is my formal appeal of the SEC preliminary determination. + +My award application was based on this very simple FACT: + +The SEC (and FINCEN) Oppenheimer AML actions were based on the FINRA Oppenheimer AML action + +FINRA + +https://www.finra.org/sites/default/files/fda documents/2009018668801 FDA KMX39652.pdf + +#### of - FINRA + +which isFINRA a party, to the entry of findings and violations consistent with the allegations of the (asComplaint sanctions amended andby the Offer of Settlement), to the imposition of the set forth andbelow, understands fully that this Order will become part ofRespondent's permanent disciplinary andrecord may anybe considered in future actions brought by FINRA. BACKGROUND ... + +www.finra.org + +The SEC + +https://www.sec.gov/litigation/admin/2015/33-9711.pdf + +#### Before the SECURITIES AND EXCHANGE COMMISSION + +Before the . SECURITIES AND EXCHANGE COMMISSION . SECURITIES ACT OF 1933 . Release No. 9711 / January 27, 2015 . SECURITIES EXCHANGE ACT O F 1934 . Release No. 74141 / January 27, 2015 . ACCOUNTING AND AUDITING ENFORCEMENT . Release No. 3621 / January 27, 2015 . ADMINISTRATIVE PROCEEDING . File No. 3 -16361 . In the Matter of + +www.sec.gov + +FINCEN + +https://www.fincen.gov/news/news-releases/fincen-fines-oppenheimer-co-inc-20-million-continued-antimoney-laundering + +FinCEN Fines Oppenheimer & Co. Inc. \$20 Million for Continued Anti— Money Laundering Shortfalls I FinCEN.gov + +Washington, D.C. — The Financial Crimes Enforcement Network (FinCEN), working closely with the U.S. Securities and Exchange Commission (SEC), assessed a \$20 million civil money penalty today against Oppenheimer & Co., Inc., for willfully violating the Bank Secrecy Act (BSA). Oppenheimer, a securities broker-dealer in New York, admitted that it failed to establish and implement an adequate ... + +www.fincen.gov + +In the summer of 2012, I had extensive correspondence with Robin Traxler at FINRA where I also cc'd Sean McKessy then SEC OWB Chief. The CURRENT OWB Chief and the SEC IG are in possession of this correspondence. My correspondence dealt with 2 penny stock shells cited in my Knight Capital TCR submitted by Berger Montague in March 2013 attached here: Colorado Goldfields and AppTech. Both shells were NITE and UBSS top traded OTCM shells in 2010-2013. These 2 shells were cited by FINRA in their Oppenheimer AML complaint. Again, the SEC and FINCEN Oppenheimer AML complaints were based on this FINRA complaint. In fact, per the FINRA Opco complaint above, customer "TC" was dumping worthless AppTech (APCX) certificates well into mid 2010. DIRECTLY overlapping with the NITE/UBSS APCX trading activity cited in my Berger 2013 TCR attached and discussed by me with Robin Traxler at FINRA. HOW is it possible that the SEC OWB didn't share my information with SEC investigators? Current SEC OWB Chief Norberg was previously an assistant to then OWB Chief McKessy. + +WHO ultimately executed the trades cited in the FINRA Opco complaint? + +Further, the SEC Gibraltar Securities complaint raises more questions than answers as well. + +https://www.sec.gov/litigation/complaints/2013/comp22683.pdf + +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK SECURITIES AND EXCHANGE COMMISSION, 13 Civ. GffiRALTAR GLOBAL SECURITIES, COMPLAINT NATURE OF THE ACTION - SEC.gov + +12. David Della Sciucca, Jr., age 27, is a resident of Fort Lauderdale, Florida. In . the Magnum d'Or complaint, the Commission charged Della Sciucca with acting as a nominee + +www sec g ov + +The SEC Gibraltar Securities complaint references only 1 OTCM money laundering shell: Magnum d'Or. The complaint specifically states that Oppenheimer sold just 969,822 shares. Again, no mention of executing BD/MM. + +The SEC Oppenheimer AML cites Gibraltar trading activity also. + +The share amounts in the SEC complaint grossly under estimate that in the FINRA complaint. WHY? + +The judge in the Gibraltar case said "the SEC's requested amount CLEARLY UNDERESTIMATES the defendants illgotten gains...." + +http://www.tribune242.com/news/2016/jan/13/bahamian-broker-25m-sanction/ + +A former Bahamian broker/dealer and its principal have been hit with a combined \$24.484 million in financial sanctions by a US court, which found that their "ill gotten gains" were likely ... + +www.tribune242.com + +WHY didn't the SEC go after ALL of the sellers in the FINRA Opco AML complaint? WHY did the SEC "strip out" \$46 million from the Gibraltar ill gotten gains claiming the customers were "UNKNOWN"? WHO is the SEC protecting? WHO were the executing BD's/MM's in the FINRA Opco CGFIA and APCX trades? They certainly know who the customers were. Is customer "JK" Justin Keener/JMJ also in my March 2013 TCR attached? While the SEC Opco AML was based on the FINRA Opco AML, it stopped short of a thorough investigation of NITE and UBSS. In fact, the trading activity of NITE/VIRT and UBSS in the FINRA complaint: my information SHOULD have triggered an immediate investigation of NITE and UBSS. It did not. Did the SEC commit fraud on the court in its OMISSION of material information? + +The timing of the SEC's preliminary determination and the reasoning for the denial ALSO raises more questions than answers. + +My Award application for the Oppenheimer AML SEC complaint was 5 years ago. That's FIVE years ago. So, WHY NOW am I so blessed by the SEC with a preliminary judgement? + +The SEC basis for denying my Award claim for covered action 2015-016: + +"Investigative staff responsible for the covered action NEVER RECEIVED ANY INFORMATION FROM THE CLAIMANT OR had any communication with the claimant" + +Let's take this whopper in 2 parts: + +First, the SEC OWB denied my Award application because The investigators in the complaint never received my information. Has the SEC OWB re written the investigative protocol in this denial? How am I or ANY whistleblower supposed to know WHO the investigators are in a particular case WHEN according to the SEC: ALL investigations are done in a confidential manner???? + +WHAT DOES THE SEC DO WITH WHISTLEBLOWER TIPS EXACTLY? Do they share whistleblower information with ENFORCEMENT as is mandated? HOW would ANY whistleblower know WHO to share information with at the SEC? Isn't that the job of the SEC OWB? + +Second, the fact that no one at the SEC contacted me DOES NOT mean the SEC didn't use my information. This is a completely bogus argument. It certainly would NOT be the first time the SEC used my information now would it Jane? + +In fact, it is NOT the responsibility of the whistleblower to get his/her information to the right Enforcement personnel. That responsibility EXPLICITLY falls on the SEC OWB. So, is the SEC OWB admitting gross negligence in handling my information? After the monumental failure in the Madoff Ponzi/ money laundering SEC facilitated scam on the public the then SEC IG made specific recommendations to the SEC with regards to the proper handling/vetting of Tips and Complaints. + +https://www.sec.gov/files/468.pdf + +Review and Analysis of OCIE Examinations of Bernard L. Madoff Investment Securities, LLC + +AGAIN: The responsibility to properly vet Whistleblower information and get the information into the right hands at the SEC falls EXPLICITLY and EXCLUSIVELY with the SEC OWB itself and is NOT the responsibility of the whistleblower. Further, according to the previous SEC IG in the monumental Madoff failure: the responsibility to contact those supplying Tips and Complaints ALSO falls explicitly and exclusively with the SEC OWB and not the whistleblower. Using these excuses as the basis of denial of Award is completely contrary to SEC MANDATED protocols and procedures. + +Is the SEC OWB admitting it doesn't comply with those recommendations? Recall: the monumental SEC Madoff failure was NOT the fault of Whistleblowers either. OR is the SEC OWB scrambling for a 5 years in the waiting preliminary determination? + +So, after 5 years of waiting for a preliminary determination for my award claim, this is what the SEC best and brightest come up with? + +My Denial of Award for covered action 2015-016 was completely made up on the fly. + +The SEC OWB has applied completely fabricated "rules" to issue this denial. Further affirmation of ALL of my allegations. + +Also by SEC admission, the SEC allowed these 2 penny stock shells to remain a clear and present risk to the investing public. Were CGFIA and APCX ONLY money laundering shells for Oppenheimer in 2008-2010 and then suddenly they were no longer money laundering shells when NITE and UBSS traded billions of shares of both shells 2010-2013? + +WHY did it take until September 2018 before the SEC finally revoked the CGFIA registration? + +https://www.sec.gov/cgi-bin/browse-edgar?company=Garpa&owner=exclude&action=getcompany + +So, WHY was there no SEC investigation of NITE and UBSS trading activity in money laundering shells APCX and CGFIA? The SEC et al facilitated NITE "glitch" took place in August 2012. This SEC/Jefferies/JPM/BX/GS/SEC Chair Clayton Sullivan Cromwell colleague Jared Fishman et al bailout coincides directly with NITE trading activity in 2 SEC/FINRA/FINCEN acknowledged money laundering shells. AND the "bailout" penny stock esque reverse merger between Getco and Knight didn't close until July 2013. HOW could the SEC conduct a COMPLETE and thorough investigation into the FINRA Opco AML complaint WITHOUT implicating NITE when NITE was CLEARLY trading billions of shares of OTCM money laundering shells BEFORE and coinciding with the SEC et al facilitated "glitch" bailout? For UBSS, the DOJ dropped its cross border AML DPA complaint in 2010. UBSS was trading money laundering shells well after the Dal claimed UBSS was in compliance with the cross border DPA. To be clear: BOTH NITE and UBSS knew CGFIA and APCX were money laundering shells when they traded billions of shares of each 2010-2013. Is that FACT disputed by the SEC? The SEC OBSTRUCTED a thorough investigation into the ENTIRETY of trading activity of NITE and UBSS in CGFIA and APCX: MY CLAIMS. Josh Sason/Hanover/ Magna knew CGFIA was a money laundering shell also + +https://www.sec.gov/Archives/edgar/data/1344394/000114420413041432/0001144204-13-041432-index.htm ALSO in my claims: Joshua Sason/Hanover Magna. CGFIA. Also my NewLead TCR1426518350699 and FreeSeas TCR1440274395191 separate but related TCR's where NITE was a top trader in both and BOTH TCR's were filed well in advance (years prior) to the Sason/Hanover/Magna February 2019 complaint. Here's one thing the SEC has been consistent about: The SEC ignores the role of executing BD's and MM's in these scams. WHY? Because NITE is the #1 OTCM shell trader. As far as the SEC is concerned Penny stock trading fairies convert worthless certificates into real money. NO! Executing BD's/MM's like NITE do. Did Oppenheimer sell this order flow to NITE? Who ultimately converted these worthless certificates to real money? As the number 1 OTCM money laundering shell trader it is statistically improbable the NITE has never been the focus of an SEC AML complaint. Per my TCR: what does the NITE Compliance Department do exactly? How many SAR's has NITE filed in the last 10 years? In a 2015 SIFMA speech then SEC Enforcement Director Ceresney was "SHOCKED" by the number of BD's filing 1 or ZERO SAR's. That was just 5 years ago. WHEN would NITE file a SAR releted to the billions of shares of OTCM money laundering shells it trades like CGFIA and APCX: BEFORE or AFTER it trades those BILLIONS of shares?Does NITE pull markets and alert regulators OR continue to trade billions of shares of OTCM money laundering shells in the face of GLARING AML red flags? In fact, in December 2019 the top traded NITE/VIRT OTCM money laundering shell was ELTZ + +https://www.sec.gov/cgi-bin/browse-edgar? + +action=getcompany&CIK=0001607281&owner=exclude&count=40&hidefilings=0 + +The SEC knows the people/entities in ELTZ well + +https://www.sec.gov/litigation/admin/34-46993.htm + +## Strata Coal Company and Terrence A. Tecco: Admin. Proc. Rel. No. 34- 46993 / December 13, 2002 + +Strata Coal Company ("Strata" or "the company") is a non-reporting Nevada shell corporation based in Frisco, Texas. Strata's shares are quoted on the Pink Sheets under the symbol SCOC. Until September 2002, the company was known as WesPac Technologies, at which time it changed its name to Strata. 2. Tecco is the sole officer, director, and ... + +www.sec.gov + +https://www.sec.govinews/press-release/2019-16 + +## SEC.gov I SEC Charges Broker-Dealer and Transfer Agent in Microcap Shell Factory Fraud + +The Securities and Exchange Commission today announced charges against a broker-dealer, a transfer agent, and three individuals for their roles in the creation of over a dozen undisclosed "blank check" companies from 2009 to 2014. + +www.sec gov + +Doesn't the NITE/VIRT compliance Department have internet service in Jersey City? As a DIRECT result of the SEC obstructing a complete and thorough investigation into the ENTIRETY of trading activity in APCX and CGFIA, the top NITE/VIRT traded OTCM money laundering shell in December 2019 was AML red flags galore ELTZ. Illegal activity ACTIVELY facilitated by the SEC. The examples cited in this e mail are not exhaustive. + +And, for it's part AppTech is up and running again/still + +https://www.sec.gov/cgi-bin/browse-edgar?company=Apptech&owner=exclude&action=getcompany + +Unfortunately, AppTech is still up and running as a direct result of the aforementioned SEC " CLEARLY under estimating" otherwise known as CLEARLY OBSTRUCTING. + +In conclusion, The SEC solicits information from whistleblowers like me. The SEC uses whistleblower information to bring actions and then doesn't compensate whistleblowers for their information. + +OR + +The SEC uses whistleblower information to protect criminality perpetrated on the investing public so that this criminal activity can continue. BOTH are gross dereliction of the stated and MANDATED SEC Whistleblower statutes. To blame a whistleblower for the SEC's EXPLICIT and EXCLUSIVE responsibility to properly vet and distribute whistleblower information within the SEC as an excuse to deny Awards is also criminal activity. The SEC: criminals using whistleblower information to protect other criminals AND deny whistleblower rightful compensation for their information. + +I appeal the SEC preliminary determination and wish to file ANOTHER complaint with the SEC IG. + +Cheers! + +Christopher J Dilorio + +Janey, + +how long have you been in possession of my Knight Capital TCR? Almost 7 years to the day. How many follow up e mails have I sent the SEC since then? + +For 7 fucking years, the SEC has known about JMJ/Keener. I told them + +https://www.sec.gov/litigation/complaints/2020/comp-pr2020-72.pdf + +## IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORIDA SECURITIES AND EXCHANGE COMMISSION No. COMPLAINT SUMMARY - sec.gov + +5. Justin W. Keener, age 45, resides in San Juan, Puerto Rico.During the Relevant Period, Keener was a resident of Miami Beach, Florida. Keener registered the name "JMJ Financial" as a fictitious name in Florida in 2008 and used it to conduct the business described + +veww sec g ov + +In February 2019, the SEC brought an action against Joshua Sason/NewLead + +I told the SEC about Magna/ Sason ALSO in my 2013 TCR. + +https://www.sec.gov/litigation/litreleases/2019/Ir24403.htm + +Joshua Sason, et al. (Release No. LR-24403; Feb. 15, 2019) + +Washington, D.C., February 15, 2019 - The Securities and Exchange Commission today announced charges against four individuals and related businesses for their roles in two microcap frauds and unlawful securities offerings. + +Then there's the UBS AML complaint. + +ALSO my claims. For which I sent 10 (TEN) separate Award applications from a commercial fax machine in + +April/May 2019. AND I have YET to receive even a preliminary determination from the OWB/Norberg + +IG, I see your "investigation" into my very very serious accusations of Obstruction related to my information was thorough. In short, the SEC has and still is ripping me off. + +Janey, be a hun and update my TCR's/Awards cited in this e mail. + +And Ms Welshhans, a couple of questions for you: + +1) Have you read the FINRA WTFC Keener complaint? Fictitious notes Ring a bell? + +Same MO as Sason/Magna/NewLead/FreeSeas etc etc etc + +2) WHO executed the Keener OTCM trades in your complaint? Penny stock trading fairies? + +YES, NITE was a top trader in BOTH FreeSeas and NewLead + +The core business at NITE/VIRT is and ALWAYS has been: abusive naked shorting OTCM (and other) shells to facilitate money laundering. + +In short Ms Welshhans, NITE/VIRT converts these worthless certs into real money. NONE of + +JMJ/Sason/IBC/Ironridge/Asher etc etc etc activity takes place without a willing,corrupt, criminal, executing BD/MM like NITE/VIRT, CDEL etc + +Finally, The Keener SEC complaint is FURTHER evidence that FINRA has NO business enforcing US securities + +LAWS. When FINRA "invited" Keener to a disciplinary hearing almost 7 years ago, Keener told them to "fuck off". FINRA bar meant nothing the last 7 years. EXCEPT JMJ/Keener/NITE ripping off more investors. + +Obviously the SEC has/is using my information. I expect to be compensated. + +Cheers! + +Christopher Dilorio + +Whistleblower + +Mr Peirce, + +Congratulations on your nomination as SEC Commissioner. I have read your paper on FINRA lack of accountability. I believe the SEC has abdicated its responsibility to enforce Broker Dealer compliance with the BSA to FINRA BECAUSE it is not accountable. The SEC has not initiated a single stand alone AML complaint. The Brown Brothers Harriman AML complaint IS my claim. ALL of the entities in the complaint are un named WHY? My SEC and IRS Whistleblower complaints explain why. + +Hello, My name is Chris Dilorio. I have filed extensive SEC and IRS Whistleblower complaints alleging a direct link between penny stock money laundering, domestic and foreign entities, Swiss Banks, and executing brokers like KCG and UBS. I can provide overwhelming evidence of SEC obstruction. Please read the FINRA Brown Brothers Harriman AML complaint. This is my claim. All of the entities in the complaint are un named. Why? + +The SEC is not only obstructing an investigation, they are aiding and abetting the activity. These are not far flung theories. The UBS Whistleblower Birkenfeld and his attorney sent 52,000 accounts to the SEC and DOJ. The DOJ at the influence of President Obama and Hillary Clinton entered into the UBS DPA based on just 4400. + +What is so egregious is the activity continues un abated today. + +Start with the so calledAugust 2012 Knight/KCG trading "glitch". Initial reports say the NYSE was breaking the trades. WHY did they stop. Former KCG CEO Joyce said he had a very frank discussion with then SEC Chair Schapiro where the SEC wanted to send a very strong message to market participants. Why not just continue to + +break the trades and hit KCG with a hefty fine? That would not create the conditions to grant KCG exception after exception to do their emergency funding which transferred 74% of the company to "glitch" funding participants and ultimate reverse merger partner GETCO. AND, despite claiming to having a "highly liquid balance sheet" KCG had to raise the entire amount of the loss. + +A very significant and public event was cited in a WSJ article where immediately following the "glitch"KCG inadvertently sent 4000 worthless securities to JPM in an attempt to secure a tri party financing where JPM guaranteed the loan. This is discussed in my attached TCR's and also the topic in a March 2014 letter I sent to the SEC. In the end, the emergency funding was NOT collateral based. The participants knew exactly what a fraud the KCG balance sheet was. After the stock was decimated to \$3, the deal was a convertible with a conversion price at a 50% discount or \$1.50/ share. + +There is much more, but this is a good start. + +Recently, KCG did a modified Dutch auction where they "sold" an asset (HotSpot) to an entity both KCG and GETCO were a major shareholder (BATS) KCG CEO Coleman called it a "highly competitive process". + +Virtually all of the proceeds went to buy back stock from "glitch" financing participants. The purchase price was \$14/share. The stock had never traded there and hasn't since. Reports say 82 million shares were tendered at or BELOW \$14. But they chose to repurchase 23 million shares AT \$1499" 9 I have overwhelming evidence that supports my allegations that the SEC is engaging in criminal obstruction to protect KCG. + +I) Current KCG Dan Coleman ran Equities at UBS during the massive REG Sho violations as well as the cross border activity detailed by Whistleblower Birkenfeld. White and Ceresney represented UBS prior to joining the SEC + +2) At June 30 2011 KCG/Knight reported just 105 million in working capital with hundreds of millions in worthless securities sitting on its balance sheet. KCG was insolvent + +3) The SEC orchestrated the emergency funding for KCG following the so called Aug 2012 trading "glitch" + +4) Read FINRA AML complaints against Brown Brothers Harriman. This is my claim. It links penny stock money laundering to executing brokers like KCG, domestic and foreign entities, and Swiss banks. ALL of the entities in the complaint are un named. WHY? + +5) The FINRA World Trade Financial AML complaint discusses several entities cited in my claims. The customer the complaint focuses on is Justin Keener. Still very much in business. The red flags cited by FINRA were cited in my claims as well. Yet still no investigation. + +6) in July 2015 I contacted Kevin Goodman Dir OCIE for Broker Dealrsat the SEC. He had never seen my information. The IG OCIE Madoff report mandated the OCIE to vet information. McKessy and Ceresney never sent my info to him + +7) I'm sure you are familiar with the Manning v Merrill,KCG,UBS et al litigation. The SEC does not want an investigation into my claims while the litigation is pending. + +8) My claims detail ex clearing trading activity by KCG and UBS. despite the glaring red flags in doing so. Ex clearing s the Obligation Warehouse. A NON GUARANTEED SERVICE set up by the SEC and DTCC to allow firms like KCG to circumvent close out requirements of Rule 204. Clearly contrary to the intent of the SEC authorization in Sec I7a of the 1934 Act to create a system of prompt and timely settlement and to remove impediments there of. + +In short, I told the SEC KCG was insolvent in 2011. Rather than investigate and prosecute, they chose to obstruct. The activity in my TCR's pre dates the "glitch". An investigation would show the SEC bailed out a criminal enterprise. Because of the obstruction, the activity continues today unabated in stocks like STBV,VELA,NEWL,FREE, and dozens more. 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sha256:3be9b5f223290c52adfaad12aacb5e21543b74a8e4763a5ab6e1f10890508a38 +size 1055 diff --git a/marker2/ds9/EFTA00088185/EFTA00088185.md b/marker2/ds9/EFTA00088185/EFTA00088185.md new file mode 100644 index 0000000000000000000000000000000000000000..734583b9800f6ed6b24eb2f5b29917a9a0e2c40f --- /dev/null +++ b/marker2/ds9/EFTA00088185/EFTA00088185.md @@ -0,0 +1,61 @@ +From: ' (USANYS)" < To: ' (USANYS)" Cc: ' (USA1.1YS)" (USANYS)" + +Subject: Re: Epstein FOIA Update + +Date: Sun, 11 Apr 2021 22:01:51 +0000 + +430 is fine for me. + +Sent from my iPhone + +On Apr 11, 2021, at 5:39 PM, (USANYS) < > wrote: + +I should be free anytime tomorrow after an initial conference at 10:30. Thanks. + +From: (USANYS) c Sent: Sunday, April 11, 2021 5:31 PM To: (USANYS) Cc: (USANYS) ; (USANYS) < Subject: Re: Epstein FOIA Update + +Unfortunately have something at 4 with Audrey though it should be over at 430 if you can all do then? + +Sent from my iPhone + +On Apr 11, 2021, at 3:58 PM, (USANYS) wrote: + +Sorry, but any chance we could do 4:00 or later? I have a call scheduled at 3:00. If not, I can have someone else cover the 3:00 call. + +Thanks. + +On Apr 11, 2021, at 3:20 PM, (USANYS) < > wrote: + +3 works for me. Please let me know if I can help with logistics here—happy to circulate invite/dial in if helpful. Thanks. + +Sent from my iPhone + +On Apr 11, 2021, at 2:44 PM, (USANYS) wrote: + +On Apr 10, 2021, at 4:12 PM, (USANYS) c > wrote: + +I understand from Audrey's email that you are scheduling a call for Monday. I unfortunately have conflicts between 11 and 3. I apologize in advance if this complicates scheduling. + +Sent from my iPhone + +On Apr 10, 2021, at 8:29 AM, (USANYS) wrote: + +Thanks, . Will review the transcript and then we can find a time to meet early in the week. It may make sense to meet first as a smaller group with you, to best understand the lay of the land and then loop in the substantive case teams. + +Sent from my iPhone + +On Apr 9, 2021, at 7:21 PM, (USANYS) > wrote: + +All, + +I'm writing to bring everyone up to speed in the Epstein FOIA. We had a pretty rough, approximately 2 hour oral argument today before Judge Engelmayer. It may be easier to share the transcript (which I have same-day ordered and will circulate once received) and/or to talk things through on a call. In sum, the Court is very skeptical of the breadth of the 7(A) withholdings here and will enter an Order on Monday directing that the withheld documents be produced to the Court for in camera review. In connection with that, the Court will direct that any material withheld under 7(A) in connection with the Tortaglione case be specifically marked out as such (as compared to the broader set of material withheld on account of its likelihood of interference with Noel). Basically, the Court has concerns that too much has been withheld on the theory of interference with the criminal cases and will undertake its own assessment of the withholding of the documents. + +The Court was also interested in exactly how much of the withheld materials have been produced to the Noel defendants under Rule 16, and it sounds like it will ask us to make specific representations about precisely which documents have been produced in Noel. + +Also, as you will see from the transcript, the Court directed that I communicate to Audrey that he wants her to consider this case and to evaluate whether it is necessary to confer with Main Justice on the FOIA response here (specifically whether more documents might be produced on reconsideration). In particular, the Court perceived a possibility that the recent change in administration could have some bearing on this. I plan to communicate this to Audrey as soon as we have the transcript (I've asked for that piece of it tonight). + +As noted I will follow up once I have the transcript and will also circulate the Court's Order when it comes out on Monday. I think it would probably make sense to have a call thereafter and will circulate an invite for early next week. I am also available to speak over the weekend if anyone would like to talk sooner. + +Assistant United States Attorney + +[Redacted] \ No newline at end of file diff --git a/marker2/ds9/EFTA00088185/EFTA00088185.metadata.json b/marker2/ds9/EFTA00088185/EFTA00088185.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..6277f4651add643809aecdcd9669701aaffa6b9f --- /dev/null +++ b/marker2/ds9/EFTA00088185/EFTA00088185.metadata.json @@ -0,0 +1,114 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00088185.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 3734, + "elapsed_seconds": 1.74, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 59 + ], + [ + "Line", + 28 + ], + [ + "Text", + 18 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 67 + ], + [ + "Line", + 34 + ], + [ + "Text", + 14 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 6 + ], + [ + "Span", + 6 + ], + [ + "PageFooter", + 2 + ], + [ + "Line", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00088185" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00088188/EFTA00088188.md b/marker2/ds9/EFTA00088188/EFTA00088188.md new file mode 100644 index 0000000000000000000000000000000000000000..35e04e23badefd3afa2cf2458fba94a370cd96ef --- /dev/null +++ b/marker2/ds9/EFTA00088188/EFTA00088188.md @@ -0,0 +1,30 @@ +**To:** [REDACTED] + +**Subject:** RE: BOP Devices + +**Date:** Wed, 04 Mar 2020 20:21:51 +0000 + +--- + +Got it, thanks [REDACTED] + +--- + +**From:** [REDACTED] > + +**Sent:** Wednesday, March 4, 2020 9:32 AM + +**To:** [REDACTED] + +**Subject:** BOP Devices + +The DOJ OIG Cyber team completed the analysis of the BOP devise. Attached is the report, they found one discussion of Epstein in a text exchange. + +[REDACTED] +U.S. Department of Justice +Office of the Inspector General +New York Field Office + +[REDACTED] + +[REDACTED] \ No newline at end of file diff --git a/marker2/ds9/EFTA00088188/EFTA00088188.metadata.json b/marker2/ds9/EFTA00088188/EFTA00088188.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..b0cfce6c62f7017e0e5bad9a7b92c1fb8962799c --- /dev/null +++ b/marker2/ds9/EFTA00088188/EFTA00088188.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00088188.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 512, + "elapsed_seconds": 3.02, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 30 + ], + [ + "Text", + 27 + ], + [ + "Line", + 15 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00088188" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00088189/EFTA00088189.md b/marker2/ds9/EFTA00088189/EFTA00088189.md new file mode 100644 index 0000000000000000000000000000000000000000..34438105b730a045284c213ede4e227db37f4c30 --- /dev/null +++ b/marker2/ds9/EFTA00088189/EFTA00088189.md @@ -0,0 +1,141 @@ +GEOFFREY S. BERMAN United States Attorney for the Southern District of New York By: STEVEN J. KOCHEVAR Assistant United States Attorney 86 Chambers Street, Third Floor New York, New York 10007 + +Tel.: Fax: + +#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +THE NEW YORK TIMES COMPANY, + +Plaintiff, + +v. + +FEDERAL BUREAU OF PRISONS, + +Defendant. + +20 Civ. 833 (PAE) + +## ANSWER + +Defendant the Federal Bureau of Prisons ("BOP"), by its attorney, Geoffrey S. Berman, United States Attorney for the Southern District of New York, hereby answers the Complaint (Dkt. No. 1) of Plaintiff the New York Times Company on information and belief as follows: + +# COMPLAINT! + +1. Paragraph 1 of the Complaint consists of Plaintiff's characterization of this action, to which no response is required. + +2. The first sentence of Paragraph 2 consists of Plaintiff's characterization of its Freedom of Information Act ("FOIA") request, and BOP respectfully refers the Court to Plaintiff's FOIA request for a complete and accurate statement of its contents. To the extent a further response is required, BOP admits that Jeffrey Epstein died at the Metropolitan + +Defendant replicates the headings from Plaintiffs' Complaint solely for ease of reference, without admitting any allegations set forth thereunder. + +Correctional Center ("MCC") on August 10, 2019, and respectfully refers the Court to the indictment entered in United States v. Jeffrey Epstein, No. 19-CRIM-00490 (S.D.N.Y.). BOP denies knowledge or information sufficient to form a belief as to the truth or falsity of the allegations set forth in the second sentence of Paragraph 2. + +#### PARTIES + +- 3. BOP denies knowledge or information sufficient to form a belief as to the truth or falsity of the allegations set forth in Paragraph 3 of the Complaint. +- 4. BOP denies the allegations of Paragraph 4 of the Complaint, except admits that it is an agency of the United States. + +#### JURISDICTION AND VENUE + +- 5. Paragraph 5 of the Complaint sets forth legal conclusions regarding jurisdiction, to which no response is required. +- 6. Paragraph 6 of the Complaint sets forth legal conclusions regarding venue, to which no response is required. +- 7. Paragraph 7 of the Complaint sets forth legal conclusions, to which no response is required. +- 8. Paragraph 8 of the Complaint sets forth legal conclusions, to which no response is required. To the extent a response is required, BOP denies the allegation that it has failed to comply with any applicable statutory deadlines. + +#### FACTS + +# The August 12. 2019 Requests + +- 9. Denies the allegations set forth in Paragraph 9 of the Complaint. + +10. Paragraph 10 consists of Plaintiff's characterization of its FOIA request, and BOP respectfully refers the Court to Plaintiff's FOIA request for a complete and accurate statement of its contents. + +11. Paragraph 11 consists of Plaintiff's characterization of its FOIA request, and BOP respectfully refers the Court to Plaintiff's FOIA request for a complete and accurate statement of its contents. + +12. Paragraph 12 consists of Plaintiff's characterization of its FOIA request, and BOP respectfully refers the Court to Plaintiff's FOIA request for a complete and accurate statement of its contents. + +13. Paragraph 13 consists of Plaintiff's characterization of its FOIA request, and BOP respectfully refers the Court to Plaintiff's FOIA request for a complete and accurate statement of its contents. + +14. Paragraph 14 consists of Plaintiff's characterization of its FOIA request, and BOP respectfully refers the Court to Plaintiff's FOIA request for a complete and accurate statement of its contents. + +15. Admits that BOP assigned Plaintiffs August 13, 2019 requests Number 2019- 05665 and sent Plaintiff a response letter dated September 23, 2019. BOP respectfully refers the Court to its response letter dated September 23, 2019, for an accurate statement of its contents. BOP otherwise denies the allegations of Paragraph 15, including to the extent they fail to reflect or accurately characterize BOP's September 23, 2019 response letter. + +16. BOP denies knowledge or information sufficient to form a belief as to the truth or falsity of the allegations set forth in the first sentence of Paragraph 16 of the Complaint, and avers that on October 7, 2019, BOP's Office of Information Policy received a letter from Plaintiff seeking review of BOP's decision on Plaintiff's FOIA request. With respect to the last + +sentence of Paragraph 16, BOP admits that it sent Plaintiff an e-mail on October 9, 2019, and respectfully refers the Court to GOP's October 9, 2019 e-mail for a complete and accurate statement of its contents. Paragraph 16 otherwise consists of Plaintiff's characterization of its FOIA appeal; BOP respectfully refers the Court to Plaintiff's FOIA appeal for a complete and accurate statement of its contents and denies the allegations to the extent they fail to reflect or accurately characterize Plaintiff's FOIA appeal. + +17. BOP denies knowledge or information sufficient to form a belief as to the truth or falsity of the allegations set forth in Paragraph 17 of the Complaint. + +18. Admits the allegations of Paragraph 18 of the Complaint. + +# The December 12, 2019 Request + +19. Paragraph 19 consists of Plaintiffs characterization of its FOIA request, and BOP respectfully refers the Court to Plaintiff's FOIA request for a complete and accurate statement of its contents. + +20. Admits the allegations of Paragraph 20 of the Complaint, and respectfully refers the Court to GOP's letter to Plaintiff dated December 16, 2019 for a complete and accurate statement of its contents. + +21. Paragraph 21 of the Complaint sets forth legal conclusions, to which no response is required. To the extent a response is required, BOP denies the allegation that it has failed to comply with any applicable statutory deadlines. + +## The January 2, 2020 Request + +22. BOP admits the allegations in the first sentence of Paragraph 22 of the Complaint. The remainder of Paragraph 22 consists of Plaintiffs characterization of its FOIA request, and BOP respectfully refers the Court to Plaintiff's FOIA request for a complete and accurate statement of its contents. + +23. Admits the allegations of Paragraph 23, and respectfully refers the Court to GOP's letter to Plaintiff dated January 9, 2020, for a complete and accurate statement of its contents. + +24. Paragraph 24 of the Complaint sets forth legal conclusions, to which no response is required. To the extent a response is required, BOP denies the allegation that it has failed to comply with any applicable statutory deadlines. + +# COUNT ONE + +25. BOP realleges and incorporates its answers to Paragraphs 1 through 25 as though fully set forth herein. + +26. Paragraph 26 of the Complaint consists of legal conclusions, to which no response is required. + +27. Paragraph 27 of the Complaint consists of legal conclusions, to which no response is required. To the extent a response is required, BOP denies the allegation that it has failed to comply with any applicable statutory deadlines. + +28. Paragraph 28 of the Complaint consists of legal conclusions, to which no response is required. To the extent a response is required, BOP denies the allegations of Paragraph 28 of the Complaint. + +29. Paragraph 29 of the Complaint consists of legal conclusions, to which no response is required. To the extent a response is required, BOP denies the allegations of Paragraph 29 of the Complaint. + +# REQUEST FOR RELIEF + +The remainder of the Complaint, Paragraphs 30 through 33, sets forth Plaintiff's requested relief, to which no response is required. To the extent a response is required, BOP denies that Plaintiff is entitled to the relief sought, or to any relief whatsoever from Defendant. + +### DEFENSES + +### FIRST DEFENSE + +Plaintiff fails to state a claim upon which relief can be granted. + +### SECOND DEFENSE + +Some or all of the requested records are not agency records subject to FOIA, see 5 U.S.C. § 552(a)(4)(B). + +## THIRD DEFENSE + +Plaintiff is not entitled to compel the production of records protected from disclosure by any applicable FOIA exemption, see 5 U.S.C. § 552(b). + +## FOURTH DEFENSE + +The Court lacks subject matter jurisdiction over Plaintiffs' requests for relief that exceed the relief authorized under FOIA, 5 U.S.C. § 552. + +### FIFTH DEFENSE + +Plaintiff's FOIA request does not reasonably describe the records sought. + +#### SIXTH DEFENSE + +Plaintiff is not entitled to have this action expedited under 28 U.S.C. § 1657. + +### SEVENTH DEFENSE + +Plaintiff is not entitled to attorney fees under 5 U.S.C. § 552(a)(4)(E). + +BOP may have additional defenses that are presently unknown but may be ascertained at a later time. Defendant reserves the right to assert each and every affirmative or other defense that may be available, including any defenses available pursuant to Federal Rules of Civil Procedure 8 and 12. + +WHEREFORE, Defendant respectfully requests that the Court: (1) dismiss the Complaint with prejudice; (2) enter judgment in favor of BOP; and (3) grant such further relief as the Court deems just and proper. + +Date: New York, New York March 4, 2020 + +> GEOFFREY S. BERMAN United States Attorney for the Southern District of New York Attorney for the United States of America + +By: Assistant United States Attorney 86 Chambers Street, Third Floor New York, New York 10007 Tel.: Fax: \ No newline at end of file diff --git a/marker2/ds9/EFTA00088189/EFTA00088189.metadata.json b/marker2/ds9/EFTA00088189/EFTA00088189.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..b04f8dd2dd1de68c36bc3ab77596ec8aecc38e7e --- /dev/null +++ b/marker2/ds9/EFTA00088189/EFTA00088189.metadata.json @@ -0,0 +1,732 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00088189.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 7, + "chars": 9392, + "elapsed_seconds": 1.44, + "image_assets": [], + 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More specifically, the list of defense attorneys comes from ECF. The information on the other two names comes from news articles you'll see with a simple google search. + +From: + +Sent: Tuesday, June 8, 2021 5:18 PM + +To: + +Cc + +Subject: RE: Attorneys + +Thanks so much for the info! Any issues with me sharing this with the agents for possible inclusion in their report? I imagine not, since it seems to all be public, but I wanted to confirm with you first. + +From: + +Sent: Tuesday, June 8, 2021 5:15 PM + +To: + +CO + +Subject: RE: Attorneys + +Hi all, + +The defense attorneys who appeared in our case and filed notices of appearances were: + +- James Brochin, Steptoe & Johnson +- Marc Allan Fernich, Law Office of Marc Fernich, +- Martin Weinberg, Martin Weinberg PC +- Michael Miller, Steptoe & Johnson +- Michael Scavelli, Steptoe & Johnson +- Reid Weingarten, Steptoe & Johnson + +Beyond that, I can't send a list of all of Epstein's attorneys, since he has had dozens of attorneys over the years, but it doesn't sound like that's really what you're looking for. With respect to the names "Colon" and "G. Tali", it was widely reported that Mariel Colon Miro and Gulnora Tali visited Epstein in jail in connection with his will. + +Hope that helps, but please let us know if you need anything else. + +Best, + +From: + +Sent: Tuesday, June 8, 2021 4:58 PM + +To: >; + +Cc: + +Subject: FW: Attorneys + +The D0J 0IG agents who have been working on the MCC guard case with us are currently working on their report concerning Epstein. They have the below question about the names of Epstein's attorneys. Could you send the names of all of Epstein's attorneys to us and we will pass them along to the 0IG agents? + +Thanks so much! + +From: + +Sent: Tuesday, June 8, 20214:51 PM + +To: + +Subject: Attorneys + +Good Evening Jessica, + +We are trying to identify the attorneys who represented Jeffrey Epstein and visited him in prison. The MCC attorney log is either illegible or the attorneys listed just one name. The names I could read were "Colon" and "G. Tali". Can you please help us identify them? Thank you. + +![](_page_1_Picture_16.jpeg) + +Special Agent + +U.S. Department of Justice • Office of the Inspector General • New York Field Office + +One Battery Park Plaza, 29th Floor, New York, NY 10004 + +Cell: \ No newline at end of file diff --git a/marker2/ds9/EFTA00088196/EFTA00088196.metadata.json b/marker2/ds9/EFTA00088196/EFTA00088196.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..452fcf9b47c79dd58fb873935d912552cc5fdbc2 --- /dev/null +++ b/marker2/ds9/EFTA00088196/EFTA00088196.metadata.json @@ -0,0 +1,98 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00088196.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2518, + "elapsed_seconds": 1.4, + "image_assets": [ + "_page_1_Picture_16.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 69 + ], + [ + "Line", + 35 + ], + [ + "Text", + 29 + ], + [ + "ListItem", + 6 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 61 + ], + [ + "Line", + 28 + ], + [ + "Text", + 20 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00088196" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00088196/_page_1_Picture_16.jpeg b/marker2/ds9/EFTA00088196/_page_1_Picture_16.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..87f8981c2214012da68f1e49fc5d5fe64ccc1d6b --- /dev/null +++ b/marker2/ds9/EFTA00088196/_page_1_Picture_16.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:6e2461a8c2ff16f29a824c9d9c6275ff825a281756c338a9c9ff9db9ef398db4 +size 6218 diff --git a/marker2/ds9/EFTA00088198/EFTA00088198.md b/marker2/ds9/EFTA00088198/EFTA00088198.md new file mode 100644 index 0000000000000000000000000000000000000000..e7f5fd57eb6c2db46f72f75268e0c95e8fa771b0 --- /dev/null +++ b/marker2/ds9/EFTA00088198/EFTA00088198.md @@ -0,0 +1,19 @@ +Cc. + +Subject: Priorities 2021 + +Date: Wed, 02 Jun 2021 18:22:28 +0000 + +Importance: Normal + +Attachments: Priorities6.2021.doex + +Attaching a somewhat rudimentary draft; just let me if you think the proposed cases are appropriate, and any I may've (very likely) forgotten. Thanks. + +Spokesman + +United States Department of Justice + +U.S. Attorney's Office ISouthern District of New York + +Mobile I Press Offic \ No newline at end of file diff --git a/marker2/ds9/EFTA00088198/EFTA00088198.metadata.json b/marker2/ds9/EFTA00088198/EFTA00088198.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..59a31eaa61be745d2c8dcc2bb90f797d337c59b9 --- /dev/null +++ b/marker2/ds9/EFTA00088198/EFTA00088198.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00088198.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 401, + "elapsed_seconds": 0.54, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 25 + ], + [ + "Line", + 13 + ], + [ + "Text", + 11 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00088198" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00088199/EFTA00088199.md b/marker2/ds9/EFTA00088199/EFTA00088199.md new file mode 100644 index 0000000000000000000000000000000000000000..fa4935815ddff2059b725af6301554253023d144 --- /dev/null +++ b/marker2/ds9/EFTA00088199/EFTA00088199.md @@ -0,0 +1,33 @@ +From: To: ' Cc: ' [=. + +Subject: Re: Mark Epstein + +Date: Mon, 28 Oct 2019 22:00:04 +0000 + +I am sony I would not have confirmed for today. I had a 4 pm doctors appointment scheduled for months. I had told mark 10/31 as well. My apologies. Can we still do 10/31? + +Sent from my iPhone + +On Oct 28, 2019, at 5:51 PM, > wrote: + +Hi S + +Per my email on October 24 below, we were confirmed for Monday (which was today, October 28). + +From: Sent: Monday, October 28, 2019 5:27 PM To: Cc: Subject: Re: Mark Epstein + +Greetings. We are set for 10/31 at three per your direction. Did I miss an update? + +Sent from my iPhone + +On Oct 28, 2019, at 3:12 PM, > wrote: + +Hi S + +Are you en route? Thanks. + +On Oct 24, 2019, at 10:55 AM, wrote: + +We are confirmed for a meeting at 3:00 p.m. on Monday at See you then. Thanks. + +Assistant United States Attorney Southern District of New York \ No newline at end of file diff --git a/marker2/ds9/EFTA00088199/EFTA00088199.metadata.json b/marker2/ds9/EFTA00088199/EFTA00088199.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..cd8df4885ae61a43bc1bb5d723c5d68ba9b173f2 --- /dev/null +++ b/marker2/ds9/EFTA00088199/EFTA00088199.metadata.json @@ -0,0 +1,80 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00088199.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 859, + "elapsed_seconds": 0.89, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 59 + ], + [ + "Line", + 28 + ], + [ + "Text", + 18 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "PageFooter", + 1 + ], + [ + "Line", + 1 + ], + [ + "Span", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00088199" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00088201/EFTA00088201.md b/marker2/ds9/EFTA00088201/EFTA00088201.md new file mode 100644 index 0000000000000000000000000000000000000000..0cc2cb7bec36607d12f39b1222f706d1b4104503 --- /dev/null +++ b/marker2/ds9/EFTA00088201/EFTA00088201.md @@ -0,0 +1,15 @@ +From: + +To: + +Cc: + +Subject: https://www.foxnews.corn/us/forensic-pathologist-jeffrey-epstein-homicide-suicide + +Date: Wed, 30 Oct 2019 12:26:32 +0000 + +Baden emphatically told FOX News this morning that his findings are more consistent with strangulations: "I've not seen in 50 years where that occurred in a suicidal hanging case," the 85-year-old medical legend told Fox News. + +We'll get a lot of inquiries about this today. + +Sent from my iPhone \ No newline at end of file diff --git a/marker2/ds9/EFTA00088201/EFTA00088201.metadata.json b/marker2/ds9/EFTA00088201/EFTA00088201.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..9e9efabebca20b44812c7b91fa73aef197234710 --- /dev/null +++ b/marker2/ds9/EFTA00088201/EFTA00088201.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00088201.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 443, + "elapsed_seconds": 0.5, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 21 + ], + [ + "Line", + 11 + ], + [ + "Text", + 9 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00088201" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00088202/EFTA00088202.md b/marker2/ds9/EFTA00088202/EFTA00088202.md new file mode 100644 index 0000000000000000000000000000000000000000..700143eba84e81439c03e751fa51cc5efaa117f6 --- /dev/null +++ b/marker2/ds9/EFTA00088202/EFTA00088202.md @@ -0,0 +1,53 @@ +To: Cc: + +Subject: Re: expstein/tartaglione + +Date: Sun, 03 Nov 2019 00:03:38 +0000 + +Dropping her because I thought she was walled off? But no, no reason to discuss further. + +Assistant U.S. Attorney + +On Nov 2, 2019, at 19:46, wrote: + +No, but let us know if there's any reason to discuss further. Looping in MoCo. + +On Nov 2, 2019, at 4:01 PM, Wrote: + +Thanks. Are you planning to change your position from a while ago that you won't be listening to what NT has to say? + +Assistant U.S. Attorney + +On Nov 2, 2019, at 15:57, wrote: + +FYI + +Begin forwarded message: + +From: Bruce Barket + +Date: November 2, 2019 at 3:14:33 PM EDT + +To: + +c: t a men:wig + +Subject: expstein/tartaglione + +Good afternoon, + +, Donna Aldea + +As you may be aware our office represents Nicholas Tartaglione who was a cellmate with Jeffery Epstein until Epstein's suicide attempt on July 22-23rd. Based on information already known to the BOP, I imagine that you are also aware that Mr. Tartaglione has information that would be helpful in rebutting the proposition that Epstein was murdered and will support the conclusion that Epstein was suicidal. Some of this information may be + +corroborated. Similarly, Mr. Tartaglione also has information about the facility and the conduct of the staff at or around the time of the attempted suicide and, albeit to a lesser degree, conduct around the time of Epstein's actual suicide. + +If you are interested in this information, I would suggest that we meet to discuss the matter. + +Bruce A. Barket, Esq. + +Barket Epstein Kearon Aldea & LoTurco, LLP + +Garden City. NY 11530 + +This transmittal may be a confidential attorney client communication or may otherwise be privileged or confidential. If it is not clear that you are the intended recipient, you are hereby notified that you have received this transmittal in error; any review, dissemination, distribution or copying of this transmittal is strictly prohibited. If you suspect that you have received this communication in error, please notify us immediately by telephone or email and immediately delete this message and all its attachments \ No newline at end of file diff --git a/marker2/ds9/EFTA00088202/EFTA00088202.metadata.json b/marker2/ds9/EFTA00088202/EFTA00088202.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..467bc8daad9581c4317b709c5d8c43fe389e7ef7 --- /dev/null +++ b/marker2/ds9/EFTA00088202/EFTA00088202.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00088202.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2089, + "elapsed_seconds": 1.06, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 61 + ], + [ + "Line", + 31 + ], + [ + "Text", + 23 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 25 + ], + [ + "Line", + 13 + ], + [ + "Text", + 6 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00088202" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00088204/EFTA00088204.md b/marker2/ds9/EFTA00088204/EFTA00088204.md new file mode 100644 index 0000000000000000000000000000000000000000..017a2e9c5c071fff2528ff40b06fcbf8e3e75fae --- /dev/null +++ b/marker2/ds9/EFTA00088204/EFTA00088204.md @@ -0,0 +1,19 @@ +From: Nicole Simmons To: "F- ‹ Cc: Jeff Pagliuca Ann Lundbe Laura Menninger • rr + +Subject: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) [Proposed Redaction to Request and Reply to Modify Protective Order (Under Seal)] + +Date: Mon, 24 Aug 2020 15:57:05 +0000 + +Attachments: 2020.08.24 JSP\_Ltr.\_Submitting\_Proposed\_Redactions\_Under Seal.pdf; Ex.\_A\_2020.08.17\_,ISP\_Proposed\_Redactions\_to\_Ltt\_re.\_Modification\_of the\_Protective\_ Order.pdf; Ex.\_B\_2020.08.24\_,ISP\_Reply\_Ltrje.\_Modification\_of the\_Protective\_Order.pdf + +Inline-Images: image00 1 jpg + +Dear Judge Nathan, + +At the request of Jeffrey S. Pagliuca, please see attached Ms. Maxwell's Proposed Redactions to her Request and Reply in Support of Modifying the Protective Order filed under. + +Regards, + +Nicole + +![](_page_0_Picture_9.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00088204/EFTA00088204.metadata.json b/marker2/ds9/EFTA00088204/EFTA00088204.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..223653f677d682fa265ca9073e944f20908e3f2e --- /dev/null +++ b/marker2/ds9/EFTA00088204/EFTA00088204.metadata.json @@ -0,0 +1,60 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00088204.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 817, + "elapsed_seconds": 0.56, + "image_assets": [ + "_page_0_Picture_9.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 55 + ], + [ + "Line", + 27 + ], + [ + "Text", + 9 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00088204" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00088204/_page_0_Picture_9.jpeg b/marker2/ds9/EFTA00088204/_page_0_Picture_9.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..69b66466387e004ee5f900cbc4c0d81952317c8b --- /dev/null +++ b/marker2/ds9/EFTA00088204/_page_0_Picture_9.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:8711303211e1f6d6cf7a9cf1145982be3c627718362d93ef8113b82bcb76931b +size 14654 diff --git a/marker2/ds9/EFTA00088205/EFTA00088205.md b/marker2/ds9/EFTA00088205/EFTA00088205.md new file mode 100644 index 0000000000000000000000000000000000000000..6838383a825df1ee482ee1e7e7028186a3594e53 --- /dev/null +++ b/marker2/ds9/EFTA00088205/EFTA00088205.md @@ -0,0 +1,79 @@ +![](_page_0_Picture_0.jpeg) + +Haddon, Morgan and Foreman. P.c Jeffrey Paglluca + +II A D D O N M OR G A N FOREMAN + +303.832.2628 + +August 24, 2020 + +## VIA EMAIL + +The Honorable Alison J. Nathan United States District Court Southern District of New York + +> Re: Reply in Support of Request to Modify Protective Order (Under Seal)i United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) + +Dear Judge Nathan, + +Defendant Ghislaine Maxwell filed a simple request: that she be permitted to disclose under seal to the Second Circuit Court of Appeals and a separate district court in this same court (the "Civil Litigation") the fact that her adversary in the civil case pending in those two fora already handed over nearly 90,000 pages of "confidential" protective-order materials, much of it also filed under seal, to the U.S. Attorney's Office pursuant to a subpoena while those two courts have sub judice whether to unseal many of the very same materials. + +The government proposes to keep both courts in the dark about the fact and method of the disclosure. They claim the civil litigation is "unrelated," that issuance of the subpoena was "standard practice," and that disclosure will jeopardize an ongoing criminal investigation and "permit dissemination of a vast swath of materials." Each of the government's arguments lack merit. + +## The Civil Litigation is Not "Unrelated": + +First, the government claims the civil action is "unrelated." Resp. at I. The assertion is frivolous. In the same pleading, the government touts its production of "more than 165,000 pages of discovery to the defense," of which (they neglect to mention), nearly 90,000 of the + +Ms. Maxwell has filed a letter motion which seeks leave to file this reply under seal, while providing the unredacted version to the government and the Court. This reply describes and discusses sealed materials and materials subject to the Protective Order in this case. Ms. Maxwell also simultaneously files under separate cover her proposed redactions to her Request to Modify Protective Order (Aug. 17, 2020), and this Reply, in accordance with the Court's Order of August 18, 2020 (Doc. 44). + +pages were taken wholesale from the adversary party to the Civil Litigation pursuant to the subpoena at issue. That more than one-half of the criminal discovery originated in the Civil Litigation, that the government intends to rely on those Civil Litigation materials to prosecute this criminal action, and that the sealed Civil Litigation materials are quoted in Counts 6 and 7 of the Indictment and Superseding Indictment renders the Civil Litigation far from "unrelated." Equally frivolous, and wholly circular, is the government's contention that Ms. Maxwell has been provided with a "trove of materials she can mine to her advantage in the civil discovery." Resp. at 2. The 90,000 pages of criminal discovery that the government now has are the civil discovery and pleadings; Ms. Maxwell already has them to use in the Civil Litigation. + +What Ms. Maxwell does not have is (and hereby seeks) permission to disclose (a) the fact that her adversary has given those materials to the government and (b) those materials now constitute more than V2 of all the 165,000 pages of criminal discovery to be used in this prosecution. The government's ad hominem suggestion that Ms. Maxwell has "cherry-pick[ed] materials" to seek an "advantage in their efforts to defend against accusations of abuse" or "delay court-ordered disclosure of previously sealed materials" reveals a fundamental (or feigned) lack of understanding as to how the unsealing process works. It also begs the question, to be fleshed out at a later time, why the government, if it thinks the sealed materials are "confidential" and important to their prosecution, is not itself objecting to the unsealing of the materials to the general public, to the press, and to other witnesses to this action, as is standard practice by their office and others in this jurisdiction. See, e.g., Securities and Exchange Commission v. Carroll, 19 Civ. 7199 (AT), 2020 WL 1272287, at \*1 (S.D.N.Y. Mar. 17, 2020); Securities and Exchange Commission v. Abraaj Investment Management Limited, 19-CV-3244 (AJN), 2019 WL 6498282, at \*1 (S.D.N.Y. Dec. 3, 2019); Nesbitt v. Benner, 18-CV-00699 (VLB), 2018 WL 5619716 (E.D.N.Y. Oct. 30, 2018) (staying Trafficking Victims Protection Act civil case during pendency of related state court prosecution). + +Ms. Maxwell simply seeks to alert the judicial officers in the related Civil Litigation to facts about which her adversary is already aware. + +# Issuance of the Subpoenas Not "Standard Practice": + +Second, the government tries to normalize, without citation to authority, its conduct as "standard practice." Resp. at 2. To the contrary, the controlling case in this Circuit, Martindell v. Intl Telephone & Telegraph Corp., 594 F.2d 291, 293 (2d Cir. 1979), mandates a wholly different procedure: the use of a non-ex pane subpoena with an opportunity for the aggrieved party to move to quash. Similar cases in this district demonstrate the "non-standard" nature of the government's conduct regarding these subpoenas. For example, Judge Koeltl observed when considering whether to release a single deposition transcript to the government: "the Second Circuit has made clear that the Government may not use its `awesome' investigative powers to seek modification of a protective order merely to compare the fruits of the plaintiffs discovery in a civil action with the results of a prosecutorial investigation in a criminal action." Botha v. Don King Prods., Inc., No. 97 CIV. 7587 (JGK), 1998 WL 88745, at \*3 (S.D.N.Y. Feb. 27, 1998) (citing Minpeco S.A. v. Conticommodity Servs., Inc., 832 F.2d 739, 743 (2d Cir. 1987) and Martindell, 594 F.2d at 297). Judge Sweet, the same judge who approved the civil protective order upon which Ms. Maxwell relied, held that the defendant's "continuing need for the + +confidentiality stipulation's protection outweighs by far the government's need for the deposition transcript...." United States v. Oshatz, 700 F. Supp. 696, 703 (S.D.N.Y. 1988); see also Pahnieri v. State of New York, 779 F.2d 861 (2d Cir. 1987); Abbott Laboratories v. Adelphia Supply USA, Case 2015-cv-5826 (CBA) (MDG), 2016 WL 11613256 (S.D.N.Y. Nov. 22, 2016) ("In the Second Circuit, there is a presumption in favor of enforcing protective orders against grand jury subpoenas."); United States v. Kerik, 07 CR 1027, 2014 WL 12710346 (S.D.N.Y. July 23, 2014). It seems that a majority of courts in this district have rejected the claimed "standard practice" arguments made by the Government before Judge McMahon. A notable difference is that the other applications were not conducted ex parte. Review of the sealed materials further illustrates the point. One of the two judicial officers presented with the government's application ex pane agreed that it was not appropriate and denied the request. The other questioned the irregularity of the procedure, applied a legal test not urged by the government, but ultimately agreed to grant the application. That she may have been incorrect remains to be litigated; Ms. Maxwell is not asking this Court to decide that question today. + +But Ms. Maxwell is seeking in both the Second Circuit and before Judge Preska that the status quo be maintained until the issue can be litigated. If, for example, without the benefit of this information, the Second Circuit and/or Judge Preska order Ms. Maxwell's deposition unsealed, the cat will be out of the bag. Should this Court ultimately decide that it was inappropriate for the government to have obtained the materials pursuant to the subpoena, the government most assuredly will claim inevitable discovery, that even though it was unconstitutional to have obtained the discovery when they did, there is no harm because the documents are now in the public domain thanks to the unsealing process. Perhaps the government's desire to have the materials publicly unsealed, or at least their failure to intervene to stay the unsealing process, can be explained by their hope to rely on that doctrine when the ultimate question is presented to this Court. + +The Government Does Not Explain How Any "Secret" Investigation Will be Compromised. Third, the government claims that the materials at issue are "Confidential" because the "full scope and details" of their very-public proclamations of an ongoing criminal investigation "have not been made public." Resp. at 3. This argument too is nonsensical: the sealed materials that Ms. Maxwell seeks to file, under seal, do not disclose the "full scope and details" of the government's criminal investigation, as a simple review of the materials makes clear. The sealed materials are comprised of applications to serve a subpoena on a law firm and the two courts' rulings on those applications. Nothing in the sealed materials reveals the names of other targets, even though the criminal discovery produced to date reveals that other named targets are fully aware of their status as such and have been interacting with the government lawyers, as Ms. Maxwell was prior to her indictment. Further, the indictment itself makes clear that the government has obtained the sealed materials from the subpoena recipient because it quotes from those materials. Certainly the subpoena recipient, otherwise known as counsel for the adverse party to the Civil Litigation, knows the two things that Ms. Maxwell seeks to file under seal in + +that matter: that the government obtained the subpoena for the materials and that they complied with the subpoena by producing 90,000 pages in response.' + +The government does not explain, because they cannot, how it will harm an ongoing criminal investigation to reveal the sealed materials under seal to two arbiters: Judge Preska and the Second Circuit panel assigned to the unsealing process. Clearly those judicial officers are fully capable of maintaining files under seal and confidences. Nor is there any support for the argument that this limited request will "permit dissemination of a vast swath of materials." Resp. at 3. The slippery slope contention is belied by the limited nature of Ms. Maxwell's request. The sealed materials are a discrete set of judicial documents, not a "vast swath of materials," and Ms. Maxwell seeks to file them under seal for those Courts to use in their determinations. Hyperbole aside, the request is appropriately limited. + +Further, the government's suggestion that "there is no impediment to counsel making sealed applications to Court- I and Court-2, respectively, to unseal the relevant materials" is, at best, baffling. Resp. at 3 n.5. Such a "sealed application" in furtherance of her Civil Litigation would be "using" the materials for the civil case, exactly the conduct proscribed by the Protective Order here. If the Court disagrees, Ms. Maxwell is more than happy to make such sealed applications to those judicial officers. The government does not explain its thinking, nor did the government suggest this course of action during the conferral process. + +## The Sealed Materials Are Important to the Courts' Sub Judice Determinations + +Fourth, the government decries the sealed materials' lack of relevance to the Civil Litigation's unsealing process. Among the legal questions pending before those two courts are whether Ms. Maxwell and the other non-parties relied on the protective order when they provided the civil discovery that now forms the basis of the indictment in this case and may soon provide the substance of indictments against the other non-parties. That Ms. Maxwell reasonably feared exactly what actually happened — that her adversary is working with the government to prosecute her — illuminates the reasonableness of her reliance, as well as the reliance of other non-parties who provided discovery under the promise of confidentiality. Moreover, those courts also must decide whether the unsealing will impact Ms. Maxwell's ability to receive a fair criminal trial in this case; that the soon-to-be-unsealed materials constitute over 12/ of the criminal discovery in this case is a fact that the courts cannot know unless Ms. Maxwell tells them. Further any application to stay the civil unsealing process will necessitate telling those courts that the sealed materials are the one and same "confidential" criminal discovery. + +By way of support, Ms. Maxwell directs the Court to her opening brief, filed in the Second Circuit on August 20, 2020. In that brief, she explains, inter alia, her arguments for maintaining + +2 Ms. Maxwell strenuously opposes the government's suggestion that it "further elaborate on the nature of the ongoing grand jury investigation" in a supplemental ex pane and sealed pleading. This Court is overseeing the criminal case pertaining to Ms. Maxwell and any ex pane pleading concerning this case to this judicial officer is inappropriate. See Standard 3.3.3 Relationship with Courts, Defense Counsel and Others, "Criminal Justice Standards for the Prosecution Function," American Bar Ass'n (4th ed. 2017) ("A prosecutor should not engage in unauthorized ex pane discussions with, or submission of material to, a judge relating to a particular matter which is, or is likely to be, before the judge."). + +her first deposition under seal, including her reliance on the protective order, the need to preserve the status quo pending any rulings regarding the propriety of the government's possession of the sealed materials, and the need to preserve her right to a fair trial. Seen Maxwell, Case No. 20-2413, Doc. 68 (Aug. 21, 2020). To contend as the government does that the Second Circuit, and Judge Preska in upcoming unsealing proceedings, should be kept in the dark about the government and her adversary's actions in circumventing the protective order, reveals a fundamental ignorance of the issues in the Civil Litigation at best, or a desire to have them undermined at worst. + +#### Protective Orders May Be Modified As Circumstances Change + +Finally, the government suggests in a myriad of ways without directly arguing that this Protective Order cannot be modified, that Ms. Maxwell somehow waived her ability to seek modification by agreeing to a Protective Order before she knew what was contained in the criminal discovery, or that there is no precedent for such a modification. These suggestions are disingenuous. Of course, the Government ignores that the Protective Order itself provides that it may be modified "by further order of the Court." Id,1 18(b). + +There is no precedence for this case. That is true because the Second Circuit has outlined a process for the government to seek civil materials subject to protective orders for use in grand jury investigations, a process the government circumvented. It also is true because typically, the government is the party to intervene in civil cases and seek a stay where materials the government has marked "Confidential" may be disclosed publicly or where the government contends the rules of criminal discovery will be circumvented. Finally, there is no other case that defense counsel has located where a U.S. district and appeals court are actively considering the unsealing of "confidential" materials simultaneous with the criminal prosecution. Nixon v. Warner Commc'ns, 435 U.S. 589 (1978), is the closest, yet even there, the U.S. Supreme Court refused press access to the tapes obtained from third parties played in the criminal trial while the matter remained on appeal. + +That Ms. Maxwell did not know what was in the sealed materials before she signed the Protective Order, or proposed a draft, is self-evident. That a Court can modify a protective order at any time is likewise well-established. Fed. R. Crim. P. 16(d)(1) authorizes the Court to regulate discovery through protective orders and modification of those orders. See Smith Kline Beecham Corp. v. Synthon Pharmaceuticals, Ltd., 210 F.R.D. 163, 166 (M.D.N.C. 2002) ("[c]ourts have the inherent power to modify protective orders, including protective orders arising from a stipulation by the parties"); see also United States v. Gurney, 558 F.2d 1202, 1211 n.I5 (5th Cir. 1977) (trial court's decisions as to which documents "will be placed in the public domain, and which are entitled to privacy and confidentiality" are discretionary and "form an integral part of trial management"); United States v. Wecht, 484 F.3d 194, 211 (3d Cir. 2007), as amended (July 2, 2007) ("it would have been proper for the District Court to unseal the records pursuant to its general discretionary powers"); Poliquin v. Garden Way, Inc., 989 F.2d 527, 532 & 535 (1st Cir. 1993). + +"The standard of review for a request to vacate or modify a protective order depends on the nature of the documents in question. There is a presumptive right of public access to judicial documents, that is, documents that are `relevant to the performance of the judicial function and useful in the judicial process.'" Kerik, 2014 WL 12710346, at \*1 (S.D.N.Y. July 23, 2014), (quoting United States v. Amodeo, 44 F.3d 141, 145 (2d Cir. 1995)). + +The Materials that Ms. Maxwell seeks to disclose (to judicial officers under seal) are, without question, judicial documents. The 90,000 pages of criminal discovery that Ms. Maxwell seeks to reference are materials already in her possession by virtue of her involvement in the Civil Litigation. And, at a minimum, Ms. Maxwell's opponent in the Civil Litigation knows both that the Government obtained an ex pane order to subpoena the information and what was produced. Accordingly, the argument that somehow grand jury secrecy will be compromised by disclosure, under seal to judicial officers reviewing the very material at issue, is absurd. Ms. Maxwell has demonstrated good cause for her very limited request to present a discrete set of sealed materials under seal to the two Courts deciding whether to unseal those materials to the public, for purposes of arguing against the unsealing of the 90,000 pages of confidential material that the government in this case has marked "confidential" and apparently intends to use to prosecute this action. The government has not articulated a cogent reason for that information to be kept from the other judicial officers. + +Sincerely, + +![](_page_5_Picture_6.jpeg) + +Jeffrey S. 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a/marker2/ds9/EFTA00088211/EFTA00088211.md b/marker2/ds9/EFTA00088211/EFTA00088211.md new file mode 100644 index 0000000000000000000000000000000000000000..5541f201cde4d912519cc4d9155da0ef3f65427f --- /dev/null +++ b/marker2/ds9/EFTA00088211/EFTA00088211.md @@ -0,0 +1,28 @@ +**From:** "[REDACTED]" <[REDACTED]> +**To:** "[REDACTED] (NY) (FBI)" <[REDACTED]>, [REDACTED] +<[REDACTED]> +**Cc:** "[REDACTED]" <[REDACTED]>, "[REDACTED] (USANYS)" +<[REDACTED]> + +**Subject:** subpoenas + +**Date:** Thu, 27 Aug 2020 13:56:07 +0000 + +[REDACTED] + +We'd like to issue subpoenas to [REDACTED] can you please confirm that the following spellings are right before we issue them? + +[REDACTED] + +Thanks, + +[REDACTED] + +[REDACTED] + +Assistant United States Attorney +Southern District of New York +One Saint Andrew's Plaza +New York, NY 10007 + +[REDACTED] \ No newline at end of file diff --git a/marker2/ds9/EFTA00088211/EFTA00088211.metadata.json b/marker2/ds9/EFTA00088211/EFTA00088211.metadata.json new 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Thanks. + +From: Maria F Suarez Landoll° + +Sent: Wednesday, August 26, 2020 4:28 PM + +To: + +Subject: PICTURES VIDEOS AND AUDIO TAPES Mr JEFFERY EPSTEIN + +Mr. Mark Remillard of ABC News gave me your contact info. I am the grandson of a woman in her 60s who worked at Mr EPSTEIN's house in Manhattan as a housekeeper between 2012 and 2017. On the day she was fired from her job she took with her some memory cards, pictures, video tapes and audio tapes that she had found hidden in the house. We are not looking for monetary compensation at all but we are being threaten by his lawyers Mr Indieke and Mr Cann to hand over this material to them. Not sure if I spelt the names correctly. Tried giving it to ABC's Mark Remillard but because it contains child ponography he is hesitant to receive it. Another news agency in the US called FOX News verified the authenticiy of the material through a local news correspondant here in Colombia but we were told that they will only release some material and not all for political reasons. If you wish to speak to me you can call me at or WhatsApp me at same number. My wife and I are cat6lica and wish no money at all for this. I just 3 weeks ago found out about this because I speak english and my grandmother trust me. 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No need to include addresses —just their names would be fine. Please use the subpoena as a template. + +Thanks) + +From: + +Sent: Thursday, August 27, 2020 11:14 AM + +To: (USANYS) < >; N. (NY) (FBI) < + +Cc: (USANYS) < (USANYS) < + +Subject: Re: subpoenas + +David R Mullen + +DOB: + +LICA: + +DOB: + +LKA: + +Lance Allen Calloway + +DOB: + +LKA: + +Also please cut us subpoena for one of Epstein's ex-assistant's that quested we reach out to: + +Thanks! + +Detectivel l + +NYPD / FBI + +Child Exploitation Human Trafficking Task Force + +Office: + +Cell: + +Fax: + +From: (USANYS) < + +Sent: Thursda Au ust 27, 2020 9:56 AM + +To: (NY) (FBI) < :.; + +Cc: (USANYS) < (USANYS) + +Subject: subpoenas + +We'd like to issue subpoenas to hruho worked for Epstein — can you please confirm that the following spellings are right before we issue them? + +- • +- • + +Thanks, + +Assistant United States Attorney + +Southern District of New York + +One Saint Andrew's Plaza \ No newline at end of file diff --git a/marker2/ds9/EFTA00088213/EFTA00088213.metadata.json b/marker2/ds9/EFTA00088213/EFTA00088213.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..45077bdb44657ef6197b6894d171aecb02682461 --- /dev/null +++ b/marker2/ds9/EFTA00088213/EFTA00088213.metadata.json @@ -0,0 +1,92 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00088213.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 1526, + "elapsed_seconds": 1.59, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 100 + ], + [ + "Line", + 43 + ], + [ + "Text", + 32 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 49 + ], + [ + "Line", + 23 + ], + [ + "Text", + 22 + ], + [ + "ListItem", + 2 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00088213" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00088215/EFTA00088215.md b/marker2/ds9/EFTA00088215/EFTA00088215.md new file mode 100644 index 0000000000000000000000000000000000000000..ff6a38fcfb1ad6463cb35de723a26faaa19cee4f --- /dev/null +++ b/marker2/ds9/EFTA00088215/EFTA00088215.md @@ -0,0 +1,41 @@ +**To:** "[REDACTED]" <[REDACTED]>, "[REDACTED]" + +<[REDACTED]> + +**Cc:** "[REDACTED]" <[REDACTED]>, "[REDACTED]" <[REDACTED]> + +**Subject:** Re: [REDACTED] + +**Date:** Sun, 08 Mar 2020 15:26:56 +0000 + +--- + +We will connect with her and keep you updated. Could you also pass along the records from Interlochen? + +Thanks! + +- + +On Mar 8, 2020 6:35 AM, "[REDACTED]" <[REDACTED]> wrote: + +Yes I remember listening to this podcast a few months ago. I texted [REDACTED] and [REDACTED] a copy of this podcast back in January and I agree she is definitely someone we should talk with. I'm pretty sure she claims she was not abused (although im not sure if that's true) but either way could be a very fruitful interview. + +I'm at the airport now headed to Aruba so I'll be out of phone contact until next Sunday. I'll check in with you guys when I get back. + +On Mar 7, 2020, at 17:00, [REDACTED] <[REDACTED]> wrote: + +[REDACTED] + +In reviewing the records we received from Interlochen, it looks like Epstein paid the summer camp tuition of a student named [REDACTED]. She was interviewed on a podcast about her dealings with Maxwell and Epstein, and we'd like to interview her. Are you able to reach out to her about an interview? + +Looks like this is her (it notes she lives in [REDACTED], which is also where [REDACTED] is): + +[REDACTED] + +And here's the podcast interview: + +[REDACTED] + +Thanks, + +[REDACTED] \ No newline at end of file diff --git a/marker2/ds9/EFTA00088215/EFTA00088215.metadata.json b/marker2/ds9/EFTA00088215/EFTA00088215.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..7ec7980dcf4738fe2a954883c506e349c8d91dec --- /dev/null +++ b/marker2/ds9/EFTA00088215/EFTA00088215.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00088215.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1384, + "elapsed_seconds": 6.25, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 42 + ], + [ + "Span", + 41 + ], + [ + "Line", + 21 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00088215" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00088216/EFTA00088216.md b/marker2/ds9/EFTA00088216/EFTA00088216.md new file mode 100644 index 0000000000000000000000000000000000000000..558182e03c2288d2a2b27beb52fb5425189ad1e4 --- /dev/null +++ b/marker2/ds9/EFTA00088216/EFTA00088216.md @@ -0,0 +1,48 @@ +**From:** "[REDACTED]" <[REDACTED]> +**To:** "[REDACTED]. (NY) (FBI)" <[REDACTED]>, "[REDACTED]" +<[REDACTED]> +**Cc:** "[REDACTED]" <[REDACTED]>, "[REDACTED]" +<[REDACTED]> + +**Subject:** RE: [REDACTED] + +**Date:** Sun, 08 Mar 2020 20:20:27 +0000 + +**Attachments:** INT\_000294\_-\_INT\_000631\_(student\_rosters\_1994-98,\_pw\_Butzel123!).pdf; 2020-02-21,\_Interlochen\_cover\_letter\_&\_custodian\_declarations.pdf; INT\_000001\_-\_INT\_000293\_(Epstein\_&\_Maxwell\_records,\_pw\_Butzel123!).pdf + +--- + +Thanks! Records are attached. + +--- + +**From:** [REDACTED]. (NY) (FBI) <[REDACTED]> +**Sent:** Sunday, March 8, 2020 11:27 AM +**To:** [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> +**Cc:** [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> +**Subject:** Re: [REDACTED] + +We will connect with her and keep you updated. Could you also pass along the records from Interlochen? + +Thanks! + +- + +On Mar 8, 2020 6:35 AM, "[REDACTED]" <[REDACTED]> wrote: +Yes I remember listening to this podcast a few months ago. I texted [REDACTED] and [REDACTED] a copy of this podcast back in January and I agree she is definitely someone we should talk with. I'm pretty sure she claims she was not abused (although im not sure if that's true) but either way could be a very fruitful interview. + +I'm at the airport now headed to Aruba so I'll be out of phone contact until next Sunday. I'll check in with you guys when I get back. + +On Mar 7, 2020, at 17:00, [REDACTED] <[REDACTED]> wrote: + +[REDACTED], + +In reviewing the records we received from Interlochen, it looks like Epstein paid the summer camp tuition of a student named [REDACTED]. She was interviewed on a podcast about her dealings with Maxwell and Epstein, and we'd like to interview her. 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Camp Arts Camp + +IM + +IM + +• + +IM + +• + +• + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Academy Arts Academy All State All State All State All State All State All State All State All State Arts Camp Arts Camp Arts Camp All State All State All State All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Academy All State All State All State All State All State All State All State All State All State All State All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +imi + 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Arts Camp All State Arts Camp Arts Camp Arts Camp All State + +Arts Academy Arts Academy Arts Camp All State Arts Camp Arts Camp + += + +• + +• + +• + += + +Arts Academy Arts Academy Arts Camp All State Arts Camp Arts Camp Arts Camp All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State Arts Academy Arts Academy All State Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Academy Arts Academy Arts Camp Arts Camp All State All State All State All State All State All State All State All State All State All State All State + += + +• + +• + +All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State Arts Camp Arts Camp Arts Academy Arts Academy Arts Camp Arts Academy Arts Camp Arts Academy Arts Academy Arts Camp Arts Academy All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State + +NM NM NM + +NM M • M + +NI + +NM MM + +NM + +M + +All State All State All State All State All State All State All State All State All State All State All State All State All State All State + +Arts Academy Arts Academy Arts Camp Arts Camp All State All State All State All State Arts Camp Arts Academy Arts Academy Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy All State Arts Camp Arts Camp All State All State All State All State All State All State All State Arts Camp Arts Academy All State All State Arts Camp Arts Academy Arts Academy Arts Academy Arts Academy + +N + +a + +S + +• + +• • + +• + +IN + +All State All State All State All State All State All State All State All State All State All State All State All State All State Arts Academy Arts Academy Arts Academy Arts Academy Arts Academy Arts Academy Arts Academy Arts Academy Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State All State All State All State All State Arts Academy Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Academy Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp + +a + +Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Camp All State Arts 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Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp + +MI + +N + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State + +Arts Academy Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Academy + +• + +• • + +m + +• + +• + +• • a + +Arts Academy Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Academy Arts Camp Arts 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Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Academy Arts Camp Arts Academy Arts Camp Arts Academy Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Academy Arts Camp Arts Academy + +Arts Camp Arts Academy Arts Academy Arts Academy Arts Academy Arts Academy All State All State + +• • + +Arts Camp Arts Academy Arts Academy Arts Camp Arts Academy + +• Arts Camp + +Arts Academy Arts Academy + +• Arts Camp • Arts Camp + +Arts Camp Arts Camp Arts Camp + +• All State + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +• Arts Camp + +Arts Camp + +• Arts Camp + +Arts Camp + +• Arts Camp + +Subtotal Count 2826 + +1995• Arts Camp + +Arts Camp Arts Camp + +• Arts Camp + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + += + +• + +I + +MI + +U + += + += = + +a + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + += + +a + +• + +C + +• + +• + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Academy Arts Camp + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State All State All State Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +a + +a + +• + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State All State All State All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State All State Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +MI + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State All State All State + 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Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +• + +a + +• • + +• + +• + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +M = =• + +M + +=MM + +• + +• = + +M = = + +• = + +• + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State All State + +Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State All State All State + +• + +All State All State All State All State All State + +Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Camp + +N + +Arts Camp All State Arts Camp All State Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +MI M • • MI M + +> • • MI + +• MI + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + += + += + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State All State All State + +Arts Academy Arts Academy Arts Academy Arts Camp Arts Camp Arts Academy All State Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Academy Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State All State + +ME M ME = + +ME + +ME • + +MM + +M + +M= M ME = + +ME ME + +I= = ME M + +I l + +Arts Academy Arts Academy Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Academy Arts Camp All State Arts Academy Arts Academy Arts Academy Arts Camp Arts Camp Arts Camp Arts Academy Arts Academy Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Academy Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Academy Arts Academy Arts Academy Arts Camp Arts Camp Arts Camp Arts Academy Arts Academy Arts Camp Arts Camp Arts Academy Arts Academy Arts Academy + +NM + +NM + +Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Academy Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Academy Arts Academy Arts Camp Arts Academy Arts Camp Arts Academy Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Academy Arts Camp Arts Camp Arts Academy Arts Academy Arts Academy Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp + += = + +NM + +All State Arts Camp Arts Academy Arts Academy Arts Academy Arts Camp Arts Academy Arts Camp Arts Academy Arts Camp All State Arts Academy Arts Academy Arts Academy Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp All State + +Arts Academy All State Arts Academy Arts Academy Arts Camp Arts Camp Arts Academy Arts Camp All State All State All State Arts Academy Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp All State All State All State Arts Camp Arts Camp Arts Academy Arts Academy All State All State + +a + +U + +All State Arts Camp Arts Camp Arts Camp Arts Camp All State All State Arts Camp Arts Academy All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Academy Arts Academy Arts Camp All State All State All State Arts Camp Arts Camp Arts Academy Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy All State All State + +Arts Academy Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Academy Arts Academy All State + +IM + +• + +• + +Arts Camp Arts Academy Arts Camp Arts Academy Arts Academy Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State All State All State All State All State All State + +Arts Academy Arts Academy Arts Camp Arts Academy Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State All State All State All State All State All State All State All State Arts Camp Arts Academy All State All State All State + +— = All State MI All State — M All State MEI All State — Arts Camp — Arts Academy — = Arts Academy - = Arts Academy + +Arts Camp Arts 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State Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Academy Arts Academy + +=I = + +> = M + +Arts Academy Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Academy Arts Academy Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp All State + +Arts Academy Arts Camp Arts Camp All State All State Arts Camp Arts Academy Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +ME + +ME + += M + +NM + +ME M + +a + +EM + +=I = + +NM + += + +NM M + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Academy All State Arts Camp Arts Camp Arts Camp Arts Academy Arts Academy Arts Camp Arts Academy Arts Camp Arts Academy Arts Academy Arts Camp Arts Camp Arts Academy Arts Academy Arts Academy Arts Camp Arts Camp Arts Academy Arts Camp Arts 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Camp Arts Camp + += + +• + +=N + += + +M + +M + +• M + +MI =I + +MI MI + += MI + +> • = + += + +I= + += M + +=I =I + += M + +Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Academy All State Arts Camp All State All State + +Arts Academy Arts Academy Arts Academy Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Academy Arts Camp Arts Camp Arts Academy + +Arts Camp Arts Academy Arts Camp Arts Academy Arts Camp Arts Camp Arts Academy Arts Camp Arts Academy Arts Academy Arts Academy Arts Academy Arts Camp Arts Camp + +IMI Arts Camp + +Arts Camp + +• Arts Camp + +All State + +=Arts Camp + +Arts Camp + +• Arts Camp + +Arts Camp Arts Academy Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +=All State + +Arts 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Camp Arts Academy Arts Camp Arts Camp Arts Academy Arts Academy Arts Camp Arts Camp Arts Academy Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +• + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Academy Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State All State All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State + +M = \_ M \_- \_ MN M Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +• + +• • + +• + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Academy Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +Arts Camp + +MI =Arts Camp MI M Arts Academy =NMI Arts Camp M = Arts Camp MI M Arts Camp + +• + +• M + +Arts Camp Arts Camp Arts Camp Arts Camp + +=Arts Camp MI Arts Camp = M Arts Camp =I Arts Camp MI =I Arts Camp + +> M Arts Camp =I Arts Camp + +• = Arts Camp = = Arts Camp + +> Arts Camp All State + +MI Arts Camp M Arts Camp MI =All State MI Arts Camp • Arts Academy =Arts Camp + +EM Arts Camp + +M Arts Camp = M All State + += = Arts Academy =Arts Camp + +M Arts Camp + +Arts Camp Arts Camp + +I l Arts Camp + +Arts Camp + += M Arts Camp + +Arts Camp Arts Camp + +MEI Arts Camp + +Arts Camp + +=Arts Camp + +NM MI Arts Camp • Arts Camp • EM Arts Camp + +• + +• + +• • + +• + +MI • + +Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State All State All State All State + +Arts Academy Arts Academy Arts Camp Arts Camp Arts Academy Arts Camp Arts Academy All State All State All State Arts Camp Arts Academy + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp 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Academy Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State + +Arts Academy All State All State All State All State Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Academy + +IMI + += = M + += + +Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp All State All State All State All State All State All State Arts Camp Arts Camp Arts Academy Arts Academy Arts Camp Arts Academy Arts Academy Arts Camp Arts Camp Arts Academy Arts Camp Arts Academy Arts Camp All State + +• + +• + +• + +• + +• + 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Academy All State All State All State All State + +• All State + +All State Arts Camp Arts Academy Arts Camp + +• Arts Camp + +Arts Camp Arts Academy Arts Academy Arts Academy Arts Camp Arts Camp All State + +Arts Camp N + +m + +Arts Camp Arts Academy Arts Academy + +• Arts Camp + +Arts Camp + +• Arts Camp + +Arts Camp Arts Camp + +• Arts Camp + +• Arts Camp + +Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +• Arts Camp + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +=I + += + +ME + +El =I + +EN + +EN = EN = Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Academy Arts Camp All State All State All State All State Arts Camp All State All State All State All State Arts Camp Arts Camp Arts Academy Arts Camp All State Arts Camp Arts Camp All State All State All State All State All State All State All State All State All State All State All State All State All State Arts Camp All State All State All State All State All State + +— All State + +MM All State + +— All State — All State — = All State — M All State + += Arts Camp = Arts Camp M All State + +- Mil All State — All State + += All State + +- Arts Camp — Arts Camp IMI Arts Camp M All State + += All State + +All State + +— = All State + +— + +IM All State + +- M All State M All State — All State - M All State - M All State — M All State + +— + +All State + +— All State — All State — M All State + +All State + +— M All State + +All State + +— + += All State = All State + +— All State + +All State All State + +MI All State - All State + +All State + +— All State + += All State + +— = All State — All State — Arts Camp + += M + +M + += + +M + +MI + +=I =I • =I + += + += + +IM + +Arts Camp Arts Academy All State Arts Camp Arts Academy All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State Arts Academy Arts Camp Arts Camp Arts Academy All State All State All State All State All State All State All State All State All State All State All State All State All State Arts Camp All State All State All State All State + +. = Arts Academy + += Arts Academy + +— + +Arts Camp + +— Mil Arts Academy + +Arts Academy + +— All State - M All State + += All State = All State + +— All State + +All State All State + +— All State — All State I= All State - All State + +MI All State + +All State + +— All State + +MI All State + +All State + +IMI IMI All State + += All State + +III All State + +All State All State + += All State = All State + +. = All State — All State — All State - All State + +— = Arts Academy — = Arts Academy — = Arts Academy — Arts Camp — Arts Camp — = Arts Camp + +Arts Academy + +MI MI Arts Camp M M All State MI I= All State + +All State + +- = All State I= All State + +All State + += + += + += + += M =I M + +• • + +EM MN + += + +I= IM + +• + +All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State + +All State All State All State All State All State All State All State All State All State All State All State All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State + +Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +— All State — M All State — All State — = All State + +- + += Arts 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All State All State All State All State All State All State All State All State Arts Camp Arts Academy Arts Camp All State All State All State + +Arts Academy Arts Camp Arts Camp All State Arts Camp Arts Academy Arts Camp Arts Camp All State All State + += All State = All State + +All State All State + += All State + +— = All State — = All State + += All State + +— All State + +I= All State = All State + +MI All State M All State + +All State + +l l All State — All State — M All State — Arts Camp + +> Arts Camp Arts Academy + +— + +Arts Camp Arts Camp + +— = All State — M Arts Camp + +=I . + +All State + +— All State + +All State + += All State + +- M All State — Arts Academy + +— = All State + += All State + +— All State + +M All State = All State + +IMI MI Arts Academy + += Arts Camp = Arts Academy + +— Arts Camp — M Arts Camp — I= Arts Camp + +All State + +— All State + +All State + +- Arts Camp — All State + +• + +All State Arts Camp All State All State All State Arts Camp Arts Academy Arts Camp All State All State All State All State Arts Camp All State All State All State All State All State All State All State All State All State All State All State All State + +Arts Academy Arts Camp All State All State + +Arts Academy All State Arts Camp Arts Camp Arts Camp Arts Academy Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp + +• + +• + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp All State All State Arts Camp Arts Camp All State Arts Academy All State All State All State All State All State Arts Academy All State Arts Camp Arts Academy Arts Academy All State All State All State Arts Camp All State All State All State All State All State Arts Academy All State All State Arts Academy Arts Academy + +• + +Arts Academy Arts Academy Arts Academy Arts Academy Arts Camp Arts Academy Arts Academy All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy All State All State Arts Academy All State Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + += + +MI + +• + +Arts Camp Arts Academy Arts Academy All State All State Arts Camp Arts Academy Arts Camp Arts Academy Arts Camp All State Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp All State Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Academy Arts Camp Arts Camp Arts Camp All State All State All State + += = + +Arts Camp All State Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State + +Arts Academy Arts Camp Arts Academy Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp All State Arts Camp Arts Academy All State + +Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Academy Arts Academy Arts Camp Arts Camp All State Arts Camp + +MI • + +• + +Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Academy Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Academy Arts Academy Arts Academy Arts Camp Arts Academy Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Academy Arts Academy Arts Academy Arts Academy + +— + +Arts Academy Arts Academy 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Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +• + +• + +• a + +N + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Camp All State All State Arts Camp Arts Academy Arts Academy Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Academy Arts Academy Arts Camp Arts Camp Arts Camp + +• = + +> = M + +• + +- + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Academy Arts Academy Arts Camp Arts Academy Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp All State All State All State All State All State All State All State All State All State All State All State All State All State Arts Academy Arts Camp Arts Academy All State All State All State All State All State All State All State All State All State All State All State All State All State + +• NM = + +All State All State All State All State All State All State All State All State All State All State All State All State All State All State Arts Camp Arts Camp Arts Academy Arts Camp All State Arts Academy Arts Camp Arts Camp Arts Academy Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Academy Arts Academy All State Arts Camp Arts Camp Arts Academy Arts Academy Arts Academy Arts Academy Arts Camp Arts Academy Arts Academy Arts Camp Arts Camp Arts Camp + +Subtotal 1996 + +MI + +Count + +I + +• + +3110 + +• + +• • + +• + +Arts Camp Arts Camp All State Arts Camp Arts Academy All State All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy 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State + +Arts Academy Arts Camp Arts Academy Arts Camp Arts Academy All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp All State All State + +Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy All State + +Arts Academy All State Arts Camp Arts Camp Arts Academy Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp + +N + +• + +MI + +• + +• + +• + +MI + +All State All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Academy Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp 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State Arts Camp Arts Camp Arts Camp Arts Academy Arts Academy Arts Camp Arts Academy Arts Camp Arts Academy Arts Academy Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Academy Arts Camp All State Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp + += + += + +• + +Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Academy Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp + +a + +• + +Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp 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State All State All State All State All State All State Arts Academy Arts Camp Arts Camp All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State Arts Camp Arts Academy Arts Camp + +— Arts Camp — =II Arts Camp - • All State — All State — M All State — All State + +M All State + +All State + +— All State + +- + +. + +All State + +- All State + +MEI All State + +All State + +— All State - I= All State — All State — M All State + += All State + +All State + +MI All State + +— All State — All State M All State — All State MI All State — All State — All State — All State + +All State + +— Arts Camp — M All State MI Arts Camp — Arts Camp + +> = All State = All State + +MI Arts Camp + +Arts Academy + +— M All State + +M All State = All State + +All State All State + +- = All State + +All State 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Academy Arts Academy Arts Academy Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp + +MI + +• + +• + +Chamber Music Camp Chamber Music Camp Chamber Music Camp + +Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp + +Arts Academy Arts Academy + +Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp + +Arts Camp Arts Camp + +Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp + +Chamber Music Camp Chamber Music Camp + +Arts Academy + +Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp + +Arts Camp Arts Academy + +Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp + +Arts Academy Arts Camp Arts Camp All State Arts Academy Arts Academy Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp + +Chamber Music Camp + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp \_ + +Chamber Music Camp Chamber Music Camp Chamber Music Camp + +All State + +Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp + +s + +• • + +• + +• + +• + +Arts Academy Arts Camp Arts Camp Arts Camp + +Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp + +Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +Chamber Music Camp Chamber Music Camp + +Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Camp + +Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp + +Arts Camp Arts Academy Arts Camp Arts Camp Arts Academy All State Arts Academy All State + +In + +MI + += + +m • + +• + +Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Academy Arts Academy Arts Camp Arts Camp Arts Academy Arts Academy Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Academy All State Arts Camp Arts Camp + +Arts Camp Arts Camp + +• Arts Academy + +MI Arts Camp + +Chamber Music Camp + +Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp + +M Arts Camp + +Arts Camp Arts Camp + +MI Arts Camp + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +MI Arts Camp + +Arts Academy Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp + +MI Arts Camp + +• Arts Camp + +Arts Camp Arts Camp Arts Camp Arts Camp + +• Arts Camp + +Arts Camp All State Arts Camp Arts Camp + +N + +MI + +• + +a + +al + +• + +N + +a + +Arts Academy Arts Camp Arts Camp Arts Academy Arts Camp Arts Academy Arts Academy Arts Camp Arts Camp Arts Academy Arts Academy Arts Academy Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Academy Arts Academy Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp + +• Arts Camp + +Arts Camp Arts Academy Arts Camp Arts Academy Arts Academy Arts Camp Arts Camp + +• + +• + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Academy Arts Camp Arts Camp + +• Arts Camp + +Arts Camp + +• Arts Camp + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy All State Arts Camp + +• Arts Camp + +• + +• + +• + +• + +• + +Arts Camp Arts Camp Arts Camp Arts Academy Arts Academy Arts Camp Arts Camp Arts Academy Arts Camp Arts Academy Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Academy Arts Academy Arts Academy Arts Camp Arts Camp Arts Academy Arts Camp Arts Academy Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp All State Arts Camp All State Arts Camp Arts Camp Arts Academy Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp + +IM + +• • + +Arts Academy Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp All State All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp All State Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Academy Arts Camp Arts Camp Arts Academy Arts Academy Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp All State + +NM + += + +• + +Arts Camp Arts Camp Arts Camp Arts Academy Arts Academy Arts Camp Arts Camp Arts Academy Arts Camp All State Arts Camp Arts Academy Arts Academy Arts Camp Arts Camp Arts Academy Arts Camp Arts Academy Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Academy + +Arts Academy Arts Camp Arts Camp Arts Academy Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp + +Chamber Music Camp + +Arts Camp Arts Academy Arts Academy Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy + +NM + +• + +Is + +• + +C + +NM + +Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Academy Arts Camp Arts Academy Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Academy Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Academy + += + += + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Academy Arts Academy All State Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Academy Arts Academy Arts Camp Arts Academy Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp + +• + +• • + +N + +• + +MI + +IMI + +Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Academy Arts Academy Arts Academy Arts Camp Arts Camp Arts Camp All State + +MI + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State All State Arts Camp All State + +Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Academy Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp All State + +a + +• + +Arts Academy Arts Camp Arts Academy Arts Camp Arts Camp Arts Academy Arts Camp Arts Academy Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Academy Arts Camp Arts Camp Arts Academy Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp + +\_ M + += + +M + += M = = + +MI + += + +Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Academy Arts Camp Arts Academy All State Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Camp + +• = + +MI + += • + += =II + +MN + +• + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp All State Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy All State All State All State + +Arts Academy Arts Academy Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Academy Arts Academy Arts Academy Arts Camp Arts Academy Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +■ + +• + +MI + +Arts Academy All State Arts Camp Arts Academy Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy + +Chamber Music Camp + +Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Academy + += + +• = + +IM + += + +Arts Academy Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Camp All State + +Arts Academy Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +• • • IN + +• • + +• + +• + +• + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Academy Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + += = + +• + += + +MUM + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +Chamber Music Camp + +Arts Academy Arts Camp Arts Camp + +N + +• + +• + +• + +• + +• + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +Arts Camp Arts Camp Arts Camp Arts Camp + +Chamber Music Camp + +Arts Camp Arts Camp Arts Camp Arts Camp + +. + +Arts Camp Arts Camp + +. + +Arts Camp + +— + +Arts Camp Arts Camp + +MI Arts Camp + +Arts Camp + +- Arts Camp — Arts Camp + +> Arts Camp Arts Camp Arts Camp + +- Arts Camp - Arts Camp — Arts Camp — Arts Camp + +> Arts Camp Arts Camp Arts Camp + +- - Arts Camp — Arts Camp + +Arts Camp + +Chamber Music Camp + +Arts Camp Arts Camp Arts Camp Arts Camp + +M Arts Camp — Arts Camp + +Arts Camp + +— Arts Camp MI Arts Camp + +Arts Camp + +— Arts Camp + +Arts Camp + +- Arts Camp + +• • + +• + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp All State Arts Camp Arts Camp + += + += + +• + +IM + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +IM + +• + +MI + +• N + +• + +• M + +• + +All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Camp + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +=I + +Arts Camp + +Chamber Music Camp + +Arts Camp Arts Camp Arts Camp + +• Arts Camp + 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Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +M + +MI + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +U + +• + +• + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State All State All State All State All State All State All State All State All State All State All State All State All State All State + +— + +Arts Academy + +- = Arts Camp + += Arts Camp + +MI IMI Arts Camp + +M All State + +M = Chamber Music Camp + +M All State + +All State All State + +— M All State + += All State + +- All State + +M All State + +— = All State MI I= All State + +All State + += All State + +- All State — = All State — IMI All State — All State — All State — All State — M All State MI I l All State + += All State + +- M All State — M All State + +All State + +M All State + +. + +All State + +— M All State M All State + +All State + +EM = All State MI All State + +M Arts Camp = Arts Camp + +— = Arts Camp M M All State + +MI All State + +— All 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= All State + +All State + += All State + +— = All State + += All State M All State Mil All State + +M All State — All State — = All State — = All State + +I= All State + +- M All State + +All State + +— All State - = All State — All State + +All State + +— All State + +MI All State + +. + +All State + +M All State + +I l IMI + += + +M M + += + +IMI + +All State All State All State All State All State All State All State All State All State All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State + += + += + +• + +1 + +All State All State All State All State All State All State All State All State All State All State All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +N + +• + += + += + +• + += + +• + +Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp All State Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State All State All State All State All State All State All State + +- All State — = All State - All State + +All State + += All State + +— = All State - = All State + +M All State M All State + +All State + +— All State — = All State + += All State + +All State + +MI All State = All State + +All State + += All State = All State + +IM All State + +All State + +M All State + +All State + +— = All State I=I I=I All State — All State - All State + += MM Chamber Music Camp + +. + +Arts Camp + +— M Arts Camp — M All State + +M Chamber Music Camp + += Chamber Music Camp + +All State + +— M All State — IMI All State M All State — = All State + += All State + +- All State + +All State All State + +— M All State — .= All State + +All State + +All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State All State + +Chamber Music Camp Chamber Music Camp Chamber Music Camp + +• + +All State All State All State All State All State All State All State + +M All State + +— =II All State + +- + += All State M All State + +- All State + +All State All State All State + +— All State — All State + +— + +All State + +M M All State + +M All State + +M All State + +All State + +M All State = All State + +- = All State — MI All State + +IMI All State + +- M All State - = All State MI =I Arts Academy + +Arts Camp + +— IMI Arts Academy - M Arts Academy + +Chamber Music Camp + +— Arts Camp - M Arts Camp — Arts Camp MI Arts Camp + += All State + +— = All State + +M All State + +— All State + +All State + +MI All State - M All State — M All State IMI IMI All State — All State I=I l l All State — All State — M All State I=I M All State + += All State + +• + +• • • • + +i + +All State All State All State All State All State All State All State All State All State All State All State All State All State + +Chamber Music Camp + +Arts Camp All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State + += = + += + += + +• + +IMI =I + += M + +MI + +All State All State All State All State All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +Chamber Music Camp + +All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State Arts Academy All State All State Arts Camp Arts Academy + +=I + +ME + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State + +Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +• + +a a + +• + +a + +• • All State + +Chamber Music Camp Chamber Music Camp + +All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State + +Arts Academy All State All State Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp All State All State + +Chamber Music Camp + +Arts Academy All State All State All State + +• + +• + +• + +All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State Arts Camp Arts Academy All State Arts Camp All State Arts Camp Arts Camp All State All State All State All State All State All State All State All State All State All State All State All State Arts Academy Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp + +— MM Arts Camp — = Arts Camp + +M Arts Academy + +Arts Academy + +— Arts Camp + +Arts Camp + += Arts Camp + +- Arts Academy + +Arts Camp + += Arts Academy + +Arts Camp Arts Academy + +M Chamber Music Camp + +— EMI Arts Camp + +M Arts Academy + += = Chamber Music Camp + +- + +I= All State = = Chamber Music Camp M = Chamber Music Camp + +— All State + +— + +Arts Academy Arts Camp + +— Arts Academy — M Arts Camp - = Arts Camp + +Arts Academy Arts Camp + +— = Arts Camp — Arts Camp — = Arts Camp — Arts Academy + +> = Arts Academy = Arts Camp + +M = All State + +All State + +— Arts Academy + +M Arts Camp + +MI I= Arts Academy + +All State Arts Camp + +— Arts Camp + +Arts Camp + +MI Arts Academy = Arts Academy + +— Arts Camp + +• + += + +• + +Arts Camp All State Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +Chamber Music Camp + +Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +— Arts Camp — Arts Academy + +> Arts Camp Arts Camp Arts Camp Arts Camp + +— Arts Camp — Arts Camp + +Arts Camp + +MI Chamber Music Camp + +All State + +MI All State + +All State + +- All State + +IM Chamber Music Camp + +— Arts Academy + +All State + +— All State MI All State — All State + +All State + +— All State — All State — All State — All State + +> All State All State All State + +— Arts Academy + +Arts Academy + +Chamber Music Camp + +— All State + +All State All State All State + +- All State + +All State + +- All State - Arts Camp - Arts Camp - Arts Camp + +Arts Camp + +Chamber Music Camp + +Arts Camp Arts Camp Arts Academy + +Arts Academy + +— Arts Camp + +M Arts Camp + +MI MI Arts Academy — = Arts Camp - = Arts Academy — = Arts Camp . Arts Camp — M Arts Camp + +Arts Academy + +— = Arts Camp — = Arts Camp — Arts Academy + +> Arts Camp Arts Academy + +— All State + += Chamber Music Camp M = Chamber Music Camp + += Chamber Music Camp + +IMI Arts Camp + +- = Arts Camp + +Chamber Music Camp + +— IMI Arts Academy + +— Chamber Music Camp MI Chamber Music Camp + += Chamber Music Camp + +— Chamber Music Camp + +— = Arts Camp + += Chamber Music Camp = = Chamber Music Camp + +— l i Arts Academy — = Arts Academy + += Chamber Music Camp + +=II Arts Camp — Arts Academy - Arts Camp + +Arts Academy + +MI M Arts Academy + +M Chamber Music Camp + +Arts Camp + +IMI Arts Academy — M Arts Academy + +Arts Camp + +I=I Arts Camp = Arts Academy + +Arts Academy + +N + += + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Academy Arts Academy Arts Camp Arts Camp Arts Camp All State All State All State Arts Camp Arts Camp Arts Camp All State All State + +Chamber Music Camp + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Academy All State Arts Camp Arts Academy Arts Camp Arts Academy Arts Academy Arts Academy Arts Academy Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp + += + += = + +• + +MI + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Academy Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp + +Chamber Music Camp + +Arts Camp Arts Camp Arts Camp All State + +Chamber Music Camp + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Academy Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp All State Arts Camp + += M + += • + +• + +I= IMI + +M + +M = + +Arts Camp All State All State All State All State All State + +Chamber Music Camp + +All State All State All State + +Chamber Music Camp + +All State All State All State All State All State All State All State All State All State Arts Academy Arts Academy Arts Camp Arts Academy Arts Camp All State Arts Academy Arts Camp Arts Camp Arts Camp Arts Academy + +Chamber Music Camp Chamber Music Camp + +Arts Camp Arts Camp Arts Academy Arts Camp All State Arts Camp All State All State All State All State Arts Academy Arts Camp Arts Camp + +1998 + +M + += • + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp + +Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp + +Arts Camp Arts Camp Arts Camp Arts Camp + +Chamber Music Camp + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Academy Arts Camp + +Chamber Music Camp + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +Chamber Music Camp Chamber Music Camp + +Arts Camp Arts Camp Arts Academy Arts Camp Arts Academy All State Arts Academy Arts Camp Arts Academy Arts Camp Arts Camp Arts Academy Arts Academy Arts Academy Arts Camp Arts Camp Arts Academy Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +MI + +NM = + +M= \_ + += = + +Arts Camp Arts Camp Arts Academy Arts Camp Arts Academy All State Arts Camp Arts Camp + +Chamber Music Camp + +Arts Camp Arts Academy Arts Camp Arts Camp Arts Academy Arts Academy Arts Academy Arts Academy Arts Academy Arts Academy Arts Academy Arts Camp Arts Academy All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp + += = + += + +M • = • + +MI MI + +• =I + +• + +Arts Camp Arts Academy Arts Academy Arts Academy Arts Academy Arts Academy Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Academy Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Academy + +Chamber Music Camp + +Arts Camp Arts Camp All State Arts Academy + +Chamber Music Camp + +Arts Academy Arts Camp Arts Camp + +Chamber Music Camp + +Arts Camp Arts Camp Arts Academy Arts Academy Arts Academy Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp + +Chamber Music Camp + +Arts Camp Arts Camp Arts Academy Arts Camp + += + +M + +M + +M = + += + += MI Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Academy Arts Academy Arts Camp Arts Camp + +Chamber Music Camp + +Arts Camp Arts Academy Arts Academy Arts Camp Arts Camp Arts Academy Arts Academy Arts Academy Arts Academy Arts Camp Arts Camp Arts Camp Arts Academy Arts Academy Arts Camp Arts Academy All State Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Academy Arts Camp + +Chamber Music Camp + +Arts Camp Arts Academy Arts Academy Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp + += + += = + +• + +NMI + +=I I l + +=I I l + +Arts Academy Arts Camp Arts Academy Arts Academy Arts Camp All State Arts Academy + +Chamber Music Camp + +Arts Academy Arts Camp Arts Academy Arts Camp Arts Camp Arts Academy + +Chamber Music Camp + +Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Academy + +Chamber Music Camp Chamber Music Camp + +Arts Camp Arts Camp + +Chamber Music Camp + +Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp + +Chamber Music Camp Chamber Music Camp + +Arts Academy + +Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp + +Arts Camp Arts Camp Arts Camp Arts Camp + += + +ME + +NM + +• + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Academy Arts Academy + +Chamber Music Camp Chamber Music Camp + +Arts Academy Arts Academy Arts Academy + +Chamber Music Camp + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +Chamber Music Camp + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy + +- = Arts Camp + +IM Arts Camp + +Arts Camp + +MI Arts Academy + +Arts Academy Arts Camp + +. + +Arts Academy + +. + +Arts Academy + +. + +Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +. 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Camp Chamber Music Camp + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +Arts Camp Arts Camp Arts Camp Arts Camp + +Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp + +Arts Academy + +Chamber Music Camp + +Arts Camp Arts Camp Arts Camp + +Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp + +Arts Camp Arts Academy Arts Camp Arts Camp + +Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +Chamber Music Camp Chamber Music Camp + +IMI + +• • + +• + +• + +Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp + +Arts Camp Arts Camp + +Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp + +Arts Academy Arts Camp + +Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp + +Arts Academy Arts Camp Arts Camp Arts Camp + +Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp + += Chamber Music Camp IMI Chamber Music Camp = Chamber Music Camp MI Chamber Music Camp M All State + +- IM All State + +All State + +- = All State - All State - All State — All State — M All State + +M All State + +— All State + +MI All State + +All State All State All State All State All State + +M All State + += All State + +Chamber Music Camp Chamber Music Camp + +— Chamber Music Camp + +— = All State — All State + +— + +. + +All State + += All State = All State + +— All State + +M All State = All State + +— All State — All State - M All State — MEI All State + +. + +All State All State + +MIMI All State + +All State + +MI All State — Arts Camp + +M Chamber Music Camp + +Chamber Music Camp + +- All State — M All State — All State + +Ell All State + +— M All State - All State + +> = All State M All State + +M All State + +All State + += All State + +All State All State + +MI All State MI All State — All State MI MI All State + +All State + += All State =I All State + +- = All State MI IM Arts Camp + +Chamber Music Camp + +M Chamber Music Camp M Chamber Music Camp + +All State All State All State All State + +- All State + +All State All State + +— All State - = All State + +All State + +MI All State — All State + +IMI All State + +- = All State — All State + +IMI All State + +All State + +l= All State + +All State Arts Camp Arts Camp + +- M Arts Camp + +— + +IMI Arts Camp + +Chamber Music Camp Chamber Music Camp + += Chamber Music Camp + +. + +All State + +— + +. + +All State + += All State + +- + += All State M All State + +All State All State + +— All State + +All State + +I=I l l All State + +All State + +— + +All State All State + += All State + +I= All State + +All State + +— = All State + += All State + +All State + +— All State + +All State + +- MEI All State — All State + +IMI IMI Arts Academy + += Arts Camp + +. + +• Arts Camp M Arts Camp + +- Arts Camp — Arts Camp + +MI Arts Camp + +— = Chamber Music Camp + +Chamber Music Camp Chamber Music Camp + += All State + +— I= All State — All State + += All State + +All State All State + +MI All State + +Arts Camp + +IM = = + +IM I= + +s + +Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +Chamber Music Camp Chamber Music Camp Chamber Music Camp + +Arts Academy Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +Chamber Music Camp + +Arts Camp Arts Academy Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Academy Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy + +Chamber Music Camp + +Arts Camp Arts Camp Arts Camp Arts Camp + +• Arts Camp + +Arts Academy Arts Camp Arts Camp Arts Academy + +Chamber Music Camp + +Arts Academy Arts Camp Arts Camp + +• Arts Camp + +Arts Camp All State + +• All State + +Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Academy Arts Camp Arts Camp + +• Arts Academy + +Arts Camp Arts Camp + +MI • Arts Camp + +Arts Camp Arts Camp + +• Arts Camp + +Arts Camp + +• Arts Camp MI Arts Camp + +Arts Academy + +• Arts Camp + +Arts Camp Arts Camp Arts Academy + +NM + +• + +• + += + +Arts Camp Arts Academy Arts Academy Arts Academy All State Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Academy Arts Camp All State Arts Academy Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Academy Arts Camp Arts Academy Arts Academy Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Academy Arts Academy Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp + +m + +Arts Camp Arts Academy Arts Academy Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Academy Arts Academy Arts Academy Arts Camp All State All State Arts Camp Arts Camp Arts Academy Arts Academy Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Academy Arts Camp Arts Academy Arts Camp Arts Academy Arts Academy Arts Camp Arts Academy Arts Academy Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +MI + +• a + +a + +• + +• + +Arts Academy Arts Academy Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Academy Arts Academy Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Academy + +Chamber Music Camp + +Arts Camp Arts Camp All State Arts Academy Arts Camp Arts Camp Arts Camp + +NM • MN • I= = + +I= I= + +MI + +EM MN EMI I= EM = + +IN + +Arts Camp Arts Academy All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Academy Arts Academy Arts Camp Arts Academy Arts Academy Arts Camp Arts Academy + +Chamber Music Camp + +Arts Camp Arts Academy Arts Camp Arts Academy Arts Camp Arts Academy Arts Camp Arts Camp Arts Academy Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +Arts Camp All State Arts Academy Arts Camp Arts Academy Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Academy Arts Academy Arts Academy Arts Camp Arts Academy Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Camp All State Arts Academy Arts Camp Arts Academy Arts Academy Arts Camp Arts Camp Arts Camp + +M + +M + +All State Arts Camp Arts Academy Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Academy Arts Academy Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp All State Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Academy + +• + +Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +Chamber Music Camp + +Arts Camp Arts Camp Arts Camp Arts Academy Arts Academy Arts Academy Arts Camp Arts Camp Arts Academy Arts Academy Arts Academy Arts Camp Arts Camp Arts Academy All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +MI • + +a + +N + +• + +• • Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Academy Arts Academy Arts Academy Arts Camp Arts Camp Arts Camp All State Arts Academy Arts Camp Arts Academy Arts Camp Arts Academy Arts Academy Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp + +Arts Camp + +N Arts Academy + +Arts Academy Arts Camp Arts Camp Arts Academy Arts Academy Arts Camp + +• N + +Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Academy Arts Camp Arts Camp + +MI Arts Camp + +Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Academy Arts Camp Arts Camp + +• Arts Academy + +Arts Camp Arts Camp Arts Camp Arts Camp + +• Arts Camp + +Arts Camp Arts Camp Arts Academy Arts Camp Arts Academy Arts Academy + +MI Arts Camp • Arts Camp • Arts Academy + +All State + +EM + +MEM I= ME M + += + += = Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Academy Arts Camp Arts Academy Arts Camp Arts Camp Arts Academy Arts Academy Arts Camp Arts Academy All State Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Academy Arts Academy Arts Academy Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Academy All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy + +Chamber Music Camp + +Arts Camp Arts Academy Arts Academy + +• • + +MI + +a + +lal + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Academy Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp All State Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy + +• • • + +• + += + +• + +Arts Academy Arts Camp Arts Academy Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp + += + +MI + +a + +• + +a + +Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy + +Chamber Music Camp + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy All State Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp + +Arts Camp Arts Camp Arts Camp Arts Camp + +• + +a + +Arts Camp Arts Academy Arts Academy Arts Camp Arts Camp Arts Camp + +Chamber Music Camp + +Arts Camp Arts Camp Arts Camp + +• Arts Camp + +Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy + += Arts Camp + +Arts Camp + +• a + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + += Arts Academy + +Arts Camp Arts Academy Arts Academy Arts Camp Arts Academy Arts Camp Arts Camp + += Arts Camp + +Arts Camp Arts Academy Arts Camp Arts Academy + +MI Arts Camp + +Arts Camp Arts Camp + +• + +• + +IMI + +• + +• + +• + +• + +• + +• • + +• + +Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy + +• + += + +• + += + += = + +Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Academy Arts Academy Arts Camp Arts Academy Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + += + +a + +• + +Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Academy Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Academy Arts Camp Arts Academy Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Academy Arts Camp Arts Camp Arts Camp + +Arts Camp + +N Arts Camp + +Arts Camp Arts Camp Arts Camp Arts Academy Arts Academy Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp + +• Arts Academy IMI Arts Camp + +Arts Academy Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp + +• Arts Camp + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +• Arts Camp + +Arts Camp + +• Arts Camp + +Arts Camp Arts Academy + +MI N + +Arts Academy Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp + +• Arts Academy + += + +• + +• • + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Academy Arts Academy Arts Academy All State Arts Camp Arts Camp + +• • a + 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+IS + +• MI N + +NM + +MI + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +Chamber Music Camp Chamber Music Camp + +All State All State All State All State All State All State All State All State Arts Camp Arts Academy Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State All State All State All State All State Arts Camp Arts Academy Arts Academy Arts Camp Arts Academy Arts Academy + +• + +• + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State All State All State All State All State All State All State All State + +• + +IMI + +• + +• + +• + +Arts Camp Arts Camp Arts Academy Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +Chamber Music Camp + +MI + +• + +All State All State All State All State All State All State All State + +Arts Academy All State Arts Camp Arts Academy Arts Academy Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +Arts Camp Arts Camp All State All State All State All State All State All State All State All State All State All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + += = + += EMI MI + +M + += MI + +MI = \_ = + += + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Academy Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +N + +• + +• + +• + +• + +NM m + +U + +• + +• + +• + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State All State All State All State All State Arts Camp All State + +Chamber Music Camp + +Arts Camp Arts Camp Arts Academy Arts Camp Arts Academy Arts Academy Arts Academy Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + += + +I= MI + +• + += = + +• + += + +M + += + += = + +MI + +ME I l + +EM + +NM + +MI MII + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State + +Chamber Music Camp + +All State All State All State All State All State All State All State All State All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy All State Arts Camp Arts Academy + += + += + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +Chamber Music Camp Chamber Music Camp + +All State All State All State All State All State All State All State All State All State All State + +■ All State + +All State Arts Academy Arts Academy Arts Academy + +Chamber Music Camp + +Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp + +• Arts Camp + +Arts Camp Arts Camp + +IMI Arts Camp + +Arts Academy + +• Arts Camp + +Arts Camp + +MI Arts Camp + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +• Arts Camp + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +• Arts Camp • Arts Camp + +Arts Camp + +MI Arts Camp + +• Arts Camp + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +=I + += + +=I + +MI + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +Chamber Music Camp Chamber Music Camp + +All State All State All State All State All State All State All State All State All State All State Arts Camp All State + +Chamber Music Camp + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +• + +• + +• • + +MI • + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State All State All State All State All State All State All State All State All State All State All State Arts Camp Arts Camp Arts Academy Arts Camp + +NM + +Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +MI + +a + +a + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +Chamber Music Camp + +All State All State All State All State All State All State All State All State Arts Academy Arts Academy Arts Academy Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +Arts Camp + +m + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +m + +Arts Camp Arts Camp Arts Camp Arts Camp + +• Arts Camp + +Arts Camp + +• Arts Camp + +Arts Camp Arts Camp Arts Camp Arts Camp + +• Arts Camp + +All State All State + +=I MI All State + +All State All State All State All State All State All State + +M All State + +Arts Academy + +a • + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +M Arts Camp + +Arts Academy Arts Camp Arts Camp + +MI Arts Camp + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +M Arts Camp + +Arts Camp + +— Arts Camp + +M Arts Camp + +Arts Camp Arts Camp + +- = Arts Camp + += Arts Camp M Arts Camp + +— + +All State + +— Arts Camp + +M Arts Camp + +— Arts Camp + +M Arts Camp + +— IMI Arts Camp + +Arts Camp + +MI Arts Camp + +- = Arts Camp + +. + +Arts Camp Arts Camp + +- Arts Camp + +Arts Camp + +M Arts Camp + +Arts Camp + +— Arts Camp + +Chamber Music Camp + +M = Chamber Music Camp + += Chamber Music Camp M Chamber Music Camp + +All State + +- IMI All State + += + +Chamber Music Camp + +. + +Arts Academy + +— = Arts Academy + += Arts Camp I= Arts Academy M Arts Camp + +— = Arts Academy — M Arts Academy — Arts Academy — Arts Camp + +Arts Camp + +EM = Arts Academy I=I IMI Arts Camp + +Arts Camp Arts Camp + += + +• + +M + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +Chamber Music Camp Chamber Music Camp + +All State All State All State All State All State + +MI M + +• + += + +=I MI + +MI MI Arts Camp Arts Camp Arts Camp Arts Academy All State + +Arts Academy Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +MI + +M + +ME + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State All State + +Arts Academy Arts Camp Arts Camp Arts Academy Arts Camp + += • + +> • • + +> > • + +Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Academy Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp Arts Camp Arts Camp Arts Academy + +Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp + +Arts Academy All State Arts Camp Arts Academy Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp All State Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Academy Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Academy Arts Camp + +• • Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +Chamber Music Camp + +Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp Arts Camp + +— Arts Camp — = Arts Camp - = Arts Academy — Arts Camp - Arts Camp + +M Arts Camp + +Arts Camp + +M = Arts Camp — Arts Camp = Mil All State = = Arts Camp = = Arts Academy — Arts Camp — Arts Camp + +> Arts Camp Arts Camp + += Arts Camp + +Arts Camp + +MI Arts Academy = Arts Camp = Arts Camp = Arts Camp + +Arts Camp + += = Chamber Music Camp + +MI I=I Arts Camp + += Arts Camp + +- All State + += All State + +M Chamber Music Camp + += Arts Academy + +M= All State M = All State + +I= All State + += = All State - Mil All State + += All State + +— Arts Camp — All State + +> = All State MI Arts Camp = Arts Camp + +M MEI Arts Camp — Arts Camp + +MI Arts Camp + += + +Arts Camp + +- = Arts Academy + += = = = M = + += = + +M = + += + +MI im + +M I= = + +M = + += + +Arts Camp Arts Academy Arts Camp Arts Academy Arts Camp Arts Academy Arts Camp + +Chamber Music Camp Chamber Music Camp + +Arts Camp Arts Academy + +Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber Music Camp Chamber 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Assistant United States Attorney Southern District of New York One St. Andrew's Plaza New York, New York 10007 + +> Re: Interlochen Center for the Arts Grand Jury Subpoenas dated February 6 &10, 2020 + +Dee + +As you know, I represent Interlochen Center for the Arts ("Interlochen") in connection with its response to the two subpoenas issued by your office. Enclosed please find executed custodian certifications along with aconfidential document production on behalf of Interlochen in response to the subpoenas duces tecum that was served by your office on the custodian of records for Interlochen. The enclosed flash drive includes those responsive documents with abates range as follows: + +- INT000001 INT000293 responsive to February 6, 2020 Subpoena; and +- INT000294 INT000631 responsive to February 10, 2020 Subpoena. + +The files are encrypted and the password will be sent to you via email. + +Consistent with our prior communications, Interlochen is committed to cooperating fully with your office. + +The submission of this letter and the materials enclosed herewith is without prejudice to, and with full reservation of, all privileges, rights, and protections. Interlochen requests that this letter and the materials attached hereto be treated as exempt from disclosure, under the Freedom of Information Act, 5 U.S.C. § 552 ("FOIA"), and as confidential pursuant to 28 C.F.R. § 16.8. + +We submit these materials to you with the understanding that your office's request for this information is relevant and materials to a valid law enforcement purpose. We further submit these materials to you with the understanding that they will remain confidential unless and until they are made public by the Court. + +Finally, we submit these materials to you with the understanding that, in the event that any privileged or work-product protected documents are produced, inadvertent or otherwise, your office will promptly destroy each copy of any such document that is in the possession, custody, or control of the United States. *See, e.g., Fed. R. Civ. P. 26(b)(5)(B).* + +If you have any questions or concerns, please do not hesitate to contact me. + +Very truly yours, + +![]()George B. Donnini + +Declaration of Custodian of Records + +Pursuant to 28 U.S.C. § 1746, I, the undersigned, hereby declare: + +My name is PATRICK M. KESSEL +(name of declarant) + +I am a United States citizen and I am over eighteen years of age. I am the custodian of records of the business named below, or I am otherwise qualified as a result of my position with the business named below to make this declaration. + +I am in receipt of a Grand Jury Subpoena, dated February 6, 2020, and signed by Assistant United States Attorney [REDACTED], requesting specified records of the business named below. Pursuant to Rules 902(11) and 803(6) of the Federal Rules of Evidence, I hereby certify that the records provided herewith and in response to the Subpoena: + +- (1) were made at or near the time of the occurrence of the matters set forth in the records, by, or from information transmitted by, a person with knowledge of those matters; +- (2) were kept in the course of regularly conducted business activity; and +- (3) were made by the regularly conducted business activity as a regular practice. + +I declare under penalty of perjury that the foregoing is true and correct. + +Executed on 2/19/20 +(date) + +PATRICK M. KESSEL +(signature of declarant) + +PATRICK M. KESSEL VP FINANCE & OPERATIONS +(name and title of declarant) + +INTERLOCHEN CENTER FOR THE ACTS +(name of business) +4000 MI - 137 HIGHWAY +INTERLOCHEN MI 49643 +(business address) + +Definitions of terms used above: + +As defined in Fed. R. Evid. 803(6), "record" includes a memorandum, report, record, or data compilation, in any form, of acts, events, conditions, opinions, or diagnoses. The term, "business" as used in Fed. R. Evid. 803(6) and the above declaration includes business, institution, association, profession, occupation, and calling of every kind, whether or not conducted for profit. + +## Declaration of Custodian of Records + +Pursuant to 28 U.S.C. § 1746, I, the undersigned, hereby declare: + +A 2C-7(C/C 1 AA. ea Am. Immigration Lawyers Ass'n v. Dep't of Homeland Sec. ,
852 F. Supp. 2d 66 (D.D.C. 2012) ..... | 10 | +|-------------------------------------------------------------------------------------------------------------------------------------------------|------| +| Assoc. Press v. Dep't of Def. ,
554 F.3d 274 (2d Cir. 2009) ..... | 5, 9 | +| Coleman v. FBI ,
13 F. Supp. 2d 75 (D.D.C. 1998) ..... | 10 | +| Dep't of Def. v. FLRA ,
510 U.S. 487 (1994) ..... | 7 | +| E.B. v. New York City Board of Educ. ,
233 F.R.D. 289 (E.D.N.Y. 2005) ..... | 8 | +| Gonzalez v. U.S. Citizenship & Immigration Servs. ,
2020 U.S. Dist. LEXIS 134482 (S.D.N.Y. July 29, 2020) ..... | 2 | +| Grand Central P'ship, Inc. v. Cuomo ,
166 F.3d 473 (2d Cir. 1999) ..... | 8 | +| Human Rights Watch v. DOJ Fed. Bureau of Prisons ,
2015 U.S. Dist. LEXIS 123592 (S.D.N.Y. Sept. 16, 2015) ..... | 2 | +| Judicial Watch, Inc. v. U.S. Dep't of Commerce ,
375 F. Supp. 3d 93 (D.D.C. 2019) ..... | 9 | +| N.Y. Times Co. v. Dep't of Def. ,
499 F. Supp. 2d 501 (S.D.N.Y. 2007) ..... | 8 | +| N.Y. Times Co. v. Dep't of Justice ,
2016 WL 5946711 (S.D.N.Y. Aug. 18, 2016) ..... | 3 | +| New York Times Co. v. Dep't of Justice ,
390 F. Supp. 3d 499, 512 (S.D.N.Y. 2019) ..... | 3 | +| N.Y. Times Co. v. Dep't of Health and Human Servs. ,
2021 U.S. Dist. Lexis 6267 (S.D.N.Y. Jan. 13, 2021) ..... | 9 | +| Nat'l Ass'n of Home Builders v. Norton ,
309 F.3d 26 (D.C. Cir. 2002) ..... | 6 | +| Nat'l Day Laborer Org. Network v. U.S. Immigration & Customs Enf't ,
2020 U.S. Dist. LEXIS 167637 (S.D.N.Y. Sept. 14, 2020) ..... | 9 | +| Neb. Press Ass'n v. Stuart ,
427 U.S. 539 (1976) ..... | 4, 5 | + +| Radcliffe v. IRS, | | +|------------------------------------------------------------------------------|-------| +| 536 F. Supp. 2d 423 (S.D.N.Y. 2008) Schiller v. City of New York, | 2 | +| 2007 U.S. Dist. LEXIS 4285 (S.D.N.Y. Jan. 19, 2007) Seife v. Dep't of State, | 8 | +| 366 F. Supp. 3d 592 (S.D.N.Y. 2019) Shapiro v. Dep't ofJustice, | 8 | +| 249 F. Supp. 3d 502 (D.D.C. 2017) United States v. Martoma, | 10 | +| 2013 U.S. Dist. LEXIS 182959 (S.D.N.Y. 2013) United States v. Noel, | 4, 5 | +| No. 19-cr-830 (AT) (S.D.N.Y.) United States v. Perez, | 4 | +| 2004 U.S. Dist. LEXIS 7500 (D. Conn. June 16, 2006) STATUTES | 3 | +| 5 U.S.C. § 552 | 2, 10 | + +# OTHER AUTHORITIES + +| Suicide, N.Y. Times (Aug. 16, 2019) | 7 | +|-----------------------------------------------|-------| +| Epstein (Aug. 17, 2019) | 5, 6 | +| Brother Says, Miami Herald (Nov. 14, 2019) | 6 | +| Correctional Center New York, New York (2008) | 6 | +| (Apr. 2010) | 9, 10 | +| Prevention (1995) | 10 | + +#### PRELIMINARY STATEMENT + +The Federal Bureau of Prisons initially told The New York Times that it could not release a single document in response to The Times's FOIA request.' That was not true. Nearly a year and a half later, it has released thousands of pages—but it continues to withhold crucial documents that would shed light on how BOP handled the incarceration and suicide of Jeffrey Epstein. + +Approximately 3,500 pages of records remain at issue. BOP relies upon Exemption 7(A) to withhold almost all of them. But BOP cannot establish that release of these records could interfere with the law enforcement proceedings it cites—the prosecution of murder defendant Nicholas Tartaglione, who shared a cell with Epstein for a brief period of time, and the prosecution of the two correctional officers who failed to perform prisoner counts at the time of Epstein's suicide. The Government also asserts Exemptions 5, 6, 7(C), and 7(E) to justify a limited number of redactions. BOP likewise fails to meet its burden with respect to these withholdings. + +The Court should deny the Government's motion for summary judgment, grant Plaintiff's cross-motion, and order that the records be disclosed. + +#### ARGUMENT + +#### I. The Government Has Failed to Satisfy Its Burden in Justifying Withholding Under Exemption 7(A) + +The Government pins its Exemption 7(A) argument primarily on two prosecutions that are only tangentially related to Epstein. No matter how often BOP describes them as presenting "weighty criminal law enforcement concerns" (See Def. Reply Mem. of L. in Supp. of Summ. J., ECF No. 41 [hereinafter "Gov't Reply Br"], at 5.), the Government has not met its burden to show (a) that the records were "compiled for law enforcement purposes" and (b) that their release "could + +&#x27; Defined terms and abbreviations have the same meaning as in our moving memorandum of law. (See Pl.'s Mem. of L. in Supp. of Summ. J., ECF No. 26 [hereinafter "Pl.'s Br."].) + +reasonably be expected to interfere" with the proceedings. 5 U.S.C. § 552(b)(7)(A). In its reply, the Government is wrong on both the law and the facts. + +As an initial matter, the Government, relying on out-of-circuit precedents, wrongly asks the court to find that any record of a law enforcement agency meets the "compiled for" requirement the so-called per se rule. (Gov't Reply Br., at 6.) The Government proposes that all the records qualify as "compiled for law enforcement purposes" because they were created "in the exercise of BOP's statutory authority to detain arrested individuals." (Supplemental Decl. of Kara Christenson, ECF No. 39 [hereinafter "Christenson Supp. Decl."], at ¶ 29.) But this sweeping application of Exemption 7(A) would effectively shield every BOP record. Cf., Human Rights Watch v. DOJ Fed. Bureau of Prisons, 2015 U.S. Dist. LEXIS 123592, at \*13 (S.D.N.Y. Sept. 16, 2015) ("This broader, commonsense understanding of law enforcement purposes' need not and does not embrace all BOP records."). To avoid such a result, courts within this Circuit—as the Government's own cited cases make clear—have consistently declined to adopt the per se rule. (See Gov't Reply Br., at 5-6 (citing to New York Times Co. v. Dep't of Justice, 2016 WL 5946711, at \*7 (S.D.N.Y. Aug. 18, 2016)); Radcliffe v. IRS, 536 F. Supp. 2d 423, 437 (S.D.N.Y. 2008); Human Rights Watch, 2015 U.S. Dist. LEXIS 123592, at \*11 (rejecting per se rule in BOP case)). Instead, the Government needs to show a "rational nexus" between the documents and the proceedings. See, e.g., Gonzalez v. U.S. Citizenship & Immigration Sews., 2020 U.S. Dist. LEXIS 134482, at \*27 (S.D.N.Y. July 29, 2020). + +That rationale falls away when the Court looks at the actual records the Government wants to shield under Exemption 7(A). The most critical documents include: (I) emails addressing Epstein's mental and physical health; (2) emails discussing details of Epstein's incarceration prior to his suicide; (3) reports, evidence, and emails addressing Epstein's July 23, 2019 apparent suicide attempt; (4) reports and evidence of Epstein's death on August 10, 2019; (5) email correspondence between Tartaglione's attorneys and legal counsel at the MCC; and (6) medical and psychological records of Epstein prepared by BOP. (Decl. oaa, ECF No. 22 [hereinafter a Decl."], at ¶¶ 24-25, 28). These sorts of records logically have no nexus with the prosecutions and therefore cannot be deemed to have been "compiled for law enforcements purposes." These are more properly viewed as administrative records created in the routine course of prison administration as part of the admission and detention of Epstein. They are tangential at best to the prosecutions.2 + +The Government fares no better on the interference prong of the 7(A) test. BOP wants the Court to believe that if Tartaglione stands trial, and if he is convicted, and if his condition of confinement somehow is relevant to penalty phase, the release of these documents could interfere with that possible far-in-the-distance proceeding. (Gov't Reply Br., at 7—8.) But in the penalty phase of a death penalty case, the focus is on findings as to the defendant's "predicate mental states ... [and] the statutory aggravating factors alleged by the government." United States v. Perez, 2004 U.S. Dist. LEXIS 7500, at \*3 (D. Conn. June 16, 2006). Even if his confinement were relevant, the Government needs to show a link between interference and the release of their records. Typically, that means that a defendant would be afforded "greater access to agency investigatory files" that would bear on the prosecution than he would under the rules of criminal procedure. New York Times Co. v. Dep't ofJustice, 390 F. Supp. 3d 499, 512 (S.D.N.Y. 2019). But, as to least one important category, emails of Tartaglione's counsel, he already has access to those records through his counsel. More generally, the Government's declarations fail to demonstrate that these particular + +2 Nor do they become "compiled for law enforcement purposes" by the fact that the Government says they play some role in preventing suicides at BOP facilities or in the investigation of Epstein's death. (See Christenson Decl. ¶ 53.) The needed logical linkage simply does not exist there either. + +documents would be of any use to the defense or materially affect any witness in the trial of murders from 2016. While the declarants march out the usual and generic parade of horribles witness interference, fair trial concerns, undue advantage to the defendants—they fall short of actually connecting these specific types of records to any of those concerns. (See Decl. ¶¶ 18-22, 24-25; Supplemental Decl. of Russell ECF No. 40 [hereinafter a Supp. Decl."], at ¶¶ 6-7, 10-13). Generic concerns that some administrative documents in some cases may interfere with some prosecutions do not establish interference in this murder prosecution. + +The case for interference is even weaker in respect to the Noel prosecution. The Government concedes that the documents have already been disclosed to defendants as part of discovery. (Gov't Reply Br., at 10.) Thus, the sole rationale is that the disclosure may taint witnesses' testimony. (Gov't Reply Br., at 9.) But the records at issue do not discuss the critical issue in the prosecution: what the two officers were doing or not doing on the shift during which the suicide took place. They are instead administrative records, such as medical files for Epstein. Decl. ¶¶ 19-21.) The declarations fail to make the connection between the release of those kinds of records and any shaping of testimony that might occur. ( Decl. ¶ 20.) BOP assumes, without basis, that witnesses will lie if exposed to these records that are of no obvious relevance to the prosecution. In any event, the protective order governing discovery in the Noel prosecution allows these documents to be provided to expert witnesses and shown to fact witnesses. (See Protective Order, United States v. Noel, No. 19-cr-830 (AT) (S.D.N.Y.), Dkt. No. 16, at ¶¶ 2(b)(ii), 3.) Release here will have no material effect. + +In a last-ditch effort to establish the possibility of interference, the Government argues that the records may negatively influence a jury. (Gov't Reply Br., at 8-9.) But "pretrial publicity, even if pervasive and concentrated, cannot be regarded as leading automatically and in every kind of + +criminal case to an unfair trial." United States v. Martoma, 2013 U.S. Dist. LEXIS 182959, at \*22 (S.D.N.Y. Dec. 8, 2013) (citing Neb. Press Ass'n v. Stuart, 427 U.S. 539, 565 (1976)). Nor is withholding the records the only measure that courts can use to mitigate the adverse effects of publicity. Neb. Press Ass 'n, 427 U.S. at 563-64 (enumerating methods to mitigate the effect of pretrial publicity including: "change of [a trial] venue," "postponement of the trial to allow public attention" to subside, "searching questioning of prospective jurors," and "the use of emphatic and clear instructions" to jurors). Ultimately, the Government can take proactive steps to mitigate any purported prejudice resulting from publicity about Tartaglione's case, including the release of the records, if and when he stands trial. + +### IL The Government Has Failed to Satisfy Its Burden in Justifying Withholding Under Exemption 6 and 7(C) + +The Government also seeks to withhold some of these same documents under FOIA's privacy exemptions, Exemption 6 and 7(C)—mainly the phone logs and visitor logs and medical records from the suicide. Those exemptions require "balancing an individual's right to privacy against the preservation of FOIA's basic purpose of opening agency action to the light of public scrutiny." Assoc. Press v. Dep't of Def, 554 F.3d 274, 291 (2d Cir. 2009). + +In its reply, in respect to the logs, BOP doubles down on what it deduces to be the privacy interests of Epstein's friends and associates. (Gov't Reply Br., at 13-14.) But BOP provides no evidence that any of these people, many of whom have been publicly linked to Epstein over the years, actually has a privacy concern; instead, BOP relies solely on its own speculation that they would not want to be associated with Epstein. (See Christenson Decl. 60.) BOP tries to use that speculation to overcome the obvious and legitimate public interest at stake here. Questions persist about whether BOP properly managed Epstein's interactions with associates and friends while incarcerated. See, e.g., Ali Watkins, Danielle Ivory & Christina Goldbaum, Inmate 76318-054: The Last Days of Jeffrey Epstein (Aug. 17, 2019), https://nyti.ms/3h8uED2. These individuals chose to call or visit an individual who had garnered international media attention during his brief detention. But, more to the point, revelations of the logs will shed light on "what [the] government is up to." Nat'l Ass'n of Home Builders v. Norton, 309 F.3d 26, 34 (D.C. Cir. 2002). BOP has established guidelines and procedures for visitation and telephone calls to inmates housed at MCC. See U.S. Dep't of Justice Federal Bureau of Prisons, Attorney's Guide to the Metropolitan Correctional Center New York, New York (2008), https://bitly/3aWIUNW. BOP acts as a gatekeeper between inmates and the outside world; those who wish to contact a prisoner through visitation or telephone call must do so through BOP. Specifically, the records provide the public information about whom Epstein was in contact with while he was under Government supervision. The Government's attempt to distance itself from these records is both disingenuous and unpersuasive (Gov't Reply Br., at 14), since the documents would facilitate public oversight and shed light on how BOP monitors visitors of high-profile inmates. Ultimately, the public interest in understanding who was afforded access to Epstein by the Government outweighs any purported privacy interest. + +The Government again relies on an unasserted privacy interests to withhold records pertaining to the death—the privacy interest of Epstein's sole surviving relative—his brother. (Gov't Reply Br., at 11.) But BOP provides no evidence of what Epstein's brother actually wants or does not want. (See Christenson Decl. ¶ 62.) In fact, he has publicly called for BOP to produce records related to the suicide. See Julie K. Brown, Jeffrey Epstein Wasn't Trafficking Women — And He Didn't Kill Himself Brother Says, Miami Herald (Nov. 14, 2019), https://hrld.us/3ibIANJ. Rather than address the public statements of Epstein's brother, the Government focuses on other issues. The Government avers that it was not required to secure declarations to demonstrate a privacy interest. + +(Gov't Reply Br., at 12.) Undoubtedly, that is so—when there is other evidence of the privacy interest. But there is none here. + +The Government then proceeds to minimize the public's interest in the records providing certain details of Epstein's death. (See Gov't Reply Br., at 12-13.) The Epstein death continues to raise troubling questions about how BOP allowed the suicide to happen. Ali Watkins & Michael Gold, Jeffrey Epstein Autopsy Results Show He Hanged Himself in Suicide, N.Y. Times (Aug. 16, 2019), https://nyti.ms/3bBRMsi. It is abnormal when a prisoner unexpectedly dies in federal custody. A death by suicide necessarily implicates a government failure. The call and visitor logs, documents about Epstein's death, and photographs would contribute directly to the "public understanding of the operations or activities of the government," insofar as they would provide the public with greater information about how Epstein died. Dep't of Def. v. FLRA, 510 U.S. 487, 495 (1994). Moreover, there is a significant amount of "media coverage of speculation and theories about Epstein's death." ( Supp. Decl. 1 8.) And the Government is inextricably intertwined with this speculation. The public has a right to know how BOP failed. + +### HI. The Government Has Failed to Satisfy Its Burden in Justifying Withholding Under Exemption 5 + +The Government next argues that certain of the documents can also be withheld as deliberative under Exemption 5.3 As an initial matter, the Government attempts to muddle the issues before this Court by quibbling about which documents remain in dispute. (See Gov't Reply Br., at 16.) There is no mystery. The Times disputes the entirety of BOP's Exemption 5 withholdings, as set forth in footnote 3 here, with the exception of communications between BOP employees and + +3 The Government now asserts Exemption 5 over four broad categories of documents: (I) the psychological reconstruction of Epstein's death; (2) psychological reconstruction responses; (3) emails pertaining to Epstein's July 23, 2019 suicide attempt; and (4) emails pertaining to Epstein's death. (Exhibit A to Christenson Decl. ("Index"), Dkt. 39-1, Entries 37, 12, 41, 52, 53.) The Times challenges each of these categories. + +Assistant United States Attorneys subject to the attorney-client privilege. (See Pl.'s Br., at 18-19.) The Government's drawn-out recitation of the remaining issues cannot distract from the fundamental problem: BOP has failed to meet its burden to justify withholding the requested records. Assoc. Press, 554 F.3d at 283 ("Consistent with FOIA's purpose and design, the strong presumption in favor of disclosure places the burden on the agency to justify the withholding of any requested documents."). + +First, the documents appear to be largely factual in nature and therefore are not subject to a blanket withholding under Exemption 5. (Pl.'s Br., at 19); see Grand Central P 'ship, Inc. v. Cuomo, 166 F.3d 473, 482 (2d Cir. 1999) ("Purely factual material not reflecting the agency's deliberative process is not protected."). Instead, the Government cherry-picks portions of documents to defend its withholdings. For example, the Government asserts that "certain emails" reflect "deliberations about where and how to house Epstein following his apparent suicide attempt in July 2019." (Gov't Reply Br., at 16-17; Christenson Decl. ¶ 49(d).) But decisions about where to place a specific prisoner after a suicide attempt are not a "policy-oriented judgment;" they are instead properly understood as "routine operating decisions." Seife v. Dep't of State, 366 F. Supp. 3d 592, 606 (S.D.N.Y. 2019). Routine operational decisions are not deliberative communications protected by the privilege. See id.; Schiller v. City of New York, 2007 U.S. Dist. LEXIS 4285, at \*34 (S.D.N.Y. Jan. 19, 2007); E.B. v. New York City Board of Educ., 233 F.R.D. 289, 293 (E.D.N.Y. 2005). Contrary to the Government's proposed application of Exemption 5, the deliberative process privilege "does not operate indiscriminately to shield all decision-making by public officials." N.Y. Times Co. v. Dep't of Def., 499 F. Supp. 2d 501, 514 (S.D.N.Y. 2007). + +Moreover, the Government's Exemption 5 withholdings cannot survive because BOP has failed to meet the "foreseeable harm" standard created by the FOIA Improvement Act of 2016. In its + +reply, the Government does little more than recite the boilerplate rationale for protecting deliberative documents. (Gov't Reply Br., at 17-18.) That is not enough. In order to satisfy the Amendment's standard, BOP "must explain how a particular Exemption 5 withholding would harm [its] deliberative process." Nat? Day Laborer Org. Network v. U.S. Immigration & Customs Enft, 2020 U.S. Dist. LEXIS 167637, at \*33 (S.D.N.Y. Sept. 14, 2020). "General explanations" that disclosure would impair or chill deliberations alone do not satisfy the foreseeable harm standard. Judicial Watch, Inc. v. U.S. Dept of Commerce, 375 F. Supp. 3d 93, 100 (D.D.C. 2019); see also N.Y. Times Co v. Dep't of Health and Human Sews., 2021 U.S. Dist. Lexis 6267, at \*30-31 (S.D.N.Y. Jan 13, 2021). That is the exact justification the Government offers. (See, e.g" Christenson Decl. ¶ 49(b) (stating that "[r]elease of the [psychological reconstruction and responses] would hamper frank and open discussions and assessments by these officials in reaching policy decisions" without further justification).) Missing is any explanation of how the disclosure of these records would cause specific harm to the agency's deliberative processes. See, e.g., Judicial Watch, Inc., 375 F. Supp. 3d at 100 (agency must articulate "a link between the specified harm and specific information contained in the material withheld"). + +## IV. The Government Has Failed to Satisfy Its Burden in Justifying Withholding Under Exemption 7(E) + +Exemption 7(E) is designed to shield secret law enforcement techniques. That necessarily means that an agency has kept the information secret. Not so here. (Pl.'s Br., at 21.) At issue are those records dealing with how BOP responds to suicide attempts. (Gov't Reply Br., at 18.) But the techniques for suicide response are not secrets. The Government's public reports address this very topic and provide comprehensive guidance as to how a BOP staff member should respond to an inmate's suicide attempt. See U.S. Dep't of Justice Nat'l Inst. of Corrections, National Study ofJail Suicide: 20 Years Later (Apr. 2010), at 52, https://bitly/31YuolCm (discussing the three requisite + +components for an effective policy regarding intervention). In fact, the Department of Justice has a detailed description of suicide attempt/post-suicide procedures discussing the specific duties of the officers on duty at the time of suicide events and the equipment needed by those staff members. U.S. Dep't of Justice Nat'l Inst. of Corrections, Prison Suicide: An Overview and Guide to Prevention (1995), at 23-25, https://bit.ly/2FhaZnb. There is nothing secret here. + +While it is true that courts have at times found that commonly known procedures may be protected from disclosure, this applies when "the manner and circumstances of the various techniques ... [are] not generally known to the public." Coleman v. FBI, 13 F. Supp. 2d 75, 83 (D.D.C. 1998); see also Shapiro v. Dep't of Justice, 249 F. Supp. 3d 502, 507 (D.D.C. 2017) ("Even though the identity of the investigative technique is more publicly known, disclosure of the manner and circumstances of the technique may still frustrate enforcement of the law.") (emphasis added). The Government has done little to actually explain why the available information does not obviate invocation of the exemption. (See Gov't Reply Br., at 20.) BOP needs to explain away why the public disclosures, but it has not done so. See Am. Immigration Lawyers Ass 'it v. Dept of Homeland Sec., 852 F. Supp. 2d 66, 80 (D.D.C. 2012) ("Where an agency has publicly disclosed information that is similar to what is being withheld, its Vaughn submission must be `sufficiently detailed' to distinguish the withheld information from the public information."). + +### CONCLUSION + +For the foregoing reasons, Plaintiff respectfully asks this Court to (i) declare that the documents sought by The Times are public under 5 U.S.C. § 552 and must be disclosed; (ii) order BOP to provide the requested documents to The Times within 20 business days of the Court's order; (iii) award The Times the costs of this proceeding, including reasonable attorneys' fees, as expressly permitted by 5 U.S.C. § 552(a)(4)(E); and (iv) grant such other and further relief as the Court deems just and proper. + +Dated: New York, NY February 10, 2020 + +Respectfully submitted, + +By: Is/ David E. McCraw David E. 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+![](_page_0_Picture_13.jpeg) + +ABC: hilps://abcnews.gthcom/USijudgerule-unsealintrecordc-defamation-case-ghislaine-maxwellistory? id=71934696 + +*The Hill: * + +![](_page_1_Picture_4.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00088575/EFTA00088575.metadata.json b/marker2/ds9/EFTA00088575/EFTA00088575.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..a4994cac005aa6953d09a461ebb5724b5fbb0287 --- /dev/null +++ b/marker2/ds9/EFTA00088575/EFTA00088575.metadata.json @@ -0,0 +1,88 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00088575.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 662, + "elapsed_seconds": 2.1, + "image_assets": [ + "_page_0_Picture_5.jpeg", + 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0000000000000000000000000000000000000000..5a26ed2d31b2ac251cb34b90028fb9ac5186007f --- /dev/null +++ b/marker2/ds9/EFTA00088575/_page_1_Picture_4.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:9ef6e0045df20bc4f6785355d7239153a1de68c8eaf2f2f47ca6c599a6349d39 +size 7332 diff --git a/marker2/ds9/EFTA00088577/EFTA00088577.md b/marker2/ds9/EFTA00088577/EFTA00088577.md new file mode 100644 index 0000000000000000000000000000000000000000..cc8f49d05b24315f33bad97e4c1450471f09b88d --- /dev/null +++ b/marker2/ds9/EFTA00088577/EFTA00088577.md @@ -0,0 +1,47 @@ +To:' + +Subject: FW: U.S. v Tartaglione, S4 16 Cr. 832 (KMK) + +Date: Mon, 27 Jul 2020 19:55:30 +0000 + +Attachments: July\_27\_Memo\_Endorsement.pdf + +Hello AUSA=. + +Please see below. I apologize, I mistakenly left out the dot between your first and last name in the original email to you and it was rejected. + +jennyer cumil7nme, Paralegal + +Barket Epstein Kearon Aldea & LoTurco, LLP + +Garden City, NY + +Website: www.BarketEpstein.com + +Please consider the environment before printing this email + +This email including all attachments may be a privileged attorney client communication or may otherwise be confidential and is intended solely for the use of the individual or entity to which it is addressed. This communication may contain information that is protected from disclosure under State and/or Federal laws. If it is not clear that you are the intended recipient, you are hereby notified that you have received this transmittal in error. If you suspect that you have received this communication in error, please notify us immediately by telephone or email and immediately delete this message and all its attachments. If you are not the intended recipient you are notified that any review, dissemination, distribution, copying or taking any action in reliance on the contents of this information is strictly prohibited. + +From: Jennifer Giambrone + +Sent: Monday, July 27, 2020 3:51 PM + +To: + +Cc: Bruce Barket Donna Aldea < Aida Leisenring + +Subject: U.S. v Tartaglione, 54 16 Cr. 832 (KMK) + +Dear Ms. Bordes, + +Attached is a letter request by Ms. Donna Aldea of Barket, Epstein, Kearon, Aldea and LoTurco, LLP, retained counsel for Mr. Tartaglione. She respectfully requests that the letter be filed under seal. + +Thank you for your time and consideration, + +Jennifer cianibrone, Paralegal + +Barket Epstein Kearon Aldea & LoTurco, LIP + +Garden City, NY + +This email including all attachments may be a privileged attorney client communication or may otherwise be confidential and is intended solely for the use of the individual or entity to which it is addressed. This communication may contain information that is protected from disclosure under State and/or federal laws. If it is not clear that you are the intended recipient, you are hereby notified that you have received this transmittal in error. If you suspect that you have received this communication in error, please notify us immediately by telephone or email and immediately delete this message and all its attachments. If you are not the intended recipient you are notified that any review, dissemination, distribution, copying or taking any action in reliance on the contents of this information is strictly prohibited. \ No newline at end of file diff --git a/marker2/ds9/EFTA00088577/EFTA00088577.metadata.json b/marker2/ds9/EFTA00088577/EFTA00088577.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..673a52e02255799d8714657913f01725fcce058a --- /dev/null +++ b/marker2/ds9/EFTA00088577/EFTA00088577.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00088577.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2670, + "elapsed_seconds": 1.15, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 67 + ], + [ + "Line", + 34 + ], + [ + "Text", + 26 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 13 + ], + [ + "Line", + 7 + ], + [ + "Text", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00088577" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00088579/EFTA00088579.md b/marker2/ds9/EFTA00088579/EFTA00088579.md new file mode 100644 index 0000000000000000000000000000000000000000..452fa0b1f46ebdccadeb3f6aff13a7c367df04e7 --- /dev/null +++ b/marker2/ds9/EFTA00088579/EFTA00088579.md @@ -0,0 +1,19 @@ +Date of entry 08/14/2019 + +On August 10, 2019 at approximately 1345 hours the reporting investigator met with BOP in an administrative office on the 9th floor opposite of the "L" tier. During that time a review of EPSTEIN's inmate records and activity conducted with the following information obtained: + +- According to computer inquiries conducted at that time by EPSTEIN had no phone calls on file with BOP. found that inquiry to be odd because she was informed that EPSTEIN had in fact made a call on 08/09/2019. An inquiry of another inmate was conducted to ensure the database was operating correctly or that the inquiry was submitted correctly and phone records were revealed for the "test" inmate run. EPSTEIN's 08/09/2019 call was provided by BOP supervisor who also reported the call. informed that the call was made on an unsecure line or "legal line" which is not recorded. informed that the reason the call was placed in that manner was because EPSTEIN related to that there was an issue with his phone account and he could not make a "normal call". When asked to utilized EPSTEIN's code to make a "test" call to determine the validity of the reason for the unsecure call, informed that it would be impossible to test because the system is voice recognizable and voice activated. further informed that inmates are given calls once per every 30 days. It is one call that may last 15 minutes max. All calls are made from within the cell and BOP personnel bring in a receiver or headset for the inmate to utilize. Records indicate BOP supervisor notified EPSTEIN next of kin; Mark Epstein at at 1100 hours on 08/10/2019. Review of EPSTEIN's commissary yielded him to have funds in the amount of \$566.27 at the time of his death. EPSTEIN had no "authorized persons" or any persons listed on his call log. +- was able to finally retrieve a record of EPSTEIN's last call. The call was placed on the unsecure line at approximately 1900 hours and was made to . According to EPSTEIN indicated he was calling his mother. informed that EPSTEIN's mother is deceased. +- EPSTEIN's last cellmate was Efrain REYES (date of birth-) who + +invcsugadon on 08/10/2019 •t New York, New York, United States (In Person) + +This document contains neither recommendations nor conclusions of the FBI. It is the moµ" ty of the FBI and is loaned to your agency; it and its contents arc no; to be distributed outside your agency. + +(U) Initial Review of EPSTEIN Inmate + +Continuation of FD-302 of Records with (HOP) i on 08/10/2019 ,page 2 of 2 + +was released from court on 08/09/2019. + +- EPSTEIN has no recorded visitors to the MCC. \ No newline at end of file diff --git a/marker2/ds9/EFTA00088579/EFTA00088579.metadata.json b/marker2/ds9/EFTA00088579/EFTA00088579.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..41bd0322ce6e63a03fd8b6975af48665a9d00ce9 --- /dev/null +++ b/marker2/ds9/EFTA00088579/EFTA00088579.metadata.json @@ -0,0 +1,136 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00088579.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2607, + "elapsed_seconds": 0.67, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "FEDERAL BUREAU OF INVESTIGATION", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 188.496, + 49.41 + ], + [ + 390.5003662109375, + 49.41 + ], + [ + 390.5003662109375, + 62.4552001953125 + ], + [ + 188.496, + 62.4552001953125 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 93 + ], + [ + "Line", + 46 + ], + [ + "Text", + 7 + ], + [ + "PageHeader", + 3 + ], + [ + "ListItem", + 3 + ], + [ + "SectionHeader", + 1 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 23 + ], + [ + "Line", + 8 + ], + [ + "Text", + 4 + ], + [ + "PageHeader", + 2 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ], + [ + "ListItem", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00088579" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00088581/EFTA00088581.md b/marker2/ds9/EFTA00088581/EFTA00088581.md new file mode 100644 index 0000000000000000000000000000000000000000..3bbf727809de67b910fed6c7ee671457e7695a64 --- /dev/null +++ b/marker2/ds9/EFTA00088581/EFTA00088581.md @@ -0,0 +1,7 @@ +Date of entry 08/14/2019 + +On August 10, 2019 at approximately 1430 hours, the reporting investigator did interview BOP nurse/medic on the 9th floor outside of the "L" tier. informed that he has been a nurse at the BOP for approximately 18 months and that on the date of incident he was working a 0600 x 1400 shift and assigned "medical duty". According to he remembers getting the call regarding EPSTEIN at 0633 via an alarm broadcast over the radios. informed he arrived at the cell at 0635 hours and observed BOP guards inside and administering CPR. checked EPSTEIN for vitals and detected no pulse and no sign of life. attempted to shock EPSTEIN through an Automated External Defibrillator (AED) and "no shock" was advised. EPSTEIN was transported via stretcher to the MCC 2nd floor medical ward where he was intubated, given oxygen, and given 3 rounds of epinephrine. again attempt to utilize an AED to shock EPSTEIN, but "no shock" was advised. stated that when he entered the cell he observed EPSTEIN laying parallel to the bunk bed with his head towards the wall the desk was affixed to and his feet towards opposite wall. stated the ligature was still around EPSTEIN's neck. + +invcsugation on 08/10/2019 at New York, New York, United States (In Person) + +This document contains neither recommendations nor conclusions of the FBI. 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I don't think it's necessary to loop in OLA, but I would draft our response conservatively in accord with their past guidance. Geoff + +On Aug 11, 2019, at 9:57 AM, (USANYS) < > wrote: + +We can put something together - do you have a sense of timing/deadline? + +Also, for re uests made directly to us, we have been loo in in LA which t icall wants to be inv lv d and + +Sent from my iPhone + +On Aug 11, 2019, at 9:45 AM, Berman, Geoffrey (USANYS) wrote: + +See below and attached letter. Can we draft a response for AG to Q 4? Geoff + +Begin forwarded message: + +From: M==la> + +Date: August I1, 2019 at 9:26:42 AM EDT + +To: "Berman, Geoffrey (USANYS)" \ No newline at end of file diff --git a/marker2/ds9/EFTA00088585/EFTA00088585.metadata.json b/marker2/ds9/EFTA00088585/EFTA00088585.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..9e813267d305ff93809bd170be9865b9f3bdcc95 --- /dev/null +++ b/marker2/ds9/EFTA00088585/EFTA00088585.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00088585.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1095, + "elapsed_seconds": 0.8, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 45 + ], + [ + "Line", + 23 + ], + [ + "Text", + 17 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00088585" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00088586/EFTA00088586.md b/marker2/ds9/EFTA00088586/EFTA00088586.md new file mode 100644 index 0000000000000000000000000000000000000000..43425347b21e450c867f088e420a4ea902bb022e --- /dev/null +++ b/marker2/ds9/EFTA00088586/EFTA00088586.md @@ -0,0 +1,29 @@ +**To:** [REDACTED] > + +**Subject:** Fwd: Draft letter to Congress on Epstein + +**Date:** Mon, 12 Aug 2019 19:55:44 +0000 + +**Attachments:** Epstein\_ltr.pdf; ATT00001.htm + +--- + +Begin forwarded message: + +**From:** [REDACTED] > + +**Date:** August 12, 2019 at 2:07:27 PM EDT + +**To:** [REDACTED] >, " [REDACTED] > + +**Subject:** Draft letter to Congress on Epstein + +This is the letter that we intend to send to the congressional leaders. Please review and let me know if you have concerns about any of the specific statements. This attempts to take into consideration your comments from last night. Apologies for the tight turnaround, but if you can review and revert with any issues in the next hour, that would be appreciated. + +[REDACTED] + +Principal Associate Deputy Attorney General + +[REDACTED] + +[REDACTED] \ No newline at end of file diff --git a/marker2/ds9/EFTA00088586/EFTA00088586.metadata.json b/marker2/ds9/EFTA00088586/EFTA00088586.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..059d5bb01842d7146decfab760dc6763823de9bc --- /dev/null +++ b/marker2/ds9/EFTA00088586/EFTA00088586.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00088586.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 800, + "elapsed_seconds": 4.0, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 33 + ], + [ + "Text", + 30 + ], + [ + "Line", + 17 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00088586" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00088587/EFTA00088587.md b/marker2/ds9/EFTA00088587/EFTA00088587.md new file mode 100644 index 0000000000000000000000000000000000000000..30ebd3231ae63189f24fefe3038f87ce3ad64e5c --- /dev/null +++ b/marker2/ds9/EFTA00088587/EFTA00088587.md @@ -0,0 +1,36 @@ +From: 'I MI=1. > + +To:' + +Cc: + +Subject: MCC Interviews - Update + +Date: Tue, 13 Aug 2019 00:49:00 +0000 + +This afternoon, OIG, FBI, and the USAO-SDNY conducted voluntary interviews with the following MCC employees. The interviews were each about 2 hours. A high-level summary of each is below. + +Interview of + +IN is an operations lieutenant at MCC, and is responsible for overseeing the operations of the prison during his duty shifts. On the morning of August 10, 2019,gm arrived at 5:30 a.m. to relieve the outgoing lieutenant, U Anderson. At 6:33 a.m. MI heard a radio call for medical staff at the SHU. responded to the SHU, where he saw who said that Epstein had hun himself. IM went into Epstein's cell, and Epstein was on the ground, on top of two mattresses, and as performing CPR. a= then started CPR until medical staff came. .. MI asked -where Epstein's cellmate was, and she said he left, and that he didn't have one overnight. told that she knew Epstein was supposed to have a cellmate, and stuttered, then said she didn't know. dmitted to 0. ME that they did not conduct the 3 a.m. and 5 a.m. counts; and said we messe up" and "we didn't do the counts" and "it's not her fault" M. =was not aware the cameras were not working in SHU. + +Interview ofd. + +has worked at the MCC since May 2019, but has a lengthy BOP career. He's the institution duty officer and has responsibilities relating to multiple units. Among other things, he helps inmates make telephone calls, including legal calls and calls from within the SHU. had spoken to Epstein briefly on multiple occasions. Epstein asked for assistance making a personal call. got Epstein his pin number a few days before Epstein's death, but Epstein had not activated it. took Epstein to the SHU showers to make the phone call. Epstein told he was calling his mother. dialed a number provided by Epstein, and overhead Epstein making small talk with a male individual. whose shift was over, left Epstein with two SHU officers — ( and a male officer and told them to return Epstein to his cell after 15 minutes. Because Epstein's pin was not activated, dialed the number on the MCC line for legal conversations, which is not recorded. was not on duty when Epstein's body was discovered. He says he was not aware that Epstein's cellmate had moved, and he did not know the camera system was not working. + +Interview of MI. + +- oversees the whole prison, and all of the lieutenants of particular units (such as SHU) report to him. stated that on multiple occasions following Epstein's apparent attempted suicide, he spoke to the lieutenants that report to him about how Epstein needed a cellmate at all times. All of those commands were made orally. +- MI said they were aware that had court, which was not out of the ordinary. No one briefed him on the fact that personal property was being collected or that he was moved. +- M. did not learn that Epstein's cellmate moved until after Epstein's apparent suicide was discovered. +- M was not working when the evening rounds and counts occurred. He was aware there was work being done on the videos but wasn't told why. + +Today, FBI and OIG agents also attempted to interview -and fc s (the officers who discovered Epstein), but they did not agree to speak with agents and agents were unable to . (An individual who the agents believe was answered the phone but then claimed he wasn't1=Nd hung up.) Agents also + +contacted four of the officers on duty on Friday August 9, 2019, but they would not speak with agents without their union representatives. We will continue conducting interviews over the next few days. Finally, FBI has not completed their analysis of the video evidence yet. + +Assistant United States Attorney United States Attorney's Office + +ISM + +Tel: \ No newline at end of file diff --git a/marker2/ds9/EFTA00088587/EFTA00088587.metadata.json b/marker2/ds9/EFTA00088587/EFTA00088587.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..9ca009e842702c139220cef92df6658276b03f34 --- /dev/null +++ b/marker2/ds9/EFTA00088587/EFTA00088587.metadata.json @@ -0,0 +1,92 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00088587.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 3757, + "elapsed_seconds": 0.78, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 106 + ], + [ + "Line", + 48 + ], + [ + "Text", + 13 + ], + [ + "ListItem", + 4 + ], + [ + "ListGroup", + 3 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 15 + ], + [ + "Line", + 8 + ], + [ + "Text", + 4 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00088587" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00088589/EFTA00088589.md b/marker2/ds9/EFTA00088589/EFTA00088589.md new file mode 100644 index 0000000000000000000000000000000000000000..f4bac1da407dfd19c8199be5d4b67ef9014acf01 --- /dev/null +++ b/marker2/ds9/EFTA00088589/EFTA00088589.md @@ -0,0 +1,37 @@ +To: USANYS)" + +Subject: FW: MCC + +Date: Tue, 13 Aug 2019 19:35:29 +0000 + +From: + +Sent: Monday, August 12, 2019 2:35 PM + +Subject: FW: MCC + +FYI + +From: Berman, Geoffrey (USANYS) + +Sent: Monday, August 12, 2019 2:33 PM + +To: . (ODAG) + +Subject: MCC + +This morning, OIG, FBI, and USAO-SDNY conducted a recorded, voluntary interview of the warden of MCC. The interview lasted approximately two hours. A high-level summary is below. + +- The Warden was notified of Epstein's July 23, 2019 apparent suicide attempt that day, and he notified his regional director, who we understand to b As a result of the apparent suicide attempt, Epstein was moved from the Secure Housing Unit (SHU) on the 9 floor of the MCC to the suicide watch unit on the 2" floor of the MCC. The Warden reviewed the incident report regarding the apparent suicide attempt. The incident report stated that Epstein denied trying to commit suicide, and he did not remember the incident. +- Epstein was initially placed on suicide watch on July 23, 2019. When on suicide watch, an inmate is dressed in a smock and has an inmate companion observing the inmate 24/7. Inmate companions receive specialized training to observe inmates on suicide watch, to ensure that they don't hurt themselves. The chief psychologist, Dr. briefed the Warden on Epstein's condition while he was on suicide watch. +- On or about July 24, 2019, Epstein was downgraded to psychological observation, but he remained on the 2nd floor suicide watch unit. While on psychological observation, Epstein was no longer required to wear a smock, and wore normal prison clothes, but continued to be observed by an inmate companion 24/7. The Warden recalls being told by DrMithat Epstein was no longer suicidal, so he would be downgraded to psychological observation. When asked whether he questioned that decision, the Warden stated that he does not, as a matter of course, second-guess the opinions of medical professionals. The Warden does not recall whether he notified his regional director that Epstein was removed from suicide watch. +- On July 29, 2019, Epstein was removed from psychological observation and transferred back to the SHU on the 9th floor. Prior to that transfer, the Warden, Dr. and other senior staff had a weekly SHU meeting, which usually occurs on Thursdays. At the SHU meeting prior to Epstein's transfer back to SHU, Dr. discussed Epstein's c oli " and noted that he should have a cellmate in SHU. The Warden directed the supervisor of the SHU (Capt. , who was present at the meellensure that Epstein had a cellmate at all times, and that the officers in the SHU were aware of this. Capt. later confirmed to the Warden that he had relayed these instructions to the SHU staff. +- Prior to Epstein's transfer, the Warden notified his regional director that Epstein would be moved back to the SHU, and discussed three potential candidates to be Epstein's cellmate in the SHU. With the regional director's input, the Warden determined that inmataan older inmate and cooperator, should be his cellmate. + +- After Epstein was moved to the SHU on July 29, the Warden repeatedly reminded Captao make sure that Epstein had a cellmate. According to the Warden, the duty officers were required to notify their supervisor, who would then notify the associate warden and the Warden, if Epstein was left without a cellmate. +- On the morning of August 9, 2019, the SHU officers received a notification that they should pack up inmate belongings, and he left the SHU. The Warden was out of the office on August 9, and was not notified that ME was released from the MCC or that Epstein did not have a cellmate. We have since learned that was transferred from MCC to GEO, a separate facility. +- The duty officers overnight on August 9 to August 10, 2019, were anc . is a corrections officer who routinely works in the SHU. According to documents we have obtained, her shift started at 4pm, and according to Warden, she was working a voluntary overtime shift overnight. normally works in the wart is trained to work as a correctional officer and was also working a voluntary overtime shift overnight. as the first person to find Epstein, and because he has not spoken to the Warden, the Warden did not know the condition that Epstein was found in. + +As we discussed, today, FBI and OIG are attempting to interview Officer and= and the officers who worked on August 9 in the SHU. When the FBI and OIG arrived at Officers home, she refused to open the door or discuss the matter and said that she had retained a lawyer. + +Geoff \ No newline at end of file diff --git a/marker2/ds9/EFTA00088589/EFTA00088589.metadata.json b/marker2/ds9/EFTA00088589/EFTA00088589.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..699c6987a8921ddc2ef47627e9a25a71e9a38ce5 --- /dev/null +++ b/marker2/ds9/EFTA00088589/EFTA00088589.metadata.json @@ -0,0 +1,100 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00088589.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 4545, + "elapsed_seconds": 0.83, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 88 + ], + [ + "Line", + 41 + ], + [ + "Text", + 14 + ], + [ + "ListItem", + 5 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 37 + ], + [ + "Line", + 18 + ], + [ + "ListItem", + 3 + ], + [ + "Text", + 2 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00088589" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00088591/EFTA00088591.md b/marker2/ds9/EFTA00088591/EFTA00088591.md new file mode 100644 index 0000000000000000000000000000000000000000..0cc2739df4a6aa40baeec0f483b228897098aa38 --- /dev/null +++ b/marker2/ds9/EFTA00088591/EFTA00088591.md @@ -0,0 +1,33 @@ +To: ' (OAG)" < + +Cc: OAG)" + +Subject: Re: + +Date: Sat, 10 Aug 2019 15:56:37 +0000 + +Does the AG plan on issuing a statement? Geoff + +On Aug 10, 2019, at 11:06 AM, (OAG) < wrote: + +Geoff. Is the FBI on scene yet? + +■ + +On Aug 10, 2019, at 10:55 AM, Berman, Geoffrey (USANYS) wrote: + +Ok. Geoff + +On Aug 10, 2019, at 10:44 AM, OPA) < > wrote: + +## Inmate Death at the MCC New York + +New York, NY: On Saturday, August 10, 2019, at approximately 6:30 a.m., inmate Jeffrey Edward Epstein was found unresponsive in his cell in the Special Housing Unit from an apparent suicide at the Metropolitan Correctional Center (MCC) in New York, New York. Life-saving measures were initiated immediately by responding staff. Staff requested emergency medical services (EMS) and life-saving efforts continued. Mr. Epstein was transported by EMS to a local hospital for treatment of life-threatening injuries, and subsequently pronounced dead by hospital staff. The FBI is investigating the incident. + +Mr. Epstein was a 66-year-old male who arrived at MCC New York on July 6, 2019 under pretrial status after being indicted for sex trafficking of minors and conspiracy. + +MCC New York is an Administrative security facility that currently houses 763 male offenders in New York, New York. + +Additional information about the Federal Bureau of Prisons can be found at www.bop.gov. + +Director Office of Public Affairs U.S. De artment of Justice \ No newline at end of file diff --git a/marker2/ds9/EFTA00088591/EFTA00088591.metadata.json b/marker2/ds9/EFTA00088591/EFTA00088591.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..8d9e8c4b35e41733680cf102a361b71ebcc4f720 --- /dev/null +++ b/marker2/ds9/EFTA00088591/EFTA00088591.metadata.json @@ -0,0 +1,82 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00088591.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1407, + "elapsed_seconds": 0.95, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Inmate Death at the MCC New York", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 214.812, + 390.41999999999996 + ], + [ + 396.395263671875, + 390.41999999999996 + ], + [ + 396.395263671875, + 405.2005615234375 + ], + [ + 214.812, + 405.2005615234375 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 63 + ], + [ + "Line", + 30 + ], + [ + "Text", + 19 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00088591" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00088592/EFTA00088592.md b/marker2/ds9/EFTA00088592/EFTA00088592.md new file mode 100644 index 0000000000000000000000000000000000000000..76783b4a91186a5e7e728d34007ddbf830e3206f --- /dev/null +++ b/marker2/ds9/EFTA00088592/EFTA00088592.md @@ -0,0 +1,33 @@ +From: (OPA)" To: "Berman, Geoffrey (USANYS)" < Cc: (OAG)" < Subject: RE: Date: Sat, 10 Aug 2019 15:57:48 +0000 (OAG)" + +Yes, the following: + +"I was appalled to learn that Jeffrey Epstein was found dead early this morning from an apparent suicide while in federal custody. Mr. Epstein's death raises serious questions that must be answered. I have ordered a full, thorough, and independent investigation be conducted into the circumstances of Mr. Epstein's death." + +From: Berman, Geoffrey (USANYS) < Sent: Saturday, August 10, 2019 11:57 AM Tom (OAG) ‹ > Cc: En= (OPA) Subject: Re: (OAG) '`: > + +Does the AG plan on issuing a statement? Geoff + +On Aug 10, 2019, at 11:06 AM (OAG) ‹ > wrote: + +Geoff. Is the FBI on scene yet? + +On Aug 10, 2019, at 10:55 AM, Berman, Geoffrey (USANYS) < > wrote: + +Ok. Geoff + +On Aug 10, 2019, at 10:44 AM, (OPA) wrote: + +## Inmate Death at the MCC New York + +New York, NY: On Saturday, August 10, 2019, at approximately 6:30 a.m., inmate Jeffrey Edward Epstein was found unresponsive in his cell in the Special Housing Unit from an apparent suicide at the Metropolitan Correctional Center (MCC) in New York, New York. Life-saving measures were initiated immediately by responding staff. Staff requested emergency medical services (EMS) and life-saving efforts continued. Mr. Epstein was transported by EMS to a local hospital for treatment of life-threatening injuries, and subsequently pronounced dead by hospital staff. The FBI is investigating the incident. + +Mr. Epstein was a 66-year-old male who arrived at MCC New York on July 6, 2019 under pretrial status after being indicted for sex trafficking of minors and conspiracy. + +MCC New York is an Administrative security facility that currently houses 763 male offenders in New York, New York. + +Director + +Office of Public Affairs + +U.S. De artment of Justice \ No newline at end of file diff --git a/marker2/ds9/EFTA00088592/EFTA00088592.metadata.json b/marker2/ds9/EFTA00088592/EFTA00088592.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..77001182657fe2300d4f5b486b477442952fb693 --- /dev/null +++ b/marker2/ds9/EFTA00088592/EFTA00088592.metadata.json @@ -0,0 +1,112 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00088592.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 1832, + "elapsed_seconds": 0.78, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Inmate Death at the MCC New York", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 214.812, + 545.94 + ], + [ + 396.77313232421875, + 545.94 + ], + [ + 396.77313232421875, + 560.4505615234375 + ], + [ + 214.812, + 560.4505615234375 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 83 + ], + [ + "Line", + 37 + ], + [ + "Text", + 13 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 10 + ], + [ + "Text", + 6 + ], + [ + "Line", + 5 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00088592" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00088594/EFTA00088594.md b/marker2/ds9/EFTA00088594/EFTA00088594.md new file mode 100644 index 0000000000000000000000000000000000000000..58fed8fb172a3c1cb780b263ad63d5535f8fa1ec --- /dev/null +++ b/marker2/ds9/EFTA00088594/EFTA00088594.md @@ -0,0 +1,15 @@ +To: ' + +Subject: DP insert + +Date: Thu, 25 Mar 2021 12:59:51 +0000 + +Attachments: JRL carve out.docx + +HIM, + +How are you feeling today? Fully recovered or almost, I hope. + +Here's a draft of my new section for the DP memo. I did a bunch of Westlaw research, but I couldn't find any cases that discussed DPs for corrections officers, so this is somewhat less persuasive than I had hoped. But take a look and let's discuss if there's anything else we can do to strengthen our position here. + +Assistant United States Attorney United States Attorney's Office Southern District of New York \ No newline at end of file diff --git a/marker2/ds9/EFTA00088594/EFTA00088594.metadata.json b/marker2/ds9/EFTA00088594/EFTA00088594.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..59f2ace93cb2640f5e124ba2166adad14c4501f6 --- /dev/null +++ b/marker2/ds9/EFTA00088594/EFTA00088594.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00088594.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 579, + "elapsed_seconds": 0.67, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 29 + ], + [ + "Text", + 14 + ], + [ + "Line", + 14 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00088594" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00088595/EFTA00088595.md b/marker2/ds9/EFTA00088595/EFTA00088595.md new file mode 100644 index 0000000000000000000000000000000000000000..6c8f0d91d7b0fac80a816d9fdb40955a7e2512c8 --- /dev/null +++ b/marker2/ds9/EFTA00088595/EFTA00088595.md @@ -0,0 +1,13 @@ +From: "SP" a &gt; To: ' IIIISSYS)" Cc: ealMIE >, (USANYS)" (USANYS)" + +Subject: Friendly subpoena to attorney + +Date: Fri, 26 Mar 2021 04:38:46 +0000 + +Attachments: 2021.03.26. + +The Maxwell team would like to send the attached "friendly subpoena" to attorney During our interviews in Florida, informed me that he has a copy of the settlement agreement between and Epstein, which resolved 2009 civil suit against Epstein. MI is willing to provide us with a copy of the agreement, but he indicated that he believes he needs a subpoena before he can do so. His firm has already provided us with copies of all other court filings and deposition transcripts from the civil case voluntarily. The settlement agreement resolving the case is relevant to our ongoing investigation into Maxwell's participation in the abuse of + +Happy to discuss. + +Thanks, \ No newline at end of file diff --git a/marker2/ds9/EFTA00088595/EFTA00088595.metadata.json b/marker2/ds9/EFTA00088595/EFTA00088595.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..f67bb9eb98ff36c1fb8e84d2fae2e84a3ae86d58 --- /dev/null +++ b/marker2/ds9/EFTA00088595/EFTA00088595.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00088595.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 862, + "elapsed_seconds": 0.5, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 43 + ], + [ + "Line", + 18 + ], + [ + "Text", + 9 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00088595" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00088596/EFTA00088596.md b/marker2/ds9/EFTA00088596/EFTA00088596.md new file mode 100644 index 0000000000000000000000000000000000000000..6934675a69ce9434462f7785289f875effad7d93 --- /dev/null +++ b/marker2/ds9/EFTA00088596/EFTA00088596.md @@ -0,0 +1,117 @@ +![](_page_0_Picture_0.jpeg) + +# U.S. Department of Justice + +United States Attorney Southern District of New York + +The Silvio J. Motto Building One Saint Andrew s Plaza + +New York, New York 10007 + +March 26, 2021 + +# VIA EMAIL + +IMIW Esq. 2139 Palm Beach Lakes Blvd. West Palm Beach FL 33409-6601 + +Re: Grand Jury Subpoena + +Please be advised that the accompanying grand jury subpoena has been issued in connection with an official criminal investigation of a suspected felony being conducted by a federal grand jury. The Government hereby requests that you voluntarily refrain from disclosing the existence of the subpoena to any third party. Though you are under no obligation to comply with our request, we are requesting you not to make any disclosure in order to preserve the confidentiality of the investigation and because disclosure of the existence of this investigation might interfere with and impede the investigation. + +If you intend to disclose the existence of this Grand Jury Subpoena request to a third party, please let me know before making any such disclosure. + +Thank you for your cooperation in this matter. + +By: + +Very truly yours, + +Audrey Strauss United States Attorney + +Assistant United States Attorney + +TO: +██████████, Esq. +2139 Palm Beach Lakes Blvd. +West Palm Beach FL 33409-6601 +██████████ + +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: April 5, 2021 Appearance Time: 10:00 am + +to testify and give evidence in regard to an alleged violation of: +18 U.S.C. §§ 1591, 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** + +N.B.: **Personal appearance is not required** if the requested records are (1) produced by on or before the return date to Assistant U.S. Attorney ██████████ at: U.S. Attorney's Office, Southern District of New York, 1 St. Andrew's Plaza, New York, NY 10007, 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.** + +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 +March 26, 2021 + +![]()Audrey Strauss +*United States Attorney for +the Southern District of New York* + +![]()██████████ +Assistant United States Attorney +One St. Andrew's Plaza +New York, New York 10007 +██████████ + +![]() + +### RIDER + +(Grand Jury Subpoena to Esq. dated March 26, 2021) + +### Instructions and Definitions: + +- I. This Subpoena calls for the production of categories of documents, as specified below, in the possession, custody, or control of Esq. +- 2. This subpoena covers all responsive documents wherever they may be found, including on computers, servers, and personal electronic devices, whether in the United States or any foreign jurisdiction. +- 3. The "Litigation" means the civil lawsuit filed by against Jeffrey Epstein on behalf of plaintiff under the case caption Jane Doe No. 2 v. Epstein, No. 08 Civ. 80119 in the United States District Court for the Southern District of Florida. +- 4. Where possible, please produce the records requested herein in electronic form. +- 5. This subpoena does not call for the production of any documents protected by a valid claim of privilege, although any responsive document over which privilege is being asserted must be preserved. Any documents withheld on grounds of privilege may be required to be specifically identified on a privilege log with descriptions sufficient to identify their dates, authors, recipients, and general subject matter. + +# Materials To Be Produced: + +- I. All non-privileged documents relating to the settlement of the Litigation, including any and all settlement agreements between the parties. + +N.B.: Personal appearance is not required if the re uested records are (1) produced by on or before the return date to Assistant U.S. Attorney at: U.S. Attorne 's Office. Southern District of New York, 1 St. Andrew's Plaza, New York, NY 10007, telephone: or via email at ; and (2) accompanied by an executed copy of the attached Declaration of Custodian of Records. PLEASE PROVIDE IN ELECTRONIC FOR NIkT IF POSSIBLE. + +### Declaration of Custodian of Records + +Pursuant to 28 U.S.C. ❑ 1746, I, the undersigned, hereby declare: + +My name is (name of declarant) + +I am a United States citizen and I am over eighteen years of age. I am the custodian of records of the business named below, or I am otherwise qualified as a result of my position with the business named below to make this declaration. + +I am in recei t of a Grand Jury Subpoena, dated March 26, 2021 and signed by Assistant United States Attorney requesting specified records of the business named below. Pursuant to Rules 902(11) and 803(6) of the Federal Rules of Evidence, I hereby certify that the records provided herewith and in response to the Subpoena: + +- (1) were made at or near the time of the occurrence of the matters set forth in the records, by, or from information transmitted by, a person with knowledge of those matters; +- (2) were kept in the course of regularly conducted business activity; and +- (3) were made by the regularly conducted business activity as a regular practice. + +I declare under penalty of perjury that the foregoing is true and correct. + +Executed on (date) + +(signature of declarant) + +(name and title of declarant) + +(name of business) + +(business address) + +## Definitions of terms used above: + +As defined in Fed. R. Evid. 803(6), "record" includes a memorandum, report, record, or data compilation, in any form, of acts, events, conditions, opinions, or diagnoses. The term, "business" as used in Fed. R. 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sha256:2abaa4637c422a82716edfbbf2d7e4eeaf6ef9c92c54b450e85858d0b81aef3b +size 6024 diff --git a/marker2/ds9/EFTA00088600/EFTA00088600.md b/marker2/ds9/EFTA00088600/EFTA00088600.md new file mode 100644 index 0000000000000000000000000000000000000000..d378dd29395fd557b41df10b3d720e721094c103 --- /dev/null +++ b/marker2/ds9/EFTA00088600/EFTA00088600.md @@ -0,0 +1,19 @@ +To: + +Cc: + +Subject: Friendly Subpoena + +Date: Fri, 26 Mar 2021 13:41:59 +0000 + +Just a heads up that the Maxwell team is going to seek your approval this morning to issue a friendly subpoena to counsel for Minor Victim-4, the latest victim whose abuse gives rise to the superseder, for a non-privileged materials related to her settlement with Epstein back in 2008 or thereabouts. As you can imagine, we think we need this stuff both to prepare for trial but also as potential Giglio for the witness, and her lawyer is happy to provide it to us but believes he needs a subpoena. + +Happy to chat further if that would be helpful, but otherwise will have the team send you an email shortly so you can approve. + +Thanks, + +Chief, Public Corruption Unit U.S. Attorney's Offfice for the Southern District of New York + +Tel: + +Cell \ No newline at end of file diff --git a/marker2/ds9/EFTA00088600/EFTA00088600.metadata.json b/marker2/ds9/EFTA00088600/EFTA00088600.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..eb4315042335f7209a5a188bfbe594eeaa778ee8 --- /dev/null +++ b/marker2/ds9/EFTA00088600/EFTA00088600.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00088600.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 817, + "elapsed_seconds": 0.58, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 37 + ], + [ + "Line", + 19 + ], + [ + "Text", + 11 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00088600" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00088601/EFTA00088601.md b/marker2/ds9/EFTA00088601/EFTA00088601.md new file mode 100644 index 0000000000000000000000000000000000000000..8a41f25bd8af29cdeee3966eecd8b8e23a793664 --- /dev/null +++ b/marker2/ds9/EFTA00088601/EFTA00088601.md @@ -0,0 +1,25 @@ +From: ' (USANYS)" To: )" Cc: a' )1H Subject: RE: Friendly subpoena to Date: Fri, 26 Mar 2021 15:49:30 +0000 (USANYS)" >, "-(USANYS)" attorney + +I think I probably would. Thanks + +From: Sent: Friday, March 26, 2021 11:47 AM To: (USANYS) Cc: Subject: RE: Friendly subpoena to attorney (USANYS) (USANYS) < + +Will do, thanks. Want me to revise the subpoena rider to just seek the agreement first? + +From: (USANYS) < Sent: Friday, March 26, 2021 11:03 AM To: Cc: Subject: RE: Friendly subpoena to attorney >; >; (USANYS) < (USANYS) < + +Subject to any discussion worth having over the questions below, Audrey is prepared to approve this, so please put together a very short email to her along the lines of our email to us, below, so she can respond approving this. Thanks + +From: (USANYS) Sent: Friday, March 26, 2021 9:39 AM To: Cc: ) ‹ ; Subject: RE: Friendly subpoena to >; attorney (USANYS) < (USANYS) < + +Thanks, Two follow up questions — first, I assume there is no protective order issue here we need to be mindful of? Second, in light of the ongoing litigation over the BSF subpoena — and given that we do seem to have some knowledge of what's in the file here and, indeed, we want a very specific thing from that file — is there are virtue to specifically asking for what we want in the rider, rather than doing our typical "all non-privileged documents..." + +Happy to chat if that would be helpful, and this will also need to be approved by Audrey, so I'll give her a heads up that it's coming. But we should probably try to cut this before Monday if possible. + +From: Sent: Friday, March 26, 2021 12:39 AM To: (USANYS) < Cc: Subject: Friendly subpoena to attorney (USANYS) < (USANYS) < + +The Maxwell team would like to send the attached "friendly subpoena" to attorney During our interviews in Florida, M informed me that he has a copy of the settlement agreement between and Epstein, which resolved 2009 civil suit against Epstein. MI is willing to provide us with a copy of the agreement, but he indicated that he believes he needs a subpoena before he can do so. His firm has already provided us with copies of all other court filings and deposition transcripts from the civil case voluntarily. The settlement agreement resolving the case is relevant to our ongoing investigation into Maxwell's participation in the abuse of + +Happy to discuss. + +Thanks, \ No newline at end of file diff --git a/marker2/ds9/EFTA00088601/EFTA00088601.metadata.json b/marker2/ds9/EFTA00088601/EFTA00088601.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..8644da7523325834b4f5a5f14643cd7648b5bd40 --- /dev/null +++ b/marker2/ds9/EFTA00088601/EFTA00088601.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00088601.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2350, + "elapsed_seconds": 0.63, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 104 + ], + [ + "Line", + 50 + ], + [ + "Text", + 11 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 17 + ], + [ + "Line", + 9 + ], + [ + "Text", + 3 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00088601" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00088603/EFTA00088603.md b/marker2/ds9/EFTA00088603/EFTA00088603.md new file mode 100644 index 0000000000000000000000000000000000000000..55514e6fc0bf195ca2036635eafa7039460116ef --- /dev/null +++ b/marker2/ds9/EFTA00088603/EFTA00088603.md @@ -0,0 +1,13 @@ +From: " To: "Strauss, Audrey (USANYS)" < IMIIIM> Cc: (USANYS)" + +Subject: Friendly Subpoena to Attorney + +Date: Fri, 26 Mar 2021 16:05:00 +0000 + +Attachments: 2021.03.26. + +Hi Audrey, + +The Maxwell team would like to send the attached "friendly subpoena" to attorney During our interviews in Florida, M informed me that he has a copy of the settlement agreement between and Epstein, which resolved 2009 civil suit against Epstein. M is willing to provide us with a copy of the agreement, but he indicated that he believes he needs a subpoena before he can do so. His firm has already provided us with copies of all other court filings and deposition transcripts from the civil case voluntarily. The settlement agreement resolving the case is relevant to our ongoing investigation into Maxwell's participation in the abuse of and other underage girls. + +Thanks, \ No newline at end of file diff --git a/marker2/ds9/EFTA00088603/EFTA00088603.metadata.json b/marker2/ds9/EFTA00088603/EFTA00088603.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..d0b4c67ca69e8da0429d1cd34f90766d9901a4ed --- /dev/null +++ b/marker2/ds9/EFTA00088603/EFTA00088603.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00088603.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 854, + "elapsed_seconds": 0.48, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 33 + ], + [ + "Line", + 16 + ], + [ + "Text", + 8 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00088603" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00088604/EFTA00088604.md b/marker2/ds9/EFTA00088604/EFTA00088604.md new file mode 100644 index 0000000000000000000000000000000000000000..7a3a0761a6f413a3bc4a952914721bcebce0597e --- /dev/null +++ b/marker2/ds9/EFTA00088604/EFTA00088604.md @@ -0,0 +1,31 @@ +**To:** "[REDACTED] (USANYS)" <[REDACTED]>, "[REDACTED] + +(USANYS)" <[REDACTED]>, "[REDACTED] (USANYS)" + +<[REDACTED]>, "[REDACTED] (USANYS)" <[REDACTED]>, "[REDACTED] + +(USANYS)" <[REDACTED]>, "[REDACTED] ()" + +<[REDACTED]> + +**Subject:** Epstein FOIA Moot + +**Date:** Fri, 26 Mar 2021 19:16:49 +0000 + +**Attachments:** + +[REDACTED] + +Hi all, + +Thank you so much for joining the moot in the Epstein FOIA. We have an all-star cast for this moot. We are a little oversubscribed, so if anyone as a conflict or needs to drop, no problem at all. + +The briefing and declarations are attached here. I just sent an invite with the dial-in. I think a few folks from BOP will join as well. + +Thanks again, + +[REDACTED] +Assistant United States Attorney +300 Quarropas Street +White Plains, NY 10601 +Telephone: [REDACTED] \ No newline at end of file diff --git a/marker2/ds9/EFTA00088604/EFTA00088604.metadata.json b/marker2/ds9/EFTA00088604/EFTA00088604.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..106d8bbc51dbf424dd6741d75556cc38d05f3e88 --- /dev/null +++ b/marker2/ds9/EFTA00088604/EFTA00088604.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00088604.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 803, + "elapsed_seconds": 4.02, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 29 + ], + [ + "Text", + 26 + ], + [ + "Line", + 15 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00088604" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00088605/EFTA00088605.md b/marker2/ds9/EFTA00088605/EFTA00088605.md new file mode 100644 index 0000000000000000000000000000000000000000..d60bc12227869eedfe9a6f76a29612543710e7a2 --- /dev/null +++ b/marker2/ds9/EFTA00088605/EFTA00088605.md @@ -0,0 +1,254 @@ +UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +THE NEW YORK TIMES COMPANY, • + +Plaintiff, + +-v- + +FEDERAL BUREAU OF PRISONS, + +Defendant. + +X + +20 Civ. 833 (PAE) + +#### REPLY MEMORANDUM OF LAW IN FURTHER SUPPORT OF THE FEDERAL BUREAU OF PRISONS'S MOTION FOR SUMMARY JUDGMENT AND IN OPPOSITION TO PLAINTIFF'S CROSS-MOTION FOR SUMMARY JUDGMENT + +AUDREY STRAUSS Acting United States Attorney Southern District of New York 86 Chambers Street, Third Floor New York, New York 10007 Telephone: (212) 637-2715 Facsimile: (212) 637-2717 + +STEVEN J. KOCHEVAR Assistant United States Attorney — Of Counsel — + +#### TABLE OF CONTENTS + +| | PRELIMINARY STATEMENT | 1 | +|----------|------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------| +| | BACKGROUND | 2 | +| I. | BOP's Productions Since August 5, 2020 | 2 | +| II. | BOP's Withholdings of Returned Records | 3 | +| A. | Withholding of Some Returned Records in Full or in Part Pursuant to Exemption 7(A) | 4 | +| B. | | Withholding of Some Returned Records in Full or in Part Pursuant to Exemption 6 and 7(C) ...4 | +| C. | Withholding of Some Returned Records in Part Pursuant to Exemptions 7(E) and 7(F) | 4 | +| ARGUMENT | | 5 | +| I. | BOP's Withholdings Were Proper | 5 | +| A. | BOP Properly Withheld Records Under Exemption 7(A) | 5 | +| B. | BOP Properly Withheld Records and Information Under Exemptions 6 and 7(C) | 11 | +| C. | BOP Properly Withheld Records and Information Under Exemption 5 | 15 | +| D. | BOP Properly Withheld Information Pursuant to FOIA Exemption 7(E) | 18 | +| | CONCLUSION | 21 | + +### TABLE OF AUTHORITIES + +| Cases ACLU v. DHS, | Page(s) | +|----------------------------------------------------------------------------------|---------| +| 243 F. Supp. 3d 393 (S.D.N.Y. 2017) Albuquerque Pub. Co. v. U.S. Dept ofJustice, | 19 | +| 726 F. Supp. 851 (D.D.C. 1989) | 19 | +| 626 F.3d 678 (2d Cir. 2010) American Civil Liberties Union v. Dep't ofJustice, | 19, 20 | +| 844 F.3d 126 (2d Cir. 2016) Amnesty Int'l USA v. CIA, | 17 | +| 728 F. Supp. 2d 479 (S.D.N.Y. 2010) Associated Press v. U.S. Dep't of Defense, | 6, 17 | +| 554 F.3d 274 (2d Cir. 2009) Bast v. US Dep't of Justice, | 12, 14 | +| 665 F.2d 1252 (D.C. Cir. 1981) | 13 | +| 789 F.2d 64 (D.C. Cir. 1986) | 5 | +| 532 U.S. 1 (2001) DOD v. FLRA, | 17 | +| 510 U.S. 487 (1994) Doherty v. U.S. Dep't of Justice, | 12, 14 | +| 775 F.2d 49 (2d Cir. 1985) | 20 | +| 489 U.S. 749 (1989) Ell v. U.S. Drug Enft Admin., | 13 | +| 878 F.3d 392 (1st Cir. 2017) Elec. Privacy Info. Ctr. v. DHS, | 11, 12 | +| 384 F. Supp. 2d 100 (D.D.C. 2005) EPA v. Mink, | 14 | +| 410 U.S. 73 (1973) Frontier Found. v. U.S Dept of Justice, | 17 | +| 739 F.3d 1 (D.C. Cir. 2014) | 17, 18 | +| 181 F. Supp. 2d 356 (S.D.N.Y. 2002) Halpern v. F.B.I., | 15 | +| 181 F.3d 279 (2d Cir. 1999) Hopkins v. HUD, | 15 | +| 929 F.2d 81 (2d Cir. 1991) | 12 | +| 2015 WL 5459713 (S.D.N.Y. Sept. 16, 2015) | 7, 21 | + +| Jordan v. U.S. Dep't of Justice. See, | | +|---------------------------------------------------------------------------------------------|------------| +| 668 F.3d 1188 (10th Cir 2011) Judicial Watch v. U.S. Dep't of State, | 6 | +| 875 F. Supp. 2d 37 (D.D.C. 2012) Judicial Watch, Inc. v. U.S. Dep't of Commerce, | 14 | +| 337 F. Supp. 2d 146 (D.D.C. 2004) Kimberlin v. DOJ, | 20 | +| 139 F.3d 944 (D.C. Cir. 1998) | 13 | +| 407 F. Supp. 3d 334 (S.D.N.Y. 2019) Kubik v. U.S. Fed. Bureau of Prisons, | 19 | +| No. 10-6078-TC, 2011 WL 2619538 (D. Or. July 1, 2011) N.L.R.B v. Robbins Tire & Rubber Co., | 19 | +| 437 U.S. 214 (1978) Nat? Archives & Records Admin. v. Favish, | 6 | +| 541 U.S. 157 (2004) New York Times Co. v. Dep't of Justice, | 11, 13, 14 | +| No. 14 Civ. 03776 (AT) (SN), 2016 WL 5946711 (S.D.N.Y. Aug. 18, 2016) | 6, 8, 10 | +| 782 F. Supp. 628 (D.D.C. 1991) NYCLU v. DNS, | 12 | +| 771 F. Supp. 2d 289 (S.D.N.Y. 2011) Radcliffe v. IRS, | 19 | +| 536 F. Supp. 2d 423 (S.D.N.Y. 2008) Summers v. DOJ, | 6 | +| No. CV 98-1837(RWR), 2004 WL 7333532 (D.D.C. Apr. 14, 2004) | 14 | + +#### PRELIMINARY STATEMENT + +This case involves records at the core of FOIA Exemption 7(A)—records that could reasonably be expected to interfere with two pending federal criminal prosecutions, one a death penalty case. The Bureau of Prisons ("BOP") properly withheld these records, and plaintiff's arguments to the contrary ignore or mischaracterize the weighty law enforcement interests at issue here. The Government has more than met its burden to articulate a rational link between public disclosure of the records and anticipated interference with the pending criminal cases through the declarations of a supervising prosecutor within the United States Attorney's Office for the Southern District of New York. Plaintiff's opposition fails to meaningfully engage with the substance of these declarations, and instead relies on speculation about how the criminal cases might proceed. The Court should uphold BOP's logical and plausible reliance on Exemption 7(A). + +BOP's reliance on Exemptions 6 and 7(C) to protect images of Epstein's body and the names of his associates was also proper. Epstein's surviving family member retains a privacy interest in the details of Epstein's suicide and images of his remains, and Epstein's associates retain a privacy interest in the Government not disclosing or officially confirming their association with Epstein. On the other side of the Exemption 6 and 7(C) balance, plaintiff fails to identify a significant public interest that is likely to be advanced by release of this information, which would not shed substantial light on how BOP works. + +BOP also properly invoked Exemption 5 and the deliberative process privilege. The portions of the documents withheld as privileged contain predecisional recommendations and discussion about where and how to house Epstein following his apparent suicide attempt in July 2019 and suicide prevention at the MCC more generally. Other documents withheld under Exemption 5 are drafts, which are quintessentially predecisional and deliberative documents. + +BOP's reliance on Exemption 7(E) was also appropriate. The limited portions of documents withheld by BOP on this basis reflect specific aspects of BOP's investigations into Epstein's apparent suicide attempt and suicide. Disclosure of this information could reduce the effectiveness of BOP's investigatory techniques—a point which plaintiff's arguments about the effectiveness of suicide prevention techniques do not meaningfully address. + +For all these reasons, the Court should grant the Government's motion for summary judgment and deny plaintiffs cross-motion. + +#### BACKGROUND + +### I. BOP's Productions Since August 5, 2020 + +The Government respectfully refers the Court to the factual and procedural background provided in the Government's opening brief. See Memorandum of law in Support of the Federal Bureau of Prisons's Motion for Summary Judgment ("BOP MOL"), at 2-4, ECF No. 25.1 The Government provides additional background here to inform the Court of developments since the filing of the Government's opening brief on August 5, 2020. + +Pursuant to an agreement between the parties, BOP continued to produce certain responsive documents after the filing of the Government's opening brief. On August 11, BOP produced 77 additional pages of records to plaintiff, consisting of 5 pages released in full and 72 pages released in part, and on August 31, 2020, BOP produced 351 additional pages of records to plaintiff, consisting of 12 pages released in full and 339 pages released in part. Supplemental Declaration of Kara Christenson ("Supp. Christenson Decl.") 9¶ 5, 7. The bases for withholdings + +Unless otherwise noted, the abbreviations used in this submission have the meaning defined in the Government's August 5, 2020, submission. + +in connection with these productions were set out in the government's opening papers, with the exception of certain redactions plaintiff agreed not to challenge' + +In October 2020, the parties reached an agreement to resolve plaintiff's challenge to the adequacy of BOP's search for records, pursuant to which the Department of Justice Office of the Inspector General ("OIG") returned to BOP electronic copies of records BOP had provided to OIG in connection with the investigation into the circumstances of Epstein's death, after which BOP reviewed these records in response to plaintiff's FOIA requests.' On January 8, 2021, BOP produced 190 pages of records to plaintiff, consisting of 14 pages released in full and 176 pages released in part. BOP withheld in full 387 pages of records among those returned to BOP by OIG (the "Returned Records"), as reflected at Entries 55-60 of the updated index submitted with the Supplemental Christenson Declaration (the "Updated Index"). + +## II. BOP's Withholdings of Returned Records + +The bases for BOP's withholdings in full or in part of certain Returned Records are set out in the Supplemental Declaration of Counsel to the Acting United States Attorney Russell Capone and the Supplemental Declaration of Kara Christenson. The bases for these withholdings are substantially the same as the bases for BOP's prior withholdings, except for certain new bases for withholdings under Exemptions 7(E) and 7(F), related to the security of the MCC, that plaintiff has agreed not to challenge. Accordingly, the review, production, and withholding of the Returned Records have not substantially changed the legal issues to be resolved by the Court. + +The Supplemental Declaration of Nicole McFarland and the Supplemental Declaration of Kara Christenson also correct and clarify certain information discovered or determined since the Government's August 5, 2020, submission. + +3The parties agreed that BOP would not review emails provided to OIG, except for emails to or from Epstein himself while he was at MCC. BOP determined that Epstein did not send or receive emails while he was at MCC, and so did not review emails in its final round of review and production. See Supp. Christenson Decl. 1 8. + +#### A. Withholding of Some Returned Records in Full or in Part Pursuant to Exemption 7(A) + +The Returned Records withheld in full or in part pursuant to Exemption 7(A) were withheld for substantially the same reasons as BOP's prior withholdings under Exemption 7(A), namely that their release could reasonably be expected to interfere with at least one—and for some portions of the withheld records, two—pending criminal cases, as explained in the Government's opening brief. See BOP MOL at 7-12. Specifically, the withheld records include possible exhibits at the Noel trial, information about which witnesses are expected to testify, and information and documents prepared by potential trial witnesses. See Supplemental Declaration of Russell Capone ("Supp. Capone Decl.") ¶¶ 6-14. In addition, information contained in two of the withheld Returned Records relates to the circumstances of Epstein's apparent suicide attempt and could reasonably be expected to interfere with the Tartaglione prosecution. See id. ¶¶ 15-16. + +### B. Withholding of Some Returned Records in Full or in Part Pursuant to Exemption 6 and 7(C) + +Each of the Returned Records withheld in full or in part pursuant to Exemptions 6 and 7(C) were withheld for substantially the same reasons as BOP's prior withholdings under Exemptions 6 and 7(C), namely that their release would constitute a clearly unwarranted invasion under Exemption 6, and, at a minimum, could reasonably be expected to constitute an unwarranted invasion under Exemption 7(C), of the personal privacy of BOP employees, BOP inmates other than Epstein, visitors or senders of funds to BOP inmates, or legal counsel for BOP inmates. See Supp. Christenson DecIll 30-40; BOP MOL at 19-20. + +### C. Withholding of Some Returned Records in Part Pursuant to Exemptions 7(E) and 7(F) + +BOP redacted portions of Returned Records pursuant to Exemptions 7(E) and 7(F), but plaintiff has agreed not to challenge the application of these exemptions to the Returned Records. These exemptions apply to two categories of information in the Returned Records. First, the personal information of certain BOP employees is protected by Exemption 7(F) because release of this information would put BOP employees at risk. See Supp. Christenson Decl. ¶ 48; BOP MOL at 21-22. Plaintiff expressly waived any challenge to this application of Exemption 7(F) in its cross-motion for summary judgment. See Memorandum of Law in Support of Plaintiff's Cross-Motion for Summary Judgment and in Opposition to Defendant's Motion for Summary Judgment ("P. MOL"), at 6 n.2, ECF No. 27. Second, some of the Returned Records contain information that, if released, would jeopardize the security of the MCC. See Supp. Christenson Decl. ¶¶ 42-45, 49-50. Through counsel, plaintiff has agreed not to challenge the applications of Exemptions 7(E) and 7(F) to such information.4 + +Accordingly, the legal issues now ripe for resolution by the Court are essentially the same as those addressed in the Government's and plaintiff's opening briefs, except the issue of the adequacy of the Government's search has been resolved by agreement of the parties. + +## ARGUMENT + +## I. BOP's Withholdings Were Proper + +### A. BOP Properly Withheld Records Under Exemption 7(A) + +BOP properly withheld records in full under Exemption 7(A). The Times's arguments to the contrary mischaracterize the weighty criminal law enforcement concerns at stake as irrational or irrelevant. They are neither. The Government's burden under Exemption 7(A) is not high: the Government need only demonstrate a "rational link" between the requested public disclosure and interference with ongoing or prospective investigations or proceedings. See Crooker v. Bureau of + +4 Through counsel, plaintiff has also agreed not to challenge the application of Exemptions 7(E) and 7(F) to such information in records withheld in full pursuant to Exemption 7(A), namely the records noted at Entries 32 and 49 of the Updated Index. + +Alcohol, Tobacco, and Firearms, 789 F.2d 64, 67 (D.C. Cir. 1986); New York Times Co. v. Dep't ofJustice, No. 14 Civ. 03776 (AT) (SN), 2016 WL 5946711, at \*7 (S.D.N.Y. Aug. 18, 2016) ("NY Times"); Radcliffe v. IRS, 536 F. Supp. 2d 423, 437 (S.D.N.Y. 2008); see also N.L.R.B v. Robbins Tire & Rubber Co., 437 U.S. 214, 236 (1978) (requiring government to establish that "disclosure of particular kinds of investigatory records . . . would generally `interfere with enforcement proceedings'). The Government has gone well beyond this requirement here by submitting two declarations of Russell Capone, a supervising prosecutor and Counsel to the Acting United States Attorney, that logically and plausibly explain how disclosure of the records or portions of records withheld under Exemption 7(A) would interfere with two ongoing prosecutions, one of them a death penalty prosecution. Such records are at the core of what Exemption 7(A) protects. The Times has failed to rebut the Government's showing. + +### i. The Records Were Compiled for Law Enforcement Purposes + +The Government has logically and plausibly established that the records withheld by BOP under Exemption 7 were compiled for law enforcement purposes, thereby satisfying the first prong of the Exemption 7(A) test. See Amnesty Intl USA v. CIA, 728 F. Supp. 2d 479, 525 (S.D.N.Y. 2010); BOP MOL at 8-10. The Times criticizes the Government for arguing that BOP documents—or at least the sort of BOP documents at issue here—should categorically be deemed compiled law enforcement documents because of BOP's institutional role. See P. MOL at 9 n.4. But the Times's fails to engage with the Government's substantive arguments on this point, which are based directly on the decision of the Tenth Circuit in Jordan v. U.S. Dep't of Justice. See 668 F.3d 1188, 1193-97 (10th Cir 2011). Instead, the Times points out (as the Government did) that other Circuits and courts in this Circuit have applied a different, more practical approach. See P. MOL at 9 n.4. But as the Government explained, even if this Court + +does not follow the Tenth Circuit's per se rule and instead applies a more practical approach, the documents at issue were still compiled for law enforcement purposes. See BOP MOL at 8-10. Specifically, the Christenson and Supplemental Christenson declarations explain how the records were compiled to help BOP take "proactive steps designed to prevent criminal activity and maintain security" within the MCC. BOP MOL at 10 (quoting Human Rights Watch v. BOP, No. I3-CV-7360 (JPO), 2015 WL 5459713, at '5 (S.D.N.Y. Sept. 16, 2015)); see BOP MOL at 10 (listing specific purposes of the compilation of the records); see Christensen Decl. ¶ 53; Supp. Christensen Decl. ¶ 29. Plaintiff fails to explain why these purposes would not satisfy the "rational nexus" or "practical" approach plaintiff urges, and so has effectively conceded that, even under its proposed approach, the records at issue here were compiled for law enforcement purposes. See P. MOL at 9. In addition, many of the records at issue were gathered and provided to OIG in connection with a law enforcement investigation into Epstein's death, and thus were compiled for law enforcement purposes. See Supp. Christenson Decl. ¶ 29. + +### ii. Disclosure of the Records Would Interfere with Pending Criminal Proceedings + +BOP properly withheld the Tartaglione Records' under Exemption 7(A). The Capone and Supplemental Capone Declarations explain why release of the Tartaglione Records would interfere with the Tartaglione prosecution, wherein the Government is seeking the death penalty. See Capone Decl. ¶¶ 27-33, Supp. Capone Decl. ¶¶ 15-16. Mr. Capone explained that "information contained in the Tartaglione Records may be relevant evidence in any possible penalty phase of the case against Tartaglione, and as a result, premature public disclosure of the Tartaglione Records could reasonably be expected to influence witness testimony and/or + +5 The Tartaglione Records now include those portions of the two Returned Records withheld pursuant to Exemption 7(A). + +potential jurors' perceptions of witness testimony or evidence." Capone Decl. ¶ 29; see Supp. Capone Decl. ¶¶ 15-16; see also Capone Decl. 1 30 ("Moreover, the nature of the charges against Epstein and the circumstances of his apparent suicide attempt and death create a risk that premature public disclosure of the Tartaglione Records could reasonably be expected to impair the government's (and the defendants') ability to seat a fair and impartial jury in Tartaglione ...."). This is more than sufficient "to trace a rational link between the nature of the document[s] and the alleged likely interference." NY Times, 2016 WL 5946711, at \*7. + +Plaintiff's arguments to the contrary downplay the impact of release of the Tartaglione Records on a federal death penalty prosecution, without any factual basis or evidentiary support. The Court should not credit plaintiff's counsel's speculation about how death penalty prosecutions work over the sworn declaration of a senior prosecutor who supervised the case. Beyond that, plaintiff's arguments miss the point of the Government's position, are wrong, or both. First, plaintiff points out that "[t]he charges against Tartaglione have nothing to do with Epstein," which is correct but irrelevant. P. MOL at 10. As the Capone Declarations explain, release of the Tartaglione Records could reasonably be expected to interfere with any potential penalty-phase hearing required by 18 U.S.C. § 3593 in Tartaglione. Second, plaintiff mischaracterizes the Government's legitimate and reasonable concern about interference with any potential penalty phase of Tartaglione as "convoluted" and "speculation about a possibility" that plaintiff claims would allow BOP to withhold information about conditions of confinement in every case. P. MOL at 11-12. This overlooks that Tartaglione's defense counsel has already put his conditions of confinement, and, specifically, the events of the night of Epstein's apparent suicide attempt, at issue in Tartaglione. See Letter dated January 13, 2020, Dkt. No. 186, United States v. Tartaglione, No. 16 Cr. 832 (KMK); Letter dated January 21, 2020, Dkt. No. 193, + +United States v. Tartaglione, No. 16 Cr. 832 (KMK). Thus, what plaintiff describes as the Government's "theory" here is not convoluted, speculative, nor even a theory: the conditions of Tartaglione's confinement and his interactions with Epstein have already been placed at issue in his criminal case.° Accordingly, the government has met its burden to show that public release of the Tartaglione records could reasonably be expected to interfere with a pending law enforcement proceeding. + +BOP also properly withheld records under Exemption 7(A) that could reasonably be expected to interfere with the prosecutions of Michael Thomas and Tova Noel. The Capone Declarations logically and plausibly explain why these records could reasonably be expected to interfere with Noel, including because they "include information about which numerous witnesses are expected to testify at trial, include details that are not publicly known or known to other witnesses, and include information and documents authored by potential trial witnesses." Capone Decl. ¶ 14; see id. 1 15 (explaining how premature disclosure of the records could reasonably be expected to impair the parties ability to seat an impartial jury); id. 1 16 ("The risks of interference with the Noel proceedings are heightened by the media coverage of speculation and theories about Epstein's death."); Supp. Capone Decl. ¶¶ 6-14. As with the Tartaglione Records, the explanations in the Capone Declarations are more than sufficient "to trace a rational + +6 Plaintiff also argues in a footnote that the Court should disregard the reasonable expectation of interference with a death penalty prosecution because of the voir dire process. See P. MOL at 12 n.7. But the premise of this argument is that release of the Tartaglione Records may in fact interfere with Tartaglione—plaintiff just asks that the Court to rely on the voir dire process to mitigate the harm. Exemption 7(A) precludes disclosure so long as the Government shows (as it has here) a "rational link" between release of records and likely interference; it is irrelevant whether future measures could potentially be taken to mitigate the interference. And it is preferable to avoid potential prejudice altogether than to rely on potential future mitigation measures. In any event, plaintiff's counsel's speculation about how effective the voir dire process might be does not undermine the logic and plausibility of the sworn declaration of one of the senior prosecutors overseeing the case. + +link between the nature of the document[s] and the alleged likely interference." NY Times, 2016 WL 5946711, at \*7. + +Plaintiff's arguments concerning the Noel prosecution are conclusory and without evidentiary basis. Plaintiff speculates that the documents withheld under Exemption 7(A) "bear little relationship to the prosecutions of Noel and Thomas." But this argument simply ignores the Capone Declaration, which logically and plausibly explains the relationship between the documents and those pending criminal cases. Plaintiff also relies on a decision by Judge Torres in Noel, but this decision and subsequent proceedings in that case cut against plaintiff's position. The Government has already disclosed to the Noel defendants, pursuant to a protective order, many of the materials withheld by BOP in this case, including materials that BOP gathered in response to plaintiff's FOIA requests and then turned over to the Government. See Protective Order, United States v. Noel, No. 19-cr-830 (AT) (S.D.N.Y.), Dkt. No. 16; Letter dated January 28, 2020, at 1, United States v. Noel, No. 19-cr-830 (AT) (S.D.N.Y.), Dkt. No. 22; Memorandum of Law of the United States of America in Opposition to Defendant Michael Thomas's Motion to Compel, United States v. Noel, at 8-9, No. 19-cr-830 (AT) (S.D.N.Y.), Dkt. No. 35. The fact that materials at issue have been disclosed to defendants as part of discovery in a criminal proceeding underscores that such materials are indeed potentially relevant to the prosecution and their premature disclosure would interfere with ongoing criminal proceedings. + +Plaintiff's argument that disclosure pursuant to a protective order would foreclose any possible interference with Noel, see P. MOL at 13, incorrectly conflates disclosure to criminal defendants pursuant to a protective order with public disclosure under FOIA. The Capone Declarations explain that public disclosure of the records could reasonably be expected to interfere with Noel, including by "influenc[ing] witnesses' potential testimony at trial," + +"allow[ing] witnesses to alter their testimony to conform to other evidence," and "impair[ing] the government's (and the defendants') ability to seat a fair and impartial jury." Capone Decl. ¶¶ 14, 15; Supp. Capone Dec111 6-7. Disclosure to defendants pursuant to a protective order does not undercut these reasonable expectations of interference. Accordingly, plaintiff fails to rebut the Government's showing of a "rational link" between disclosure of the records and alleged likely interference. The Court should uphold BOP's reliance on Exemption 7(A).7 + +## B. BOP Properly Withheld Records and Information Under Exemptions 6 and 7(O8 + +BOP properly withheld two categories of personal information under FOIA Exemptions 6 and 7(C): details of Epstein's death and images of his body, and the personal information of third-party individuals other than Epstein. For each of these categories, the balancing test under Exemptions 6 and 7(C) weighs in favor of withholding the information at issue. + +With respect to the details of Epstein's death and images of his body, plaintiff dismisses as de minimis the privacy interest of Epstein's brother in not having details and images of his brother's corpse publicly released. This position is contrary to Nat'l Archives & Records Admin. v. Favish, 541 U.S. 157, 165-71 (2004), and lower court decisions that expressly recognize surviving family members' interests in avoiding the public release of details of a family member's death. See Eil v. U.S. Drug Enf't Admin., 878 F.3d 392, 400 (1st Cir. 2017) (protecting + +7 For the records withheld in full by BOP pursuant to Exemption 7(A), as noted on the Updated Index, the Court need not reach the applicability of other exemptions if it concludes that BOP's withholdings under Exemption 7(A) were proper. For each issue discussed below, the Government notes where the Court need not reach an issue if it concludes that BOP's withholdings under Exemption 7(A) were proper. + +If the Court concludes that BOP's withholdings under Exemption 7(A) were proper, it need not reach the issue of whether Exemptions 6 and 7(C) apply to details of Epstein's death and images of his body, but would need to reach the issue of whether Exemptions 6 and 7(C) apply to the personal information of third-party individuals other than Epstein. + +under Exemption 7(C) medical and death-related records that had been admitted as exhibits at criminal trial); New York Times Co. v. Nat'l Aeronautics & Space Admin., 782 F. Supp. 628, 631-32 (D.D.C. 1991) (protecting under Exemption 6 audio recording of Challenger astronauts' final moments). Plaintiff attempts to distinguish Favish by arguing that surviving family members in that case submitted a declaration. But a declaration is not necessary to establish a privacy interest expressly recognized by the Supreme Court and other courts. See Eil, 878 F.3d at 400 (no discussion of declaration); New York Times Co., 782 F. Supp. At 631-32 (same). Indeed, requiring family members to submit public declarations could itself infringe on their privacy. + +An additional flaw in plaintiff's argument regarding the details and images of Epstein's death is the lack of any cognizable public interest in their disclosure. Under Exemptions 6 and 7(C), the "only relevant public interest in disclosure to be weighed in this balance is the extent to which disclosure would ... contribut[e] significantly to public understanding of the operations or activities of the government." DOD v. FLRA, 510 U.S. 487, 495 (1994) (quotation marks omitted); see also Associated Press v. U.S. Dep't of Defense, 554 F.3d 274, 285 (2d Cir. 2009) ("[T]here is only one relevant interest, namely, to open agency action to the light of public scrutiny." (quotation marks omitted)). The records or information themselves must reveal information about government operations or activities. Assoc. Press v. DOD, 554 F.3d 274, 291 (2d Cir. 2009) ("[D]isclosure of information affecting privacy interests is permissible only if the information reveals something directly about the character of a government agency or official" (quoting Hopkins v. HUD, 929 F.2d 81, 88 (2d Cir. 1991))). Plaintiff advances no reason why releasing details of Epstein's death and photos of his body would reveal direct information about BOP's conduct or contribute significantly to an understanding of BOP's operations. The public knows that Epstein committed suicide by hanging himself in his cell at the MCC. Disclosure of + +images of his body and further details of the mechanics of his death would not provide meaningful insight into how BOP works. Cf. Favish, 541 U.S. at 173-74 (requiring requester to "establish more than a bare suspicion in order to obtain disclosure" of information that requester believes would show Government impropriety). Accordingly, FOR Exemptions 6 and & 7(C) protect such information from disclosure. + +Similarly unavailing are plaintiff's arguments that the personal information of third-party individuals that appear on logs and other BOP documents should be disclosed. First, plaintiff's argument that no third parties have privacy interests in nondisclosure of their identities or connection to a high-profile matter, or that release of the records would not cause harm because some individuals have been publicly associated with Epstein in media reports, overlooks the well-established difference between reporting and official Government confirmation of facts, Even if an individual's name has been associated with Epstein in media reports, they still maintain a privacy interest in the government not confirming or further publicizing any association. See Kimberlin v. DOJ, 139 F.3d 944, 949 (D.C. Cir. 1998); Bast v. U.S Dep't of Justice, 665 F.2d 1252, 1255 (D.C. Cir. 1981); see also DOJ v. Reporters Comm. for Freedom of the Press, 489 U.S. 749, 771 (1989) (finding that individuals retain substantial privacy interests in criminal rap sheet information, even though the criminal convictions reflected in the rap sheets are already public). Moreover, contrary to plaintiff's assertion, without citing any authority, that the "privacy interest in nondisclosure is fixed," P. MOL at 17 n.11, the high-profile nature and substantial media coverage of Epstein's death heightens the third-party individuals' privacy interests in avoiding public disclosure of their names under Exemptions 6 and 7(C). See + +9 Defendants' argument appears to concede that individuals whose association with Epstein is not publicly known have a substantial privacy interest in such an association not being publicized. + +Summers v. Dal, No. CV 98-1837(RWR), 2004 WL 7333532, at \*4 (D.D.C. Apr. 14, 2004). The potential intrusion on privacy interests is particularly acute in these circumstances. See Judicial Watch v. U.S. Dep't of State, 875 F. Supp. 2d 37, 47 (D.D.C. 2012) (finding a substantial privacy interest where there was an articulable risk of media scrutiny and harassment) (citing Elec. Privacy Info. Ctr. v. DHS, 384 F. Supp. 2d 100, 118 (D.D.C. 2005)). + +Second, plaintiff again fails to explain how the specific information at issue—the names and contact information of third-party individuals who called, visited, or transferred funds to Epstein or were approved to do so—would shed any direct or significant light on "the operations or activities of the government." DOD v. FLRA, 510 U.S. at 495; see Associated Press, 554 F.3d at 285. The names and contact information of the third-party individuals who interacted with Epstein while he was incarcerated do not bear on BOP operations. While plaintiff lists various aspects of BOP operations that information about Epstein's incarceration might shed light upon—such as whether Epstein was afforded special treatment, see P. MOL at 17—plaintiff does not connect these aspects of GOP's operations with third-party names and identifring information, which is the information actually at issue here. For example, it is not clear how the names of Epstein's visitors or transferors of funds could show whether or not he was afforded special treatment. To take another example, plaintiff argues that release of the names would show "whether BOP were effectively screening visitors who might represent a threat or assist in further criminal acts by Epstein or on behalf of him." P. MOL at 17. A premise of this argument—for which plaintiff does not provide any evidentiary basis-is that a visit to Epstein implies criminality, or that criminality could somehow be inferred from the release of a thirdparty name. This is too speculative and attenuated theory on which to rest an actual public interest in this case. See Favish, 541 U.S. at 159 ("[W]here there is a privacy interest protected + +by Exemption 7(C) and the public interest asserted is to show that responsible officials acted negligently or otherwise improperly in performing their duties, the requester must produce evidence that would warrant a belief by a reasonable person that the alleged Government impropriety might have occurred."). The identities of Epstein's associates may be newsworthy, but, if so, it is not because they shed any light on government operations, the only relevant public interest in the analysis under Exemptions 6 and 7(A). And to the extent plaintiff suggests that disclosure would suggest or imply some sort of impropriety or criminality on the part of the visitor, that would only heighten that individual's privacy interest in avoiding public disclosure of his or her name and contact information. See Halpern v. F.B.I., 181 F.3d 279, 297 (2d Cir. 1999) (describing privacy interests of third parties "insofar as the material in question demonstrates or suggests they had at one time been subject to criminal investigation"); Garcia v. U.S. Dept of Justice, Office of Information and Privacy, 181 F. Supp. 2d 356, 371 (S.D.N.Y. 2002) (collecting cases) ("Case law has identified a number of potential adverse results related to the disclosure of the identities of individuals who appear in documents compiled for law enforcement purposes, concluding that the privacy interests of such individuals must weigh heavily against disclosure."). + +Contrary to plaintiff's arguments, there are substantial privacy interests in the records and information BOP has withheld under Exemptions 6 and 7(C), and the information sheds little if any light on how the BOP works. Accordingly, the balancing test weighs in favor of nondisclosure, and BOP properly applied Exemptions 6 and 7(C). + +# C. BOP Properly Withheld Records and Information Under Exemption 510 + +I° If the Court concludes that GOP's withholdings under Exemption 7(A) were proper, then the Court need not reach the issue of GOP's withholdings pursuant to Exemption 5, except for two pages of draft letters withheld in full, noted at Entry 11 of the Updated Index, and a relatively small number of redactions pursuant to Exemption 5 on records released by BOP in part. In light of this, the parties respectfully request that, in the event the Court concludes that GOP's + +BOP has properly withheld some records and information under Exemption 5. The government's opening brief identified four sets of decisions and related predecisional documents falling within the scope of Exemption 5. See BOP MOL at 14-16. Plaintiff does not meaningfully challenge the withholding of draft letters or records pertaining to press inquiries under Exemption 5. See generally P. MOL; BOP MOL at 15-16 (setting out the third (draft letters) and fourth (press inquiries) categories of Exemption 5 materials)." Plaintiff only challenges the withholding under Exemption 5 of "documents pertaining to where and how Epstein was housed and how Epstein died." P. MOL at 18. + +Portions of the psychological reconstruction prepared following Epstein's death (withheld in full under Exemption 7(A)), as well as the portions of other documents BOP withheld in part under Exemption 5, contain material protected by the deliberative process privilege.' These documents contain predecisional recommendations and discussion of suicide prevention measures at MCC, as well as (in the case of certain emails) deliberations about where + +withholdings under Exemption 7(A) were proper, the parties meet and confer and then inform the Court whether it will be necessary for the Court to adjudicate any withholdings pursuant to Exemption 5 and propose a schedule for any additional submissions, if necessary. + +&quot; Plaintiff's submission briefly mentions the press inquiries, but only the context of its broader arguments challenging BOP's assertion of the deliberative process privilege in connection with decisionmaking about where and how Epstein was housed and how he died. See Opp. MOL at 19. But this does not address BOP's decisionmaking about whether and how to respond to press inquiries concerning Epstein and his death. See BOP MOL at 15-16. + +12 BOP has re-reviewed certain records it previously withheld in full under Exemption 5. As a result of this re-review, BOP has withdrawn its assertion of Exemption 5 as to the (1) incident report from Epstein's apparent suicide attempt, (2) the final version of the response to the psychological reconstruction prepared following Epstein's death, and (3) five pages consisting of a timeline of events that were included within the responses to the psychological reconstruction prepared following Epstein's death. These records are still withheld in full under Exemption 7(A). + +and how to house Epstein following his apparent suicide attempt in July 2019. See Christenson Decl. ¶¶ 49(b), (d), (f). Such predecisional recommendations and deliberations are protected by the deliberative process privilege. See Dep't of Interior v. Klamath Water Users Protective Ass'n, 532 U.S. I, 8 (2001) ("[D]eliberative process covers documents reflecting advisory opinions, recommendations and deliberations comprising part of a process by which governmental decisions and policies are formulated." (quotation marks and citation omitted)). In addition, many of the pages reflecting responses to the psychological reconstruction prepared following Epstein's death are essentially drafts: they contain comments from various authors and offices within BOP in versions of the document before it was finalized. See Supp. Christenson Decl. ¶ 16. These prior versions of the ultimate response document were properly withheld under Exemption 5 as drafts. See American Civil Liberties Union v. Dep't ofJustice, 844 F.3d 126, 133 (2d Cir. 2016); Amnesty Int'l USA v. CIA, 728 F. Supp. 2d 479, 518 (S.D.N.Y. 2010) ("It is wellsettled that draft document, by their very nature, are typically predecisional and deliberative." (quotation marks and alteration omitted)). + +BOP has also reasonably explained how release of deliberative materials would harm its operations and decisionmaking. The Christenson Declaration explains that disclosure would harm interests protected by Exemption 5 primarily by hampering the ability of BOP employees to frankly discuss and assess conditions and incidents at BOP facilities, as well as related BOP policies. See Christenson Decl. ¶ 49. Plaintiff dismisses BOP's explanations out of hand as boilerplate, see P. MOL at 20, but this anticipated harm is entirely logical and plausible, and it relates directly to the purpose of the deliberative process privilege to "protect[] agencies from being 'forced to operate in a fishbowl.'" Elect. Frontier Found. v. U.S. Dept of Justice, 739 F.3d I, 7 (D.C. Cir. 2014) (quoting EPA v. Mink, 410 U.S. 73, 87 (1973)). Accordingly, BOP's + +reasonable explanations are closely tethered to the purpose of Exemption 5 and indeed are similar in kind and specificity to anticipated harms the D.C. Circuit has held support withholdings under Exemption 5. See Elec. Frontier Found., 739 F.3d at 6, 13. + +## D. BOP Properly Withheld Information Pursuant to FOIA Exemption 7(E)" + +Plaintiff's arguments challenging GOP's withholdings under Exemption 7(E) fail to engage with the reasons BOP has withheld certain portions of documents, and instead focus on publicly available methods of preventing suicides. The withheld information involves techniques and procedures for how BOP investigates suicides and suicide attempts, including particular observations and investigative steps taken by BOP in response to Epstein's apparent suicide attempt and suicide. + +BOP properly withheld portions of eight documents14 (all separately withheld in full pursuant to Exemption 7(A)) because they would disclose particular investigative steps, actions, and observations BOP staff made in investigating Epstein's apparent suicide attempt and suicide. Such documents include forms used by BOP as part of its investigation (such as a Form 583 and a chain of custody form) and memoranda and reports prepared by BOP employees following + +If the Court concludes that GOP's withholdings under Exemption 7(A) were proper, then the Court need not reach the issue of GOP's withholdings pursuant to Exemption 7(E), except for a relatively small number of redactions pursuant to Exemption 7(E) on records released by BOP in part. In light of this, the parties respectfully request that, in the event the Court concludes that GOP's withholdings under Exemption 7(A) were proper, the parties meet and confer and then inform the Court whether it will be necessary for the Court to adjudicate any redactions pursuant to Exemption 7(E) on records released in part and propose a schedule for any additional submissions, if necessary. + +14 BOP has re-reviewed certain documents it previously withheld in full under Exemption 7(E), and now asserts Exemption 7(E) only as to discrete portions of some of those documents. Specifically, BOP has withdrawn its assertion of Exemption 7(E) as to the MCC New York Updates document or photo sheets. BOP continues to assert Exemption 7(E) in part as to the records reflected at Entries I, 2, 9, 12, 13, 15, 17, and 18 of the Updated Index. + +Epstein's suicide attempt that discuss steps taken immediately following Epstein's apparent suicide attempt and results of steps taken during the subsequent investigation. Exemption 7(E) applies to portions of these records because they contain non-public information that would reveal specific details about the application of law enforcement techniques and procedures protected by Exemption 7(E). Supp. Christenson Decl. ¶¶ 17-25. + +"[A] `technique' is `a technical method of accomplishing a desired aim' and a `procedure' is `a particular way of doing or going about the accomplishment of something.'" ACLU v. DHS, 243 F. Supp. 3d 393, 402 (S.D.N.Y. 2017) (quoting Allard K. Lowenstein Int'l Human Rights Project v. Dep't of Homeland Sec., 626 F.3d 678, 682 (2d Cir. 2010)); see NYCLU v. DHS, 771 F. Supp. 2d 289, 292 (S.D.N.Y. 2011) (upholding application of 7(E) over specific details of use of cameras and license plate readers, even though such use of such items was generally known). Here, for example, certain of the reports prepared during the course of BOP's investigation include Security Threat Group ("STG") designations, which are an enhanced monitoring technique used by BOP. See Supp. Christenson Decl. ¶¶ 20, 23. As another example, the August 14, 2019 letter withheld by BOP contains details of the After Action Review Team formed to investigate Epstein's suicide, which would disclose non-public law enforcement techniques and procedures employed by BOP.15 See id. ¶ 22. + +15 The cases plaintiff cites to the contrary are not on point. ACLU and Knight First Amendment Institute at Columbia Univ. v. U. S. Dep't of Homeland Security, 407 F. Supp. 3d 334 (S.D.N.Y. 2019), appeal filed, No. 20-3837, rejected questions (or questions or answers) asked of groups of individuals in the immigration context as techniques. Albuquerque Pub. Co. v. U.S. Dep't of Justice, 726 F. Supp. 851 (D.D.C. 1989), rejected general descriptions of wiretapping and related surveillance methods as too publicly known. Kubik v. U.S. Fed. Bureau of Prisons, No. 10-6078- TC, 2011 WL 2619538 (D. Or. July 1, 2011), rejected the withholding of a video of a prison riot and discussions of prison guards' tactics in a report prepared following the riot essentially because the contents of the video and the tactics used during the riot were already public. None of these cases involves the disclosure of specific investigatory steps taken in response to a specific incident, the details of which are not publicly known. + +Plaintiff's arguments about the public availability of documents pertaining to suicide prevention and the techniques described therein miss the point of BOP's Exemption 7(E) withholdings. The techniques and procedures embodied in the records at issue here are not suicide prevention techniques, but investigatory techniques deployed in response to a specific suicide attempt and suicide that exemplify how BOP investigates such incidents in federal prisons. See, e.g., Supp. Christenson Decl.11 18-25. Plaintiff fails to establish that the investigatory techniques at issue and their specific application here are publicly known, even if the suicide prevention techniques it describes are publicly known. See P. MOL at 21-22. + +Second, even if plaintiff had established that the techniques and procedures at issue were publicly known as a general matter, BOP has shown that the withheld information regarding their application in this particular context could reduce or nullify their effectiveness. While Exemption 7(E) generally covers only "investigatory records that disclose investigative techniques and procedures not generally known to the public," Doherty v. U.S. Dep't of Justice, 775 F.2d 49, 52 n.4 (2d Cir. 1985), "even commonly known procedures may be protected from disclosure if the disclosure could reduce or nullify their effectiveness," Judicial Watch, Inc. v. U.S. Dep't of Commerce, 337 F. Supp. 2d 146, 181 (D.D.C. 2004). Although an agency need not show a risk of circumvention of the law in order to justify withholding of law enforcement techniques or procedures under Exemption 7(E), see Allard K. Lowenstein Int'l Human Rights Project, 626 F.3d at 681-82, BOP has explained that releasing the information contained in the Exemption 7(E) records at issue here would in fact make it easier for inmates to circumvent BOP's investigatory techniques and procedures. See Supp. Christenson Dec1.111 18-25. The disclosure of these investigatory techniques and their use in the context of specific incidents at BOP facilities is simply not the same as disclosure of the general suicide prevention techniques + +identified by plaintiff, such as double-ceiling. See P. MOL at 22. In particular, BOP has withheld information regarding STG designations, steps taken in response to an inmate emergency in the Special Housing Unit, sources typically relied upon and information-gathering steps taken in investigating incidents at the MCC, details about how BOP After Action Review teams conduct their work, and information about where evidence is stored. See Supp. Christenson Decl. q¶ 18- 25; see also, e.g., Human Rights Watch, 2015 WL 5459713, at \*6 (concluding that "the conduct giving rise to STG status is `investigative in nature' although not reaching Exemption 7(E) as a basis for its decision to uphold the withholding of STG information). Accordingly, the government has carried its burden here to properly invoke Exemption 7(E). + +### CONCLUSION + +For the foregoing reasons, the Court should grant the government's motion for summary judgment and deny plaintiff's cross-motion for summary judgment. + +Dated: New York, New York January 15, 2021 + +Respectfully submitted, + +AUDREY STRAUSS Acting United States Attorney for the Southern District of New York Counsel for Defendant + +By: + +![](_page_24_Picture_8.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00088605/EFTA00088605.metadata.json b/marker2/ds9/EFTA00088605/EFTA00088605.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..4cbed0abfb024ac69fc9d3fef01db2208fe52732 --- /dev/null +++ b/marker2/ds9/EFTA00088605/EFTA00088605.metadata.json @@ -0,0 +1,1418 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00088605.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 25, + "chars": 52009, + "elapsed_seconds": 3.09, + "image_assets": [ + "_page_24_Picture_8.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "REPLY MEMORANDUM OF LAW IN FURTHER SUPPORT OF THE FEDERAL \nBUREAU OF PRISONS'S MOTION FOR SUMMARY JUDGMENT AND IN \nOPPOSITION TO PLAINTIFF'S CROSS-MOTION FOR SUMMARY JUDGMENT", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 88.12799999999999, + 315.09000000000003 + ], + [ + 524.636474609375, + 315.09000000000003 + ], + [ + 524.636474609375, + 356.9830322265625 + ], + [ + 88.12799999999999, + 356.9830322265625 + ] + ] + }, + { + "title": "TABLE OF CONTENTS", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 236.232, + 87.48 + ], + [ + 372.2944030761719, + 87.48 + ], + [ + 372.2944030761719, + 101.72406005859375 + ], + [ + 236.232, + 101.72406005859375 + ] + ] + }, + { + "title": "TABLE OF AUTHORITIES", + "heading_level": null, + "page_id": 2, + "polygon": [ + [ + 228.88800000000003, + 71.28 + ], + [ + 383.57696533203125, + 71.28 + ], + [ + 383.57696533203125, + 86.103515625 + ], + [ + 228.88800000000003, + 86.103515625 + ] + ] + }, + { + "title": "PRELIMINARY STATEMENT", + "heading_level": null, + "page_id": 4, + "polygon": [ + [ + 219.70799999999997, + 72.08999999999999 + ], + [ + 391.9075622558594, + 72.08999999999999 + ], + [ + 391.9075622558594, + 86.103515625 + ], + [ + 219.70799999999997, + 86.103515625 + ] + ] + }, + { + "title": "BACKGROUND", + "heading_level": null, + "page_id": 5, + "polygon": [ + [ + 258.876, + 319.95000000000005 + ], + [ + 352.65252685546875, + 319.95000000000005 + ], + [ + 352.65252685546875, + 333.9735412597656 + ], + [ + 258.876, + 333.9735412597656 + ] + ] + }, + { + "title": "I. 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+THE NEW YORK TIMES COMPANY, + +Plaintiff, + +No. 20-CV-833 (PAE) + +v. + +FEDERAL BUREAU OF PRISONS. + +Defendant. + +## SUPPLEMENTAL DECLARATION OF KARA CHRISTENSON + +I. I am employed by the United States Department of Justice, Federal Bureau of Prisons ("BOP"), as a Government Information Specialist ("GIS") for Central Office, stationed at the Federal Medical Center in Rochester, Minnesota ("FMC Rochester"). My background and employment history with BOP are described in my declaration filed in this matter on August 5, 2020. + +2. The statements made in this declaration are based upon my personal knowledge and information available to me in my official capacity and about which I have become knowledgeable. + +3. I submit this supplemental declaration in further support of BOP's motion for summary judgment in this case and in opposition to plaintiffs' cross-motion for summary judgment. + +4. Plaintiffs have raised the issue of whether BOP received FOIA requests for video footage before plaintiffs' own request on August 12, 2020. BOP received a separate FOIA + +request (not from plaintiffs) for Metropolitan Correctional Center video records dated August 10, 2019, the same day BOP turned over the video records to the Federal Bureau of Investigation, and this request was logged on August 12, 2019. + +### BOP 's Productions Since August 5, 2020 + +5. On August 11, 2020, BOP produced 77 additional pages of records to plaintiffs, consisting of 5 pages released in full and 72 pages released in part. These pages included approximately 57 pages of various log books pertaining to Epstein, including approximately 51 pages of attorney log books showing attorney visits to Epstein. In connection with the GOP's releases of pages of log books, I need to make a correction to my declaration filed on August 5, 2020. In that declaration at Paragraph 22, I stated that BOP had located two pages of scanned visitor logs, which it was reviewing and intended to release in part. Instead, BOP located approximately 51 pages of copies of scanned attorney log books showing attorney visits to Epstein, which it released to plaintiffs with appropriate redactions. + +6. Relatedly, at Paragraph 39 of my declaration filed on August 5, 2020, I inadvertently stated that BOP had located and produced with redactions a page from a log showing a visitor for Epstein on July 30, 2019. In fact, the page (copied onto two pages) that was produced to plaintiffs with redactions came from an Intake Screening Phone Log showing that Epstein made a phone call on July 30, 2019, not that he received a visit on that date. BOP did not produce the cover to this log because it does not refer to Epstein and is non-responsive. Because the log book showed a phone call, rather than a visit, Paragraph 36 of my declaration filed on August 5, 2020, should be modified to state that BOP also located one physical log book, the Intake Screening Phone Log, showing a call made by Epstein on July 30, 2019. + +7. On August 31, 2020, BOP produced 351 additional pages of records to plaintiffs, consisting of 12 pages released in full and 339 pages released in part. These pages included the + +approximately 51 pages of attorney log books, showing attorney visits to Epstein, as attachments to email records. + +8. In October 2020, BOP reached an agreement with plaintiffs, through counsel, pursuant to which the Office of Inspector General of the United States Department of Justice ("OIG") would produce back to BOP certain records BOP had produced to OIG in connection with investigations into Epstein's death, and that BOP would review these records in response to plaintiffs' FOIA request. BOP subsequently reached a further agreement with plaintiffs, through counsel, that it would not review emails records in OIG's possession, except for emails to or from Epstein himself while he was at MCC. BOP has determined that Epstein did not send or receive any emails himself while he was at MCC. Specifically, any email sent or received by Epstein while he was at MCC would be logged in GOP's Trulincs system, and Trulincs shows that Epstein did not send or receive any emails while he was at MCC. Accordingly, BOP did not review the email records in OIG's possession. + +9. BOP received approximately 7,475 pages of records back from OIG, not including emails. I reviewed these pages and determined that approximately 6,898 were nonresponsive or duplicative of records previously reviewed by BOP. Of the remaining pages (the "Returned Records"), BOP withheld 387 pages in full, pursuant to Exemptions 6, 7(C), and/or 7(A). On January 8, 2021, BOP produced the remaining 190 pages of records to plaintiffs, consisting of 14 pages released in full and 176 pages released in part. These pages included 8 pages of records that BOP had previously withheld in full pursuant to Exemption 7(A), but that BOP has since determined in consultation with the United States Attorney's Office for the Southern District of New York could be released with certain redactions. + +# BOP's Updated Index + +10. Attached as Exhibit 1 to this declaration is an updated index of records withheld in full by BOP in this case (the "Updated Index"). The Updated Index includes certain changes and additions to the Index submitted as Exhibit 8 to my declaration submitted on August 5, 2020 (the "Original Index"). + +II. The Updated Index reduces the number of pages of count documents noted as withheld at Entry 24 by 18 pages. These 18 pages consist of an inmate census roster dated August 9, 2019, containing Epstein's name and the names of other inmates held at MCC. Two of the 18 eighteen pages, including the page showing Epstein's name, were released in part to plaintiffs.' The remaining 16 pages were withheld in full under Exemptions 6 and 7(C) and are now included at Entry 59 of the Updated Index, along with pages of other inmate census rosters for other dates. + +12. The Updated Index omits two entries of the Original Index, Entries 34 and 37, consisting of records from the MCC's Special Housing Unit (the "SHU") that BOP determined could be released in part, with redactions pursuant to Exemptions 6, 7(A), and 7(C), instead of withheld in full pursuant to Exemption 7(A).2 The Updated Index also omits Entry 54, consisting + +&#x27; The first, cover page of this inmate census roster, as received from BOP, appears to have barely legible handwriting on it. BOP located a copy of this pages with the handwriting moderately more visible among its previously withheld records. BOP released the version returned by OIG with the barely legible handwriting and would have redacted the handwriting pursuant to Exemptions, 6, 7(C), 7(E), and/or 7(F) had it released the more legible version. This census inmate roster does not appear to specifically concern Epstein (apart from his appearance on one page of the roster, which was released in part), and the handwriting does not appear to relate to Epstein but instead appears to relate to counting of inmates. + +2 Of the three pages noted at Entry 37 of the Original Index, two pages were duplicates, with handwritten notes on one of the pages. Because those portions of the page were redacted, only one copy of these two pages were released in part to plaintiffs. The redacted portions and the handwritten portions do not appear to relate to Epstein. In addition, the four pages noted at Entry 34 of the Original Index had also been counted in the pages noted at Entry 22, and the page count noted at Entry 22 of the Updated Index has been reduced accordingly. + +of emails withheld under Exemption 5 and the attorney-client privilege, because plaintiff is not challenging the withholding of these records. + +13. Entry 19 of the Updated Index includes 12 pages of Epstein's medical records, withheld in full under Exemption 7(A), and in part under Exemption 6 and 7(C). On August 31, 2020, after I submitted my previous declaration, BOP produced 88 pages of Epstein's medical records, but withheld in full 12 pages for reasons explained at Paragraph 20 of the August 5, 2020, declaration of Counsel to the Acting United States Attorney Russell Capone. + +14. The Updated Index corrects an inadvertent error that resulted in double counting of seventeen pages of emails listed at Entry 52 and twenty-nine pages of emails listed at Entry 53. + +# BOP 's Assertions of Exemptions 5 and 7(E) Over Documents Previously Withheld in Full + +15. The Updated Index clarifies that BOP is not asserting Exemptions 5 or 7(E) as a basis to withhold certain documents in full. BOP has conducted a further review of certain records that previously were withheld in full pursuant to Exemptions 5 and/or 7(E), in addition to Exemption 7(A). As a result of that further review, and as reflected on the Updated Index, BOP is withdrawing its assertion of Exemption 5 as a basis to withhold in full Entries 1, 2, and 12. BOP continues to assert Exemption 5 as a basis to withhold portions of Entries 2 and 12 for the reasons explained in my prior declaration, but not Entry 1, as reflected on the Updated Index. All of these documents are separately withheld in full pursuant to Exemption 7(A). + +16. With respect to the responses to the psychological reconstruction prepared after Epstein's death, listed at Entry 12 on the Updated Index, the majority of the pages withheld are drafts, containing comments from various perspectives within BOP on versions of the document preceding its final version. Five pages of the responses to the psychological reconstruction + +prepared after Epstein's death consist of a timeline of events, over which BOP is no longer asserting Exemption 5. + +17. As a result of its further review, BOP is no longer asserting Exemption 7(E) to withhold any document in full. Specifically, and as reflected on the Updated Index, BOP is withdrawing its assertion of Exemption 7(E) as a basis to withhold in full Entries 2, 9, 10, 12, 13, 15, 17, 18, and 36. As reflected on the Updated Index, BOP continues to assert Exemption 7(E) as to non-public information in these documents that would reveal investigatory techniques and procedures or the specific application thereof, except for Entries 10 and 36, over which BOP no longer asserts Exemption 7(E). All of these documents are separately withheld in full pursuant to Exemption 7(A). + +18. BOP is asserting Exemption 7(E) to protect information in the incident report, listed at Entry 1 on the Updated Index, which would reveal specific steps taken in responding to an inmate emergency in the Special Housing Unit. Releasing this type of information would allow inmates to learn the manner in which MCC staff are likely to respond to emergencies and potentially interfere with staff's ability to manage emergency situations. + +19. BOP is asserting Exemption 7(E) to protect information in the psychological reconstruction of inmate death, listed at Entry 2 on the Updated Index, which would reveal particular sources of information that such investigations typically rely on or seek to rely on. Specifically, it discusses how the availability or lack thereof of specific sources of information affected an investigation, as well as typical sources routinely relied upon. Because of the specific constraints under which investigations must proceed in the correctional facility setting, identification of sources that are typically relied upon or that are unavailable or relied upon in a specific instance are part of BOP investigatory plans and response, and disclosure of sources that were unavailable or relied upon or typical sources relied upon could hamper GOP's ability to + +conduct investigations in the future by alerting staff and/or inmates to such sources and allowing them to take steps to interfere with sources or evidence. + +20. BOP is asserting Exemption 7(E) to protect information in the inmate investigative report, listed at Entry 9 on the Updated Index, regarding the use of Security Threat Group ("STG") designations. STG is an enhanced monitoring technique used to maintain balanced prison populations in an effort to protect the safety and security of staff and inmates. Inmates are generally not aware of their placement in an STG, and only certain inmates are assigned an STG. Not every inmate has an STG assignment. BOP is also asserting Exemption 7(E) to protect information in the inmate investigative report concerning specific steps taken in responding to an inmate emergency in the Special Housing Unit. Releasing this type of information would provide an opportunity for inmates to learn the manner in which staff are likely to respond to emergencies and potentially interfere with staff's ability to manage emergency situations. + +21. BOP is asserting Exemption 7(E) to protect information in the responses to the psychological reconstruction prepared following Epstein's death, listed at Entry 12 on the Updated Index, which would reveal specific steps taken in responding to an inmate emergency in the Special Housing Unit. Releasing this type of information would provide an opportunity for inmates to learn the manner in which staff are likely to respond to emergencies and potentially interfere with staff's ability to manage emergency situations. + +22. BOP is asserting Exemption 7(E) to protect information in an August 14, 2019, letter, listed at Entry 13 on the Updated Index, that would reveal details about how a BOP team investigating an incident, known as an After Action Review Team, conducts an investigation, and the access it requires to BOP facilities to complete its work. Release of these details would alert staff to systems and information reviewed as part of an investigation and could lead to + +attempts to distort, delete, or otherwise manipulate details and data relevant to an investigation. Release of the names of members of the After Action Review Team, contained in the August 14, 2019 letter, would also disclose law enforcement techniques and procedures because the manner in which team members are selected, the positions they hold, and the locations from which they were chosen and deployed are critical considerations in the assembly of an After Action Review Team. Withholding the names of team members protects the investigative process by ensuring staff are not aware of who is deemed an appropriate team member and reducing the opportunity to attempt to influence the investigation of an event. + +23. BOP is asserting Exemption 7(E) to protect information in a memorandum and report from Epstein's July 23, 2019 apparent suicide attempt (Form 583), listed at Entry 15 on the Updated Index, regarding the use of STG designations, for the reasons stated above with regard to the inmate investigation report. BOP is also asserting Exemption 7(E) to protect certain information in the memorandum and report from Epstein's July 23, 2019 attempt (Form 583) that was obtained from witnesses. In any investigation, identifying witnesses and how an interview is conducted, including questions and responses, are critical components of the investigatory techniques of security staff of the BOP, especially in a correctional setting where there are often multiple witnesses and the correctional setting poses a significant risk of contamination or influence of witness by other witnesses and/or other inmates. The investigative techniques involved include what witnesses to interview and what procedures must be undertaken to ensure the greatest cooperation by the witness during any interview. Witnesses to an event might influence each other if they are not separated before any interactions or conversations occur between them. In this sense, the investigative techniques, in a correctional setting, include strategic decisions that account for the secure and orderly operations of the correctional facilities to ensure inmate and staff safety is not put in jeopardy. Disclosure of this + +information in the memorandum and report would reveal how the information was gathered and could provide an opportunity for inmates to manipulate victims or witnesses to an incident in an effort to improperly influence an investigation. + +24. BOP is asserting Exemption 7(E) to protect information in a chain of custody form, listed at Entry 17 on the Updated Index, about where evidence is stored. Release of this information could provide an opportunity for staff to manipulate evidence or the staff responsible for controlling it. + +25. BOP is asserting Exemption 7(E) to protect information in the reports of Epstein's July 23, 2019, apparent suicide attempt, listed at Entry 18 on the Updated Index, regarding specific procedures, including notification processes, used in an inmate emergency in the Special Housing Unit. Releasing this type of information would provide an opportunity for inmates to learn the manner in which staff are likely to respond to emergencies and potentially interfere with staff's ability to manage emergency situations. + +# Application of Exemptions to the Returned Records + +26. The Updated Index identifies at Entries 55-61 the pages of the Returned Records withheld in full by BOP. All of the Returned Records withheld in full by BOP are withheld under FOIA Exemption 7(A), except for the 2 pages of records showing transferors of funds to Epstein noted at Entry 58 of the Updated Index and the 274 pages of inmate census rosters at Entry 59 of the Updated Index, which are withheld under Exemption 6 and 7(C) and discussed below. The basis for withholdings of Returned Records under Exemption 7(A) is explained in the accompanying supplemental declaration of Counsel to the Acting United States Attorney Russell Capone. In addition to the withholdings in full under Exemptions 6, 7(A), and 7(C), BOP has also withheld certain portions of Returned Records under Exemptions 6, 7(A), 7(C), 7(E), and 7(F). + +#### Threshold Justification for Application of Exemption 7 + +27. As a threshold to applying Exemption 7, an agency has to demonstrate that the "records or information [were] compiled for law enforcement purposes." 5 U.S.C. §552(b)(7). + +28. As explained at Paragraphs 51-53 of my previous declaration, the BOP is a law enforcement agency. + +29. All of the Returned Records were compiled for law enforcement-purposes because they were compiled in the exercise of BOP's statutory authority to detain certain individuals. All of these records relate to BOP's operations and were compiled in order to carry out BOP's responsibilities to protect the safety, security, and orderly operation of BOP facilities, specifically MCC New York, to protect the public, and/or to protect the safety and care of inmates at MCC New York, including Epstein. In addition, as with many of the records previously withheld in this matter, the Returned Records were gathered and provided to OIG in connection with a law enforcement investigation of Epstein's death. The records at issue in this FOIA request meet the law enforcement threshold of Exemption (b)(7). + +# Records Withheld Pursuant to Exemptions 6 and 7(C) + +30. 5 U.S.C. § 552(bX6) ("FOIA Exemption 6") protects from disclosure "personnel and medical files and similar files the disclosure of which would constitute a clearly unwarranted invasion of personal privacy." 5 U.S.C. § 552(b)(6). + +31. 5 U.S.C. § 552(bX7)(C) ("Exemption 7(C)") exempts from disclosure records or information compiled for law enforcement purposes where its disclosure "could reasonably be expected to constitute an unwarranted invasion of personal privacy." 5 U.S.C. § 552(b)(7)(C). + +32. Some of the Returned Records withheld by BOP contain personal information withheld under Exemptions 6 and 7(C) (the "6 & 7(C) Returned Records"). The 6 & 7(C) Returned Records include personnel files within the meaning of Exemption 6, such as daily + +assignment rosters for the MCC. The remainder of the 6 & 7(C) Returned Records are "similar files" within the meaning of Exemption 6 because they contain information about particular, identifiable individuals. This information includes personally identifying information, such as names and contact information, of various third-party individuals other than Epstein. + +33. Exemptions 6 and 7(C) each require a balancing of the privacy interests implicated by disclosure of a record with the public interest in its disclosure. The privacy interests implicated by the 6 & 7(C) Returned Records include the privacy interests of BOP employees, BOP inmates other than Epstein, visitors or senders of funds to BOP inmates, and legal counsel for BOP inmates. The 6 & 7(C) Returned Records contain personally identifying information, such as names and contact information, for each of these categories of individuals and for some individuals detail their association with Epstein or their involvement in Epstein's incarceration. Release of this information—particularly in light of the intense media interest in and public speculation concerning Epstein's death—could reasonably be expected to expose these third parties to unwanted scrutiny, embarrassment, and even harassment or retaliation. + +34. The sole public interest in disclosure to be weighed against these privacy interests under both Exemption 6 and 7(C) is the public's understanding of BOP or other government operations. The personal information withheld from the 6 and 7(C) Records will not significantly contribute to the public's understanding of the operation or activities of BOP or any other government agency. The withheld personal information does not provide significant insight into government activities or operations in connection with Epstein's incarceration or the response of BOP or any other government agency to Epstein's death. + +35. The large volume of publicity and often unfounded speculation concerning the circumstances of Epstein's death increase the likelihood that disclosure of the information + +withheld under Exemptions 6 and 7(C) would cause an unwarranted invasion of personal privacy. + +36. In light of this public and unfounded speculation about Epstein's death and the media coverage thereof, it is reasonable to expect that individuals identified through government disclosures as associated with Epstein's incarceration and death, or investigation of the charges against Epstein or the circumstances of his death, could be targeted or harassed. Accordingly, publicizing the identity, contact information, or other personal information about a particular individual's associations or interactions with Epstein will amount to a significant invasion of personal privacy, with no meaningful contribution to the public's understanding of how the government works. + +37. For each category of individuals with personally identifying information present in the 6 & 7(C) Returned Records, the individual privacy concerns outweigh the putative public interest in their disclosure. + +- a. The disclosure of personally identifying information of BOP employees, such as their names or contact information, would significantly invade their personal privacy without contributing significantly to public understanding of how BOP works. Disclosing the names or contact information of individual BOP employees does not provide insight into how BOP works. +- b. The disclosure of personally identifying information of BOP inmates, such as their names or contact information, would significantly invade their personal privacy without contributing significantly to public understanding of how BOP works. The names or contact information of particular inmates sheds no light on how BOP works. +- c. The disclosure of personally identifying information of visitors or senders of funds to BOP inmates, such as their names and contact information, would significantly invade their personal privacy without contributing significantly to public understanding of how the government works. Identification of individuals who visited or sent money to Epstein or other inmates does not shed light on BOP conduct or how BOP or any other government agency works. + +- d. The disclosure of personally identifying information of legal counsel to Epstein and other BOP inmates, such as their names and contact information, would significantly invade their personal privacy without contributing significantly to public understanding of how the government works. Identification of counsel to Epstein or other inmates does not shed light on BOP conduct or how BOP or any other government agency works. + +38. Two sets of Returned Records were withheld in full under Exemptions 6 & 7(C). One set of the Returned Records, noted at Entry 59 of the Updated Index, consists of 274 pages from inmate census rosters for July 23-25 and 27-31, 2019, and August 1-6 and 8-10, 2019. Although Epstein's name appears once on each of these rosters, the pages with his name were released in part. The 274 pages withheld in full contain no information about Epstein and instead list the names and some personal information of other inmates at MCC on those dates. Identification of other inmates incarcerated at the same time as Epstein would shed no light on BOP's or the government's operations, but would invade the privacy of the other inmates, including by associating them with Epstein in a government document. + +39. The other set of Returned Records withheld in full under Exemptions 6 & 7(C), noted at Entry 58 of the Updated Index, consists of 2 pages showing the transferors of funds to Epstein. Specifically, these pages are electronically generated pages containing details of transfers of funds to Epstein. The transfers themselves, including the amount of the transfer but not the names of the transferors, were documented in pages released in part. The pages withheld in full include identifying details of the transferors. The identity of the transferors of funds to Epstein would not shed any light on how BOP or the government works, but would invade the privacy of the transferors, including by detailing their association with Epstein during his incarceration. + +40. The release of the personally identifying information in the 6 & 7(C) Returned Records would constitute a clearly unwarranted invasion under Exemption 6, and, at a minimum, could reasonably be expected to constitute an unwarranted invasion under Exemption 7(C), of the personal privacy of BOP employees, BOP inmates other than Epstein, visitors or senders of funds to BOP inmates, or legal counsel for BOP inmates. + +### Returned Records Withheld Pursuant to Exemptions 7(E) + +41. 5 U.S.C. § 522 (b)(7)(E) ("Exemption 7(E)") exempts from disclosure "records or information compiled for law enforcement purposes, but only to the extent that the production of such law enforcement records or information ... would disclose techniques and procedures for law enforcement investigations or prosecutions, or would disclose guidelines for law enforcement investigations or prosecutions if such disclosure could reasonably be expected to risk circumvention of the law." + +42. Some of the Returned Records withheld in part by BOP contain information about or discussion of law enforcement techniques and procedures or guidelines for law enforcement investigations or prosecutions (the "7(E) Returned Records"). + +43. Portions of the 7(E) Returned Records fall within the scope of Exemption 7(E) because they include information or discussions that would disclose law enforcement techniques and procedures or guidelines for law enforcement investigations and their use in managing the MCC. With one exception, none of the information in the Returned Records withheld by BOP under Exemption 7(E) pertains specifically to Epstein. Instead, the information concerns steps taken by BOP staff in response to issues at the MCC unrelated to Epstein or primarily routine actions taken by BOP staff. Specifically, BOP disclosed in part pages of lieutenant's logs, TRUINTEL logs, inmate census roster pages, and an MCC running board page that mention or refer to Epstein but also document techniques, procedures, and/or guidelines used in managing + +the MCC and enforcing the law there? For example, disclosing details of counts within the MCC or the use of body alarms there would disclose law enforcement techniques, procedures, and/or guidelines. If the Court requires further information, BOP is prepared to file an ex parte supplemental declaration explaining in greater detail the techniques, procedures, and guidelines at issue. + +44. The one redaction in the 7(E) Returned Records made by BOP pursuant to Exemption 7(E) that does pertain specifically to Epstein is the redaction of certain information on an electronically generated inmate profile of Epstein that would disclose how BOP classifies certain inmates for security purposes. Disclosure of that portion of Epstein's inmate profile would disclose a law enforcement technique or procedure by disclosing how BOP classifies certain inmates in connection with security issues. + +45. Disclosure of the information in the 7(E) Returned Records withheld pursuant to Exemption 7(E) would create a risk of circumvention of the law. Disclosure of the information would provide inmates or other individuals with details about how MCC works and its security. They could use this information to destabilize the MCC and to perpetrate crimes there. + +## Returned Records Withheld Pursuant to Exemption 7(F) + +46. 5 U.S.C. § 522 (b)(7)(F) ("Exemption 7(F)") exempts from disclosure "records or information compiled for law enforcement purposes, but only to the extent that the production of such law enforcement records or information ... could reasonably be expected to endanger the life or physical safety of any individual." + +3 Lieutenant's logs withheld in full pursuant to Exemption 7(A), noted at Entry 49 of the Updated Index, also contain information that falls with the scope of Exemption 7(E) for the reasons discussed here. + +47. Some of the Returned Records withheld by BOP in full or in part contain information that falls within the scope of Exemption 7(F) (the "7(F) Returned Records"). Such information falls into two categories. First, disclosure of the personally identifying information, such as names and contact information, of third-party individuals employed by BOP could reasonably be expected to endanger the life or physical safety of these individuals. Second, disclosure of certain techniques and procedures used in the management of the MCC could reasonably be expected to endanger the life or physical safety of BOP employees and inmates held by BOP. + +48. First, some of the 7(F) Returned Records fall in part within the scope of Exemption 7(F) because the release of the personally identifying information contained in these records could reasonably be expected to endanger the life or physical safety of BOP employees whose personally identifying information is contained in the 7(F) Returned Records. BOP employees work with inmates and criminal defendants who, upon their release from incarceration or during their incarceration, might target BOP employees for reprisal. BOP employees in many cases live in the cities where they work, frequently utilize public transportation, and regularly engage in community and social activities in those cities. The release of personally identifying information of BOP employees increases the risks of such targeting or harassment because it would make it easier for identified employees to be targeted or harassed. Because of the attention and speculation surrounding Epstein's death, it is reasonable to expect that individuals identified through disclosures by the government as associated with Epstein's incarceration and death could be targeted. + +49. Second, some of the 7(F) Returned Records fall in part within the scope of Exemption 7(F) because the release of information contained therein would reveal details about the operation and management of the MCC that could be used to destabilize the MCC and + +perpetrate crimes there, endangering the lives and physical safety of BOP employees and MCC inmates. With one exception, none of this information pertains specifically to Epstein. Instead, the information concerns steps taken by BOP staff in response to issues at the MCC unrelated to Epstein or primarily routine, but sensitive, actions taken by BOP staff. Specifically, BOP disclosed in part pages of lieutenant's logs, TRUINTEL logs, inmate census roster pages, an MCC running board page, and SHU records that mention or refer to Epstein but also document aspects of the MCC and its operations that are not public and could enable individuals to harm BOP employees or MCC inmates.' For example, disclosing certain details of counts within the MCC or the use of body alarms there could reasonably be expected to endanger the lives and physical safety of BOP employees and MCC inmates. If the Court requires further information, BOP is prepared to file an ex parte supplemental declaration explaining in greater detail the information at issue. + +50. The one set of redactions in the Returned Records made by BOP pursuant to Exemption 7(F) that does pertain specifically to Epstein is the redaction of certain information on an electronically generated inmate profile of Epstein that would disclose how BOP classifies certain inmates for security purposes. Disclosure of those portions of Epstein's inmate profile could reasonably be expected to endanger the lives and physical safety of BOP employees and MCC inmates by revealing how BOP classifies certain inmates in connection with security issues. + +TRUINTEL reports and lieutenant's logs withheld in full pursuant to Exemption 7(A), noted at Entries 32 and 49 of the Updated Index, also contain information that falls with the scope of Exemption 7(F) for the reasons discussed here. + +Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge and belief. + +Executed this 15th day of January 2021. + +![](_page_17_Picture_3.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00088630/EFTA00088630.metadata.json b/marker2/ds9/EFTA00088630/EFTA00088630.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..7b0bee3c6274ba174c54f820145ea2c6592f9d28 --- /dev/null +++ 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BOP, 20 Civ. 833 (SDNY) + +## Index of Withholdings in Full + +| Entry | Page count | Description | Status Withheld in Full (WIF) under 7(A); Exemptions 6 and 7(C) applicable in | +|-------|------------|-----------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------| +| 1 | 2 | Incident Report of Jeffrey Epstein's July 23, 2019 Apparent Suicide Attempt | part WIF under 7(A); Exemptions 5 (Deliberative Process Privilege), 6, | +| 2 | 37 | Psychological Reconstruction of Inmate Death | 7(C), 7(E), and 7(F) applicable in part WIF under 7(A); Exemptions 6, 7(C), | +| 3 | 23 | Overtime Logs for MCC, 07/22/19-07/23/19 | and 7(F) applicable in part WIF under 7(A); Exemptions 6, 7(C), | +| 4 | 23 | Overtime Logs for MCC, 08/09/19-08/10/19 | and 7(F) applicable in part WIF under 7(A), except for one page released in part; Exemptions 6, 7(C), | +| 5 | 8 | MCC Daily Assignment Roster for 07/22/19 | and 7(F) applicable in part WIF under 7(A), except for one page released in part; Exemptions 6, 7(C), | +| 6 | 7 | MCC Daily Assignment Roster for 07/23/19 | and 7(F) applicable in part WIF under 7(A), except for one page released in part; Exemptions 6, 7(C), | +| 7 | 9 | MCC Daily Assignment Roster for 08/09/19 | and 7(F) applicable in part WIF under 7(A), except for one page released in part; Exemptions 6, 7(C), | +| 8 | 10 | MCC Daily Assignment Roster for 08/10/19 | and 7(F) applicable in part WIF under 7(A); Exemptions 6, 7(C), | +| 9 | 5 | Inmate Investigative Report | 7(E), and 7(F) applicable in part | +| 10 | 4 | MCC New York Updates | WIF under 7(A) WIF under 5 - Deliberative Process Privilege; Exemptions 6 and 7(C) | +| 11 | 2 | Draft Letters | applicable in part WIF under 7(A); Exemptions 5 (Deliberative Process Privilege), 6, | +| 12 | 129 | Responses to Psychological Reconstruction of Inmate Death | 7(C), 7(E), and 7(F) applicable in part | + +| 13 | 2 | Letter to Warden dated August 14, 2019 | +|----|-----|---------------------------------------------------------------------------------------------| +| 14 | 16 | Photo Sheet from 07/23/19 Apparent Suicide Attempt 7(C) applicable in part | +| 15 | 7 | Memo and Report from 07/23/19 Apparent Suicide Attempt (Form 583) | +| 16 | 2 | Photo Sheet from 07/23 Apparent Suicide Attempt 7(C) applicable in part | +| 17 | 1 | Chain of Custody Form from 07/23 Apparent Suicide Attempt | +| 18 | 4 | Reports of 07/23 Apparent Suicide Attempt | +| 19 | 48 | Medical and Psychological records of Epstein 7(C) applicable in part | +| 20 | 17 | Memo and Reports from 08/10 Suicide (Form 583) | +| 21 | 1 | Memo from Unit Manager dated 08/10/19 7(C) applicable in part | +| 22 | 24 | Count Documents (e.g., Watch Calls, Body Alarm Records) and 7(F) applicable in part | +| 23 | 145 | Count Documents (30 Minute Check Sheets) 7(C) appliable in part | +| 24 | 163 | Count Documents (e.g., Count Slips, Rosters, Out-Count Forms) 7(C) appliable in part | +| 25 | 20 | Investigative Documents from Suicide (e.g., Chain of Custody Forms) 7(C) applicable in part | +| 26 | | Entry Deleted | +| 27 | 3 | Investigative Documents from Suicide 7(C) applicable in part | +| 28 | 4 | 08/10/2020 TRUINTEL Reports (including email) 7(C) applicable in part | +| 29 | 1 | Memo to Warden dated 08/13/2019 7(C) applicable in part | +| 30 | 24 | Count Documents 7(C) applicable in part | + +| 31 | 5 | Investigative Documents from Suicide 7(C) applicable in part | +|----|----|---------------------------------------------------------------------------------------| +| 32 | 8 | TRUINTEL Reports (8/9/19-8/10/19) and 7(F) applicable in part | +| 33 | 5 | Count Documents (30 Minute Check Sheets) 7(C) applicable in part | +| 34 | | Entry Deleted | +| 35 | 46 | Photo Sheets from 08/10/19 Suicide 7(C) applicable in part | +| 36 | 14 | Photo Sheets from 07/23/19 Apparent Suicide Attempt 7(C) applicable in part | +| 37 | | Entry Deleted | +| 38 | 27 | SHU Weekly Review (08/08/2019) and 7(F) applicable in part | +| 39 | 1 | Cop Out Note 7(C) applicable in part | +| 40 | 2 | SHU Computer Screenshots 7(C) applicable in part | +| 41 | 4 | Psychological Reconstruction Responses | +| 42 | 1 | SHU Computer Screenshot 7(C) applicable in part | +| 43 | 4 | 24-hour death report and death notification (including email) 7(C) applicable in part | +| 44 | 13 | Office of Chief Medical Examiner Documents 7(C) applicable in part | +| 45 | 40 | Psych Observation Logs 7(C) applicable in part | +| 46 | 16 | Suicide Watch Logs (including one SENTRY page) 7(C) applicable in part | +| 47 | 1 | SHU Computer Screenshots 7(C) applicable in part | +| 48 | 1 | Memo dated 08/12/2019 7(C) applicable in part | + +| 49 | 7 | Lieutenant's Log (08/09-08/10) | +|----|-----|-----------------------------------------------------------------------------------------------------------------| +| 50 | 1 | Scan of sign WIF under 7(A) | +| 51 | 2 | Memo dated 08/10/2019 7(C) applicable in part | +| 54 | | Entry Deleted | +| 55 | 32 | Count slips and associated inmate rosters 7(F) applicable in part | +| 56 | 17 | MCC Daily Assignment Rosters for July 23, 2019; 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My employment history with the BOP is described in a declaration I submitted in the abovecaptioned case on August 5, 2020 (the "Declaration"). +- 2. I submit this declaration in support of the BOP's motion for summary judgment and to correct certain statements in the Declaration that incorrectly described one record that BOP produced in response to Plaintiffs' FOIA requests. +- 3. In Paragraphs 17 and 30 of the Declaration, I stated that MCC's searches for records responsive to Plaintiff's FOIA request had located "one log book showing a visitor for Jeffrey Epstein on July 30, 2020." I have since learned that this log book showed a phone call Epstein made on July 30, 2020, not a visit that he received on that date. Specifically, the log book is an Intake Screening Phone Log kept in the Receiving & Discharging area within + +the MCC. I advertently described the log as showing a visit, when, in fact, it shows a phone call. + +- 4. For the same reason, Paragraph 28 of the Declaration should be corrected to reflect that the searches at MCC located one log showing a phone call made by Epstein on July 30, 2020, specifically the Intake Screening Phone Log described above. + +Pursuant to 28 U.S.C. § 1746, I declare under the penalty of perjury that the foregoing is true and correct. + +Executed et this t day of October 2020. + +![](_page_1_Picture_5.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00088652/EFTA00088652.metadata.json b/marker2/ds9/EFTA00088652/EFTA00088652.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..68151a7888644be7d14a6e8d92c727d4eebb0c97 --- /dev/null +++ b/marker2/ds9/EFTA00088652/EFTA00088652.metadata.json @@ -0,0 +1,142 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00088652.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 1693, + "elapsed_seconds": 0.66, + "image_assets": [ + "_page_1_Picture_5.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 193.053, + 77.76 + ], + [ + 418.09381103515625, + 77.76 + ], + [ + 418.09381103515625, + 106.8580322265625 + ], + [ + 193.053, + 106.8580322265625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 46 + ], + [ + "Line", + 24 + ], + [ + "Text", + 7 + ], + [ + "ListItem", + 3 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "SectionHeader", + 1 + ], + [ + "ListGroup", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 25 + ], + [ + "Line", + 11 + ], + [ + "Text", + 3 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "ListGroup", + 1 + ], + [ + "Picture", + 1 + ], + [ + "ListItem", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00088652" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00088652/_page_1_Picture_5.jpeg b/marker2/ds9/EFTA00088652/_page_1_Picture_5.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..9ad122854ed87d5ff362b37f9153980c37d6b431 --- /dev/null +++ b/marker2/ds9/EFTA00088652/_page_1_Picture_5.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:d3c7c22a187b75378bc8da426cf63497d4cda03516e7e0ebb9aa845e75e8cc9d +size 8438 diff --git a/marker2/ds9/EFTA00088654/EFTA00088654.md b/marker2/ds9/EFTA00088654/EFTA00088654.md new file mode 100644 index 0000000000000000000000000000000000000000..1aa6a64d883b1e28a4ba7c732881f197c8301c9a --- /dev/null +++ b/marker2/ds9/EFTA00088654/EFTA00088654.md @@ -0,0 +1,73 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +THE NEW YORK TIMES COMPANY. + +Plaintiff, + +No. 20-CV-833(PAE) + +v. + +FEDERAL BUREAU OF PRISONS, + +Defendant. + +reby declare as follows: + +I. I am Counsel to the Acting United States Attorney for the Southern District of New York ("USAO-SDNY"). My prior declaration in this matter dated August 5, 2020, details my service in this capacity and prior service in the USAO-SDNY. As noted therein, I am familiar with the Freedom of Information Act requests filed by the New York Times Company (the "FOIA Requests") that are the subject of this case, which seek records related to the incarceration of Jeffrey Epstein at the Metropolitan Correctional Center ("MCC"). I am also familiar with the responsive records that defendant the Federal Bureau of Prisons ("BOP") has withheld in whole or in part pursuant to various FOIA exemptions, including BOP's withholdings from the records provided back to BOP by the Office of the Inspector General of the Department of Justice ("OIG") since the submission of my August 5, 2020, declaration. + +2. The statements contained in this declaration are based on my personal knowledge, documents maintained in the files of the USAO-SDNY, conversations with members of the Noel and Tartaglione prosecution teams at the USAO-SDNY, public court filings, and conclusions made in accordance therewith. + +3. I submit this declaration in further support of BOP's motion for summary judgment in this case. Specifically, this declaration addresses the bases for the withholding in whole or in part of certain records provided back to BOP by OIG pursuant to FOIA Exemption 7(A). + +## Records Withheld in Full or in Part from Disclosure Pursuant to FOIA Exemption 7(A) on Account of Likely Interference with Noel + +4. 5 U.S.C. § 522 (b)(7)(A) ("Exemption 7(A)") exempts from disclosure "records or information compiled for law enforcement purposes, but only to the extent that the production of such law enforcement records or information ... could reasonably be expected to interfere with enforcement proceedings ...." + +5. I and the prosecutors responsible for the Noel prosecution have reviewed each of the records provided back to BOP by OIG that BOP withheld in full or in part under Exemption 7(A) (the "7(A) Returned Records"), including those reflected as withheld in full at Entries 55- 57 and 60 on the updated index attached to the Supplemental Declaration of Kara Christenson (the "updated BOP index"). The 7(A) Returned Records fall into four categories: documents related to counts of inmates, staffing records, psychology records, and entries on certain BOP logs for August 9 and 10, 2019. Each of these categories fall within the scope of Exemption 7(A). + +6. Public disclosure of the 7(A) Returned Records could reasonably be expected to interfere with the pending Noel prosecutions. These records include information about which numerous witnesses are expected to testify at trial, details that are not publicly known or known to other witnesses, and information and documents prepared by potential trial witnesses. These records also include potential trial exhibits, which some or all potential trial witnesses have not seen. Premature disclosure of these records and/or the information contained therein could + +reasonably be expected to influence witnesses' potential testimony at trial and/or enable witnesses to alter or shape their testimony to conform to other evidence. + +7. Further, premature public disclosure of any of the 7(A) Returned Records could reasonably be expected to impair the government's (and the defendants') ability to seat a fair and impartial jury in Noel. The government anticipates that some of these records will be entered into evidence as exhibits at trial, and other records that may not be trial exhibits bear on the contents of potential trial exhibits. Premature disclosure of these records and/or the information contained therein could influence potential jurors' understanding of the evidence at trial and the case overall. Similarly, premature disclosure of the records and/or the information contained therein could prejudice potential jurors for or against the defendants in the Noel action, which would also impair the government's (and the defendants') ability to seat a fair and impartial jury. In addition, as noted above, these records include specific information about which witnesses are expected to testify at trial, as well as information and documents prepared by potential trial witnesses, such that premature public disclosure could reasonably be expected to influence potential jurors' perception of the witnesses and the evidence to be presented at trial. + +8. The risks of interference with the Noel proceedings are heightened by the media coverage of speculation and theories about Epstein's death. Many publicly-discussed theories of Epstein's death are unfounded. Premature release of the withheld records, particularly if the records are released in part or without full context, may influence the perception of jurors who have been exposed to such media coverage of speculation and theories. + +9. The considerations discussed above apply to each of the categories of 7(A) Returned Records. + +10. First, as discussed in my prior declaration, the government anticipates that documents related to counts of inmates, including count slips, associated inmate rosters, and records of rounds and checks, for dates between and including July 23, 2019, and August 12, 2019, will be the subject of trial testimony at the Noel trial. 7(A) Returned Records containing such documents are noted at Entry 55 of the updated BOP index.' In addition, the government anticipates that some of these documents will be trial exhibits. Releasing these materials prematurely could reasonably be expected to influence witnesses' potential testimony at trial, allow witnesses to alter or shape their testimony to conform to other evidence, identify potential government witnesses at the Noel trial, and/or influence potential jurors' perceptions of witness testimony or evidence. + +II. One subcategory of these documents are records from the Special Housing Unit (the "SHU"), specifically rosters of inmates in the SHU on August 9 and 10, 2019, and SHU records showing which BOP employees conducted rounds in the SHU. Although BOP had previously withheld six pages of these records in full, included at Entries 22, 34 and 37 of the prior index submitted by BOP, the prosecutors responsible for the Noel prosecution and I determined that these records could be released in part without interfering with the Noel prosecution, provided that information on these records showing details of the occupants of the SHU on August 9 and 10, 2019, and which BOP employees conducted rounds in the SHU was redacted. Releasing such information prematurely could reasonably be expected to influence witnesses' potential testimony at trial, allow witnesses to alter or shape their testimony to + +In reviewing the records returned to BOP by OIG, the prosecutors responsible for the Noel and Tartaglione prosecutions and I determined that a one-page attorney visit room inventory log, dated July 21, 2019, and an 18-page inmate census roster, dated August 9, 2019, each of which BOP had previously withheld in full under Exemption 7(A), could be released without a reasonable expectation of interference with the Noel or Tartaglione prosecutions. The attorney visit room inventory log was previously listed at Entry 26 of GOP's index, and the census roster was previously included among the count documents noted at Entry 24 of GOP's index. + +conform to other evidence, identify potential government witnesses at the Noel trial, and/or influence potential jurors' perceptions of witness testimony or evidence. + +12. Second, as discussed in my prior declaration, the government anticipates that MCC staffing records, including daily assignment rosters for the MCC on July 23, August 9, and 10, 2019, will be the subject of witness testimony at the Noel trial. 7(A) Returned Records containing such documents are noted at Entry 56 of the updated BOP index.2 In addition, the government anticipates that some of these documents will be trial exhibits. Releasing these materials prematurely could reasonably be expected to influence witnesses' potential testimony at trial, allow witnesses to alter or shape their testimony to conform to other evidence, and/or influence potential jurors' perceptions of witness testimony or evidence. + +13. Third, as discussed in my prior declaration, the government anticipates that certain psychological notes and records of Epstein prepared by BOP may be trial exhibits, the subject of witness testimony, and/or were prepared by witnesses who will testify at trial. 7(A) Returned Records containing such documents are noted at Entry 57 of the updated BOP index. Premature disclosure of these records could influence the testimony of potential witnesses, including by potentially causing them to alter or shape their testimony to conform to other evidence. In addition, premature disclosure of these records could reasonably be expected to prejudice potential jurors for or against the defendants in the Noel action, which would impair the government's (and the defendants') ability to seat a fair and impartial jury. + +14. Fourth, as discussed in my prior declaration, the government anticipates that entries in certain BOP logs for August 9 and 10, 2019, may be trial exhibits, the subject of + +2 The daily assignment rosters included in the 7(A) Returned Records appear identical to the daily assignment rosters BOP previously located and withheld in response to the FOIA Requests, except that they contain a different date stamp, which I understand to indicate when they were electronically generated. + +witness testimony, and/or were prepared by witnesses who will testify at trial. 7(A) Returned Records containing such documents are noted at Entry 60 of the updated BOP index. Premature disclosure of these materials could reasonably be expected to influence witnesses' potential testimony at trial, allow witnesses to alter their testimony to conform to other evidence, and/or influence potential jurors' perceptions of witness testimony or evidence. + +## 7(A) Returned Records Withheld in Part from Disclosure Pursuant to Exemption 7(A) on Account of Likely Interference with Tartaglione + +15. The release of portions of two 7(A) Returned Records could also be reasonably expected to interfere with the Tartaglione prosecution. First, portions of psychological records, withheld in full as noted at Entry 57 of the updated BOP index, concerning the circumstances of Epstein's apparent suicide attempt on July 23, 2019, could reasonably be expected to interfere with the prosecution of Tartaglione. Second, premature release of one of the entries in a lieutenant's log dated July 23, 2019, concerning the circumstances of Epstein's apparent suicide attempt on that date, could reasonably be expected to interfere with the prosecution of Tartaglione. + +16. As discussed in my prior declaration, Tartaglione's interactions with Epstein in July 2019 have been placed at issue by Tartaglione's defense counsel, specifically in connection with the potential penalty phase of the case against Tartaglione. See Letter dated January 13, 2010, Dkt. No. 186, United States v. Tartaglione, No. 16 Cr. 832 (KMK); Letter dated January 21, 2020, Dkt. No. 193, United States v. Tartaglione, No. 16 Cr. 832 (KMK). In light of defense counsel's position, the information contained in the psychological records and in the entry in the lieutenant's log may be relevant evidence in any possible penalty phase of the case against Tartaglione. In that event, premature release of the information could reasonably be expected to + +adversely affect the Tartaglione proceedings and influence potential jurors' perceptions of Tartaglione, thereby impairing the district court's ability to scat a fair and impartial jury. + +## Segregabilitv + +17. The 7(A) Returned Records withheld in full are exempt from disclosure in their entirety under Exemption 7(A). To the extent the records contain any non-exempt information, such information is inextricably intertwined with information that could reasonably be expected to interfere with the Noel prosecution for the reasons discussed above. As noted in my previous declaration, the media coverage of speculation and theories about Epstein's death makes the segregation of any possibly non-exempt information particularly difficult because providing information pertaining to Epstein without complete context risks contributing to the dissemination of speculation and theories about his death. This, in turn, could reasonably be expected to interfere with the district court's ability to seat a fair and impartial jury in Noel, for the reasons discussed above. + +Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge and belief. + +Executed this 12 day of January 2021. + +![](_page_6_Picture_6.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00088654/EFTA00088654.metadata.json b/marker2/ds9/EFTA00088654/EFTA00088654.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..9525f8b8f6f9775c9f47c48c6731cc4e62cd7ae1 --- /dev/null +++ b/marker2/ds9/EFTA00088654/EFTA00088654.metadata.json @@ -0,0 +1,385 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00088654.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": 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sha256:e4bd13d1b76731ab18dc91ba86752d3ab57c92e86971d1692c0ebd73c4e0eb20 +size 8613 diff --git a/marker2/ds9/EFTA00088661/EFTA00088661.md b/marker2/ds9/EFTA00088661/EFTA00088661.md new file mode 100644 index 0000000000000000000000000000000000000000..f6a81e8f82621ee1f9fc30592956be466b5b21c7 --- /dev/null +++ b/marker2/ds9/EFTA00088661/EFTA00088661.md @@ -0,0 +1,83 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +THE NEW YORK TIMES COMPANY, + +Plaintiff, + +v. + +FEDERAL BUREAU OF PRISONS. + +Defendant. + +eclare as follows: + +20-CV-00833 (PAE) + +- 1. I am employed by the United States Department of Justice, Federal Bureau of Prisons ("BOP"), as a Staff Attorney at the Metropolitan Correctional Center ("MCC"). I have served in this role since December 2019. Prior to that time, I was the Senior Staff Attorney at MDC Brooklyn from January 2009 until December 2019 and the Staff attorney at FCI Fort Dix from September 2005 until January 2009. I have been employed by the BOP since September 2005. +- 2. As a Staff Attorney, my duties include coordinating searches at MCC when a Freedom of Information Act ("FOIA") requires MCC staff to undertake a search for responsive documents. In this capacity, I typically work with staff at BOP's Central Office. In this case, I communicated with BOP Government Information Specialist Kara Christenson regarding Plaintiff's FOIA requests. +- 3. I submit this declaration in support of the BOP's motion for summary judgment and to + +describe GOP's search at MCC for records responsive to the FOIA requests submitted by Plaintiff. + +- 4. The statements made in this declaration are based upon my personal knowledge, conversations and communications with other BOP staff, and information available to me in my official capacity and about which I have become knowledgeable. +- 5. To conduct the search at MCC for records responsive to Plaintiff's FOIA request, I conferred with staff at MCC and staff at Central Office to determine that the following individuals would likely have documents responsive to Plaintiff's request: Lieutenant, MCC Associate Warden; MCC Chief Psychologist; Executive Assistant to the MCC Warden; Case Management Coordinator in the MCC Records Department; Special Investigave Agent at the MCC; Deputy Regional Counsel for the Northeast Regional Office and former BOP Staff Attorney at the MCC; former MCC Warden; and Unit Managers. Based on my conversations with staff at MCC and Central Office and my own experience, no other individuals at MCC, or who formerly worked at MCC, are reasonably likely to have records responsive to Plaintiff's request. +- 6. I asked each of the individuals identified in Paragraph 5 to search their electronic and nonelectronic files for documents responsive to Plaintiff's FOIA requests. Each of them advised me that he or she conducted a manual search of electronic and non-electronic files for documents responsive to Plaintiff's FOIA requests. Their searches included a search of drives on GOP's computer system where individual BOP employees can save documents. Separate from these searches conducted by individuals, a search for email records and searches of other BOP electronic systems, including SENTRY and TRULINKS, for records responsive to + +Plaintiff's FOIA requests was conducted by Central Office and is detailed in the Declaration of Kara Christenson (the "Christenson Declaration"). + +- 7. The results of the searches conducted by MCC in response to Plaintiffs' requests are described in the following paragraphs. +- 8. SHU LOGS With respect to Plaintiff's request for "[t]he signed log in the Special Housing Unit at MCC that shows when prison staff did rounds on July 22 and 23, and Aug. 9 and 1," MCC staff determined that the SHU log books in question were handed over to the Office of the Inspector General ("OM") on or about August 22, 2019. With the exception of the scanned copies of certain log book pages described in the Christenson Declaration, the searches at MCC did not return additional records responsive to this request. +- 9. \$ENTRY OUARTER'S HISTORY With respect to Plaintiff's request for "[a]ll quarter entries (showing which cells he was housed in) for Jeffrey Epstein at MCC[,]" Central Office conducted a search of the SENTRY database, as described in the Christenson Declaration. The searches at MCC did not return additional records responsive to this request, apart from records relating to Epstein that indicated which cell or part of the facility he was housed in. +- 10. CIM CLEARANCE SHEET/SEPARATEE DATA With respect to Plaintiff's request for "CIM Clearance and Separatee data sheet for Jeffrey Epstein at MCC[,]" Central Office conducted a search of the SENTRY database, as described in the Christenson Declaration. The searches at MCC did not return additional records responsive to this request. 11 DISCIPLINARY RECORDS With respect to Plaintiff's request for "chronological disciplinary records for Jeffrey Epstein at MCC[,]" Central Office conducted a search of the SENTRY database, as described in the Christenson Declaration. The searches at MCC did + +not return additional records responsive to this request. + +- 12. INTAKE SCREENING FORM Based on my own experience and conversations with BOP staff at MCC and Central Office, the DROP File for Epstein was the only likely place where "the intake screening form for Jeffrey Epstein at MCC" would be located. To locate the DROP File for Epstein, I requested that the Case Management Coordinator for the MCC Records Department, obtain the file. The Case Management Coordinator obtained the file, which did not contain records responsive to Plaintiff's request for intake screening forms. Based on my own experience and conversations with MCC and Central Office staff, there are no other locations likely to produce records responsive to this request. +- 13. SECURITY DESIGNATION With respect to Plaintiff's request for "the security designation records for Jeffrey Epstein at MCC[,]" Central Office conducted a search of the SENTRY database, as described in the Christenson Declaration. The searches at MCC did not return additional records responsive to this request. +- 14. INMATE PROFILE With respect to Plaintiff's request for "the inmate profile for Jeffrey Epstein at MCC(,)" Central Office conducted a search of the SENTRY database, as described in the Christenson Declaration. The searches at MCC did not return additional records responsive to this request. +- 15. INCIDENT REPORTS With respect to Plaintiff's request for "[a]ll incident reports related to Jeffrey Epstein at MCC[,]" Central Office conducted a search of the SENTRY database, as described in the Christenson Declaration. The searches at MCC did not return additional records responsive to this request +- 16. MEDICAL REPORTS With respect to Plaintiff's request for "all medical reports related + +to Jeffrey Epstein at MCC [,]" Central Office conducted a search of the Bureau Electronic Medical Record ("BEMR") database, as described in the Christenson Declaration. The searches at MCC did not return additional records responsive to this request. + +17 VISITOR LOG — With respect to Plaintiff's request for visitor "[t]he signed visitor log for Jeffrey Epstein at MCC[,]" MCC staff searched for responsive log books and located one log book showing a visitor for Jeffrey Epstein on July 30, 2020. MCC staff determined that any other responsive log books were handed over to OIG on or about August 22, 2019. With the exception of the scanned copies of certain log book pages described in the Christenson Declaration, the searches at MCC did not return additional records responsive to this request. + +18 MEETING DOCUMENTS — With respect to Plaintiff's request for "[d]ocuments showing when MCC staff held meetings regarding Jeffrey Epstein, and who attended[,]" Central Office conducted a search for responsive emails and meeting invites within the GROUPWISE system, as described in the Christenson Declaration. In addition, MCC staff searched for responsive records. The individuals identified in Paragraph 5 who searched for responsive records include all MCC staff likely to have attended any staff meetings regarding Epstein and therefore the only MCC staff reasonably likely to have responsive records. The searches at MCC did not locate documents responsive to Plaintiff's request. + +19. si Reno: WATCH REMOVAL MEETING DOCUMENTS — With respect to Plaintiff's request for lap records generated from the meeting at MCC during which it was decided that Jeffrey Epstein would be taken off suicide watch[,]" Central Office conducted a search for responsive emails and meeting invites within the GROUPWISE system, as described in the Christenson Declaration. In addition, MCC staff searched for responsive records. The + +individuals identified in Paragraph 5 who searched for responsive records include all MCC staff likely to have attended any meetings regarding the removal of Epstein from suicide watch and therefore the only MCC staff reasonably likely to have responsive records. The searches at MCC did not locate documents responsive to Plaintiff's request relating to any meeting regarding the removal of Epstein from suicide watch. + +- 20. POST- WATCH REPORT With respect to Plaintiff's request for "the Post-Watch report compiled in order to take Jeffrey Epstein off suicide watch[,]" Central Office conducted a search of the BEMR, as described in the Christenson Declaration. The searches at MCC did not return additional records responsive to this request. +- 21. OVERTIME. SIGN-I1P SHEETS With respect to Plaintiffs request for "[t]he overtime sign-up sheets for the Special Housing Unit (9 South) at MCC for Aug. 9 and 10, and on July 22 and 23[,]" Central Office conducted a search of the Roster/Overtime Program, as described in the Christenson Declaration. The searches at MCC did not return additional records responsive to this request. +- 22. STAFF AUGMENTING RECORDS With respect to Plaintiff's request for "[d]ocuments showing which staff were augmented at MCC and what positions they worked in on Aug. 9 and 10, and on July 22 and 23[,]" Central Office conducted a search of the Roster/Overtime Program, as described in the Christenson Declaration. The searches at MCC did not return additional records responsive to this request. +- 23. VIDEO CAMERA FOOTAGF,— With respect to Plaintiff's request for "[a]ll video camera footage at MCC pertinent to the Jeffrey Epstein suicide and the first suicide attempt[,]" MCC staff determined that all responsive video footage had been handed over to the Federal Bureau + +of Investigation on or about August 10, 2019. Nonetheless, MCC searched the Special Investigator Administrator's office, the place where video camera footage responsive to the request would ordinarily be located. No responsive video footage was located. + +24. SUICIDE ATTEMPT AND SUICIDE RECORDS — With respect to plaintiffs request for "[a]ll BOP documents pertaining to Jeffrey Epstein's suicide and first suicide attempt[,]" in addition to the searches by Central Office described in the Christenson Declaration, MCC staff located responsive records through their searches of their files. + +25. SUICIDE WATCH REMOVAL DOCUMENTS With respect to Plaintiff's request for "[a]ll BOP documents, including email correspondence and meeting minutes, pertaining to the decision to remove Jeffrey Epstein from suicide watch[,]" Central Office conducted a search for responsive emails and meeting invites within the GROUPWISE system and a search for psychological records in the BEMR database, as described in the Christenson Declaration. In addition, MCC staff searched for responsive records. The individuals identified in Paragraph 5 who searched for responsive records include all MCC staff reasonably likely have records responsive to plaintiff's request, including meeting minutes or email correspondence. In particular, the individuals identified in Paragraph 5 who searched for responsive records include all MCC staff likely to have attended any meetings regarding the removal of Epstein from suicide watch. The searches at MCC located responsive records, including saved email correspondence but no meeting minutes. The results of the MCC staff's search largely overlapped with the results of Central Office's search of the GROUPWISE and BEMR systems, but also located the Form 583 for Epstein's apparent suicide attempt, and memoranda and reports of Epstein's apparent suicide attempt. After these searches were + +conducted, I double-checked with the Executive Assistant to the MCC Warden and the MCC's chief psychologist and confirmed that they did not have any meeting minutes or any record of a meeting held to determine that Epstein would be removed from suicide watch. The Executive Assistant to the MCC Warden and MCC's chief psychologist are the only individuals likely to have attended or to have been aware of such a meeting, and thus the only MCC staff reasonably likely to have responsive records. + +- 26. SPECIAL INVESTIGATIVE REPORTS With respect to Plaintiff's request for "[s]ll BOP special investigation reports mentioning Jeffrey Epstein[,]" Central Office conducted a search of the BOP Special Investigative Section, as described in the Christenson Declaration. The searches at MCC did not return additional records responsive to this request. +- 27. CORRESPONDENCE With respect to Plaintiff's request for "[a]ll BOP correspondence with the U.S. Attorney's Office regarding Jeffrey Epstein[,]" Central Office conducted a search of the BOP GROUPWISE system, as described in the Christenson Declaration. The searches at MCC did not return additional records responsive to this request. +- 28. PHONE. LOGS With respect to Plaintiffs request for a "full log of Mr. Epstein's phone calls to and from the MCC[,]" Central Office searched the TRUVIEW system, as discussed in the Christenson Declaration. In addition, MCC staff searched for responsive records and located memoranda regarding calls that Epstein had made on legal lines at the MCC. Several of his calls on the MCC legal line were described in memoranda saved on MCC computer systems and located by MCC staff. Other than these memoranda, no systematic record or log was located of Epstein's calls while he was incarcerated. +- 29. EMAIL COMMUNICATIONS With respect to Plaintiff's request for "[a]ll email correspondence to and from Mr. Epstein while he was at the MCC (including any + +correspondence through the Corrlinks system or any other email system he had access to[,]" Central Office conducted a search of the TRULINCS system. The searches at MCC did not return additional records responsive to this request. + +- 30. VISITOR LOGS With respect to Plaintiff's request for "[t]he full log of people who visited Mr. Epstein while he was at the MCC and when they visited[,]" MCC staff searched for responsive log books and located one log book showing a visitor for Jeffrey Epstein on July 30, 2020. MCC staff determined that any remaining responsive log books were handed over to OIG on or about August 22, 2019. With the exception of the scanned copies of certain log book pages described in the Christenson Declaration, the searches at MCC did not return additional records responsive to this request. +- 31. VISITOR LISTS With respect to Plaintiff's request for "[t]he full list of people that Mr. Epstein had requested to be on his approved visitor list[,]" Central Office conducted a search of the TRUVIEW system, as described in the Christenson Declaration. The searches at MCC did not return additional records responsive to this request. +- 32. FMAII. LIST With respect to Plaintiff's request for title full list of people that Mr. Epstein had requested to be on his approved email correspondence list[,]" Central Office conducted a search of the TRUVIEW system, as described in the Christenson Declaration. The searches at MCC did not return additional records responsive to this request. +- 33. APPROVED CALL. LIST With respect to Plaintiff's request for "[t]he full list of people that Mr. Epstein had requested to be on his approved call list[,]" Central Office conducted a search of the TRUVIEW system, as described in the Christenson Declaration. The searches at MCC did not return additional records responsive to this request. + +34. RECORDINGS OF TELEPHONE CALLS With respect to Plaintiff's request for a "recordings of the last three phone conversations that Mr. Epstein had[1" Central Office searched the TRUVIEW system. as discussed in the Christenson Declaration. In addition, MCC staff searched for responsive records, and did not locate any recording of any calls by Epstein. BOP has determined that no recording was made of Epstein's calls on any legal or non-legal line. + +Pursuant to 28 U.S.C. 1746. 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PRISONS'S +MOTION FOR SUMMARY JUDGMENT** + +AUDREY STRAUSS +Acting United States Attorney +Southern District of New York +86 Chambers Street, Third Floor + +![](_page_0_Picture_76.jpeg) + +![](_page_0_Picture_77.jpeg) + +### TABLE OF CONTENTS + +| | PRELIMINARY STATEMENT | | +|------------|---------------------------------------------------------------------------------|----| +| BACKGROUND | | 2 | +| I. | Criminal Proceedings Against Jeffrey Epstein | 2 | +| II. | Criminal Proceedings Against Tova Noel and Michael Thomas | 2 | +| III. | Criminal Proceedings Against Nicholas Tartaglione | 3 | +| IV. | The Times's FOIA Requests and This Action | 3 | +| ARGUMENT | | 4 | +| I. | FOIA and the Summary Judgment Standard | 4 | +| II. | BOP Conducted an Adequate Search for Responsive Records | 5 | +| III. | BOP's Withholdings Were Proper | 6 | +| IV. | BOP Has Satisfied Its Duty to Segregate and Release Any Non-Exempt Information. | 22 | +| CONCLUSION | | 23 | + +#### TABLE OF AUTHORITIES + +| Cases ACLU v. DOD, | Page(s) | +|---------------------------------------------------------------------------------|-----------| +| 389 F. Supp. 2d 547 (S.D.N.Y. 2005) ACLU v. DOI, | 21, 22 | +| 844 F.3d 126 (2d Cir. 2016) Adamowitz v. I.R.S., | 15, 16 | +| 552 F. Supp. 2d 355 (S.D.N.Y. 2008) | 5 | +| 626 F.3d 678 (2d Cir. 2010) | 20 | +| Del, 901 F.3d 125 (2d Cir. 2018) Amnesty Intl USA v. CIA, | 5 | +| 728 F. Supp. 2d 479 (S.D.N.Y. 2010) Associated Press v. U.S. Dept of Defense, | 7, 15, 16 | +| 554 F.3d 274 (2d Cir. 2009) Barney v. I.R.S., | 18 | +| 618 F.2d 1268 (8th Cir.1980) Billington v. U.S. Dep't of Justice, | 8 | +| 301 F. Supp. 2d 15 (D.D.C. 2004) Carney v. DO.I, | 20 | +| 19 F.3d 807 (2d Cir. 1994) | 5 | +| CIA v. Sala, | | +| 471 U.S. 159 (1985) Conti v. U.S. Dep'I of Homeland Sec., | 4 | +| No. 12 Civ. 5827 (AT), 2014 WL 1274517 (S.D.N.Y. Mar. 24, 2014) | 22, 23 | +| 789 F.2d 64 (D.C. Cir. 1986) Cut for Nall Sec. Studies v. U.S. Dept of Justice, | 8 | +| 331 F.3d 918 (D.C. Cir. 2003) DOD v. FLRA, | 8 | +| 510 U.S. 487(1994) Doherty v. U.S. Dep't of Justice, | 18 | +| 775 F.2d 49 (2d Cir. 1985) Eil v. U.S. Drug Enf 't Admin., | 20 | +| 878 F.3d 392 (1st Cir. 2017) | 19 | + +| Ferguson v. FBI, | | +|------------------------------------------------------------------------------------------------|---------------| +| 957 F.2d 1059 (2d Cir. 1992) Ferguson v. FBI, | 8 | +| No. 89 Civ. 5071 (RPP), 1995 WL 329307 (S.D.N.Y. June 1, 19 95) Garcia v. U.S. Dept ofJustice, | 5 | +| 181 F. Supp. 2d 356 (S.D.N.Y. 2002) Grand Cent. P.ship v. Cuomo, | 5 | +| 166 F.3d 473 (2d Cir. 1999) | 13, 14 | +| 929 F.2d 81 | 13 | +| Human Rights Watch v BOP, No. 13-CV-7360 | (JPO), | +| 2015 WL 5459713 (S.D.N.Y. Sept. 16, 2015) In re County of Erie, | 9, 10, 11, 20 | +| 473 F.3d 413 (2d Cir. 2 007) John Doe Agency v. John Doe Corp., | 14, 17 | +| 493 U.S. 146 (1 989) | 4 | +| Jordan v. U.S. Dep .t of Justice, | | +| M8 F.3d 1188 (10th Cir. 2 011) Judicial Watch, Inc. v. U.S. Dept of Commerce, | 9, 10, 21, 22 | +| 337 F. Supp. 2d 146 (D.D.C. 2004) Kansi v. U.S. Depst of Justice, | 20, 21 | +| 11 F. Supp. 2d 42 (D.D.C. 1998) | 8 | +| Kay v. F.C.C., | | +| 976 F. Supp. 23 (D.D.C. 199 7) Kidder v. FBI, | 7 | +| 517 F. Supp. 2d 17 (D.D.C. 200 7) | 8 | +| No. 16-2517 (CKK), 2020 WL 805380 (D.D.C. Feb. 18, 2020) Maynard v. C.I.A., | 15 | +| 986 F.2d 547 (1st Cir. 19 93) N.L.R.B. v. Robbins Tire & Rubber Co., | 5, 6 | +| 437 U.S. 214 (1 978) | 7, 8, 12 | +| N.Y. Times v. Dep of Justice, | | +| 872 F. Supp. 2d 309 (S.D.N.Y. 2012) | 5 | +| No. 07 Civ. 3378 (GEL), 2007 WL 4233008 (S.D.N.Y. Nov. 30, 2 00 7) | 15 | +| 541 U.S. 157 (200 4) Nat 7 Assoc. of Homebuilders v. Norton, | 19 | +| 309 F.3d 26 (D.C. Cir. 2 002) | 17 | + +New York Tunes Co. v. Dep't o/•.Justice, + +No. 14 Ch,. 03776 (AT) (SN), 2016 WL 5946711 (S.D.N.Y. Aug. 18, 2016) 8, 9, 11 + +New York Tunes Co. v. Nat'l Aeronautics & Space Admin., + +782 F. Supp. 628 (D.D.C. 1991) 19 + +NLRB v. Sears, Roebuck, + +421 U.S. 132 (1975) 13 + +North v. Walsh, + +881 F.2d 1088 (D.C. Cir. 1989) 8 + +Oglesby v. U.S. Army, + +920 F.2d 57 (D.C. Cir. 1990) 5 + +Pinson v. Dept of .htstice, + +236 F. Supp. 3d (D.D.C. 2017) 22 + +Radcliffe v. IRS, + +536 F. Supp. 2d 423 (S.D.N.Y. 2008) 7, 8 + +Renegotiation Bd. v. Grumman Aircraft Eng'g Corp., + +421 U.S. 168 (1975) 13 + +Robbins, Geller, Rudman & Dowd, LLP v. United States Sec. & Exch. Comm'n, + +No. 3:14-CV-2197, 2016 WL 950995 (M.D. Tenn. Mar. 12, 2016) 22 + +SafeCard Sens., Inc. v. S.E.C., + +926 F.2d 1197 (D.C. Cir. 1991) 5 + +Shapiro v. U.S. Dept oflustice, + +37 F. Supp. 3d 7 (D.D.C. 2014) 9 + +Tigue v. U.S. Dep 't of Justice, + +312 F.3d 70 (2d Cir. 2002) 13 + +U.S. Dep 't of State v. Washington Post Co., + +456 U.S. 595 (1982) 17 + +United States ex rel. Touhy v. Ragen, + +340 U.S. 462 (1951) 16 + +United States v. Schwimmer, + +892 F.2d 237 (2d Cir. 1989) 14 + +W. Journalism Ctr. v. Office of Indep. Counsel, + +926 F. Supp. 189 (D.D.C. 1996) 11 + +Williams v. F.B.I., + +730 F.2d 882 (2d Cir. 1984) 9, 10 + +Wafter v. NSA, + +592 F.3d 60 (2d Cir. 2009) 5 + +# Statutes + +5 U.S.C. § 522 passim + +# Regulations + +#### PRELIMINARY STATEMENT + +The New York Times (the 'Times") seeks records at the core of a pending criminal prosecution of two former Federal Bureau of Prisons ("BOP") employees on duty the night Jeffrey Epstein died. Some of the same records could also affect the penalty phase of a pending death penalty case against Epstein's former cell mate. Congress did not intend the Freedom of Information Act, 5 U.S.C. § 552 et seq., to interfere with pending criminal prosecutions. To make sure this would not happen, Congress expressly exempted records that could reasonably be expected to interfere with law enforcement proceedings from public disclosure under FOIA. See 5 U.S.C. § 552(b)(7)(A). Many of the records sought by the Times fall at the heart of this exemption. + +Other FOIA exemptions also justify BOP 's withholding of records in response to the FOIA request. BOP properly withheld information reflecting its predecisional deliberations about how to respond to Epstein's apparent suicide attempt on July 23, 2019, his later suicide on August 10, 2019, and related matters. See 5 U.S.C. § 552(b)(5). BOP also properly withheld information where disclosure clearly would, and/or could reasonably be expected to, result in an unwarranted invasion of privacy of Epstein's surviving family members, such as photographs of Epstein's body following his suicide, or third parties other than Epstein, such as BOP employees or other inmates. See 5 U.S.C. § 552(b)(6), (7)(C). The personal information of BOP employees is also protected because its disclosure could place those employees at risk of harm. See 5 U.S.C. § 552(b)(7)(F). Some of the withheld records are protected by an additional FOIA exemption because their disclosure would reveal sensitive law enforcement techniques or procedures, including those relating to investigating and preventing inmate suicides. See 5 U.S.C. § 552(b)(7)(E). + +BOP has logically and plausibly established that its search was adequate and its withholdings under each of these FOIA exemptions were proper. Accordingly, the Court should grant summary judgment in BOP 's favor. + +### BACKGROUND + +#### I. Criminal Proceedings Against Jeffrey Epstein + +On July 2, 2019, the United States Attorney's Office for the Southern District of New York ("USAO-SDNY") charged Jeffrey Epstein with one count of conspiracy to commit sex trafficking and one count of sex trafficking. See Indictment, Dkt. No. 2, United States v. Epstein, No. 19-cr-490 (RMB) (S.D.N.Y.). Epstein was arrested on July 6, 2019, and thereafter incarcerated at the Metropolitan Correctional Center ("MCC") until his death. Declaration of Russell Capone, Counsel to the Acting United States Attorney for the Southern District of New York ("Capone Declaration") ¶ 4; see Docket Entry dated July 8, 2019, United States v. Epstein, No. 19-cr-490 (RMB) (S.D.N.Y.). On July 23, 2019, Epstein apparently attempted suicide in his cell at the MCC. Capone DecL ¶ 6. On August 10, 2019, Epstein committed suicide in his cell at the MCC. Id. 17. + +### II. Criminal Proceedings Against Tova Noel and Michael Thomas + +On August 9-10, 2019, the night of Epstein's death, Tova Noel and Michael Thomas were correctional officers on duty at the MCC's Special Housing Unit, where Epstein was then housed. Capone DecL ¶ 9. As alleged in the November 19, 2019, indictment against Noel and Thomas, they repeatedly failed to perform mandated counts of prisoners under their watch, including Epstein, and to conceal this failure, they repeatedly signed fake certifications attesting to having conducted multiple counts of inmates. Id.; see Indictment, Dkt. No. 1, United States v. Noel, No. 19-cr-830 (AT) (S.D.N.Y.) (the "Noel Indictment"). As a result of their actions that + +night, Noel and Thomas have been charged with one count of conspiring to defraud the United States and to make or use a false writing or document, and five counts of making or using a false writing or document. See Capone DecL ¶ 9; Noel Indictment. The Noel prosecution is pending before the Honorable Analisa Torres, U.S.D.J., with trial scheduled to begin on January 4, 2021. Capone DecL ¶ 9. + +## III. Criminal Proceedings Against Nicholas Tartaglio nc + +Nicholas Tartaglione has been charged with fifteen criminal violations arising from the murders of Hector Gutierrez, Martin Luna, Urbano Santiago, and Miguel Luna. Id. ¶ 10; see Superseding Indictment, Dkt. No. 120, United States of America v. Tartaglione, No. 16-CR-832 (KMK) (S.D.N.Y.). On April 19, 2019, the USAO-SDNY filed a Notice of Intent to Seek the Death Penalty against Tartaglione. Capone DecL ¶ 10; Notice of Intent to Seek Death Penalty, Dkt. No. 121, United States of America v. Tartaglione, No. I6-CR-832 (KMK) (S.D.N.Y.). Tartaglione has been detained since he was arrested on December 19, 2016. Capone DecL ¶ 11. For certain periods in July 2019—including on July 23, 2019, the night of Epstein's apparent suicide attempt—Tartaglione was housed at the MCC with Epstein as his cellinate. Id. + +## IV. The Times's FOIA Requests and This Action + +On August 13, 2019, the Times submitted two FOIA requests to BOP collectively seeking twenty different categories of documents relating to Epstein. See Declaration of Kara Christenson ("Christenson DecL") ¶¶ 5-6. On September 23, 2019, BOP denied the Times's requests in full based on its determination that any responsive records were exempt from disclosure, in full or in part, under FOIA Exemptions 5, 6, 7(A), 7(C), 7(E), and/or 7(F). Christenson DecL ¶ 7. + +The Times subsequently sent BOP two additional FOIA requests. On December 12, 2019, the Times requested six categories of documents relating to Epstein, id. 19, and on January 2, 2020, the Times requested recordings of Epstein's last three phone calls, id. ¶ 10. + +The Times commenced the present action on January 30, 2020, seeking production of records responsive to its four FOIA requests. See Complaint, Dkt. No. 1. Over the course of three productions on June 22, July 7 and July 10, 2020, respectively, BOP produced approximately 584 pages of responsive records with appropriate redactions. Christenson DecL ¶ 47. Through an agreement between the parties, BOP will continue to produce certain responsive records after the filing of this submission, with the basis for any partial withholdings explained herein. See id.147. + +#### ARGUMENT + +### I. FOIA and the Summary Judgment Standard + +FOIA generally requires federal agencies to make documents and other material "available to the public," see 5U U.S.C. § 552(a), but specifically exempts nine categories of information from that requirement, see id. § 552(b). Congress adopted this structure "to reach a workable balance between the right of the public to know and the need of the [g]overnment to keep information in confidence." John Doe Agency v. John Doe Corp.,493 U.S. 146, 152 (1989) (quoting H.R. Rep. No. 89-147 at 6 (1966), reprinted in 1966 U.S.C.C.A.N. 2418, 2423)). The nine FOIA exemptions reflect Congress's determination that "public disclosure is not always in the public interest." CIA v. Sims, 471 U.S. 159, 166-67 (1985). + +Summary judgment is warranted in a FOR case if the agency submits declarations that (1) supply "facts indicating that the agency has conducted a thorough search" and (2) give "reasonably detailed explanations why any withheld documents fall within an exemption." + +Carney v. DOJ,19 F.3d 807, 812 (2d Cir. 1994).' The agency's declaration is "accorded a presumption of good faith," and discovery is "unnecessary if the agency's submissions are adequate on their face." Id. (internal quotation marks omitted); accord Wilner v. NSA, 592 F.3d 60, 69 (2d Cr. 2009). An agency's justification for asserting an exemption "is sufficient if it appears logical and plausible." Am. Civil Liberties Union v. United States Dep't of Def, 901 F.3d 125, 133 (2d Cir. 2018), as amended (Aug. 22, 2018). + +## IL BOP Conducted an Adequate Search for Responsive Records + +"If an agency demonstrates that it has conducted a reasonable search for relevant documents, it has fulfilled its obligations under FOIA and is entitled to summary judgment on this issue." Garcia v. U.S. Dep't of Justice,181 F. Supp. 2d 356, 366 (S.D.N.Y. 2002). The agency must demonstrate that its search was "reasonably calculated to discover the requested documents." SafeCard Servs., Inc. v. S.E. C., 926 F.2d 1197, 328 (D.C. Cir. 1991). An agency's search may be reasonable even if it does not return every responsive document. See Adamowicz v. I.R.S., 552 F. Supp. 2d 355, 361 (S.D.N.Y. 2008). An agency must only search those "files likely to contain responsive materials (if such records exist)." Oglesby v. U.S. Army, 920 F.2d 57, 68 (D.C. Cir. 1990). Where an agency's declaration demonstrates that it has conducted a reasonable search, "The FOIA requester can rebut the agency's affidavit only by showing that the agency's search was not made in good faith." Maynard v. C.I.A., 986 F.2d 547, 560 (1st Cir. 1993). + +BOP 's declarations demonstrate that its search was reasonable and adequate. Multiple offices at BOP undertook searches for documents responsive to the Times's requests. First, as + +&#x27; Because an agency declaration can satisfy the government's burden on a motion for summary judgment, "Local Civil Rule 56.1 statements are not required." N.Y. Times v. Dep't of Justice, 872 F. Supp. 2d 309, 314 (S.D.N.Y. 2012); Ferguson v. FBI,No. 89 Civ. 5071 (RPP), 1995 WL 329307, at \*2 (S.D.N.Y. June I, 1995), aff'd, 83 F.3d 41 (2d Cir. 19%). + +detailed in the Christenson Declaration, BOP's Central Office searched five electronic systems for records responsive to the Times's requests: SENTRY, TRUVIEW, TRULINCS, GROUPWISE, and TRUINTEL. See, e.g., Christenson DecL ¶¶ 14, 22, 34, 37, 44-46. For the search of each electronic system, the Christenson Declaration explains what the system is, what information it contains, the search methods, and the search parameters that BOP used. See, e.g., id. ¶¶ 14, 22, 34, 37, 44-46. Each search of an electronic system returned responsive records, see id., except for the search of the TRULINCS system, as Epstein apparently did not send or receive emalls on that system, see id.1 37. + +In addition to these searches conducted by the Central Office, individual staff at the MCC conducted searches for records responsive to the Times's request. As detailed in the Declaration of Nicole McFarland, BOP staff conferred to determine which MCC staff members would be likely to have records responsive to the Times's request and identified eight such individuals. See Declaration of Nicole McFarland ("McFarland DecL") ¶ 5. Each individual searched his or her electronic and non-electronic files for records responsive to the FOIA requests. Id. ¶ 6. These searches located memoranda, reports, photographs, and other material responsive to the Times's request, including forms and reports created following Epstein's July 23, 2019, apparent suicide attempt and his August 10, 2019, suicide. See Christenson Dec1 ¶ 32; McFarland DecL ¶¶ 24, 25. + +Based on the foregoing and as described in the Christenson and McFarland Declarations, BOP conducted reasonable and adequate searches, and BOP's motion for summary judgment as to the sufficiency of its search should be granted. + +## III. BOP's Withholdings Were Proper + +### A. BOP Properly Withheld Records and Information Pursuant to FOIA Exemption 7(A) + +#### it. Exemption 7(A) + +As indicated in the index submitted by BOP, see Christenson Decl. Attachment 8, all of the records BOP withheld in full fall within the scope of FOIA Exemption 7(A), except two pages of draft letters and one set of emails discussed below that were properly withheld in full under Exemption 5.2 + +Exemption 7(A), 5 U.S.C. § 552 (b)(7)(A), exempts from disclosure "records or information compiled for law enforcement purposes, but only to the extent that the production of such law enforcement records or information . .. could reasonably be expected to interfere with enforcement proceedings." "To fit within Exemption 7(A), the government must show that (1) a law enforcement proceeding is pending or prospective and (2) release of the information could reasonably be expected to cause some articulable harm." Amnesty Int'l USA v. CIA, 728 F. Supp. 2d 479, 525 (S.D.N.Y. 2010) (internal quotation marks omitted). The term "enforcement proceedings" as used Exemption 7(A) encompasses criminal and civil proceedings, and proceedings must be either pending or reasonably foreseeable at the time of the withholding. See, e.g.,Kay v. F.C.C., 976 F. Supp. 23, 37-38 (D.D.C. 1997) (citing N.L.R.B. v. Robbins Tire & Rubber Co.,437 U.S. 214, 220 (1978)). + +The government's burden to establish the applicability of Exemption 7(A) is not high; the government need only show that "disclosure of particular kinds of investigatory records .. . would generally interfere with enforcement proceedings." Robbins Tire, 437 U.S. at 236 (quotation marks omitted); Radcliffe v. IRS, 536 F. Supp. 2d 423, 437 (S.D.N.Y. 2008). The + +2 For the records withheld in full by BOP, the Court need not reach the applicability of other exemptions if it concludes that GOP's withholdings under Exemption 7(A) were proper, except for the following documents identified on the BOP index: 2 pages of draft letters withheld under Exemption 5's deliberative process privilege and 56 pages of emails withheld under Exemption 5's attorney-client privilege. + +government need only demonstrate a "rational link" between the requested public disclosure and interference with the government's ongoing or prospective investigations or proceedings. See Crooke,. v. Bureau ofAlcohol, Tobacco, and Firearms, 789 F.2d 64, 67 (D.C. Cir. 1986); New York Times Co. v. Dep't opustice, No. 14 Civ. 03776 (AT) (SN), 2016 WL 5946711, at \*7 (S.D.N.Y. Aug. 18, 2016) ("NY Times"). Moreover, Exemption 7(A) permits the categorical wi0nholding of records. See Robbins Tire,437 U.S. at 236. In contrast to some other exemptions, + +the government is not required to make a specific factual showing with respect to each withheld document that disclosure would actually interfere with a particular enforcement proceeding. Rather, federal courts may make generic determinations that, with respect to particular kinds of enforcement proceedings, disclosure of particular kinds of investigatory records while a case is pending would generally interfere with enforcement proceedings. + +Radcliffe, 536 F. Supp. 2d at 437 (quoting Barney v. I.R.S., 618 F.2d 1268, 1273 (8th Cir.1980)). "Exemption 7(A) . .. is designed to block the disclosure of information that will genuinely harm the government's case in an enforcement proceeding or impede an investigation." North v. Walsh, 881 F.2d 1088, 1097 (D.C. Cir. 1989) (R.B. Ginsburg, J.).3 + +## ii The Records Were Compiled for Law Enforcement Purposes + +As a threshold matter, all of the documents withheld by BOP were "compiled for law enforcement purposes," and thus satisfy the threshold requirement of Exemption 7. 5 U.S.C. § 552(b)(7). + +The government has the burden of proving that records were compiled for law enforcement purposes, see Ferguson v. FBI, 957 F.2d 1059, 1070 (2d Cir. 1992), but lbJecause the DOJ is an agency specializing in law enforcement, its claim of a law enforcement purpose is entitled to deference," Ctr. for Nat'l Sec. Studies v. U.S. Dep't of Justice,331 F.3d 918, 926 + +Exemption 7(A) also protects records that, if released, could interfere with post-trial criminal proceedings, such as an appeaL See, e.g.,Kidder v. FBI, 517 F. Supp. 2d 17, 27-28 (D.D.C. 2007); Kansi v. U.S. Dep 't of Justice, 11 F. Supp. 2d 42, 44 (D.D.C. 1998). + +(D.C. CE 2003) (quotation marks and brackets omitted). Records qualify as "compiled for law enforcement purposes" if they "relate to anything that can fairly be characterized as an enforcement proceeding." Shapiro v. U.S. Dep 't of Justice,37 F. Supp. 3d 7, 29 (D.D.C. 2014) (quotation marks omitted). The Tenth Circuit has adopted a "per se rule" that "for an agency like the BOP, whose primary function is law enforcement, all records and information it compiles are in furtherance of its law enforcement function . . . ."Jordan v. U.S. Dep't ofJustice,668 F.3d 1188, 1193-97 (10th Cir. 2011) (characterizing case law from the First, Second, Sixth, and Eighth Circuits as adopting a "per se rule" that all records of law enforcement agencies are compiled for law enforcement purposes) (citing, inter alia, Williams v. F.B.I., 730 F.2d 882, 883- 86 (2d Cir. 1984) (noting that "[t]hroughout the debate on the 1974 amendments, Congress assumed that all investigatory records of the FBI were compiled for a law enforcement purpose")); but see Jordan, 668 F.3d at 1193-94 (noting that an alternative approach, a "rational nexus test" has been adopted by the Third, Ninth, and D.C. Circuits). In Human Rights Watch v. BOP, No. 13-CV-7360 (JPO), 2015 WL 5459713 (S.D.N.Y. Sept. 16, 2015), Judge Oetken concluded that Williams did not require the per se rule, did not adopt the Tenth Circuit's per se rule for BOP records, and followed a "practical approach," observing that "[t]he ordinary understanding of the term [law enforcement] includes proactive steps designed to prevent criminal activity and maintain security." Id. at \*5 (quotation marks and ellipses omitted); see also Opinion and Order, Dkt. No. 59, Gonzalez v. ICE, No. 19-cv-2911 (JGK) (S.D.N.Y. July 29, 2020), slip op. at 27-28 (requiring a "rational nexus" between withheld records and an agency's law enforcement duties). + +As the Tenth Circuit recognized in Jordan, documents created by BOP are compiled for law enforcement purposes because "[t]he BOP is an integral component of a comprehensive + +federal law enforcement system" and because statutory amendments to FOIA have preserved the broad scope of Exemption 7's language. Jordan, 668 F.3d at 1195; see id. at 1196-97 (discussing amendments to Exemption 7); see also Williams, 730 F.2d at 884-85 (discussing amendments to Exemption 7). But even applying a "practical approach" or "rational nexus" standard, the withheld records readily qualify as "compiled for law enforcement purposes." As explained in the Christenson Declaration, the withheld records were compiled to help BOP take "proactive steps designed to prevent criminal activity and maintain security" within the MCC. Human Rights Watch v. BOP, 2015 WL 5459713 at '5; see Christenson DecL ¶ 53. They were compiled, inter alia, to prevent suicides by inmates awaiting trial or sentencing at BOP facilities; to protect the safety, security, and orderly operation of BOP facilities, particularly the MCC, a pretrial detention facility; and to facilitate investigation of the incidents addressed in the records, including Epstein's suicide, which gave rise to a criminal investigation and prosecution. See id. Even if the Court does not apply a per se rule, BOP ' s declarations show that the records at issue were compiled for law enforcement purposes. + +#### iii Disclosure of the Records Would Interfere with Multiple Pending Criminal Proceedings + +Disclosure of the records withheld under Exemption 7(A) would interfere with the pending prosecutions against Noel, Thomas, and Tartaglione, as logically and plausibly explained in the declaration of Russell Capone, who serves as Counsel to the Acting United States Attorney for the Southern District of New York and has a supervisory role with regard to the prosecutions. Capone DecL ¶¶ 1, 9-10, 13-32. The withheld records include possible exhibits at the Noel trial, information about which numerous witnesses are expected to testify, and information and documents authored by potential trial witnesses. See id. ¶¶ 14-25. Premature disclosure of these records or the information contained therein could reasonably be expected to + +influence witnesses' potential testimony at trial, allow witnesses to alter their testimony to conform to other evidence, and/or influence potential juror's perceptions of witness testimony or evidence. See id.; W. Journalism Ctr. v. Office of Indep. Counsel, 926 F. Supp. 189, 192 (D.D.C. 1996) (Exemption 7(A) applies where "[w]itnesses with access to such information could easily alter, conform or construct their testimony depending upon the information disclosed"). This is more than sufficient "to trace a rational link between the nature of the document and the alleged likely interference." NY Times, 2016 WL 5946711, at \*7. + +In addition to interfering with Noel, release of a subset of the withheld records that discuss or refer to Tartaglione (the "Tartaglione Records") would also interfere with the prosecution of Tartaglione. The Tartaglione Records contain information about Tartaglione's conditions of confinement and his interactions with Epstein, which have been put directly at issue by Tartaglione's defense counsel, specifically in connection with the potential penalty phase of the case against Tartaglione. Capone DecL ¶ 29. The Capone Declaration explains how premature release of the Tartaglione Records could reasonably be expected to influence witness testimony and potential juror perceptions of any interactions between Epstein and Tartaglione. See Capone Decl ¶¶ 29-31. These explanations similarly "allow the court to trace a rational link between the nature of the document and the alleged likely interference," NY Times, 2016 WL 5946711, at \*7 (brackets omitted), and provide independent basis for BOP's withholding of the Tartaglione Records under Exemption 7(A), independent of the likely interference with Noel. + +The Capone Declaration's categorical descriptions of the withheld records, and how their premature disclosure under FOIA is reasonably likely to interfere with pending criminal prosecutions, satisfies BOP's burden to justify its withholdings under Exemption 7(A). The Supreme Court has instructed that federal courts may make "generic determinations" "that, with respect to particular kinds of enforcement proceedings, disclosure of particular kinds of investigatory records while a case is pending would generally interfere with enforcement proceedings." Robbins Tire, 437 U.S. at 236 (quotation marks omitted). The particular "kinds of enforcement proceedings" at issue here are among the most sensitive—pending federal criminal prosecutions, including one where the government is seeking the death penalty. And the Capone Declaration logically and plausibly explains how the particular kinds of records at issue—MCC staffing records, BOP records relating to Epstein's apparent suicide attempt and suicide, certain medical and psychological records, documents related to counts of inmates, an August 8, 2019 review of SHU inmates, and emails relating to Epstein—could "generally" be expected to interfere with enforcement proceedings. See Capone DecL ¶¶ 18-23. The Capone Declaration further explains how subcategories of withheld emails—emails pertaining to Epstein's apparent suicide attempt, his incarceration, and his mental health and emails pertaining to Epstein's death—would generally be expected to interfere with enforcement proceedings. See Capone DecL ¶¶ 24-25. It is entirely rational, logical and plausible that, as articulated by a senior prosecutor overseeing the prosecutions at issue, each of these categories and subcategories of documents could improperly influence witnesses and jurors. Under the approach ratified by the Supreme Court in Robbins Tire, BOP properly withheld these records under Exemption 7(A). + +## B. BOP Properly Withheld Records and Information Pursuant to FOIA Exemption 5 + +## i. Exemption 5 and Applicable Privileges + +Exemption 5 of FOIA, 5 U.S.C. § 552(b)(5), exempts from disclosure "inter-agency or intra-agency memorandums or letters which would not be available by law to a party . .. in litigation with the agency." 5 U.S.C. § 552(b)(5). Exemption 5 encompasses the 'deliberative process' or `executive' privilege, which protects the decisionmalcing processes of the executive branch in order to safeguard the quality and integrity of governmental decisions." Hopkins v. U.S. Dep't of Housing and Urban Dev., 929 F.2d 81, 84 (2d Cr. 1991). Information in an agency record must satisfy two criteria to qualify for the deliberative process privilege: it "must be both 'predecisional' and 'deliberative.' Grand Cent P'ship v. Cuomo,166 F.3d 473, 482 (2d Cir. 1999) (quoting Renegotiation Bd. v. Grumman Aircraft Eng'g Corp.,421 U.S. 168, 184 (1975)). + +A document is "predecisional" when it is "prepared in order to assist an agency decisionmaker in arriving at his decision." Grumman, 421 U.S. at 184. While a document is predecisional if it "precedes, in temporal sequence, the 'decision' to which it relates," Grand Cent. P'ship,166 F.3d at 482, the government need not "identify a specific decision" made by the agency to establish the predecisional nature of a particular record. NLRB v. Sears, Roebuck, 421 U.S. 132, 151 n.18 (1975); accord Tigue v. U.S. Dep 't offustice,312 F.3d 70, 80 (2d Cr. 2002). Rather, so long as the document "was prepared to assist [agency] decisionmaking on a specific issue," it is predecisionaL Id. + +"A document is "deliberative' when it is actually . . . related to the process by which policies are formulated." Grand Cent. P'ship,166 F.3d at 482 (internal quotation marks omitted; alteration in original). In determining whether a document is deliberative, courts inquire as to whether it "formed an important, if not essential, link in [the agency's] consultative process," Grand Cent. P 'ship, id. at 483, reflects the opinions of the author rather than the policy of the agency, id. at 483; see Hopkins, 929 F.2d at 84-85, or might 'reflect inaccurately upon or prematurely disclose the views of [the agency]:' Grand Cent. P 'ship, 166 F.3d at 483. + +Separate from the deliberative process privilege, the attorney-client privilege requires "[t]he relationship of attorney and client, a communication by the client relating to the subject matter upon which professional advice is sought, and the confidentiality of the expression for + +which the protection is claimed." United States v. Schwinanzer, 892 F.2d 237, 243 (2d Cir. 1989). "[T]he traditional rationale for the [attorney-client] privilege applies with special force in the government context." In re County of Erie, 473 F.3d 413, 419 (2d Cir. 2007). + +#### ii BOP Properly Withheld Records Pursuant to Exemption 5 + +Some of the withheld records are protected in full or in part by Exemption 5 and the deliberative process privilege. As logically and plausibly explained in the Christenson Declaration, BOP withheld records or information pertaining to four sets of decisions made by BOP. See Christenson DecL ¶¶ 49. Each set of records satisfies the two-prong test to fall within the scope of the deliberative process privilege. + +First, prior to Epstekes suicide, BOP made decisions concerning how to house Epstein and whether or not to house him with a celknate. See Christenson DecL ¶¶ 49a, 49d. The incident report of Epstein's July 23, 2019, apparent suicide attempt, as well as information contained in emails and related documents about Epstein's incarceration prior to his death, are predecisional because they were prepared to assist BOP in making such decisions about Epstein's incarceration. Id. 9 49a, 49d. The documents and withheld information are deliberative because they were part of the process by which BOP made these decisions and "bear on the formulation or exercise of policy-oriented judgment," namely, how to appropriately house Epstein during his incarceration, including following his apparent suicide attempt. Grand Cent P'ship, 166 F.3d at 482; see Christenson DecL ¶¶ 49a, 49d. + +Second, following Epstein's suicide, BOP undertook an investigation into his death and made decisions about how to conduct that investigation and what conclusions—including concerning possible changes to GOP's policies at MCC—should be drawn from it. See id. 49b, 43f. The psychological reconstruction of Epstein's suicide and internal BOP responses + +thereto, as well as information contained in emails and related documents discussing Epstein's suicide and GOP's response to it, are predecisional because they were prepared to assist BOP in making decisions following Epstein's suicide, including possible changes to GOP's suicide prevention policy at MCC. They are deliberative because they bear on BOP 's policies relating to preventing inmate suicides at facilities like MCC, investigating suicides when they occur, and reviewing BOP 's policies at MCC. See id. ¶¶ 49b, 49f. For example, the psychological reconstruction of Epstein's suicide contains multiple recommendations—and responses to certain recommendations—for how MCC should change its suicide prevention policies and measures, such as recommendations about double-ceiling and direct observation of inmates. See id.1 49b. + +Third, the draft letters withheld by BOP are predecisional and deliberative because they precede final versions of those letters, and represent iterative versions as BOP determined how best to present the information in question. See Christenson DecL ¶ 49c. "It is well-settled that draft documents, by their very nature, are typically predecisional and deliberative. They reflect only the tentative view of their authors; views that might be altered or rejected upon further deliberation by their authors or by their superiors." Amnesty Intl USA v. CIA, 728 F. Supp. 2d 479, 518 (S.D.N.Y. 2010) (quotation marks and brackets omitted); see ACLU v. DOJ, 844 F.3d 126, 133 (2d Cir. 2016); NAACP Legal Def. & Educ. Fund, Inc. v. U.S. Dell? of Haus. & Urban Dev., No. 07 Civ. 3378 (GEL), 2007 WL 4233008, at \*11 (S.D.N.Y. Nov. 30, 2007) ("Draft documents, by their very nature, are typically predecisional and deliberative.") + +Fourth, BOP properly withheld information in emails pertaining to press inquiries concerning Epstein and his death and how BOP would respond to them. "Governmental decisions and policies can include the formulation of an agency's statements to the public and other outside entities." Leopold v. Office ofDirector ofNational Intelligence, No. 16-2517 + +(CKK), 2020 WL 805380, at \*5 (D.D.C. Feb. 18, 2020); see id.at \*6 (collecting cases, including from this district, on both sides of the question whether agency communications about how to interact with the public may be subject to the deliberative process privilege and concluding, including by relying on the Second Circuit's decision in ACLU, 844 F.3d at 133, that "[a's long as communications are pre-decisional and deliberative, internal agency communications about public statements can be protected by the deliberative process privilege"). The withheld information in the emails in this case is predecisional and deliberative because it was prepared to assist BOP in its determination of, and were part of the process by which BOP decided, whether and how to change its policies at MCC and whether and how to respond to press inquiries concerning Epstein and his death. See Christenson DecL ¶ 43e. In addition, some of the emails also contain predecisional and deliberative material because they include draft responses to press inquiries. See id.; Amnesty Int'l, 728 F.Supp.2d at 518. + +Separate from the deliberative process privilege, one set of emails withheld in full under Exemption 5 is protected by the attorney-client privilege, as indicated on the BOP index. This group of emails consists of communications between BOP employees and Assistant United States Attorneys in the Civil Division of the USAO-SDNY, which represented BOP in connection with litigation requests for documents related to Epstein, and how to respond to these requests pursuant to Department of Justice regulations (known as Touhy regulations). See Christenson DecL ¶ 50; see also United States ex reL Touhy v. Roger:, 340 U.S. 462 (1951); 28 C.F.R. § 16.21 et seq. As confidential communications between attorneys and a client for the purpose of obtaining and providing legal advice, see Christenson DecL ¶ 50, these emails are privileged and were properly withheld under Exemption 5. + +Under the FOIA Improvement Act of 2016, "[a]n agency shall . . . withhold information under [FOIA] only if . . . (I) the agency reasonably foresees that disclosure would harm an interest protected by an exemption described in subsection (b); or (II) disclosure is prohibited by law." 5 U.S.C. § 552(a)(8)(A)(i). The legislative history of this amendment expressly acknowledges that it "does not alter the scope of information that is covered under an exemption." H.R. Rep. No. 114-391, at 10 (2016). The Christenson Declaration explains how disclosure of the materials withheld under Exemption 5 would harm interests protected by Exemption 5, primarily by hampering the ability of BOP employees to frankly discuss and assess and conditions and incidents at BOP facilities, as well as related BOP policies. See Christenson DecL 149. In addition, disclosure of the emails protected by the attorney-client privilege would impair BOP 's ability to seek out and receive frank and complete advice from legal counsel, which is particularly important for a government agency. See Christenson DecL ¶ 50; Erie, 473 F.3d at 419. + +## C. BOP Properly Withheld Information Pursuant to FOIA Exemptions 6 and 7(C) + +FOIA Exemption 6, 5 U.S.C. § 552(b)(6), protects from disclosure "personnel and medical files and similar files the disclosure of which would constitute a clearly unwarranted invasion of personal privacy." 5 U.S.C. § 552(b)(6). The statutory language concerning files "similar" to personnel or medical files encompasses any "information which applies to a particular individual .. . sought from government records." U.S. Dep't of State v. Washington Post Co., 456 U.S. 595, 602 (1982). Under Exemption 6, a court considers whether the "public interest in disclosure outweighs the individual privacy concerns." Nat'l Assoc. of Hoinebuilders v. Norton, 309 F.3d 26, 35 (D.C. Cr. 2002) (internal quotation marks omitted). But the "only relevant public interest in disclosure to be weighed in this balance is the extent to which + +disclosure would .. . contribut[e] significantly to public understanding of the operations or activities of the government." DOD v. FLRA, 510 U.S. 487, 495 (1994). + +Even more protective of privacy interests, Exemption 7(C), 5 U.S.C. § 552(bX7)(C), exempts from disclosure records or information compiled for law enforcement purposes where its production "could reasonably be expected to constitute an unwarranted invasion of personal privacy." 5 U.S.C. § 552(b)(7)(C). Under Exemption 7(C), a court again "balance[s] the public interest in disclosure against the [privacy] interest." Associated Press v. U.S. Dept of Defense, 554 F.3d 274, 284 (2d Cr. 2009). In this analysis, "[t]here is only one relevant public interest, that of opening agency action to the light of public scrutiny." Id. at 284 (quotation marks and brackets omitted). "The [FOIA requester] must show that the public interest sought to be advanced is a significant one, an interest more specific than having the information for its own sake and . . . must also show the information is likely to advance that interest." Id. + +Some of the records withheld by BOP contain personal information about third parties that, if publicly disclosed, would constitute a clearly unwarranted invasion of privacy, and at a minimum, could reasonably be expected to constitute an unwarranted invasion of personal privacy. These records contain two general categories of personal information: details of Epstein's death and images of his body, and the names, contact information, and other personal details of third-party individuals other than Epstein.4 + +One category of records implicates the privacy interests of Epsteies surviving family members because these records contain highly personal details about his death, including images + +As a threshold matter, each of the records withheld under Exemptions 6 and 7(C) qualifies for the protection of Exemptions 6 and 7 because, with respect to Exemption 6, the records consist of "personnel .. . files," such as overtime logs for MCC, or "similar files" containing information about particular individua Is. See Christenson DecL ¶ 56. These records also qualify for Exemption 7(C) because, as discussed supra, they were compiled for law enforcement PulPoses- + +of his body after his suicide. Christenson Dec1 ¶ 62. The Supreme Court and lower courts have recognized surviving family members's privacy interests in medical records and details of a relative's death. For example, in National Archives & Records Administration v. Favish, 541 U.S. 157, 165-71 (2004), the Supreme Court held that Exemption 7(C) protected death-scene photographs held in law enforcement files because their release could be painful and invasive for surviving family members. See also Eil v. U.S. Drug Enf it Admin., 878 F.3d 392, 400 (1st Cir. 2017) (protecting under Exemption 7(C) medical and death-related records that had been exhibits at criminal trial); New York Tunes Co. v. Nat'l Aeronautics & Space Admin.,782 F. Supp. 628, 631-32 (D.D.C. 1991) (protecting under Exemption 6 audio recording of Challenger astronauts' final moments). On the other side of the Exemption 6 and 7(C) balance, the Times cannot show that disclosure of the information in these records is likely to offer any significant insight into BOP operations. Particularly in light of the New York City Medical Examiner's public conclusion that Epstein hanged himself, the specific details of his suicide or the appearance of his body shortly thereafter do not shed any substantial light on BOP operations. + +The second category of the materials withheld under Exemptions 6 and 7(C) consists of personally identifying information of BOP employees, BOP inmates other than Epstein, visitors or senders of funds to BOP inmates (including but not limited to Epstein), legal counsel for BOP inmates (including but not limited to Epstein), USAO-SDNY employees, and journalists. See Christenson DecL ¶ 61. The Christenson Declaration explains how the balancing test weighs in favor of protecting personally identifying information under Exemptions 6 and 7(C) for each of these categories of individuals. See id. Moreover, the publicity and unfounded speculation surrounding Epstein's death make it more likely that disclosure of personally identifying information of an individual who interacted with Epstein or participated in the response to his + +death would cause an unwarranted invasion of privacy. See Christenson Decl. ¶¶ 58-59. Accordingly, the personally identifying information of third parties other than Epstein contained in these Records is protected from disclosure by Exemptions 6 & 7(C). See Human Rights Watch, 2015 WL 5459713, at\*9-10 (upholding application of Exemptions 6 and 7(C) to withhold details about inmates BOP documents); Billington v. U.S. Dep't of Justice, 301 F. Supp. 2d 15, 19-21 (D.D.C. 2004) (upholding application of Exemption 6 to withhold identity of journalist). + +### D. BOP Properly Withheld Records and Information Pursuant to FOIA Exemption 7(E) + +Exemption 7(E), 5 U.S.C. § 522 (b)(7)(E), exempts from disclosure law enforcement records where release "would disclose techniques and procedures for law enforcement investigations or prosecutions, or would disclose guidelines for law enforcement investigations or prosecutions if such disclosure could reasonably be expected to risk circumvention of the law." Exemption 7(E) contains "two alternative clauses," one covering "techniques and procedures," and the other addressing "guidelines." Allard K. Lowenstein Int'l Human Rights Project v. Dep 't of Homeland Sec., 626 F.3d 678, 680-81 (2d Cir. 2010). The first clause of Exemption 7(E) provides categorical protection to information that would disclose law enforcement "techniques and procedures," without requiring any showing of harm as a result of disclosure. See id. at 681. While Exemption 7(E) generally covers only "investigatory records that disclose investigative techniques and procedures not generally known to the public," Doherty v. U.S. Dep't of Justice, 775 F.2d 49, 52 n.4 (2d Cr. 1985), "even commonly known procedures may be protected from disclosure if the disclosure could reduce or nullify their effectiveness," Judicial Watch, Inc. v. U.S. Dep 7 of Conunerce,337 F. Supp. 2d 146, 181 (D.D.C. 2004) + +As indicated on the BOP index, some of the records withheld by BOP fall within the scope of Exemption 7(E) because they contain information or discussion of sensitive law enforcement techniques and procedures.5 As explained in the Christenson Declaration, release of these records would disclose GOP's law enforcement techniques and procedures for preventing and investigating suicides, suicide attempts, and other incidents within its facilities. See Christenson DecL ¶¶ 65-68. Release of these records, particularly the Inmate Investigative Report, would reveal how BOP responds to and investigates certain incidents at facilities. And although BOP need not make a specific showing of a risk of circumvention of the law in order to withhold techniques and procedures under Exemption 7(E), BOP has explained that releasing these records would make it easier for inmates to circumvent measures designed to prevent suicides, as well as GOP's investigatory techniques and procedures. Id. Accordingly, BOP properly withheld these records under Exemption 7(E). See Jordan, 668 F.3d at 1201 (upholding application of Exemption 7(E) to BOP psychological records). + +## E. BOP Properly Withheld Information Pursuant to FOIA Exemption 7(F) + +Exemption 7(F), 5 U.S.C. § 522 (b)(7)(F), exempts from disclosure law enforcement records where release "could reasonably be expected to endanger the life or physical safety of an individua L" "Exemption 7(F) was enacted to protect the safety of individuals involved in law enforcement investigations." ACLU v. DOD, 389 F. Supp. 2d 547, 576 (S.D.N.Y. 2005). Application of Exemption 7(F) "is appropriate . . . where disclosure of identifying information would put the life and physical safety of law enforcement agents and other third parties in danger." Gonzalez No. 19-cv-2911, slip op. at 34. "An agency's burden to prove that disclosure + +s As discussed supra, all of these records were compiled for law enforcement purposes. + +would result in the endangerment of life or physical safety is a low one." Gonzalez,No. 19-cv-2911, slip op. at 33 (quotation marks omitted). + +The personally identifying information of BOP employees described above as protected under Exemptions 6 and 7(C) is also protected by Exemption 7(F). As described in the Christenson Declaration, BOP employees work with inmates who, during or after their incarceration, might target such employees for reprisals. Christenson DecL ¶ 25. Releasing the personally identifying information of such individuals would increase the risk of such targeting by making it easier for government staff to be identified and located. See id. These concerns are heightened because of the media attention and public speculation surrounding Epstein's death. See id. Accordingly, BOP properly withheld the personally identifying information of BOP employees under Exemption 7(F). See Jordan, 668 F.3d at 1198 (upholding application of Exemption 7(F) to BOP Supermax roster); Pinson v. Dep 't opustice, 236 F. Supp. 3d 388, 370 (D.D.C. 2017) (upholding application of Exemption 7(F) to BOP assignment rosters). + +### IV. BOP Has Satisfied Its Duty to Segregate and Release Any Non-Exempt Information + +FOIA requires that "[a]ny reasonably segregable portion of a record shall be provided to any person requesting such record after deletion of the portions which are exempt under this subsection." 5 U.S.C. § 552(b). Where, as here, an agency asserts Exemption 7(A) by describing the categories of records it has withheld, the government satisfies this obligation by explaining why those categories of records do not contain reasonably segregable non-exempt information. See, e.g.,Robbins, Geller, Rudman & Dowd, LLP v. United States Sec. & Exch. Comm'n, No. 3:14-CV-2197, 2016 WL 950995, at \*9 (M.D. Tenn. Mar. 12, 2016) (citing examples). Moreover, nonexempt portions of documents may "be withheld if they are inextricably intertwined with the exempt portions." Conti v. U.S. Dep't of Homeland Sec., No. 12 Civ. 5827 + +(AT), 2014 WL 1274517, at \*25 (S.D.N.Y. Mar. 24, 2014) (quotation marks omitted). "The agency is entitled to a presumption that it complied with its obligation to disclose reasonably segregable materiaL" Id. + +In the present case, BOP has already produced 584 pages of records, with appropriate redactions, in response to the Times's FOIA requests and intends to produce more. Christenson DecL 147. The records withheld in full by BOP do not contain any reasonably segregable nonexempt information. See Christenson DecL ¶¶ 47. With regard to the records withheld in full under Exemption 7(A), the Capone Declaration explains that, to the extent there is non-exempt information contained in the records withheld under Exemption 7(A), that information is intertwined with exempt information and cannot reasonably be segregated without risking interference with the Noel and Tartaglione prosecutions. Capone DecL ¶ 34. The public speculation and unfounded theories about Epstein's death make segregation particularly difficult because the provision of information related to Epstein without complete context risks compounding the unfounded speculation about Epstein's death, and heightening the risk of interference with Noel and Tartaglione. Id. As to the remaining records withheld in full, either the records are privileged in their entirety (e.g., as attorney-client communications or draft documents) or any non-exempt information in the documents is inextricably intertwined with exempt information, such that segregating any non-exempt information would be of little to no informational value. See Christenson DecL ¶ 47. Accordingly, BOP has satisfied its obligation to reasonably segregate any non-exempt portions of the records withheld in full. + +## CONCLUSION + +For the foregoing reasons, the Court should grant the government's motion for summary judgment. + +Dated: New York, New York August 5, 2020 + +Respectfully submitted, + +AUDREY STRAUSS Acting United States Attorney for the Southern District of New York Counsellor Defendant + +By: + +![](_page_29_Picture_5.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00088671/EFTA00088671.metadata.json b/marker2/ds9/EFTA00088671/EFTA00088671.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..08f77cdeb3ca7c4ddcb4cd57a083cccf3fc11d80 --- /dev/null +++ b/marker2/ds9/EFTA00088671/EFTA00088671.metadata.json @@ -0,0 +1,1782 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00088671.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 30, + "chars": 54705, + "elapsed_seconds": 9.6, + "image_assets": [ + "_page_0_Picture_76.jpeg", + "_page_0_Picture_77.jpeg", + "_page_29_Picture_5.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "MEMORANDUM OF LAW IN SUPPORT OF THE FEDERAL BUREAU OF PRISONS'S MOTION FOR SUMMARY JUDGMENT", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 70.38, + 311.85 + ], + [ + 541.62, + 311.85 + ], + [ + 541.62, + 344.25 + ], + [ + 70.38, + 344.25 + ] + ] + }, + { + "title": "TABLE OF CONTENTS", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 235.00799999999998, + 86.67 + ], + [ + 372.3465881347656, + 86.67 + ], + [ + 372.3465881347656, + 101.72406005859375 + ], + [ + 235.00799999999998, + 101.72406005859375 + ] + ] + }, + { + "title": "TABLE OF AUTHORITIES", + "heading_level": null, + "page_id": 2, + "polygon": [ + [ + 228.276, + 72.08999999999999 + ], + [ + 384.0433349609375, + 72.08999999999999 + ], + [ + 384.0433349609375, + 85.8170166015625 + ], + [ + 228.276, + 85.8170166015625 + ] + ] + }, + { + "title": "Statutes", + "heading_level": null, + "page_id": 4, + "polygon": [ + [ + 67.932, + 651.24 + ], + [ + 112.59126281738281, + 651.24 + ], + [ + 112.59126281738281, + 668.1035308837891 + ], + [ + 67.932, + 668.1035308837891 + ] + ] + }, + { + "title": "Regulations", + "heading_level": null, + "page_id": 5, + "polygon": [ + [ + 67.932, + 69.66 + ], + [ + 129.62258911132812, + 69.66 + ], + [ + 129.62258911132812, + 85.85999999999999 + ], + [ + 67.932, + 85.85999999999999 + ] + ] + }, + { + "title": "PRELIMINARY STATEMENT", + "heading_level": null, + "page_id": 6, + "polygon": [ + [ + 219.70799999999997, + 72.9 + ], + [ + 391.927978515625, + 72.9 + ], + [ + 391.927978515625, + 86.103515625 + ], + [ + 219.70799999999997, + 86.103515625 + ] + ] + }, + { + "title": "BACKGROUND", + "heading_level": null, + "page_id": 7, + "polygon": [ + [ + 257.652, + 153.89999999999998 + ], + [ + 353.4814453125, + 153.89999999999998 + ], + [ + 353.4814453125, + 168.603515625 + ], + [ + 257.652, + 168.603515625 + ] + ] + }, + { + "title": "I. 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FEDERAL BUREAU OF PRISONS, Defendant. X + +# MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFF'S CROSS-MOTION FOR SUMMARY JUDGMENT AND IN OPPOSITION TO DEFENDANT'S MOTION FOR SUMMARY JUDGMENT + +David E. McCraw Al-Amyn Sumar Alexandra Perloff-Giles The New York Times Company Legal Department 620 Eighth Avenue New York, NY 10018 Phone: 212-556-4031 Facsimile: (212) 556-4634 Email: mccraw@nytimes.com + +Counsel for Plaintiff + +## TABLE OF CONTENTS + +| TABLE OF AUTHORITIES | iii | +|-----------------------------------------------------------------------------|-----| +| PRELIMINARY STATEMENT | 1 | +| FACTUAL BACKGROUND | 2 | +| I. Epstein's Arrest and Suicide | 2 | +| II. Procedural History | 4 | +| ARGUMENT | 5 | +| I. The Government Has Not Met Its Burden of Showing the Search was Adequate | 6 | +| 7(A) | 8 | +| and 7(C) | 13 | +| 7(E) | 21 | +| CONCLUSION | 23 | + +## TABLE OF AUTHORITIES + +## CASES + +| ACLU Found. v. Dep't of Homeland Sec. , | | +|------------------------------------------------------------------------------|-------| +| 243 F. Supp. 3d 393 (S.D.N.Y. 2017)..... | 21 | +| Albuquerque Publ'g Co. v. U.S. Dep't of Justice , | | +| 726 F. Supp. 851 (D.D.C. 1989)..... | 21 | +| Am. Civil Liberties Union v. Dep't of Def. , | | +| 543 F.3d 59 (2d Cir. 2008)..... | 5 | +| Assoc. Press v. U.S. Dep't of Defense , | | +| 554 F.3d 274 (2d Cir. 2009)..... | 5 | +| Associated Press v. U.S. Dep't of Def. , | | +| 554 F.3d 274 (2d Cir. 2009)..... | 14 | +| Bloomberg, L.P. v. Bd. of Governors of the Fed. Reserve Sys. , | | +| 601 F.3d 143 (2d Cir. 2010)..... | 5, 6 | +| Campbell v. Dep't of Health and Human Servs. , | | +| 682 F.2d 256 (D.C. Cir. 1982)..... | 9 | +| Church of Scientology v. U.S. Dep't of the Army , | | +| 611 F.2d 738 (9th Cir. 1979)..... | 9 | +| Cook v. Nat'l Archives & Records Admin. , | | +| 758 F.3d 168 (2d Cir. 2014)..... | 17 | +| Ctr. for Investigative Reporting v. U.S. Customs & Border Prot. , | | +| 2019 U.S. Dist. LEXIS 223077 (D.D.C. Dec. 31, 2019)..... | 20 | +| Dep't of Air Force v. Rose , | | +| 425 U.S. 352 (1976)..... | 5, 14 | +| Dep't of Interior v. Klamath Water Users Protective Ass'n , | | +| 532 U.S. 1 (2001)..... | 18 | +| Dep't of Justice v. Reporters Comm. for Freedom of the Press , | | +| 489 U.S. 749 (1989)..... | 2 | +| Diamond v. FBI , | | +| 707 F.2d 75 (2d Cir. 1983)..... | 14 | +| Doherty v. U.S. Dep't of Justice , | | +| 775 F.2d 49 (2d Cir. 1985)..... | 21 | +| Envt'l Prot. Agency v. Mink , | | +| 410 U.S. 73 (1973)..... | 19 | +| Gentile v. State Bar of Nev. , | | +| 501 U.S. 1030 (1991)..... | 12 | +| Gonzalez v. U.S. Citizenship & Immigration Servs. , | | +| 2020 U.S. Dist. LEXIS 134482 (S.D.N.Y. July 29, 2020)..... | 9 | + +| Grand Central p'ship, Inc. v. Cuomo, | | +|--------------------------------------------------------------------------------------------------------|--------| +| 166 F.3d 473 (2d Cir. 1999) | 18, 19 | +| 742 F. Supp. 2d 68 (D.D.C. 2010) Hopkins v. U.S. Dep't of Hous. & Urban Dev., | 9 | +| 929 F.2d 81 (2d Cir. 1991) | 19 | +| 2015 U.S. Dist. LEXIS 123592 (S.D.N.Y. Sept. 16, 2015) Judicial Watch, Inc. v. U.S. Dep't of Commerce, | 9 | +| 375 F. Supp. 3d 93 (D.D.C. 2019) | 20 | +| 407 F. Supp. 3d 334 (S.D.N.Y. 2019) Kubik v. U.S. Fed. Bureau of Prisons, | 21 | +| 2011 U.S. Dist. LEXIS 71300 (D. Or. July 1, 2011) Lawyers Conun. for Human Rights v. INS, | 21 | +| 721 F. Supp. 552 (S.D.N.Y. 1989) Local 3, Intl Bhd. of Elec. Workers v. NLRB, | 11 | +| 845 F.2d 1177 (2d Cir. 1988) Malizia v. U.S. Dep't ofJustice, | 19 | +| 519 F. Supp. 338 (S.D.N.Y. 1981) Maydak v. U.S. Dep't ofJustice, | 9 | +| 218 F.3d 760 (D.C. Cir. 2000) | 9, 13 | +| 566 F.2d 242 (1977) Meyer v. Bush, | 6 | +| (D.C. Cir. 1993) Morley v. C.I.A., | 7 | +| 508 F.3d 1108 (D.C. Cir. 2007) Multi Ag Media LLC v. Dep't ofAgric., | 14 | +| 515 F.3d 1224 (D.C. Cir. 2008) N.Y. Times Co. v. FCC, | 14 | +| 2020 U.S. Dist. LEXIS 76710 (S.D.N.Y. Apr. 30, 2020) N.Y. Times Co. v. U.S. Dep't ofJustice, | 17 | +| 872 F. Supp. 2d 309 (S.D.N.Y. 2012) Nat'l Archives & Records Admin. v. Favish, | 3 | +| 541 U.S. 157 (2004) Nat'l Council of La Raza v. Dep't ofJustice, | 15 | +| 411 F.3d 350 (2d Cir. 2005) | 6 | + +| NLRB v. Robbins Tire & Rubber Co., | | +|-----------------------------------------------------------------------------------|-------| +| 437 U.S. 214, 227 (1978) NRDC v. EPA, | 9, 10 | +| 2019 U.S. Dist. LEXIS 124353 (S.D.N.Y. July 25, 2019) Pratt v. Webster, | 20 | +| 673 F.2d 408 (D.C. Cir. 1982) Radcliffe v. IRS, | 9 | +| 536 F. Supp. 2d 423 (S.D.N.Y. 2008) United States v. Noel, | 10 | +| No. 19-CR-00830-AT (S.D.N.Y. June 9, 2020) U.S. Dep't of Justice v. Tax Analysts, | 13 | +| 492 U.S. 136 (1989) U.S. Dep't of State v. Ray, | 6,7 | +| 502 U.S. 164 (1991) Wessler v. U.S. Dep't of Justice, | 5 | +| 381 F. Supp. 3d 253 (S.D.N.Y. 2019) Wither v. NSA, | 15 | +| 592 F.3d 60 (2d Cir. 2009) Wood v. F.B.I., | 6 | +| 432 F.3d 78 (2d Cir. 2005) | 6 | + +## STATUTES + +## OTHER AUTHORITIES + +| Suicide, N.Y. Times (Aug. 16, 2019) | 16 | +|---------------------------------------------------------|----| +| Epstein (Aug. 17, 2019) | 16 | +| Hours; Guard Was Substitute, N.Y. Times (Aug. 12, 2019) | 1 | +| 2011) | 21 | +| Brother Says, Miami Herald (Nov. 14, 2019) | 15 | + +| Matt Zapotosky, | Trump questions whether Jeffrey Epstein was killed in federal custody. His | +|---------------------------------------------------------------------------|----------------------------------------------------------------------------| +| (Aug. 4, 2020) | 1, 18 | +| And Records Surrounding His Apparent Suicide (Aug. 12, 2019) | 8 | +| 2015) | 16 | +| Communications to Prevent Radicalization (March 2020) | 17 | +| Day in Court, N.Y. Times (Nov. 29, 2018) | 2 | +| S. Rep. No. 114-4, at 8 (2015) | 20 | +| Lenient Than Anyone Knew, S. Fla. Sun Sentinel (Aug. 16, 2019) | 16 | +| N.Y. Times (Aug. 19, 2019) | 16 | +| (Apr. 2010) | 22 | +| Prevention (1995) | 21, 22 | +| World Health Organization, Preventing Suicide in Jails and Prisons (2007) | 22 | + +Plaintiff The New York Times Company ("The Times") respectfully submits this memorandum of law in opposition to the motion for summary judgment by Defendant Federal Bureau of Prisons ("BOP") and in support of The Times's cross-motion for summary judgment on its complaint brought under the Freedom of Information Act ("FOIA"). + +### PRELIMINARY STATEMENT + +Financier Jeffrey Epstein's suicide in August 2019, and subsequent revelations about what Attorney General William Barr called the Metropolitan Correctional Center's (MCC) "failure to adequately secure this prisoner," led to widespread calls for accountability and reform. Ali Watkins, Katie Benner & Danielle Ivory, In Short-Staffed Jail, Epstein Was Left Alone for Hours; Guard Was Substitute, N.Y. Times (Aug. 12, 2019), https://nyti.ms/2F9mXzs. The Federal Bureau of Investigation, the Department of Justice's Inspector General, and the Bureau of Prisons itself all launched investigations. For his part, the President has suggested that Epstein was "killed" while in federal custody. Matt Zapotosky, Trump questions whether Jeffrey Epstein was killed in federal custody. His attorney general and the medical examiner say it was suicide, Wash. Post (Aug. 4, 2020), https://wapo.st/2Zij5mA. As part of the public scrutiny of the "serious irregularities" at the facility, reporters at The Times filed several Freedom of Information Act requests, seeking records that would shed light on the conditions of Epstein's confinement and the circumstances surrounding his death. + +BOP has withheld or heavily redacted thousands of pages of records responsive to those requests, citing a smattering of FOIA exemptions. Among other things, the Government has improperly invoked FOIA's privacy exemptions to shield information that is in the public interest, failed to justify the withholding of other information as deliberative under Exemption 5, and made no credible argument that disclosure of materials will reveal secret law enforcement techniques. In addition, BOP has failed to fulfill its obligations to search records in its custody. + +But the crux of this case is BOP's unsupportable reliance on Exemption 7(A) to withhold thousands of pages of documents in whole or in part. The Government contends that disclosure of the records would interfere with the pending prosecutions of Nicholas Tartaglione (an ex-cop charged in four drug-related killings, who at one time shared a cell with Epstein), and of the two correctional officers on duty the night Epstein committed suicide, who are accused of falsifying paperwork to hide the fact that they were shopping for furniture online rather than completing their rounds. But the records at issue—e-mails, reports, and observation logs about Epstein's mental health; correspondence about Epstein's incarceration prior to his suicide; photos of the suicide; records of who visited or communicated with Epstein while he was in jail; and the like bear no relationship to the charges at issue in those criminal prosecutions. + +Because the Government has not met its burden of justifying withholding under FOIA, and consistent with "the basic purpose of the Freedom of Information Act 'to open agency action to the light of public scrutiny,'" Dep't of Justice v. Reporters Comm. for Freedom of the Press, 489 U.S. 749, 772 (1989), the records must be disclosed. + +## FACTUAL BACKGROUND + +## I. Epstein's Arrest and Suicide + +Until 2019, Jeffrey Epstein, a financier with connections to powerful people in politics, law, and academia, had never been held accountable for sexually abusing dozens of girls, including runaways and foster children, some as young as 14 or 15. See Patricia Manzi, Years After Plea Deal in Sex Case, Jeffrey Epstein's Accusers Will Get Their Day in Court, N.Y. Times (Nov. 29, 2018) https://nyti.ms/2R5uf9L. In 2007, Epstein took a plea deal, avoiding federal criminal charges and instead pleading guilty to lesser state charges of soliciting prostitution and serving a jail sentence under terms that permitted him to work out of his office six days a week. See id. Epstein's luck ran out when, on July 2, 2019, he was charged with one count of + +conspiracy to commit sex trafficking, in violation of 18 U.S.C. § 371, and one count of sex trafficking, in violation of 18 U.S.C. § 1591. (See Declaration of Russell Capone, ECF No. 22 [hereinafter "Capone Decl."], at ¶ 4.) On July 6, 2019, he was arrested and charged by federal prosecutors and thereafter incarcerated at the MCC. (Id.) On July 10, 2019, Epstein was assigned to the Special Housing Unit ("SHU'), at least in part because of the risk of suicidal ideation. (Id. 1 5.) Nonetheless, on July 23, 2019, Epstein was found on the floor of his cell with a strip of bedsheet around his neck, having apparently attempted suicide. (Id. ¶ 6.) Epstein was then transferred out of the SHU, placed on suicide watch for 24 hours, and then put under psychological observation in MCC's hospital ward. (Id.) On July 30, 2019, Epstein was transferred back to the SHU. (Id.) On August 10, 2019, Epstein was found unresponsive in his cell with a noose around his neck. (Id. 1 7.) An autopsy confirmed that he had committed suicide by hanging himself. (Id.) + +Since then, charges have been brought against Michael Thomas and Tova Noel, both correctional officers on duty at the SHU the night of Epstein's death, who allegedly failed to perform prisoner counts and then signed false certifications to conceal their failure to conduct those required counts. (Id. ¶ 9.) Also pending is federal prosecutors' case against Nicholas Tartaglione, who was charged in 2016 with killing four people in connection with a drugtrafficking crime. Tartaglione, for a time, was Epstein's cell mate—including on July 23, 2019, when Epstein first attempted suicide—but not after that.' (M. 10-11.) + +I Like the Government, and in accordance with the practice in FOIA cases in this District, The Times has not submitted a Local Rule 56.1 statement. See N.Y. Times Co. v. U.S. Dep't of Justice, 872 F. Supp. 2d 309, 314 (S.D.N.Y. 2012) ("[T]he general rule in this Circuit is that in FOR actions, ... Local Civil Rule 56.1 statements are not required."). + +### II. Procedural History + +The history of The Times's attempt to obtain public records in this case has been marked by BOP delay. On August 13, 2019, BOP received two FOIA requests from The Times, each seeking several categories of documents related to Epstein. (See Declaration of Kara Christenson, ECF No. 24 [hereinafter "Christenson Decl."], at ¶¶ 5-6.) BOP consolidated the requests and, on September 23, 2019, BOP denied the request in full, asserting that "any records responsive to your request are categorically exempt from disclosure" and that it would therefore not conduct a search. (Id. 1 7.) On October 3, 2019, The Times appealed the denial of those two requests. On December 12, 2019, while that appeal was pending, The Times submitted a third FOIA request for additional information, including Epstein's call log, e-mail correspondence while at MCC, visitor log, and lists of approved visitors, callers, and e-mail correspondents. (Id. ¶ 9.) On January 2, 2020, The Times submitted a fourth FOIA request, based on new information it learned, for recordings of the last three phone conversations Epstein had before he died. (ld.1 10.) + +On January 30, 2020, having not received documents responsive to any of the four requests, The Times filed this action. For a time, BOP doubled-down on its refusal to release any documents. On March 5, 2020, BOP responded to The Times's October 3, 2019 administrative appeal, affirming the denial of the request. Then, on April 15, 2020, the parties submitted a joint letter to the Court, in which BOP laid out its position that "any documents potentially responsive to the Times's request are exempt from disclosure under FOIA." ECF No. II. + +Only when this Court became involved did BOP finally acknowledge its obligations to abide by FOIA's dictates. After a conference with the Court on April 20, 2020, at which the Court ordered BOP to file its motion for summary judgment by June 22, 2020, BOP belatedly changed course. On June II, 2020, BOP told the Court that it now intended to disclose some + +records responsive to The Times's request and would complete its disclosure of records by July 7, 2020, and accordingly sought to postpone the deadline to file its motion for summary judgment to July 22, 2020. + +On June 22, July 7, and July 10, 2020, BOP made three productions of documents to The Times. With respect to the first production, BOP released 10 pages in full and nine heavily redacted pages and withheld 434 pages in their entirety. With respect to the second, BOP released 66 pages in full and 328 redacted pages and withheld 1,093 pages. With respect to the third, BOP released 56 pages in full, redacted 67 pages, and withheld 1,566 pages. BOP subsequently discovered that additional documents had been "inadvertently omitted from its search" and sought an additional extension of time to file its opening brief. ECF No. 18. On August 5, 2020, BOP filed its motion for summary judgment. On August 11, 2020, BOP produced an additional five pages in full and 72 heavily redacted pages. On August 31, BOP produced a further 12 pages in full and 339 pages in part and withheld 135 pages. In total, BOP is withholding more than 3,000 pages, with another 800-plus pages redacted. + +## ARGUMENT + +FOIA requires that government records be made available to the public unless a statutory exemption applies. 5 U.S.C. § 552(a)(3)(A), (b)(1)—(9). "The basic purpose of FOIA reflect[s] a general philosophy of full agency disclosure." Bloomberg, LP. v. Bd. of Governors of the Fed. Reserve Sys., 601 F.3d 143, 147 (2d Cir. 2010) (quoting Dep't of the Air Force v. Rose, 425 U.S. 352, 360-61 (1976) (alterations omitted)). In light of this purpose, "FOIA exemptions are to be construed narrowly." Associated Press v. U.S. Dep't of Def., 554 F.3d 274, 283 (2d Cir. 2009). There is a "strong presumption in favor of disclosure [that] places the burden on the agency to justify the withholding of any requested documents." Id. (quoting U.S. Dep't of State v. Ray, 502 U.S. 164, 173 (1991)); see Halpern v. FBI, 181 F.3d 279, 286 (2d Cir. 1999). "[W]hen an agency seeks to withhold information it must provide a relatively detailed justification, specifically identifying the reasons why a particular exemption is relevant and correlating those claims with the particular part of a withheld document to which they apply." Mead Data Cent., Inc. v. U.S. Dep't of the Air Force, 566 F.2d 242, 251 (D.C. Cir. 1977); see 5 U.S.C. § 552(b) (requiring the government to disclose "the exemption under which [each] deletion is made"). Failure to meet that burden requires disclosure of the requested documents. See Nat'l Council of La Raza v. Dep't of Justice, 411 F.3d 350, 355-56 (2d Cir. 2005). + +A court reviews de novo an agency's decision to withhold information from the public. See 5 U.S.C. § 552(a)(4)(B). The agency's decision as to the applicability of a given exemption is entitled to no judicial deference. See Bloomberg, 601 F.3d at 147. Although courts review reasonably detailed agency affidavits with a presumption of good faith, this primarily is for determining the need for further fact-finding. See, e.g., Wood v. FBI, 432 F.3d 78, 85 (2d Cir. 2005); see also Wither v. NSA, 592 F.3d 60, 69, 73 (2d Cir. 2009) (presumption does not replace de novo review by courts). + +The Government contends that the withheld information is exempt under FOIA Exemptions 7(A), 6, 7(C), 5, and 7(E).2 None of those exemptions justifies the extent of BOP's redactions and withholdings here. + +## I. The Government Has Not Met Its Burden of Showing the Search was Adequate + +FOIA requires agencies to make reasonable efforts to locate responsive "agency records." 5 U.S.C. § 552(a)(3). Two requirements must be satisfied for materials to be deemed "agency records." U.S Dep't ofJustice v. Tax Analysts, 492 U.S. 136, 144-45 (1989). First, the agency + +2 The Times does not challenge the withholding of information protected by the attorney-client privilege. The Times also does not challenge the Government's withholding of the personally identifying information of BOP employees under Exemptions 6, 7(C), and 7(F). + +must "either create or obtain the requested materials." Id. at 144 (internal quotation marks and citation omitted). Second, "the agency must be in control of the requested materials at the time the FOIA request is made." Id. at 145 (emphasis added). The Supreme Court was clear on what constitutes "control" for FOIA purposes: "By control we mean that the materials have come into the agency's possession in the legitimate conduct of its official duties." Id. Put simply, FOIA requires an agency to produce records under its control on the date the FOIA request comes in. + +Here, BOP ignores that rule. It contends that it does not have possession of certain records, and therefore cannot produce them in response to The Times's requests, because it has turned those records over to other agencies. Specifically, BOP contends that it cannot produce the SHU log books showing when prison staff did rounds on certain days because they "were handed over to the Office of the Inspector General (`OIG') on or about August 22, 2019," and therefore "the BOP is no longer in possession of the log books" (Christenson Decl. 1 13; Declaration of Nicole McFarland, ECF No. 23 [hereinafter "McFarland Decl."], at ¶ 8). But, as BOP concedes, BOP received a FOIA request from The Times on August 13, 2019, seeking those logs for July 22 and 23 and August 9 and 10. (Christenson Decl. ¶ 5.) Accordingly, "at the time the FOIA request [was] made," BOP was in control of the requested records. See Tax Analysts, 492 U.S. at 145. BOP had a duty to preserve those documents and cannot now exclude them from the universe of responsive documents on the ground that it gave them away nine days after receiving The Times's request. See Meyer v. Bush, 1991 U.S. Dist. LEXIS 13626, at \*32 n.44 (D.D.C. Sept. 30, 1991), rev'd on other grounds, 981 F.2d 1288 (D.C. Cir. 1993) (indicating that, when an agency transfers records after receiving a FOIA request, it "would have to suffer the consequences of [its] improper transfer and search those records, as well"). + +Similarly, BOP asserts that it cannot produce certain physical visitor logs because they "were handed over to the OIG on or about August 22, 2019, and BOP is no longer in possession of these logs." (Christenson Decl. ¶ 39; McFarland Dec1.11 17, 30). But, again, BOP had already received at least one FOIA request for the physical logs before it handed over the documents: On August 12, 2019, the National Legal and Policy Center submitted a FOIA request to BOP by email, seeking, among other records, visitor logs of Epstein from July 23, 2019 to August 10, 2019." See National Legal and Policy Center, NLPC Files FOIA Request Seeking Photos Of Jeffrey Epstein And Records Surrounding His Apparent Suicide (Aug. 12, 2019), https://pm.to/3m1d0Vo• FOIA Request from Paul D. Kamenar, Counsel for NLPC, to BOP FOIA Officer (Aug. 12, 2019), https://bit.ly/2DGhxv9. Accordingly, under Tax Analysts, BOP had an obligation to preserve copies of the physical logs as of August 12, 2019, and should have produced them in response to The Times's request.; + +## II. The Government Has Not Met Its Burden of Justifying Withholding Under Exemption 7(A) + +The Government contends that essentially all of the undisclosed records at issue may be withheld under Exemption 7(A). (See Mem. of L. in Supp. of the Fed. Bureau of Prisons' Mot. for Summ. J., ECF No. 25 [hereinafter "Gov't Br."], at 7.) Exemption 7(A) permits withholding of "records or information compiled for law enforcement purposes, but only to the extent that production of such law enforcement records or information ... could reasonably be expected to interfere with enforcement proceedings." 5 U.S.C. § 552(b)(7)(A). "The principal purpose of Exemption 7(A) is to prevent disclosures which might prematurely reveal the government's + +BOP also contends that it cannot produce video camera footage relevant to Epstein's suicide and to Epstein's earlier suicide attempt because "all video/NICE vision equipment was handed over to the FBI on or about August 10, 2019." (Christenson Decl. ¶ 28.) Given GOP's record of disregarding its FOIA obligations in this case, BOP should be required to establish that it had no pending FOIA requests for the footage at the time of the turnover to the FBI. + +cases in court, its evidence and strategies, or the nature, scope, direction, and focus of its investigations, and thereby enable suspects to establish defenses or fraudulent alibis or to destroy or alter evidence." Maydak v. U.S. Dep't of Justice, 218 F.3d 760, 762 (D.C. Cir. 2000) (citing NLRB v. Robbins Tire & Rubber Co., 437 U.S. 214, 227 (1978)). The agency affidavits or declarations "must demonstrate specifically how each document or category of documents, if disclosed, would interfere." Gray v. United States Army Crim. Investigation Command, 742 F. Supp. 2d 68, 74 (D.D.C. 2010); Campbell v. Dep't of Health and Human Servs., 682 F.2d 256, 265 (D.C. Cir. 1982). + +To invoke Exemption 7(A), an agency must meet two requirements, neither of which is met here. First, BOP must establish a rational nexus between the documents withheld and enforcement of a federal law. See, e.g., Gonzalez v. U.S. Citizenship & Immigration Servs., 2020 U.S. Dist. LEXIS 134482, at \*27 (S.D.N.Y. July 29, 2020) ("To show that particular documents qualify as `records or information compiled for law enforcement purpose,' an agency must establish a rational nexus between the agency's activity in compiling the documents and its law enforcement duties.'")4 Second, BOP must establish that production of the records is likely to + +4 The Government suggests that because BOP is a law enforcement agency, any BOP records qualify as law enforcement records. But, as the Government cannot help but acknowledge, courts in this circuit—like the Ninth Circuit and the D.C. Circuit—have squarely rejected that per se approach, instead requiring a rational nexus to enforcement of a federal law. See Human Rights Watch v. Dep't of Justice & Fed. Bureau of Prisons, 2015 U.S. Dist. LEXIS 123592, at \*10-14 (S.D.N.Y. Sept. 16, 2015) ("To acknowledge that law enforcement purpose' defies rigid formulation, then, is not to allow all information about BOP administration and procedure to satisfy the Exemption 7 threshold."); Gonzalez, 2020 U.S. Dist. LEXIS 134482, at \*27; Malizia v. U.S. Dep't of Justice, 519 F. Supp. 338, 347 (S.D.N.Y. 1981) ("To meet this requirement an agency must demonstrate at least `a colorable claim of a rational nexus' between activities being investigated and violations of federal laws."); see also Church of Scientology v. U.S. Dep't of the Anny, 611 F.2d 738, 748 (9th Cir. 1979) (holding that agencies with a law enforcement mandate must "establish a `rational nexus' between enforcement of a federal law and the document for which an exemption is claimed"); Pratt v. Webster, 673 F.2d 408, 420 (D.C. Cir. 1982) ("To satisfy this requirement of a `nexus,' the agency should be able to identify a particular individual + +interfere with enforcement proceedings. See 5 U.S.C. § 552(b)(7)(A); NLRB v. Robbins Tire & Rubber Co., 437 U.S. 214, 236 (1978); see also, e.g., Radcliffe v. IRS, 536 F. Supp. 2d 423, 437 (S.D.N.Y. 2008) ("Affidavits must contain more than mere conclusory statements to show why disclosure of requested documents could reasonably be expected to interfere with enforcement proceedings."). Here, the enforcement proceedings cited by BOP—the prosecutions of Nicholas Tartaglione for a murder years ago and Michael Thomas and Tova Noel for falsifying records bear little relationship to the particular documents at issue, which deal with GOP's treatment of Epstein, including psychological treatment, and Epstein's contacts with people who are not associated with BOP. 5 + +The charges against Tartaglione have nothing to do with Epstein. Tartaglione is charged with one count of conspiracy to distribute narcotics, four counts of intentional killing in furtherance of a drug trafficking crime, three counts of murder through the use of a firearm in furtherance of a drug trafficking crime, one count of conspiracy to commit kidnapping, four counts of kidnapping resulting in death, and four counts of using a facility of interstate commerce to commit a crime of violence, all arising from the murder of four individuals in April 2016, none of whom has any connection to Epstein (Capone Decl. 1 10.) BOP has withheld, on account of purported interference with the Tartaglione prosecution, reports and evidence of Epstein's July 23, 2019 apparent suicide attempt, reports and evidence of Epstein's death on August 10, 2019, medical and psychological records of Epstein prepared by BOP, and emails + +or a particular incident as the object of its investigation and the connection between that individual or incident and a possible security risk or violation of federal law."). + +5 Although the Government devotes a portion of its Facts section to discussing the prosecution of Epstein himself, that of course cannot justify withholding under Exemption 7(A), as Judge Berman entered an order of tiolle prosequi against Epstein on August 29, 2019 (Capone Dec1.1 8.) + +pertaining to Epstein's July 23, 2019 apparent suicide attempt, Epstein's mental and physical health, and Epstein's incarceration prior to his suicide.° + +The Government has provided no credible basis for concluding that disclosure of the records at issue would interfere with Tartaglione's prosecution for murder and related crimes. The Government instead weaves a convoluted theory about how BOP records might somehow play a role in the penalty phase of Tartaglione's trial at some distant point in the future if Tartaglione is convicted. The theory goes like this: Tartaglione shared a cell with Epstein for a period of time, including July 23, 2019 (but not at the time of his death, when some of the socalled "Tartaglione Records" were created). Therefore, some of the documents about Epstein's conditions of confinement may somehow shed light on Tartaglione's conditions of confinement at the facility. As a result, those conditions of Tartaglione's confinement at the MCC may be relevant to the penalty phase of the Tartaglione case. + +The theory falls far short of what the Government needs to show to overcome the presumption of openness that is central to FOIA. The theory would effectively prevent any information about prison conditions from ever being disclosed because there will always be some prisoner whose trial date is pending and whose defense counsel may seek to introduce evidence about their conditions of confinement at some stage of the trial. BOP will always be able to argue that disclosing information about prison conditions could color the perceptions of potential jurors for some potential trial at some point in the future. Such generalized concerns are insufficient under FOIA. See, e.g., Gray, 742 F. Supp. 2d at 74; Lawyers Comm. for Human Rights v. INS, 721 F. Supp. 552, 565-66 (S.D.N.Y. 1989) (rejecting "generalized discussion" and "boilerplate descriptions" of the harm from disclosure as insufficient to carry the government's + +6As noted above, The Times does not contest the withholding of "email correspondence between Tartaglione's attorneys and legal counsel at the MCC." (Capone Decl. 1 28.) + +burden on Exemption 7).7 That Epstein and Tartaglione were cellmates, without more, is not enough to show that disclosure would prematurely reveal the Government's case against Tartaglione or otherwise interfere with the proceedings. Whatever the statutory phrase "could reasonably be expected to interfere" may mean in close cases, here the Government effectively replaces "reasonable expectations" with "speculation about a possibility." + +The Government's case fares no better with respect to the Thomas and Noel prosecutions. BOP contends that several categories of BOP records could interfere with these proceedings, including (1) MCC staffing records; (2) reports and memoranda prepared by BOP concerning Epstein's July 23, 2019 suicide attempt, Epstein's August 10, 2019 suicide, and MCC and GOP's response to Epstein's death; (3) medical and psychological records of Epstein; (4) documents related to inmate counts; (5) an August 8, 2019 review of inmates in the SHU; (6) emails pertaining to Epstein's July 23, 2019 suicide attempt, his incarceration before his suicide, and his mental health; and (7) emails relating to Epstein's death, investigations into Epstein's death, and GOP's response to Epstein's death. (Capone Dec111 12-26.) + +Those records bear little relationship to the prosecutions of Noel and Thomas for making false statements and for conspiring to defraud the United States in connection with falsely attesting to having conducted multiple inmate counts when they had not done so. (The focus of those prosecutions is on the false certifications they are alleged to have signed.) A June 9, 2020 order by Judge Torres, denying Thomas's motion to compel "disclosure of `reports generated by + +7The Government's vague allegations of the impact of disclosure on juror testimony also entirely disregard the voir dire process, which "can play an important role in reminding jurors to set aside out-of-court information and to decide the case upon the evidence presented at trial." Gentile v. State Bar of Nev., 501 U.S. 1030, 1055 (1991) (holding that risk of prejudice from pretrial publicity was insufficient to justify restricting attorney speech about ongoing proceedings). As the Supreme Court observed, "[e)mpirical research suggests that in the few instances when jurors have been exposed to extensive and prejudicial publicity, they are able to disregard it and base their verdict upon the evidence presented in court." Id. at 1054-55. + +investigators within the [BOP] regarding' Epstein's death," makes clear as much: Judge Tones found "no evidence" that the prosecutors in the Noel and Thomas cases "reviewed information arising from a BOP investigation" into Epstein's death. United States v. Noel, No. 19-CR-00830- AT, ECF No. 36 (June 9,2020 Order), at 7—8. Information that is relevant to the Noel prosecutions—"all of the materials gathered by OIG [Office of Inspector General] personnel in the course of investigating [the Noel] case," including "count slips, thirty minute round forms, and staffing rosters for the three-week period surrounding Epstein's suicide"—was already disclosed to Thomas and Noel, id. at 2,5-6, and the Government has not established that that disclosure was subject to any kind of protective order.8 And because defendants have received the BOP information relevant to their cases, BOP has failed to show that disclosures here would disclose the prosecution's strategies or tactics or otherwise interfere with the trial. See Maydak, 218 F.3d at 762. The Government speculates that some of the documents may be trial exhibits or used in preparing witnesses, but the 7(A) standard focuses on "interference" with the prosecution's tactics or strategy, and nothing on the face of the documents indicates whether a particular document might be used by the prosecutors, let alone how. Certainly, the Government is not suggesting that it plans to use stealth evidence to get a conviction. + +### III. The Government Has Not Met Its Burden of Justifying Withholding Under Exemptions 6 and 7(C) + +The Government also seeks to justify withholding or redacting several categories of documents under Exemptions 6 and 7(C). Both exemptions provide limited protection for privacy interests, which must be balanced against the public interest in disclosure. Exemption 6 + +8If there is in fact any material responsive to The Times's requests that is subject to a protective order and that is expected to be introduced into evidence as exhibits at trial, the Government ought to specifically identify that material in a sealed declaration to this Court. BOP cannot simply rest on the generalized assertion that "some of the records withheld under Exemption 7(A) will be entered into evidence as exhibits at trial." (Capone Decl. ¶ 15 (emphasis added).) + +applies to "personnel and medical files and similar files the disclosure of which would constitute a clearly unwarranted invasion of personal privacy." 5 U.S.C. § 552(b)(6). The provision contemplates a balancing between the privacy interests in the information sought and the public interest in disclosure. See Associated Press v. U.S. Dep't of Del, 554 F.3d 274, 291 (2d Cir. 2009) (citing Dep't of Air Force v. Rose, 425 U.S. 352, 372 (1976)). The "requirement that disclosure be `clearly unwarranted' instructs [courts] to tilt the balance . . . in favor of disclosure." Morley v. C.I.A., 508 F.3d 1108, 1127 (D.C. Cir. 2007) (internal marks omitted). "[U]nder Exemption 6, the presumption in favor of disclosure is as strong as can be found anywhere in the Act." Multi Ag Media LLC v. Dep't of Agric., 515 F.3d 1224, 1227 (D.C. Cir. 2008). Similarly, Exemption 7(C)—which exempts from disclosure records or information compiled for law enforcement purposes if release "could reasonably be expected to constitute an unwarranted invasion of personal privacy," 5 U.S.C. § 552(b)(7)(C)—requires that a court "balance the public interest in disclosure against the [privacy] interest." Associated Press, 554 F.3d at 284.9 + +The information withheld under Exemptions 6 and 7(C) fall into two categories: (1) details of Epstein's death and images of his body and (2) names of third-party individuals that appear on call logs, visitor logs, and Epstein's approved call list and visitor list.10 Neither category may properly be withheld. + +With respect to the first category, a person's privacy interests after death are minimal at best. See Diamond v. FBI, 707 F.2d 75, 77 (2d Cir. 1983) (noting that "death ... so diminished + +&#x27;Because Exemption 7(C) is more protective than Exemption 6—the former uses the language "could reasonably be expected" while the latter refers to "would reasonably be expected"—the 7(C) language is operative when both exemptions apply. + +i° Insofar as the Government has withheld contact information such as phone numbers or addresses of third-party individuals not associated with BOP, The Times does not challenge these withholdings. + +any privacy interest as to amount to a waiver"); Wessler v. U.S. Dep't of Justice, 381 F. Supp. 3d 253, 259 (S.D.N.Y. 2019) (IA] personal privacy interest fades with the death of the subject of the medical records."). In limited circumstances, surviving family members may have independent privacy interests with respect to their close family's death-scene images. See Nat? Archives & Records Admin. v. Favish, 541 U.S. 157, 165-71 (2004). But unlike the Favish case cited by the Government, in which the Court relied upon a sworn declaration from the deceased's sister describing the harassment that the family had experienced, here the Government makes no effort to describe whose interests would be hurt how, referring only in vague terms to the privacy interests of Epstein's surviving family members. Epstein's parents died long ago, and he was unmarried and (at least officially) childless. His sole surviving relative is his brother Mark, who has said they "were not that close" and is himself eager for more documents to be released by BOP. See Julie K. Brown, Je •ey Epstein Wasn't Trafficking Women — And He Didn't Kill Himself Brother Says, Miami Herald (Nov. 14, 2019), hups://hrld.us/3ibIANJ (noting that "Mark Epstein said he is awaiting further documents they've requested from the medical examiner, the paramedics and the Bureau of Prisons" to support his contention that Epstein died by homicide and not suicide). In short, there is no reason to believe that any family member of Epstein has any interest in nondisclosure. + +With respect to the second category, the Government has not established that any third parties have a privacy interest in nondisclosure or that disclosure of the records at issue would cause additional incremental harm, in light of all the information that has already been disclosed about Epstein's lawyers and his wide circle of acquaintances. Hundreds, if not thousands, of articles have been written about Epstein, at least four miniseries have been produced or are in the works, and countless celebrities have had their ties to Epstein publicly dissected. The names of + +lawyers on Epstein's legal team, including Reid Weingarten, Martin G. Weinberg, and Michael Miller, have been widely publicized. See, e.g., Ali Watkins & Michael Gold, Jeffrey Epstein Autopsy Results Show He Hanged Himself in Suicide, N.Y. Times (Aug. 16, 2019), https://nyti.ms/3bBRMsi. Epstein is known to have summoned numerous lawyers to visit him at MCC, including David Schoen, whom he met with in the days after his initial suicide attempt. See, e.g., Ali Watkins, Danielle Ivory & Christina Goldbaum, Inmate 76318-054: The Last Days of Jeffrey Epstein (Aug. 17, 2019), https://nyti.ms/3h8uED2. Reporting has also identified individuals—such as Epstein associates and ' —who met with him when he was in jail in Florida, as well as individuals who remained close to him until the time of his death, such as longtime associates Darren K. Indyke and Richard D. Kahn, whom Epstein named as executors of his will. See Skyler Swisher & Marc Freeman, Jeffrey Epstein's Special Treatment in Jail Was Far More Lenient Than Anyone Knew, S. Fla. Sun Sentinel (Aug. 16, 2019), https://bit.lv/3304vD; Steve Eder & Ali Watkins, Jeffrey Epstein's Will: He Signed 2 Days Before Killing Himself, N.Y. Times (Aug. 19, 2019), https://nvti.ms/2R6XR6O. Finally, there has been widespread reporting about individuals listed in Epstein's "little black book" thought to be a diary of his houseguests or people in his social circle, ranging from household names like Prince Andrew, Donald Trump, Ken Starr, and Alan Dershowitz, to lesser known individuals like film producers, fashion executives, magazine editors, and others. See, e.g., Nick Bryant, Here Is Pedophile Billionaire Jeffrey Epstein's Little Black Book, Gawker (Jan. 23, 2015), https://bit.ly/2DExAcI. + +In short, withholding the names of persons known to have associated with Epstein serves no privacy interest. Their connection to Epstein is no secret, and disclosure of the fact that they visited or communicated with Epstein during this period of time would cause no incremental + +harm. As to others, whatever privacy interest exists is easily overcome by the weighty public interest in disclosure." The focus of the privacy analysis is whether "disclosure would serve the core purpose of FOIA, which is contributing significantly to public understanding of the operations or activities of the government." N.Y. Times Co. v. FCC, 2020 U.S. Dist. LEXIS 76710, at \*13-14 (S.D.N.Y. Apr. 30, 2020) (quoting Cook v. Nat'l Archives & Records Admin., 758 F.3d 168, 177 (2d Cir. 2014)), appeal docketed, No. 20-2042 (2d Cir. June 26, 2020). + +The Government itself has implicitly admitted that BOP operations failed when it brought criminal charges against the two BOP officers on duty the night of Epstein's suicide. See United States v. Noel, No. 19-cr-830 (AT) (S.D.N.Y.). A recent report by the Department of Justice's Office of Inspector General has revealed further problems at MCC and BOP generally, including the failure to properly monitor terrorist inmates' phone calls and visits due to inadequate technology. See Office of the Inspector General, Audit of the Federal Bureau of Prisons' Monitoring of Inmate Communications to Prevent Radicalization (March 2020), https://bitly/3m5lvvU. The records requested relate directly to MCC practices and procedures: whether Epstein was accorded special treatment when it came to visits, calls, and deposits of money; whether he was subject to more restrictive rules than others; whether BOP personnel were effectively screening visitors who might represent a threat or assist in further criminal acts by Epstein or on behalf of him; and whether GOP's recordkeeping was accurate—a relevant concern in light of the prosecutions in this case. + +The Government gets the balancing test precisely backwards when it contends that "the publicity and unfounded speculation surrounding Epstein's death make it more likely that disclosure of personally identifying information of an individual who interacted with Epstein or participated in the response to his death would cause an unwarranted invasion of privacy." (Gov't Br. 19-20.) Just the opposite: the privacy interest in nondisclosure is fixed, but the significant media attention demonstrates the newsworthiness of the information and heightens the public interest in disclosure. + +The President himself has highlighted the public interest in disclosure of documents regarding Epstein. As he put it in a recent interview, "people are still trying to figure out how [Epstein died in jail]." Zapotosky, Trump questions whether Jeffrey Epstein was killed in federal custody, supra. The possibility that the records could shed light on that fact favors disclosure, too. + +### IV. The Government Has Not Met Its Burden of Justifying Withholding Under Exemption 5 + +Exemption 5 permits an agency to withhold "inter-agency or intra-agency memorandums or letters that would not be available by law to a party other than an agency in litigation with the agency." 5 U.S.C. § 552(b)(5). As noted above, The Times does not contest the withholding of communications between BOP employees and Assistant United States Attorneys pursuant to the attorney-client privilege. However, the Government also seeks to withhold under Exemption 5 documents pertaining to where and how Epstein was housed and how Epstein died. With respect to these records, the Government has not met its burden of establishing that the records are both predecisional and deliberative, see Grand Central P 'ship, Inc. v. Cuomo, 166 F.3d 473, 482 (2d Cir. 1999), or that disclosure would foreseeably harm the candid exchange of recommendations during the policymaking process, as required under the 2016 FOIA Improvement Act, see 5 U.S.C. § 552(a)(8)(A). + +The deliberative process privilege applies to "documents reflecting advisory opinions, recommendations and deliberations comprising part of a process by which governmental decisions and policies are formulated." Dep't of Interior v. Klamath Water Users Protective Ass'n, 532 U.S. I, 8 (2001) (quoting Sears, 421 U.S. at 150). But the records withheld are largely not akin to advisory opinions or policy recommendations and do not relate to any policymaking process. BOP has improperly deemed a broad range of documents deliberative: an incident report of Epstein's apparent suicide attempt, a psychological reconstruction (or psychological autopsy) of his suicide, e-mails and other unspecified documents about Epstein's housing at MCC, responses to Epstein's suicide, and responses to press inquiries. Emblematic of the misuse of the exemption are the incident report of the suicide attempt and the psychological reconstruction, both of which appear to be essentially factual documents summarizing and analyzing events that have already taken place. Indeed, according to guidance issued by BOP, psychological reconstructions of inmate suicides include background information about the inmate, medical history, a full description of the suicide act and scene, information such as staff and inmate opinions of the deceased, and interviews with staff and other inmates. Fed. Bureau of Prisons, Program Statement: Suicide Prevention Program (Apr. 5, 2007), https://bit.ly/3ioiEyN [hereinafter "BOP Program Statement"]. These withheld documents are not recommendations and advice from employees to management about shaping policies. + +The Government's assertion that the records contain policy recommendations about "how MCC should change its suicide prevention policies and measures" (Gov't Br. 15) is not obviously borne out by the face of the descriptions. But even if the description is right, it does not justify blanket withholding. FOIA requires that the Government redact the relevant deliberative portions, rather than withhold in full. See, e.g., Envt'l Prot. Agency v. Mink, 410 U.S. 73, 88-91 (1973) ("Exemption 5 ... requires different treatment for materials reflecting deliberative or policymaking processes," which are exempt from disclosure, and "purely factual, investigative matters," which are not exempt); Grand Central P'ship, 166 F.3d at 482 ("Purely factual material not reflecting the agency's deliberative process is not protected."); Local 3, Intl Bhd. of Elec. Workers v. NLRB, 845 F.2d 1177, 1180 (2d Cir. 1988) (same); Hopkins v. U.S. Dep't of Hous. & Urban Dev., 929 F.2d 81, 85 (2d Cir. 1991) (same). Accordingly, all factual + +information—including information about how Epstein was in fact housed at MCC and who he shared a cell with, and the factual determinations of the psychological reconstruction—is required to be disclosed. The same analysis applies to other documents withheld as deliberative, including emails exchanged within BOP about Epstein's housing at MCC, Epstein's suicide, and GOP's immediate response. + +Finally, the Government has not met its - independent and meaningful" burden under the 2016 FOIA Improvement Act. NRDC v. EPA, 2019 U.S. Dist. LEXIS 124353, at \*2 (S.D.N.Y. July 25, 2019). The 2016 Act provides that agencies relying on discretionary exemptions (including all of the exemptions at issue in this case) may withhold information only if the agency reasonably foresees that disclosure would cause harm to an interest protected by the exemption. See 5 U.S.C. § 552(a)(8)(A). In passing this Act, "Congress was especially concerned about agencies' reliance on Exemption 5 and the deliberative process privilege." Ctr. for Investigative Reporting v. U.S. Customs & Border Prot., 2019 U.S. Dist. LEXIS 223077, at \*20 (D.D.C. Dec. 31, 2019) (holding that the Government failed to meet its burden of showing foreseeable harm to an interest protected by Exemption 5). With respect to the psychological autopsy, for example, the Government's declarant states that disclosure "would hamper frank and open discussions and assessments by [senior BOP] officials in reaching policy decisions." (Christenson Decl. 49(b).) Such generalized, boilerplate assertions are insufficient to meet the Government's burden. See id. at \*25; Judicial Watch, Inc. v. U.S. Dep't of Commerce, 375 F. Supp. 3d 93, 100-01 (D.D.C. 2019) (rejecting an agency's "general" "boiler plate" claims of harm to the deliberative process); see also S. Rep. No. 114-4, at 8 (2015) ("[M]ere speculative or abstract fears . . . are an insufficient basis for withholding information."). + +#### V. The Government Has Not Met Its Burden of Justifying Withholding Under Exemption 7(E) + +Exemption 7(E) permits an agency to withhold law enforcement records that "would disclose techniques and procedures for law enforcement investigations or prosecutions, or would disclose guidelines for law enforcement investigations if such disclosure could reasonably be expected to risk circumvention of the law." 5 U.S.C. § 552(b)(7)(E). The exemption protects only techniques and procedures "not generally known to the public." Doherty v. U.S. Dep't of Justice, 775 F.2d 49, 52 n.4 (2d Cir. 1985). Thus, where the agency fails to establish that "the material being withheld truly embod[ies) a specialized, calculated technique or procedure" unknown to the public, Exemption 7(E) does not apply. ACLU Found. v. Dep't of Homeland Sec., 243 F. Supp. 3d 393, 405 (S.D.N.Y. 2017); see also, e.g., Knight First Amendment Inst. v. U.S. Dep't of Homeland Sec., 407 F. Supp. 3d 334, 354 (S.D.N.Y. 2019) (rejecting the government's invocation of Exemption 7(E) where it "remain[ed] unclear" how the records "embod[ied] a specialized, calculated technique or procedure"); Albuquerque Publ'g Co. v. U.S Dep't of Justice, 726 F. Supp. 851, 857 (D.D.C. 1989) (rejecting the government's invocation of Exemption 7(E) where there was "nothing exceptional or secret about the techniques it described"); Kubik v. U.S. Fed. Bureau of Prisons, 2011 U.S. Dist. LEXIS 71300, at \*34 (D. Or. July 1, 2011) (holding that tactical maneuvers used during prison riots "are no secret to the prison inmates" and ordering disclosure of records, even if those records would reveal the location of a security camera that the inmates were assumed to be unaware of). + +Here, the Government has not met its burden of showing that techniques for preventing prison suicide are generally unknown. Countless reports have been publicly released on how to prevent suicide in jails and prisons—including several reports issued by the federal government. See, e.g., U.S. Dep't of Justice Nat'l Inst. of Corrections, Prison Suicide: An Overview and + +Guide to Prevention (1995), https://bit.ly/2FhaZnb [hereinafter "DOJ Guide to Prevention"]; Fed. Bureau of Prisons, Suicide Prevention in a Correctional Setting — Lessons Learned (Dec. 2011), https://bitly/3m1fUt3 (listing lessons such as "Double ceiling offenders prevents suicide"; "Cover vents with expanded metal to prevent tie-off points"; and "Ensure sprinkler heads cannot be used as tie-off points"); BOP Program Statement (describing new suicide prevention guidance); U.S. Dep't of Justice Nat'l Inst. of Corrections, National Study of Jail Suicide: 20 Years Later (Apr. 2010), https://bit.ly/31YuoKm (describing instruments used to commit suicide, such as the use of bedding, clothing, shoelaces, belts, and telephone cords for hangings along with various anchoring devices). + +Those reports describe in detail how certain practices, such as holding victims in isolation or segregation cells, tend to increase the risk of suicide. They explain how to mitigate the risk of prisoner suicide, such as by training correctional staff, conducting psychological screenings at intake and at regular intervals, constantly supervising those who are actively suicidal and closely observing those at risk at 5-15 minute staggered intervals, housing inmates in dormitories or shared cells, eliminating or minimizing unsupervised access to potentially lethal materials such as bed sheets or shoe laces, and having multidisciplinary team meetings involving correctional, health care, and mental health personnel. See World Health Organization, Preventing Suicide in Jails and Prisons (2007) https://bit.ly/2GHiHro. They provide a "Suicide Potential Checklist," enumerating questions that should be asked to assess an inmate's suicide risk, detailed postsuicide procedures, and lists of equipment that should be available to officers responding to incidents of attempted suicide. See DOJ Guide to Prevention, at 24-25,43. They even provide a template for a psychological reconstruction of an inmate suicide and a sample memorandum documenting mock suicide emergency training. See BOP Program Statement, at 20-25. + +In short, there is nothing secret about what policies prisons ought to have in place to prevent suicide or how prisons investigate and respond to suicides and suicide attempts. Because there is no reason to believe that the records BOP is withholding would reveal any law enforcement techniques and procedures that are not already generally known, the Government has not met its burden of demonstrating that Exemption 7(E) applies, and the records are required to be released. + +## CONCLUSION + +For each and every one of the reasons set forth above, Plaintiff respectfully asks this Court to (i) declare that the documents sought by The Times are public under 5 U.S.C. § 552 and must be disclosed; (ii) order BOP to provide the requested documents to The Times within 20 business days of the Court's order; (iii) award The Times the costs of this proceeding, including reasonable attorneys' fees, as expressly permitted by 5 U.S.C. § 552(a)(4)(E); and (iv) grant such other and further relief as the Court deems just and proper. + +Dated: New York, NY September 10, 2020 + +Respectfully submitted, + +By: /s/ David E. McCraw + +David E. McCraw Al-Amyn Sumar Alexandra Perloff-Giles The New York Times Company Legal Department 620 Eighth Avenue New York, NY 10018 Phone: 212-556-4031 Facsimile: (212) 556-4634 Email: mccraw@nytimes.com + +Counsel for Plaintiff \ No newline at end of file diff --git a/marker2/ds9/EFTA00088701/EFTA00088701.metadata.json b/marker2/ds9/EFTA00088701/EFTA00088701.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..454db98632b61c92aa02fde25dd0ea55308cd610 --- /dev/null +++ b/marker2/ds9/EFTA00088701/EFTA00088701.metadata.json @@ -0,0 +1,1521 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00088701.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 29, + "chars": 59655, + "elapsed_seconds": 11.95, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 71.28 + ], + [ + 281.41961669921875, + 71.28 + ], + [ + 281.41961669921875, + 99.603515625 + ], + [ + 68.544, + 99.603515625 + ] + ] + }, + { + "title": "MEMORANDUM OF LAW IN SUPPORT OF \nPLAINTIFF'S CROSS-MOTION FOR SUMMARY JUDGMENT \nAND IN OPPOSITION TO DEFENDANT'S MOTION FOR \nSUMMARY JUDGMENT", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 104.03999999999999, + 320.76 + ], + [ + 508.74163818359375, + 320.76 + ], + [ + 508.74163818359375, + 386.0009460449219 + ], + [ + 104.03999999999999, + 386.0009460449219 + ] + ] + }, + { + "title": "TABLE OF CONTENTS", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 239.29200000000003, + 72.08999999999999 + ], + [ + 374.134521484375, + 72.08999999999999 + ], + [ + 374.134521484375, + 86.9830322265625 + ], + [ + 239.29200000000003, + 86.9830322265625 + ] + ] + }, + { + "title": "TABLE OF AUTHORITIES", + "heading_level": null, + "page_id": 2, + "polygon": [ + [ + 229.5, + 72.08999999999999 + ], + [ + 383.57696533203125, + 72.08999999999999 + ], + [ + 383.57696533203125, + 86.853515625 + ], + [ + 229.5, + 86.853515625 + ] + ] + }, + { + "title": "CASES", + "heading_level": null, + "page_id": 2, + "polygon": [ + [ + 68.544, + 97.19999999999999 + ], + [ + 114.25033569335938, + 97.19999999999999 + ], + [ + 114.25033569335938, + 111.9735107421875 + ], + [ + 68.544, + 111.9735107421875 + ] + ] + }, + { + "title": "STATUTES", + "heading_level": null, + "page_id": 4, + "polygon": [ + [ + 67.932, + 400.95000000000005 + ], + [ + 138.28700256347656, + 400.95000000000005 + ], + [ + 138.28700256347656, + 415.4830322265625 + ], + [ + 67.932, + 415.4830322265625 + ] + ] + }, + { + "title": "OTHER AUTHORITIES", + "heading_level": null, + "page_id": 4, + "polygon": [ + [ + 67.932, + 450.36 + ], + [ + 206.55789184570312, + 450.36 + ], + [ + 206.55789184570312, + 464.9830322265625 + ], + [ + 67.932, + 464.9830322265625 + ] + ] + }, + { + "title": "PRELIMINARY STATEMENT", + "heading_level": null, + "page_id": 6, + "polygon": [ + [ + 219.70799999999997, + 182.25 + ], + [ + 391.927978515625, + 182.25 + ], + [ + 391.927978515625, + 196.353515625 + ], + [ + 219.70799999999997, + 196.353515625 + ] + ] + }, + { + "title": "FACTUAL BACKGROUND", + "heading_level": null, + "page_id": 7, + "polygon": [ + [ + 229.5, + 457.65 + ], + [ + 383.79827880859375, + 457.65 + ], + [ + 383.79827880859375, + 472.4830322265625 + ], + [ + 229.5, + 472.4830322265625 + ] + ] + }, + { + "title": "I. 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@@ -0,0 +1,23 @@ +To: + +Cc• + +Subject: Financial Trust Co - Ownership + +Date: Fri, 25 Jun 2021 16:09:09 +0000 + +The referenced document are from the JPMC production regarding Jeffery Epstein. + +| Description | Beginning Bates Number | Ending Bates Number | Comment | +|------------------------------------------------------------------------------|------------------------|---------------------|-----------------------------------------------------------------------------------------------------------------| +| Financial Trust Company Inc. corporate documents & email regarding ownership | 2587 | 2594 | Certificate Of Secretary of Financial Trust Company, Inc. states that Jeffery E Epstein is the sole shareholder | +| Document regarding Citibank, NA v Epstein et al | 2641 | 2641 | | +| Due diligence document re Jeffery Epstein | 2713 | 2721 | | + +If you have any questions, please contact me. + +Best + +Forensic Accountant + +FBI New York Field Office \ No newline at end of file diff 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+ ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00088730" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00088731/EFTA00088731.md b/marker2/ds9/EFTA00088731/EFTA00088731.md new file mode 100644 index 0000000000000000000000000000000000000000..62c7afb3e621e1880abaebdc90b33e403dd7238f --- /dev/null +++ b/marker2/ds9/EFTA00088731/EFTA00088731.md @@ -0,0 +1,23 @@ +Main Cell Fax + +## VIA Email + +Honorable Alison J. Nathan United States District Judge United States Courthouse 40 Foley Square New York, NY 10007 + +Dear Judge Nathan: + +33 West 19th Street - 4th Floor New York, New York 10011 + +April 13, 2021 + +Re: United States v. Ghislaine S2 20 Cr. 330 (AJN) + +I write to request that Court sign the attached proposed order directing the U.S. Marshal to permit Ghislaine Maxwell to have access to her legal papers while in the cellblock at 500 Pearl Street awaiting the evidence review being conducted in the U.S. Attorney's Office on the 5th floor. Today, she arrived at the courthouse at approximately 5:15 am and remained idle in the cellblock until approximately 8:30 am when she was brought to the to the evidence review. Ms. Maxwell will be attending the evidence review throughout this week. + +Your consideration is greatly appreciated. + +Very truly yours, + +gOuz C. Stunda.:m. BOBBI C. STERNHEIM + +Enc. cc: All counsel \ No newline at end of file diff --git a/marker2/ds9/EFTA00088731/EFTA00088731.metadata.json b/marker2/ds9/EFTA00088731/EFTA00088731.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..87d4bf87e33f0ab240d0e565190bdccf446bcd09 --- /dev/null +++ b/marker2/ds9/EFTA00088731/EFTA00088731.metadata.json @@ -0,0 +1,105 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00088731.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 953, + "elapsed_seconds": 0.63, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "LAW OFFICES OF BOBBI C. 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NATHAN United States District Judge \ No newline at end of file diff --git a/marker2/ds9/EFTA00088732/EFTA00088732.metadata.json b/marker2/ds9/EFTA00088732/EFTA00088732.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..5bc0e78d475ec48e59b8c8863ec5f0ce2266b9ed --- /dev/null +++ b/marker2/ds9/EFTA00088732/EFTA00088732.metadata.json @@ -0,0 +1,82 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00088732.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 548, + "elapsed_seconds": 0.64, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 71.28 + ], + [ + 282.744, + 71.28 + ], + [ + 282.744, + 101.25 + ], + [ + 68.544, + 101.25 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 35 + ], + [ + "Line", + 17 + ], + [ + "Text", + 12 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00088732" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00088733/EFTA00088733.md b/marker2/ds9/EFTA00088733/EFTA00088733.md new file mode 100644 index 0000000000000000000000000000000000000000..98dcdfde5f9d7ff9e5046650c41295cd07f2984f --- /dev/null +++ b/marker2/ds9/EFTA00088733/EFTA00088733.md @@ -0,0 +1,181 @@ +From: To: ' (USANYS)" Cc: SMIe ' PO + +Subject: RE: Question re Epstein Relativity + +Date: Wed, 17 Mar 2021 13:39:46 +0000 + +Inline-Images: image001.png; image002.png; image003.png + +Hello, + +The screenshots are referencing a different case but the process is the same. + +Here are the steps to create your tags: + +- 1. Open up any document +- 2. At the right of the screen click on edit +- 3. Under the field you want to add the tag (for this case all tags are under issue designation) find manage and click Manage on it. +- 4. The following window will appear: + +## Manage Choices (26) 0 + +Filter + +![](_page_1_Picture_7.jpeg) + +![](_page_1_Picture_8.jpeg) + +![](_page_1_Picture_9.jpeg) + +![](_page_1_Picture_10.jpeg) + +![](_page_1_Picture_11.jpeg) + +![](_page_1_Picture_12.jpeg) + +| | | Hot Document | +|--------------------------|-------------------------------------|--------------| +| | | | +| | | | +| | | | +| | | | +| | | | +| | | | +| | | | +| | | | + +See All Choices + +BAl I 0 Add Choice 0 Add Many Choices - + +- 5. You can click on add choice to add a single choice (tag) or add many choice to add multiple choices (tags) at one time. When you click on add many choices you will see the following: + +## Manage Choices (26) 0 + +![](_page_2_Picture_7.jpeg) + +![](_page_2_Picture_8.jpeg) + +![](_page_2_Picture_9.jpeg) + +![](_page_2_Picture_10.jpeg) + +![](_page_2_Picture_11.jpeg) + +![](_page_2_Picture_12.jpeg) + +Filter j F gi I 0 Add Choice 0 Add Many Choices + +![](_page_2_Picture_14.jpeg) + +![](_page_2_Picture_15.jpeg) + +O Complaints + +![](_page_2_Picture_17.jpeg) + +![](_page_2_Picture_18.jpeg) + +O Potential Leads + +![](_page_2_Picture_20.jpeg) + +![](_page_2_Picture_21.jpeg) + +O Civil Case + +Copy and paste choices. Race each choice on a separate line. + +![](_page_2_Picture_24.jpeg) + +![](_page_2_Picture_25.jpeg) + +Add all of your choices and then click apply. + +- 6. Once you have added your choice or many choices click Save and Close and you will see your choice appear in the field. + +Please let me know if there are any questions. + +Thank you. + +![](_page_2_Picture_30.jpeg) + +From: (USANYS) < + +Sent: Wednesday, March 17, 2021 9:34 AM + +To: + +Cc: >; < + +Subject: Re: Question re Epstein Relativity + +The below tag has been added to the database. Please note that you do the ability to add your own tags to the database so please feel free to do so if necessary. + +Thank you. + +From: (USANYS) Sent: Tuesday, March 16, 2021 7:08 PM To: (USANYS) [Contractor] Subject: RE: Question re Epstein Relativity + +Can you please create another issue designation tag — "CVRA Litigation"? + +Thanks, + +From: Sent: Monday, March 15, 2021 2:19 PM To: Cc: (USANYS) < Subject: RE: Question re Epstein Relativity + +Let's make this an Issue designation tag, please. That's where all of our other tags review tags are currently located. + +S hanks n + +From Sent: Monday, March 15, 2021 2:13 PM To: ) C .>; Cc: (USANYS) Subject: RE: Question re Epstein Relativity + +Do you want to create a new field that says "Not Epstein Related" or do you want to add this to an existing field (ex. Issue designation). Please note that if you want to add this to an existing field that such as issue designation you should see something that says manage and you can add this tag to that field as well. + +Thank you. + +From: < )\* Sent: Monday, March 15, 2021 2:08 PM To: Cc: (USANYS) Subject: RE: Question re Epstein Relativity + +Thanks for your help with this review project. For this batch only, could you please add a tag that says "Not Epstein Related"? Thanks. + +From: Sent: Monday, March 15, 2021 10:14 AM To: Cc: (USANYS) < Subject: RE: Question re Epstein Relativity >; + +Great, thank you! That's the correct STR. + +From: Sent: Monday, March 15, 2021 10:13 AM To: Cc: (USANYS) Subject: RE: Question re Epstein Relativity > + +Here is the STR. Please let me know if this is the STR you need. + +Thank you. + +From: Sent: Monda March 15 2021 10:09 AM To Cc: (USANYS) < Subject: RE: Question re Epstein Relativity >; + +Thanks =. I think you forgot to attach the STR hits. Mind resending that attachment, please? + +From Sent: Monday, March 15, 2021 10:08 AM To: Cc: (USANYS) Subject: RE: Question re Epstein Relativity + +Hello- + +The following is regarding the batches: + +BATCH003 - USAO-SDFL is all of the data from the following folder: + + + +BATCH004 - OPR Materials is from the following folder and attached STR Hits: + + + +From: + +Sent: Friday, March 12, 2021 5:56 PM + +To: + +Cc: (USANYS) > + +Subject: Question re Epstein Relativity + +Hi= + +We're hoping you can clarify for us the contents of two separate batches on the USvEpstein Relativity database. Batch 003 - USAO-SDFL appears to reference the documents we've been talking with and about. Batch 004 - OPR Materials appears to reference the emails that we received from OPR and that you ran the attached search terms through. 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a/marker2/ds9/EFTA00088739/EFTA00088739.md b/marker2/ds9/EFTA00088739/EFTA00088739.md new file mode 100644 index 0000000000000000000000000000000000000000..b5ad7dbbbb8e3558af2ca7dd194783329c1b2827 --- /dev/null +++ b/marker2/ds9/EFTA00088739/EFTA00088739.md @@ -0,0 +1,42 @@ +To: Cc: (USANYS (USANYS) [Contractor]" (USANYS) + +Subject: RE: Witness Spreadsheet + +Date: Fri, 19 Mar 2021 16:19:07 +0000 + +Attachments: Copy\_of Witness\_Spreadsheet-moe.xlsx + +Thanks so much for putting this spreadsheet. I'm attaching an updated version, which incorporates everyone's edits, so this version is ready to go. As you're prepping the production, please let us know if you have any questions. Two notes: + +- There are a number of folders marked "not a witness." Could you please move all of those folders into one place and send us a link to that group? We are going to review those materials and likely produce all or most of the documents, but outside the context of 3500, for a variety of reasons. +- As a heads up, we have a call scheduled with our case agents next week to discuss any e-communications they may have had with witnesses. We'll talk to them about the process of gathering those materials. Down the road, we'll connect them with you to hand off those materials to add to our 3500 productions, but we wanted to let you know in advance about this additional universe of disclosures. + +Thanks very much, + +From: + +Sent: Wednesday, March 17, 2021 3:59 PM + +To: (USANYS) [Contractor] \*C ) > ; (USANYS) + +Cc: (USANYS) [Contractor] c (USANYS) [Contractor] + +Subject: RE: Witness Spreadsheet + +Thanks so much,M + +I've taken a stab at filling this in on the attached. would you please double check this and make any changes you think are appropriate? + +From: (USANYS) [Contractor] < + +Sent: Wednesday, March 17, 2021 12:37 PM + +To: + +**Cc:** "[REDACTED] (USANYS)" <[REDACTED]> + +**Subject:** RE: Press Question (Ghislaine Maxwell Trial) + +**Date:** Fri, 29 Oct 2021 22:08:58 +0000 + +--- + +**From:** [REDACTED] <[REDACTED]> + +**Sent:** Friday, October 29, 2021 6:08 PM + +**To:** [REDACTED] <[REDACTED]> + +**Cc:** [REDACTED] (USANYS) <[REDACTED]> + +**Subject:** FW: Press Question (Ghislaine Maxwell Trial) + +--- + +**From:** [REDACTED] <[REDACTED]> + +**Sent:** Friday, October 29, 2021 6:08 PM + +**To:** [REDACTED] <[REDACTED]> + +**Cc:** [REDACTED] [Contractor] <[REDACTED]>; [REDACTED] (USANYS) + +<[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] + +<[REDACTED]> + +**Subject:** RE: Press Question (Ghislaine Maxwell Trial) + +--- + +**From:** [REDACTED] <[REDACTED]> + +**Sent:** Friday, October 22, 2021 11:54 AM + +**To:** [REDACTED] <[REDACTED]> + +**Cc:** [REDACTED] [Contractor] <[REDACTED]>; [REDACTED] (USANYS) + +<[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] + +<[REDACTED]> + +**Subject:** RE: Press Question (Ghislaine Maxwell Trial) + +--- + +**From:** [REDACTED] <[REDACTED]> + +**Sent:** Friday, October 22, 2021 11:42 AM + +**To:** [REDACTED] <[REDACTED]> + +**Cc:** [REDACTED] [Contractor] <[REDACTED]>; [REDACTED] (USANYS) + +<[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] + +<[REDACTED]> + +**Subject:** Re: Press Question (Ghislaine Maxwell Trial) + +--- + +On Oct 22, 2021, at 11:26 AM, wrote: + +Passing this on. + +From: Thrapp, Jacklyn + +Sent: Friday, October 22, 2021 11:18 AM + +To: (USANYS) + +Subject: (EXTERNAL) Press Question (Ghislaine Maxwell Trial) + +Hello, + +I'm a reporter for the National Enquirer covering the trial of Ghislaine Maxwell. I heard won't be called to the stand during the trial. + +Is this true? And if so, can you elaborate on why, if possible. + +Thanks + +JACKI THRAPP + +REPORTER + +THE NATIONAL ENQUIRER + + + + \ No newline at end of file diff --git a/marker2/ds9/EFTA00088743/EFTA00088743.metadata.json b/marker2/ds9/EFTA00088743/EFTA00088743.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..7b17901cfee071013e1c48cf620465a6d70c65f9 --- /dev/null +++ b/marker2/ds9/EFTA00088743/EFTA00088743.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00088743.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 1897, + "elapsed_seconds": 6.97, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 64 + ], + [ + "Span", + 58 + ], + [ + "Line", + 27 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 39 + ], + [ + "Line", + 20 + ], + [ + "Text", + 16 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00088743" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00088745/EFTA00088745.md b/marker2/ds9/EFTA00088745/EFTA00088745.md new file mode 100644 index 0000000000000000000000000000000000000000..afd9b7f46a46cd1e2322c60a393d40d7e2907342 --- /dev/null +++ b/marker2/ds9/EFTA00088745/EFTA00088745.md @@ -0,0 +1,21 @@ +From: "a" alMIN> + +To: Christian Everdell , Laura Menninger , Jeff Pagliuca ipagliuca@hmflaw.com>, "'BOBBI C STERNHEIM"' + +Cc: ' " , ' SANYS " I, 11 + +Subject: Maxwell - Verdict form and proposed stips + +Date: Sat, 30 Oct 2021 02:19:29 +0000 + +Attachments: Maxwell Verdict\_Sheeti2021.10.29Do\_defense counsel.docx; GX\_1004\_- \_Birth Certificates\_(2021.10.29\_version).pdf; GX— 1001\_- Records\_(2021.10.29\_version).pdf; GX 1002\_- \_FedEx Records\_(2021.10.29 version).pdf; GX—\_1003 - Palm neach School Districi(2021.10.29\_version).p7ff + +Counsel, + +Although we've sent you our draft joint proposed request to charge, we haven't send you a verdict sheet. One is attached here. + +We've also attached four proposed stips. Please return them to us by a week from today— November 5 — so we know whether to begin preparing records custodians. We also anticipate sending you a few additional steps. + +Thanks, + +Assistant United States Attorney Southern District of New York 1 Saint Andrews Plaza New York, New York 10007 \ No newline at end of file diff --git a/marker2/ds9/EFTA00088745/EFTA00088745.metadata.json b/marker2/ds9/EFTA00088745/EFTA00088745.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..8ae497ff64dd87151e207e2553c1d27ba8884093 --- /dev/null +++ b/marker2/ds9/EFTA00088745/EFTA00088745.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00088745.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1095, + "elapsed_seconds": 0.68, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 51 + ], + [ + "Line", + 24 + ], + [ + "Text", + 13 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00088745" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00088746/EFTA00088746.md b/marker2/ds9/EFTA00088746/EFTA00088746.md new file mode 100644 index 0000000000000000000000000000000000000000..702980f02366d2ae30a899f644ec3f71aaafb048 --- /dev/null +++ b/marker2/ds9/EFTA00088746/EFTA00088746.md @@ -0,0 +1,43 @@ +#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +UNITED STATES OF AMERICA + +S2 20 CR 330 (AJN) + +GHISLAINE MAXWELL, + +Defendant. + +HONORABLE ALISON J. NATHAN: + +# VERDICT SHEET + +Please indicate your verdict with a check mark (c). + +# COUNT ONE: Conspiracy to Entice an Individual to Travel with Intent to Engage in Illegal Sexual Activity + +Guilty Not Guilty + +# COUNT TWO: Enticement of an Individual to Travel with Intent to Engage in Illegal Sexual Activity (Minor Victim-1) + +Guilty Not Guilty + +#### COUNT THREE: Conspiracy to Transport a Minor to Travel with Intent to Engage in Illegal Sexual Activity + +Guilty Not Guilty + +## COUNT FOUR: Transportation of a Minor with Intent to Engage in Illegal Sexual Activity (Minor Victim-1) + +Guilty Not Guilty + +# COUNT FIVE: Sex Trafficking Conspiracy + +Guilty Not Guilty + +# COUNT SIX: Sex Trafficking of a Minor (Minor Victim-4) + +Guilty Not Guilty + +Foreperson + +Date and Time \ No newline at end of file diff --git a/marker2/ds9/EFTA00088746/EFTA00088746.metadata.json b/marker2/ds9/EFTA00088746/EFTA00088746.metadata.json new file mode 100644 index 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United States Attorney for the Southern District of New York, and and Assistant United States Attorneys, of counsel, and defendant Ghislaine Maxwell, by and with the consent of her attorneys, Christopher Everdell, Esq., Laura Menninger, Esq., Jeffrey Pagliuca, Esq., and Bobbi Sternheim, Esq., that: + +- 1. Government Exhibit 11 is a true and correct certified copy of a birth certificate reported to the New York Department of State. Government Exhibit 11 accurately reflects the date of birth of the person named on the certificate. +- 2. Government Exhibit 12 is a true and correct certified copy of a birth certificate reported to the Rhode Island Department of Health. Government Exhibit 12 accurately reflects the date of birth of the person named on the certificate. +- 3. Government Exhibit 13 is a true and correct certified copy of a birth certificate reported to the Missouri Department of Health and Senior Services. Government Exhibit 13 accurately reflects the date of birth of the person named on the certificate. + +4. Government Exhibit 14 is a true and correct certified copy of a birth certificate reported to Sacramento County, California. Government Exhibit 14 accurately reflects the date of birth of the person named on the certificate. + +5. Government Exhibit 15 is a true and correct certified copy of a birth certificate reported to the Massachusetts Department of Public Health. Government Exhibit 15 accurately reflects the date of birth of the person named on the certificate. + +6. Government Exhibit 16 is a true and correct copy of a birth certificate reported to the General Register office of England and Wales. Government Exhibit 16 accurately reflects the date of birth of the person named on the certificate. + +7. IT IS FURTHER STIPULATED AND AGREED THAT this stipulation, marked as Government Exhibit 1004, and Government Exhibits 11, 12, 13, 14, 15, and 16, may be received in evidence at trial. + +Dated: November \_\_\_, 2021 +New York, New York + +DAMIAN WILLIAMS +United States Attorney for the +Southern District of New York + +By: + +\_\_\_\_\_ / \_\_\_\_\_ +\_\_\_\_\_ / \_\_\_\_\_ + +Assistant United States Attorneys +Southern District of New York + +--- + +Christopher Everdell, Esq. / Laura Menninger, Esq. +Jeffrey Pagliuca, Esq. / Bobbi Sternheim, Esq. +Attorneys for Defendant Ghislaine Maxwell \ No newline at end of file diff --git a/marker2/ds9/EFTA00088748/EFTA00088748.metadata.json b/marker2/ds9/EFTA00088748/EFTA00088748.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..c88e045d2a400844397d9c97ca4d7079c0496944 --- /dev/null +++ b/marker2/ds9/EFTA00088748/EFTA00088748.metadata.json @@ -0,0 +1,173 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00088748.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 2592, + "elapsed_seconds": 2.95, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 69.156, + 71.28 + ], + [ + 281.41961669921875, + 71.28 + ], + [ + 281.41961669921875, + 101.853515625 + ], + [ + 69.156, + 101.853515625 + ] + ] + }, + { + "title": "STIPULATION", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 329.25600000000003, + 151.47 + ], + [ + 413.0368347167969, + 151.47 + ], + [ + 413.0368347167969, + 165.603515625 + ], + [ + 329.25600000000003, + 165.603515625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 49 + ], + [ + "Line", + 25 + ], + [ + "Text", + 8 + ], + [ + "ListItem", + 3 + ], + [ + "SectionHeader", + 2 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 21 + ], + [ + "Line", + 11 + ], + [ + "Text", + 3 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 31 + ], + [ + "Line", + 16 + ], + [ + "Text", + 14 + ], + [ + "PageFooter", + 4 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00088748" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00088751/EFTA00088751.md b/marker2/ds9/EFTA00088751/EFTA00088751.md new file mode 100644 index 0000000000000000000000000000000000000000..5d38c8e261f1d99cd0b1af09a393843db19e7ae5 --- /dev/null +++ b/marker2/ds9/EFTA00088751/EFTA00088751.md @@ -0,0 +1,33 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +x + +UNITED STATES OF AMERICA + +## STIPULATION + +GHISLAINE MAXWELL, + +Defendant. + +x + +S2 20 CR 330 (AJN) + +IT IS HEREBY STIPULATED AND AGREED by and among the United States of America, by Damian Williams. United States Attorney for the Southern District of New York, and and Assistant United States Attorneys, of counsel, and defendant Ghislaine Maxwell, by and with the consent of her attorneys, Christopher Everdell, Esq., Laura Menninger, Esq., Jeffrey Pagliuca, Esq., and Bobbi Sternheim, Esq., that: + +I. Government Exhibit 551 is a true and correct copy of records from AT&T Corporation ("AT&T"), a telephone service provider. Government Exhibit 551 contains billing records for a cellular telephone number. The records reflected in Government Exhibit 551 were created by a person with knowledge of, or created from information transmitted by a person with knowledge of, the information shown; were created at or near the time the information became available to AT&T; and were created and maintained by AT&T as part of its regularly conducted business activities. + +2. IT IS FURTHER STIPULATED AND AGREED THAT this stipulation, + +marked as Government Exhibit 1001 may be received in evidence at trial. + +Dated: November 2021 New York, New York + +> DAMIAN WILLIAMS United States Attorney for the Southern District of New York + +By: + +Assistant United States Attorneys Southern District of New York + +Christopher Everdell, Esq. / Laura Menninger, Esq. Jeffrey Pagliuca, Esq. / Bobbi Sternheim, Esq. 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United States Attorney for the Southern District of New York, and and Assistant United States Attorneys, of counsel, and defendant Ghislaine Maxwell, by and with the consent of her attorneys, Christopher Everdell, Esq., Laura Menninger, Esq., Jeffrey Pagliuca, Esq., and Bobbi Sternheim, Esq., that: + +1. Government Exhibits 801, 802, and 803 are true and correct copies of records from FedEx Corporation ("FedEx"). Government Exhibits 801, 802, and 803 contain billing records for a FedEx account. The records reflected in Government Exhibits 801, 802, and 803 were created by a person with knowledge of, or created from information transmitted by a person with knowledge of, the information shown; were created at or near the time the information became available to FedEx; and were created and maintained by FedEx as part of its regularly conducted business activities. + +2. IT IS FURTHER STIPULATED AND AGREED THAT this stipulation, + +marked as Government Exhibit 1002, may be received in evidence at trial. + +Dated: November 2021 New York, New York + +> DAMIAN WILLIAMS United States Attorney for the Southern District of New York + +By: + +Assistant United States Attorneys Southern District of New York + +Christopher Everdell, Esq. / Laura Menninger, Esq. Jeffrey Pagliuca, Esq. / Bobbi Sternheim, Esq. 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United States Attorney for the Southern District of New York, and and Assistant United States Attorneys, of counsel, and defendant Ghislaine Maxwell, by and with the consent of her attorneys, Christopher Everdell, Esq., Laura Menninger, Esq., Jeffrey Pagliuca, Esq., and Bobbi Sternheim, Esq., that: + +I. Government Exhibits 781, 782, and 783 are true and correct copies of records from Palm Beach School District ("PBSD") in Palm Beach County, Florida. Government Exhibits 781, 782, and 783 contain education records for The records reflected in Government Exhibits 781, 782, and 783 were created by a person with knowledge of, or created from information transmitted by a person with knowledge of, the information shown; were created at or near the time the information became available to PBSD; and were created and maintained by PBSD as part of its regularly conducted business activities. + +2. IT IS FURTHER STIPULATED AND AGREED THAT this stipulation, + +marked as Government Exhibit 1003, may be received in evidence at trial. + +Dated: November 2021 New York, New York + +> DAMIAN WILLIAMS United States Attorney for the Southern District of New York + +By: + +Assistant United States Attorneys Southern District of New York + +Christopher Everdell, Esq. / Laura Menninger, Esq. Jeffrey Pagliuca, Esq. / Bobbi Sternheim, Esq. Attorneys for Defendant Ghislaine Maxwell \ No newline at end of file diff --git a/marker2/ds9/EFTA00088755/EFTA00088755.metadata.json b/marker2/ds9/EFTA00088755/EFTA00088755.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..5e3191c28d345be35ef4444e936b809b4f1e27d0 --- /dev/null +++ b/marker2/ds9/EFTA00088755/EFTA00088755.metadata.json @@ -0,0 +1,135 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00088755.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 1622, + "elapsed_seconds": 0.61, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 69.156, + 71.28 + ], + [ + 281.41961669921875, + 71.28 + ], + [ + 281.41961669921875, + 101.853515625 + ], + [ + 69.156, + 101.853515625 + ] + ] + }, + { + "title": "STIPULATION", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 329.25600000000003, + 151.47 + ], + [ + 413.0368347167969, + 151.47 + ], + [ + 413.0368347167969, + 165.603515625 + ], + [ + 329.25600000000003, + 165.603515625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 45 + ], + [ + "Line", + 23 + ], + [ + "Text", + 9 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 29 + ], + [ + "Line", + 15 + ], + [ + "Text", + 8 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00088755" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00088757/EFTA00088757.md b/marker2/ds9/EFTA00088757/EFTA00088757.md new file mode 100644 index 0000000000000000000000000000000000000000..7cf9c939af52708d202af65aaa99c8ad97d9baae --- /dev/null +++ b/marker2/ds9/EFTA00088757/EFTA00088757.md @@ -0,0 +1,25 @@ +From: (USANYS)" I + +To: "-(USANYS)" I + +Subject: RE: Memo for AUSA + +Date: Fri, 16 Oct 2020 16:24:51 +0000 + +approved + +From: (USANYS) < + +Sent: Friday, October 16, 2020 12:15 PM + +To: (USANYS) < + +Subject: Memo for AUSA + +Urgent. Please send the below email and the attachment back to me. + +The SDNY requests approval for travel by AUSA to the U.K. from October 12 to October 17, 2020. This travel is required at this time as Mwill be conducting an interview of victim/witness in the case against Ghislaine Maxwell. The victim was a victim of Jeffrey Epstein. She will only talk to us person and it is necessary for us to get her statement on the record to preserve the government's right to use her at trial. + +Please issue an approval from EOUSA for her travel to the U.K. + +Acting United States Attorney. \ No newline at end of file diff --git a/marker2/ds9/EFTA00088757/EFTA00088757.metadata.json b/marker2/ds9/EFTA00088757/EFTA00088757.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..cace987770724c5ece064e1ce69c23c4fe4daafd --- /dev/null +++ b/marker2/ds9/EFTA00088757/EFTA00088757.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00088757.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 796, + "elapsed_seconds": 0.74, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 33 + ], + [ + "Line", + 17 + ], + [ + "Text", + 15 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00088757" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00088758/EFTA00088758.md b/marker2/ds9/EFTA00088758/EFTA00088758.md new file mode 100644 index 0000000000000000000000000000000000000000..51b0e659f1c51542e7746846109c67528554ddd1 --- /dev/null +++ b/marker2/ds9/EFTA00088758/EFTA00088758.md @@ -0,0 +1,14 @@ +To: + +: " [REDACTED] )" < [REDACTED] >, " [REDACTED] )" < [REDACTED] >, " [REDACTED] )" < [REDACTED] >, " [REDACTED] )" < [REDACTED] >, " [REDACTED] )" < [REDACTED] >, " [REDACTED] (USANYS)" < + +**Subject:** Weekend Update: The Devil on His Latest Accomplishments - SNL - YouTube + +**Date:** Mon, 25 Oct 2021 23:24:32 +0000 + +ICYMI: the devil, the prince, and Jeffrey Epstein + + +U.S. Attorney's Office, SDNY + +[Redacted text block] \ No newline at end of file diff --git a/marker2/ds9/EFTA00088758/EFTA00088758.metadata.json b/marker2/ds9/EFTA00088758/EFTA00088758.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..8f6156b4c1f6135254906c2c3cf040c1dca49fa6 --- /dev/null +++ b/marker2/ds9/EFTA00088758/EFTA00088758.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00088758.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 468, + "elapsed_seconds": 162.66, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 18 + ], + [ + "Span", + 11 + ], + [ + "Line", + 6 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00088758" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00088759/EFTA00088759.md b/marker2/ds9/EFTA00088759/EFTA00088759.md new file mode 100644 index 0000000000000000000000000000000000000000..261edff59875b94003cf1f787c02101b5c72aa99 --- /dev/null +++ b/marker2/ds9/EFTA00088759/EFTA00088759.md @@ -0,0 +1,534 @@ +# Exhibit A + +# The Construct of Grooming in Child Sexual Abuse: Conceptual and Measurement Issues + +NATALIE BENNETT and WILLIAM O'DONOHUE + +Unhvisay of Nevada, Reno, Reno, Nmula, USA + +There have been claims that some child molesters engage in a "seduction stage"prior to committing abuse. These behaviors, commonly known as "grooming," are understood as methods child molesters use to gain access to and prepare future victims to be compliant with abuse. However; there is a lack of consensus regarding exactly what this process entails and bow it is clearly distinguished from normal adult-child interactions. It is important to devise an accurate definition ofgrooming for scientific, clinical, and forensic purposes. We critically evaluate the various definitions and reveal problematic heterogeneity. Furthermore, there are no methods of known psychometrics to validly assess grooming. We review the empirical literature regarding the occurrence of grooming and propose future directions for research. + +KEYWORDS grooming, child sexual abuse, measurement + +Understanding the process of child sexual abuse (CSA) is important for both its prevention and treatment. Some clinicians and researchers (e.g., Budin & Johnson, 1989; Burgess & Holmstrom, 1980; Conte, Wolf, & Smith, 1989; Elliott, Browne, & Kilcoyne, 1995) agree that a type of seduction stage, commonly called "grooming" but also variously known as "entrapment," "engagement," or "subjection" often precedes the actual sexual abuse. Offenders have admitted that they use techniques such as identifying a particularly vulnerable child, gift giving, and sexual desensitization to prepare the child for the abuse (Seto, 2008). + +Understanding grooming has both important clinical and legal implications. First, it is possible that if professionals were able to identify grooming + +Received 23 May 2013; revised 28 January 2014; accepted 10 April 2014. + +Address correspondence to William O'Donohue, Department of Psychology, University of Nevada, Reno, Mail Stop 298, Reno, NV 89557. E-mail: wroSunr.edu + +before abuse has actually taken place the abuse may be prevented. Second, in a forensic context, sexual abuse allegations might be partially substantiated when it is established that grooming did indeed occur. However, without a clear grooming definition and a valid way of measuring grooming, this judgment that a behavior constitutes grooming becomes problematic. For example, a recently convicted sex offender in las Vegas, Nevada, is seeking to appeal his conviction on the grounds that the testimony provided by a psychologist regarding his grooming behavior is unreliable (Mower, 2012). His defense attorney claimed that "[Grooming) is not a proven science. It's a behavioral thing. .. . How can you tell that this was in the mind of this guy?" + +There have been attempts to criminalize grooming in several countries. In the United States, a federal law (18 USC S 2252A(a)(6)) has made it illegal and thus adds years onto a sentence for people who knowingly offer child pornography to a minor to persuade the minor to participate in an illegal activity such as adult—child sexual contact (18 USC 2252A, certain activities relating to material constituting or containing child pornography). In the United Kingdom, Section 15 of the Sexual Offences Act 2003 has covered "the behavior of an offender who meets, or seeks to meet, a child with the intention of committing a sexual assault, if he has met or communicated with that child on at least two earlier occasions" (McAlinden, 2006, p. 342). However, as Gillespie (2004) noted, definitional problems with the construct of grooming limit the use of this law, as grooming is "a transient feature that is difficult to capture and virtually impossible to decide when it begins and ends" (p. 586). McAlinden also described another law designed to criminalize grooming in the UK: + +Sections 123.9 introduce the risk of sexual harm order—a new civil preventative order which can be used to prohibit specified behaviours, including the 'grooming' of children. ... This order effectively criminalizes acts which may be carried out for the purposes of sexual grooming, but only after an individual had been identified as posing a risk to children. (p. 342) + +O'Callaghan (2011) described that in Wales a man pled guilty and was sentenced to a year in prison for one count of meeting a child following sexual grooming that consisted of inappropriate communication via Facebook. In addition, Vance (2012) described a proposed law in New Zealand that provides a sentence of three years in prison for anyone who participates in online "indecent communication with anyone under 16." This law is aimed at sexual offenders who use Internet chatrooms or other social media websites to find victims. + +It is evident that these legal definitions of grooming are both varied and limited. The sorts of activities that these laws target do not actually capture the notion of grooming because these already involve illegal and abusive contract with a child. Grooming is generally regarded as prior activities intended to prepare the child for abuse, not actual illegal or abusive activities themselves. Thus, legitimate questions can be raised about whether showing a child pornography ought not to be regarded as grooming because it constitutes abuse itself. Clarifying a definition of grooming can thus make these laws applicable to many more behaviors that are used by offenders intending to sexually abuse children. + +It is important to note that clarifying key constructs is a difficult yet important process. The prominent philosopher of science Larry Laudan (1977) suggested that science has both empirical and conceptual problems and that scientific progress is made when either type of problem is addressed. Conceptual analysis is particularly difficult as it is traditionally not included as a part of the research method in the social sciences and also because it involves the inherent complexity of language (O'Donohue, 2013). Here, conceptual analysis of the grooming construct is necessary in the research process, as it is a salient example where the complexity of language contributes to definitional confusion and leads to problematic implications in clinical and forensic fields. + +The aim of this paper is to highlight the need for a clearer definition of the grooming construct that may be applied to both clinical and forensic work. The courts are currently unable to take much legal action against grooming as it is not well understood and clearly demarcated. Furthermore, psychologists are currently using clinical judgment to determine whether an alleged perpetrator's behaviors are considered grooming. The reliability and validity of these judgments are largely unknown, leaving concerns of unacceptable rates of false positives and false negatives. An additional aim is to review the empirical literature regarding what is known about the occurrence of grooming so that a clear definition can be constructed. With a clearer definition of grooming, a more scientific assessment of such behavior can be established. This article proposes future directions for research, including validation of the proposed definition and development of an IgAessment device. + +#### CURRENT DEFINITIONS + +The three tables presented here list various definitions of the construct of "grooming" currently found in the literature. Table 1 provides various general definitions of the term, Table 2 provides subcategories of grooming that some authors have proposed, and Table 3 provides stages of grooming that several authors have suggested. + +Thus there is a wide variability that exists in defining sexual grooming as well as possible subtypes or stages of grooming. Although many of the + +TABLE 1 General Definitions of Grooming + +| Author(s) | Definition of Grooming (taken directly from reference) | | +|----------------------------------------------------------|-------------------------------------------------------------|----------------| +| -How does [the perpetrator] get the child | to participate in some type of | | +| or implicitly... | . Perhaps rewards or bribes will be offered? | | +| | unaware of what he is doing, or even to make them likely | to help him, | +| Inducements to | draw children into abusive situations and increases | | +| | through a nonsexual approach, which is designed to entice a | victim into | +| child's secrecy to avoid disclosure. This process serves | to | strengthen the | + +TABLE 2 Proposed Subtypes of Grooming + +| Author | Types of Grooming | +|-------------------------------------|-----------------------------------| +| Leberg (1997) | 1. Physically grooming the victim | +| Craven, Brown, and Gilchrist (2006) | 1. Self-grooming | +| McAlinden (2006) | 1. Personal | +| Wyre (1987) as discussed in I Iowan | I. Exuafamilial | +| (1995) | 2. Intrafamilial | + +definitions share some key similarities, many behaviors may be classified as grooming under some definitions but not under others. Some of these similarities in definition include the criterion of preparing a child for abuse (Brackenridge, 2001; Craven, Brown, & Gilchrist, 2006; Gallagher, 1999), gaining a child's trust (Berson, 2003; Craven et al., 2006; Gillespie, 2002; Salter, 1995), making it more difficult to the child to resist or disclose the abuse (Berson, 2003; Craven et al., 2006; Gallagher, 1999; Gillespie, 2002; Knoll, 2010; Leberg, 1997), and the enumeration of specific tactics used to groom the child (Berson, 2003; Gallagher, 1999; Sgroi, 1982). + +Furthermore, a variety of different kinds of definitional features are proposed. For example, one definition mentions "betrayal" (Salter, 1995) while another references "courtship" (Howitt, 1995). Some proposed definitions give concrete examples of grooming (Gallagher, 1999; Sgroi, 1982), while others try to give abstract properties to capture what the authors take to be the essential properties of grooming (O'Connell, 2003; Spiegel, 2003). Some definitions are fairly brief and more vague (Brackenridge, 2001; Howitt, 1995; Spiegel, 2003), whereas others are much longer and more detailed about what grooming looks like (Berson, 2003; Craven et al., 2006; Sgroi, 1982). Obviously this heterogeneity presents serious challenges for forensic and clinical work. + +Some of these definitions involve additional difficulties in that the terms used to define grooming present additional serious definitional problems themselves. For example, Salter (1995) used the phrase "emotional seduction" in her grooming definition. This requires further delineation of what exactly emotional seduction entails as well as a measurement strategy to validly capture this alleged dimension. As another example, Spiegel's (2003) definition involves constructs such as "boundary diffusion" and "role confusion." These constructs are not part of the standard scientific lexicon and thus create further impediments to enhancing our scientific understanding of the grooming process. Finally, some definitions propose stages of grooming, + +TABLE 3 Proposed Stages of Grooming + +| Author | Stages of Grooming | +|------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------| +| van Dam (2001) | 1. Identify vulnerable child
2. Engage that child in peerlike environment
3. Desensitize the child to touch
4. Isolate the child
5. Make the child feel responsible | +| Brackenridge (2001)
Applies to grooming in sport. | 1. Targeting a potential victim
2. Building trust and friendship
3. Developing isolation and control, building loyalty
4. Initiation of sexual abuse and securing secrecy | +| Wyre (1987) as discussed in
Howitt (1995) | Applies to extrafamilial grooming:
1. The offender masturbates and fantasizes about future contacts, a boy is befriended while an effort is made to earn his parents' trust, outings are common to achieve intimacy
2. The offender finds out about the boy's home/school problems—a "counseling" role is created
3. Physical contact of a nonsexual sort begins, offender's masturbation and fantasy continue, sexual touches begin and gradually increase in severity

Applies to intrafamilial grooming:
1. Tickling the child
2. Bathing
3. The offender's sexual arousal and fantasy
4. The child going to the offender's bed
5. The offender knows the child likes being tickled
6. "Sex education"
7. Tickling reaches child's sexual parts
8. Offender masturbates the child's genitals
9. The child is trapped into silence
10. Sexual contact is increased
11. Offenders cognitive distortions increase
12. Becomes difficult to end sexual contact
13. Offending behavior reinforced through masturbation to fantasies | +| Christiansen and Blake (1990)
Applies to father-daughter grooming. | 1. Trust
2. Favoritism
3. Alienation
4. Secrecy
5. Boundary violations | +| O'Connell (2003)
Applies to online grooming. | 1. Friendship-forming
2. Relationship-forming
3. Risk assessment
4. Exclusivity
5. Sexual | + +which makes the definitional and measurement process even more complex as each of these stages must be delineated and validly measured, and this must be done with the proposed sequencing as well. For example, Wyre's (1987) proposed stages for intrafamilial abuse involved 13 separate steps, the first 10 of which according to the author can be identified as grooming behaviors. As Howitt (1995) pointed out, this account of the abuse cycle makes it "appear a relatively short-term and repetitive process" (p. 85), which certainly is not representative of all cases of child sexual abuse. + +# GROOMING AS A DEVIANT PROCESS + +Part of the difficulty in identifying and clarifying a useful definition of grooming is the fact that many behaviors used by perpetrators appear quite similar to behaviors seen in normal adult—child relationships. Buying gifts for children or taking them on private outings obviously are not always precursors to sexual abuse. Using the male sports world as an example, Hartill (2009) wrote that "in preparing for the abuse, the perpetrator is able to use such 'disinhibiting' techniques through drawing on practices and discourses that are, to varying degrees, a normative feature within many, if not all, male sports contexts" (p. 239). Obviously part of the reason for this similarity to normative behavior is that the potential abuser does not want to be detected and thus wants to disguise what he is setting out to accomplish. In addition, it must be recognized that not all sexual offenders use grooming techniques. Groth, Hobson, and Gary (1982) differentiated between "child molesters" and "child rapists." Part of this distinction for these authors stems from their observation that child molesters use a grooming process on their victims, whereas child rapists do not, as their assaults occur suddenly. These authors also pointed out that child molesters are much more common than child rapists. Alternatively, some authors seem to construe grooming behaviors as mirroring behaviors seen in dating relationships between two consenting adults. For example, Herman (1981) wrote that sexually abusive fathers make an attempt to "court" their daughters by giving them flowers or presents (e.g., expensive jewelry or lingerie). + +# THE PREVALENCE OF GROOMING + +Because the definition of grooming varies from study to study, currently there is no way to know precisely how prevalent grooming is because each study employs some variant of the definition. Nevertheless, there have been several empirical studies conducted with child molesters to determine what specific methods they frequently use to choose their victims, initiate the abuse, and keep their victims from disclosing. Other researchers have chosen to focus + +on the victims and ask them what techniques their abusers used prior to the abuse. It is important to note that in this article, examples of grooming with different genders of perpetrator and genders of victim are not readily distinguished. This is primarily due to the fact that the grooming literature reviewed did not always provide statistics about which grooming behaviors were used on boys versus girls. In addition, most of the grooming literature reviewed discussed male offenders. + +#### Identifying Potential Victims + +Elliott and colleagues (1995) interviewed 91 child sex offenders about the strategies they used when committing their offenses. They found that 33% of the offenders explicitly worked on becoming welcome in the child's home and 18% offered incentives or threatened their victims to recruit other children and then gave bribes to the recruits. + +Conte, Wolf, and Smith (1989) interviewed 26 offenders about their crimes. They found that offenders often admitted to being able to identify what they considered a vulnerable child—often one who was "needy" and seemed "quiet." For example, one offender stated that his tactic was to "look for a kid who is easy to manipulate. They will go along with anything you say. I would approach them by being friendly, letting them think I was someone they could confide in and talk to" (Conte et al., 1989, p. 298). + +In her review of literature about sexual abuse involving teachers, Shakeshaft (2004) noted that selection of a victim is "influenced by the compliance of the student and the likelihood of secrecy" (p. 32). Teachers usually look to victimize students whom they have control over. Shakeshaft also identified factors that make a child vulnerable to educator sexual abuse, such as problems at home with parents, lack of confidence, and participation in other risky behavior. However, it also must be remembered that nonoffending adults could see the same needs in these vulnerable children and want to help them in legitimate ways. Thus the child's vulnerability and needs cannot be a sufficient condition for defining grooming. + +#### The Use of Attention, Bribery, and Coercion + +Elliott and colleagues (1995) found that 53% of the offenders in their sample offered to play games, teach a sport, or teach how to play a musical instrument. Forty-six percent gave bribes, took the child for an outing, or drove the child home. Thirty percent admitted to using affection and love to gain the child's trust. Forty-six percent of the offenders used gifts as bribes in exchange for sexual favors. + +The offenders interviewed by Conte and colleagues (1989) also claimed they used bribery and coercive strategies prior to sexual contact. For example, one sex offender stated that his specific methods included "play, talking, giving special attention, trying to get the child to initiate contact with me. Get the child to feel safe to talk with me" (p. 297). + +In his literature review on teacher sexual misconduct, Knoll (2010) found that educator sexual offenders tend to use bribery by giving their students special attention or rewards. According to Knoll, "the power of such rewards to affect the student should not be underestimated. Rewards from a teacher may have a crucial impact on the student's motivation and cognitions" (p. 376). + +Budin and Johnson (1989) interviewed 72 sex offenders about methods they used to gain access to and abuse their victims. When asked what they did to gain their victims' trust, the majority of offenders admitted to acting like the child's friend and playing games with them. Other strategies included giving money, toys, candy, cigarettes, beer, or drugs to the child. + +In his study of institutional sexual abuse, Gallagher (2000) looked at a sample of 65 substantiated cases of abuse. He found that grooming, or "entrapment," which he defined as "the process by which perpetrators draw children into abusive situations and make it difficult for them to disclose" (p. 810) was reported in 35% of cases. In these cases, he found that 39% of perpetrators took the child away from the institution (thus isolating the child), 22% gave the child extra attention, 22% gave money to the child, 9% provided the child with illicit goods, and 4% provided the child with games or toys. + +In their interviews with 23 CSA victims, Berliner and Conte (1990) found that many children shared similar experiences with bribery and coercion prior to their abuse. Sixty-one percent of children reported that their abusers made excuses to spend time alone with them; 61% indicated that they were told that they were special, different, or the only one who understood the abuser; 61% said that their abuser treated them as an adult or he acted as a child toward them; 57% reported that their abusers gave them special privileges that made them feel obligated to be compliant in the abuse; 39% indicated that their abuser shared private information about spouses with them; 39% reported that their abuser prevented them from having friends or doing activities that other children do; and 30% reported that their abuser treated them "meaner" than other children. + +Shakeshaft (2004) wrote that in educator sexual abuse, teachers usually "coerce" their student victims by providing additional help (e.g., advisement on a project or taking on an outing) that not only allows for time alone with the victim but are also activities for which the victim's parents tend to be grateful to the teacher. Furthermore, she pointed out that because these acts do not yet constitute recognizable sexual abuse and because they share similarities with legitimate activities, any complaint about these activities cannot lead to much disciplinary action. + +Christiansen and Blake (1990) discussed that in father—daughter incest, most fathers purposely build a trusting relationship with their daughters prior to beginning any sexual abuse. However, this is a somewhat flawed analysis, as there ought to be a trusting relationship in all father—daughter relationships, at least prior to any abuse. Seventy-three percent of perpetrating fathers viewed this trust as crucial to the sexual relationship to reduce the risk of the daughter disclosing the abuse (Warner-Kearney, 1987, as cited in Christiansen & Blake, 1990). Many fathers also show clear signs of favoritism toward their victimized daughter relative to their other children. Burgess and Holmstrom (1980) wrote that molesters tend to use three types of pressure to make their victims compliant: material goods, misrepresentation of moral standards, and the need for human contact. They noted that material goods are the most frequent tool that offenders use. + +One difference has been found between genders of the victim in this emotional coercion type of grooming. Spiegel (2003) noted that in male victims, emotional coercion can take on a negative tone. For example, perpetrators may use name-calling words such as "fag" or "whore" to put the male child down and make him feel ashamed and thus less likely to disclose the abuse. + +# Sexual Desensitization + +Elliott and colleagues (1995) found that of those offenders who used babysitting as a strategy to gain access to their victims, 27% started talking to the child about sex, 21% misrepresented the abuse as educational or loving (which again may not be part of grooming because some of this would be postabuse), and 20% offered to bathe or clothe the child. Furthermore, these authors found that 40% of all offenders said the first move they made was sexual touching or genital kissing. Thirty-two percent of the offenders asked the child for help with undressing or lying down. Forty-four percent of the offenders used coercion and persuasion, 49% talked about sex with the child, and 47% used "accidental" touch. Sixty-one percent of the offenders would stop the abuse if the child became resistant and then persuaded the child to let them begin again. Many offenders committed the abusive acts in their own homes, where 33% used pornographic videos and magazines to desensitize the child. + +Conte and colleagues (1989) found that sexual desensitization was commonly used among the offenders in their sample. For example, one offender stated, + +Most of the time I would start by giving them a rub down. When I got them aroused, I would take the chance and place my hand on their penis to masturbate them. If they would not object, I would take this to mean it was OK. I would isolate them. I might spend the night with them. Physical isolation, closeness, contact are more important than verbal seduction. (p. 297) + +Knoll (2010) found that while a teacher is using bribery to gain the trust of a victim, typically conversation about sexual matters with the student is also starting to emerge. Physical contact is then gradually increased. Furthermore, Gallagher (2000) found that in cases where "entrapment" behaviors were reported, 43% of perpetrators initiated physical contact with the child and 17% behaved in a sexual manner with the child. + +Furthermore, differences between genders of the victim have also been noted in the sexual desensitization type of grooming. Spiegel (2003) noted that the use of pornography to sexually desensitize children is more common with male victims than with female victims. + +# Boundary Violations + +Berliner and Conte (1990) found that 70% of children reported that their abusers "accidentally" came into their bedroom or bathroom while they were undressing; 61% indicated that their abusers "accidentally" touched their private parts; 61% said that their abusers did not respect their privacy or let them close doors; 61% reported that their abusers "accidentally" showed their naked body to them; 57% indicated that their abusers would purposely do things with the child that involved physical contact; 48% said that their abusers made sexual comments about the child's body or clothing; 44% reported that their abusers asked them to do things that involved physical contact; 30% said that their abusers would inspect the child's body "to see how it was developing"; 30% indicated that their abusers "taught sex education" by showing pornographic pictures and touching the child's body; 26% reported that their abusers told the child about sexual things he had previously done; and 22% indicated that their abusers put lotion or ointment on the child when they were alone but said he was doing nothing wrong. + +According to Christiansen and Blake's (1990) stages of grooming in father—daughter incest, the last step involves the father violating his daughter's boundaries. In particular, fathers may insist on bathing their daughters and do not allow other family members to do this. These baths frequently involve inappropriate sexual behavior. Fathers also insist on dressing their daughters or on watching them get dressed. In addition, fathers will tend to watch the child use the bathroom. Finally, perpetrating fathers will have sexually explicit conversations with the daughter to further desensitize them. + +# Grooming the Child's Environment + +Elliott and colleagues (1995) found that 20% of the offenders in their sample admitted they gained the trust of the child's family with the purpose of abusing the child. Forty-eight percent isolated their victims through babysitting. Furthermore, Knoll (2010) found that a teacher can also manipulate the relationship with her victim's parents to gain their approval of spending time with their child. + +Van Dam (2001) pointed out that many child molesters spend years gaining the trust of members in the community before actually sexually abusing any children. She hypothesized that these offenders use several social psychological techniques to groom the community effectively. As an example, they may use "foot-in-the-door technique" by showing up uninvited to a child's birthday party and spending time playing games with the children. The parents would feel uncomfortable asking this person to leave and have thus subtly cooperated with the offender. From then on it would be easier for the offender to gain cooperation from the parents on spending time with the children. Offenders can also use conformity against these parents—it would go against social norms and be rude to ask a person to leave a party when the children are enjoying spending time with an offender. In addition, cognitive dissonance can play a role as the parents will try to make their beliefs about the offender consistent with their actions of letting their children around him or her (they will believe that they think he or she is a good person). Finally, confirmation bias can also play a role as the parents will tend to only accept information that is confirming their existing beliefs about the offender. + +#### Commonalities + +The two major commonalities in the definitions reviewed as well as the empirical studies of grooming are (a) some sort of inappropriate behavior on the part of the prospective abuser (whether it is a bribe, boundary violation, invasion of privacy, misstatement of morality, mischaracterizing an interaction as a "game," isolation, emotional manipulation, etc.) and (b) the function of this inappropriate behavior is to increase the likelihood that the adult can sexually abuse the child (by, for example, gaining access to them, gaining their trust, silencing them, isolating them, desensitizing them to nudity or sex, etc.). Each component of the definition may have different topographies in individual cases (e.g., sometimes the inappropriate behavior is removing a door to the child's bedroom, or sometimes it may be buying the child a bikini), but the function of the behavior is to increase the likelihood of future abusive contact. + +### A PROPOSED DEFINITION + +Any definition ought to use the empirical findings reviewed previously about common strategies used by sexual molesters. In addition, we believe that the most useful definition of grooming would attempt to instantiate the following definitional meta-criteria: + +- 1. Minimize false negatives. Thus, we wanted the definition to be sensitive to all occurrences of grooming. +- 2. Minimize false positives. Thus we also wanted the definition at the same time to be specific and not overinclusive (including perfectly appropriate behaviors as invalid examples of grooming). +- 3. Be capable of providing the basis for a valid assessment procedure. +- 4. Not include constructs that in themselves bring about further definitional problems. +- 5. Minimize judgment, although not completely avoid it as we believe that determining a behavior to be grooming essentially requires some complex judgments regarding appropriateness. +- 6. Show interrater reliability (have a high degree of agreement across raters). +- 7. Allow the rater to have multiple choices regarding final decisions given the complexity of individual cases, such as clearly grooming, probably grooming, uncertain, or not grooming. +- 8. Allow a third party to understand the logic of these judgments and conclusions by explicating the decision pathway for these final judgments. + +We propose that grooming be defined as "antecedent inappropriate behavior that functions to increase the likelihood of future sexual abuse." There are no stages of grooming as there are in some definitions as proposing stages necessitates additional definitions and demarcations of each stage. Therefore, there are two individual criteria that must be met to consider a behavior to be "grooming:" (a) the behavior being evaluated must in and of itself be inappropriate and a case for this inappropriateness must be made, and (b) a sound argument must be presented that the behavior or behaviors increases the likelihood of future sexual abuse. The definition is further elucidated by providing a number of exemplars of grooming: + +- 1. Any sexualization of the relationship such as talking about sex in a way that is not permissible given the adult's relationship with the child (e.g., it is permissible for parents to provide sex education to their children) or exposing the child to sexually explicit materials such as R rated movies (showing the child pornography would be abusive in and of itself and therefore not grooming). +- 2. Inappropriate gift giving (developmentally or socially inappropriate, such as bikinis or bras purchased by a neighbor or teacher). +- 3. Inappropriate nonsexual communication with the child (e.g., telling the child she is the only one who understands the offender, or telling her "I love you" when the social role is not appropriate for this type of communication), particularly when an adult uses these statements to manipulate the child to do something (e.g., "I love you and people who love each other touch each other"). + +- 4. Inappropriate touching of the child (e.g., excessive tickling, hugging, wrestling, sitting on lap). +- 5. Bribes for inappropriate contact (e.g., bribes for nonsexual or sexual touching or bribes to meet the adult secretly). +- 6. Threats related to not participating in inappropriate contact. +- 7. Inappropriate isolation of the child (e.g., trips where the offender and victim are alone that are not part of the normal adult-child relationship. It is permissible for a father to drive a child to school), or inappropriately discouraging the child to play with friends or be with family. For parents or other caretakers, the threshold for what is considered inappropriate behavior is higher than for other adults. +- 8. Favoritism directed toward the child (e.g., the child is treated much better than siblings or classmates, particularly when this is intimate or isolating). +- 9. Boundary violations such as inappropriately bathing the child, clothing the child, sleeping with the child, the adult being in underwear around the child, the adult acting like a child, or the adult sharing private information with the child, particularly sexual or relationship information (e.g., "my wife and I are not having sex"). Again, for parents, family members or caregivers the threshold is much higher for defining a boundary violation than for others. +- 10. Asking the child to keep secrets, particularly about their contact (e.g., the mother's Christmas present would not be regarded as a problematic secret, whereas asking the child to not tell that she was with the offender would be). +- 11. Providing the child drugs or alcohol (note: although this behavior is already abusive, it is not sexually abusive; thus, it can be considered a grooming behavior as it is inappropriate and serves to facilitate compliance with the intended sexual abuse). +- 12. Misstating moral standards regarding touching, contact, or sex, particularly when these relate to adult—child sexual contact or sexualizing a situation. +- 13. Repeated violations of the child's privacy (e.g., walking into bathroom when child is in there, watching her get dressed, etc.). + +The more of these features present, the more likelihood the individual's behavior represents grooming. To further clarify the grooming definition, it may be helpful to also look at a few specific exemplars of nongrooming behaviors that may be misinterpreted: + +- 1. Purchasing appropriate gifts for the child (e.g., for birthdays). +- 2. Engaging in appropriate hand-holding (e.g., to cross the street). +- 3. Bathing a young child by a legitimate caregiver without any inappropriate touching. + +- 4. Having age-appropriate and relationship-appropriate discussions of body parts. +- 5. A care-giving figure saying "I love you" without the goal of manipulation (not using the phrase to get the child to do something inappropriate). + +# THE ASSESSMENT OF GROOMING + +Because grooming is a set of common behaviors seen in child sexual offenders (as the previous reviewed literature seems to support this conclusion), it should be possible to accecs behaviors to determine whether they are indicative that sexual abuse is likely to occur. We have reviewed the published literature and have not been able to find any measures that validly assess grooming behaviors (by any definition of grooming). This greatly reduces the value of any definition as the practical usefulness of a definition is seen in its ability to be operationalized in valid measurement processes. It is important to develop valid measures as it is not ideal for the detection of grooming to be an entirely post hoc process—that is, only after the abuse occurs are the gifts seen as inappropriate and thus as part of a grooming process. The grooming acts should seem at least somewhat inappropriate at the time they are occurring and thus ideally adults can intervene to stop future abuse. To resolve this problem, grooming requires a valid definition and a psychometrically adequate assessment procedure to reduce both the number of false positives and false negatives. + +We are currently developing an assessment device that would aid a clinician in coming to a valid conclusion as to whether an individual's behaviors can be considered grooming. As mentioned, an assessment of grooming in our proposed definition would involve a two-step process: (a) determining that the adult's behavior is inappropriate in and of itself, such as if the tickling is excessive or the bikini gift is not justified by the nature of the relationship; and (b) reasonably arguing that the function of this inappropriate behavior is to increase the likelihood of future abusive contact. + +What is "inappropriate" admittedly is somewhat of a vague term that requires judgment because we need to clearly differentiate the behavior from normal adult—child relationships. However, this judgment requirement currently exists for other psychological constructs as well. For example, the diagnosis of a major depressive episode might require that a clinician judges the client's guilt as "excessive." In addition, under our criteria these judgments of inappropriateness should be explicit (there must be a clear argument as to why the behavior is inappropriate). Since the argument must be explicated, others would be able to evaluate it and decide whether it is a nonproblematic judgment of the behavior. + +To illustrate, a male coach buying an eight-year-old girl a bikini would generally be considered inappropriate, but the act of buying her a pair of gym shoes with her mother's consent generally would not. A criticism of this definition is that -appropriate" behaviors may be used by some perpetrators to groom (e.g., buying a poor child gym shoes may still be performed to gain the child's trust to eventually abuse her). However, because this behavior can be entirely unrelated to abuse and because the assessment ought to strive to minimize false positives, we have chosen to require that all grooming behaviors be inappropriate in and of themselves. Second, we recognize that not all inappropriate behaviors ought to be considered grooming—an adult offering cigarettes to a child may be inappropriate but in addition we narrow the class of these inappropriate behaviors to those that are related to increasing the probability of sexual contact. + +It is important to note that there may be instances in which the questionable behavior falls in some gray area between grooming and nongrooming. For example, a father buying his daughter a bikini may or may not be considered inappropriate. Unless more details are known about the context of this purchase (perhaps it was just impossible for the mother or some other female to do this and the need for a bathing suit was urgent), one could explicate reasonable arguments that the behavior is and is not representative of grooming. The most logical judgment to come to, then, is that this behavior is an indeterminate case and that it is unclear whether it should be considered grooming. + +Arguments also need to be made regarding the second criterion of the definition: whether the function of the inappropriate behavior was to increase the likelihood of abuse in the future. Interpreting behavior and the intentions of a person performing a behavior is admittedly complex. The rational appraisal of behavior involves setting up a universe of plausible interpretations and gathering evidence in the individual case to rule in or rule out each. As an example, if a male neighbor has a pool and buys a bikini for a five-year-old girl to come over to swim and has her change into the bikini at his house while they are alone (the purchase of the bikini and having her change in his house without her guardian present would be considered inappropriate and thus meet the first criterion of the definition), the set of major plausible interpretations regarding the function of the behavior include: + +- 1. Buying a bikini for the girl was the only way to allow the child to engage in the appropriate activity of swimming. Changing at his house was the only way to have the child dressed appropriately for swimming. These facts do not function to set the occasion for abuse to occur. +- 2. Buying a bikini and having the child change alone is not appropriate as there are more appropriate, prudent alternatives. In addition, bikinis can be thought of as sexualized clothing and changing alone without a guardian present is also a boundary violation. For example, giving money to the child's guardian to buy whatever bathing suit the guardian thought + +appropriate (perhaps a one piece) is a better way to allow the child to engage in the healthy activity of swimming. In addition, the child's guardian should always be present when the child is swimming in the pool or changing into her bathing suit. This pathway does not increase the probability that abuse will occur in the future. + +In this case, clearly the second alternative explanation is superior due to the fact that it respects the guardian's control, enhances the guardian's ability to supervise the child, does not isolate the child, might involve a less revealing swimsuit, and allows the guardian to exercise his or her discretion regarding what is appropriate swimwear. In addition, because the first alternative contains false assertions and can set the occasion for abuse, while the second alternative contains true assertions and is consistent with decreasing the likelihood of abuse, it is concluded that the behavior under question meets the second criterion of our definition of grooming as it is functioning to increase the likelihood of future abuse. + +Again, the advantage of this approach is that it explicates the arguments for a person's behavior as meeting or not meeting the definitional criteria. The situation is complex because often grooming is meant to be disguised or ambiguous by the would-be abuser. However, this approach does allow the generation of alternatives that would be more prudent and reasonable and thus both the inappropriateness and function of the behavior can be rationally identified. + +Finally, before this assessment method is accepted it must be evaluated with respect to its interrater reliability, predictive validity, sensitivity, and specificity. Currently, it is unfortunate that the field has no assessment methods to properly identify grooming and thus understanding the psychometrics of this definitional approach (as well as others) ought to be a priority. + +Obviously the proposal of this definition is just a first step, and it generates a large research agenda. Validity studies need to be run on a sample of what experts clearly identify as instances of grooming and instances of normal behavior to see the extent to which professionals trained in this definition can correctly identify these two kinds of behaviors. The rates of false positives and false negatives need to be identified in these sorts of studies and modifications in the definition, assessment, or training need to occur in attempts to minimize these. Randomly controlled studies can be used to compare the accuracy of this method as compared to other proposed methods and definitions. Studies need to be conducted investigating different types of abuse (e.g., familial versus nonfamilial, boys versus girls, young children versus teenagers, majority versus minority culture) to see the extent to which this definition is robust across these varying dimensions. Again, modifications would need to be made when problems or limitations are found. It would also be useful to conduct some longitudinal research with high-risk samples to determine the likelihood of accurate detection of grooming and the prevention of future abuse (by perhaps a comparison with a no treatment control). Another important issue is to investigate what sort of training programs or materials need to be developed so that a wide variety of professionals can faithfully implement the definition and proposed assessment methods. + +# CONCLUSIONS + +Currently there is no consensus regarding how to define grooming. In addition, there is no valid method to assess whether grooming has occurred or is occurring. The field poetesses an insufficient amount of knowledge about key issues such as the interrater reliability of these judgments or the error rates of these judgments including the frequency of false negatives or false positives. Thus currently it appears that grooming is not a construct that ought to be used in forensic settings as it does not meet some of the criteria in the Daubert standard. The Daubert standard indicates that in court an expert witness may only testify if (a) "the expert's scientific, technical, or other specialized knowledge will help the trier of fact to understand the evidence or to determine a fact in issue; (b) the testimony is based on sufficient facts or data; (c) the testimony is the product of reliable principles and methods; and (d) the expert has reliably applied the principles and methods to the facts of the case" (Rule 702: Testimony by expert witness). Right now it does not appear to be the case that there are "reliable principles and methods" to define and detect grooming. + +We propose a definition of grooming that involves two parts: (a) inappropriate behavior on the part of the adult and (13) sound arguments that this inappropriate behavior functions to increase the probability of future sexual abuse. We then provide exemplars of this kind of inappropriate behavior. Future research on grooming would be more useful to the field if data were collected using a single, clear definition such as the one we have proposed. This would provide a basis for data to be easily aggregated and better understood, which could lead to the admissibility of grooming evidence in forensic settings. Furthermore, we are currently working to develop valid psychometric instruments with known reliability and validity to assess grooming according to this standard. + +#### REFERENCES + +18 USC 2252A. Certain activities relating to material constituting or containing child pornography. (n.d.). In Legal Information Institute online. Retrieved from http://www.law.comell.edu/uscode/text/18/2252A + +Berliner, L., & Conte, J. R. (1990). The process of victimization: The victims' perspective. Child Abuse and Neglect, 14, 29-40. Berson, I. It (2003). Grooming cybervictims: The psychosocial effects of online exploitation for youth. Journal of School Violence, 2(1), 5-18. 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The child molester: Clinical observations. In J. R. Conic 8c D. A. Shore (Eds.), Social work and child sexual abuse (pp. 129-144). Binghamton, NY: The Haworth Press. Hartill, M. (2009). The sexual abuse of boys in organized male sports. Men and Masculinities, 12, 225-249. Herman, J. L. (1981). Father-daughter incest. Cambridge, MA: Harvard University Press. Howitt, D. (1995). Paedophiles and sexual offences against children. Oxford, England: John Wiley and Sons. Knoll, J. (2010). Teacher sexual misconduct: Grooming patterns and female offenders. Journal of Child Sexual Abuse, 19, 371-386. Laudan, L. (1977). Progress and its problems. Berkeley, CA: University of California Press. Leberg, E. (1997). Understanding child molesters: Taking charge. Thousand Oaks, CA: Sage. + +McAlinden, A. (2006). "Setting 'ern up": Personal, familial and institutional grooming in the sexual abuse of children. Social & Legal Studies, 15(3), 339-362. Mower, L. (2012, July 22). Sex assault conviction may be test case for testimony standards. Las Vegas Reviewfournal. Retrieved from http://www.Ivrj.com/news/sexassault-conviction-may-be-test-case-for-testimony-standards-163325306.html O'Callaghan, D. (2011, November 7). Jailed after grooming teen online: Facebook groomer is jailed. South Wales Everting Post. Retrieved from www.lexisnexis. com/hottopic.s/Inacademic O'Connell, R. (2003). A typology of child cybersexploitation and online grooming practices. Retrieved September 2012 from http://www.jisc.ac.uk/uploaded\_ documents/lis\_PaperfPrice.pdf O'Donohue, W. (2013). Clinical psychology and the philosophy of science. New York, NY: Springer. Rule 702. Testimony by expert witness. (n.d.). In Legal Information Institute online. Retrieved from http://www.law.cornell.edu/rules/fre/rule\_702 Salter, A. (1995). Transforming trauma: A guide to understanding and treating adult survivors of child sexual abuse. Newbury Park, CA: Sage. Seto, M. (2008). Pedophilia. In D.R. Laws & W. O'Donohue (Eds.), Sexual deviance: Theory, assessment, and treatment. New York, NY: Guilford. Sgroi, S. M. (1982). Handbook of clinical intervention in child sexual abuse. Lexington, MS: Lexington Books. Shakeshaft, C. (2004). Educator sexual misconduct: A synthesis of existing literature (U.S. Department of Education Document No. 2004.09). Washington, DC: U.S. Department of Education. Spiegel, J. (2003). Sexual abuse of males: The SAM model of theory and practice. New York, NY: Brunner-Routledge. Van Dam, C. (2001). Identifying child molesters: Preventing child sexual abuse by recognizing the patterns of the offenders. Binghamton, NY: The Haworth Press. Vance, A. (2012, August 29). Prison for online grooming proposed. The Dominion Post (Wellington, New Zealand). Retrieved from www.lexisnexis.corn/hottopics/ lnacademic Wyre, R. (1987). Working with sex offenders. Oxford, England: Perry Publications. + +# AUTHOR NOTES + +Natalie Bennett, BS, is a graduate student in the Clinical Psychology Doctoral Program at the University of Nevada, Reno. Her current research interests focus on child sexual abuse and assessment of psychological constructs. + +William O'Donohue, PhD, is a professor of psychology at the University of Nevada, Reno. He is also the clinical director of the Victims of Crime Treatment Center, a treatment clinic for victims of sexual abuse or assault, in Reno, Nevada. He received his MA and PhD from the State University of New York at Stony Brook in Stony Brook, New York. + +# Grooming and Seduction + +Park Dietz' + +Journal of Interpersonal Violence + +2018. Vol. 33(I) 2046 + +0 The Author(,) 2017 + +Reprints and pensions: + +iagepuecanfloumabPermIstionsser + +DOt: 10.117703\$6260S 17742060 + +iournalasappuboorwhomerliv + +![](_page_21_Picture_11.jpeg) + +#### Abstract + +Ken Lanning's recollections of the origins of the use of the term "grooming" to refer to techniques used by acquaintances to gain sexual access to and control over children is an important contribution to the history of the significant recognition that many cases of child sexual abuse occur at the hands of offenders who are acquaintances of the child and who do not need to use force, threats, or violence to gain the compliance of their victims. That this recognition was slow in coming is obvious in retrospect. as is true of any social problem that remains hidden for centuries only to burst into public consciousness over the course of a few years. In this article, I report the results of searches using Google Scholar to look at the introduction of this use of the term "grooming" to the peer-reviewed literature in 1984 and its increasing use through 2016. Since 2008. the usage has been adopted in hundreds of articles in the professional literature each year. suggesting that this usage of the term "grooming" will remain common in the decades ahead. I also examine the history of the term "seduction" in the context of child sexual abuse, particularly two archaic uses of the term: as a euphemism for any sexual or sexually stimulating encounter between child and adult and in the context of suggestions that it was the child who seduced the adult. To avoid resurrecting any confusion over these issues. it would be a mistake to abandon "grooming" in favor of "seduction." I conclude that the best strategy may be that adopted by Lanning of using the terms grooming and seduction in tandem, explaining the parallels between the seduction of one adult by another and the grooming or seduction of a child by an adult. + +#### Corresponding Author: + +Park Dim. Park Dieu & Associates, Newport Beach. CA 92663. USA. + +Emelt expert@parkdletrassociates.com + +&#x27;Park Olen & Associates. Newport Beach. CA. USA + +#### Keywords + +grooming, seduction, child sexual abuse, acquaintance molestation, litigation + +# Grooming and Seduction + +In the development of knowledge of child sexual abuse, few discoveries could outweigh the importance of recognizing that a large proportion of offenses are committed by acquaintances of the child using techniques other than force or threat of force. No individual has done more to share this insight with the international law enforcement community than Ken Lanning, whose writings and teachings have also reached mental health professionals, those who work in the criminal justice and social service systems, those who care for the nation's children, and countless concerned citizens and parents. + +The application of the terms "seduction" or "grooming" to these nonforceful, nonthreatening, and nonviolent techniques has been in the service of disseminating this important insight, which first burst into public consciousness as a real possibility in the mid-1980s as a result of partially untrue media reports about the McMartin School case and the case of Father Gilbert Gauthe, both of which stories first broke in 1984. Yet even today, far too many people, including many who should know better, have difficulty grasping the possibility of nonforceful, nonthreatening, and nonviolent acquaintance molestation, as their preconceptions of childhood innocence and predatory molesters are too strong to allow them to accept that children can be so readily manipulated into doing or allowing things that others find abhorrent. + +## Grooming + +Lanning (2018) is precisely correct in dating to the 1980s the use of the term "grooming" to refer to techniques for gaining sexual access to children and in his observation that during the 1980s, this usage gradually increased. Using the search capabilities of Google Scholar, I found no use of the word "grooming" to mean such techniques in conjunction with the terms "child sexual abuse," "child molestation," or "child molester" in the professional literature from 1850 through 1983. The first publication identified by Google Scholar as using the term "grooming" in this way was an article by Conte (1984) citing Groth and Bimbaum (1979) for the proposition that "[i]n most cases, except those involving abuse by a stranger, the perpetrator involves children in sexual abuse through a grooming process in which a combination of kindness, attention, material enticement, special privilege, and coercion are + +![](_page_23_Figure_2.jpeg) + +Figure 1. Use of the term "grooming" in association with "child sexual abuse" in the professional literature accessed by Google Scholar. 19842016. as of 25 August, 2017. + +expertly applied" (p. 558). Groth and Birnbaum accurately describe the process (at p. 142.143), but do not use the term "grooming." + +Figure 1 shows how the maximum number of publications in the database using the term "grooming" for this meaning' has increased since 1984. For the remainder of the 1980s, zero to nine publications per year used "grooming" for this meaning. From 1990.1999, the annual frequency rose from eight to 63, and from 2000 to 2009, from 64 to 227. From 2010 to 2016, the annual frequency rose from 282 to 533. + +My own recollection of the growing use of the term "grooming" in this context during the 1980s and 1990s is that it spread not only through peerreviewed literature and books, but also though the teaching and training being conducted by Ken Lanning, Ann Burgess, and other thought leaders of the era, and that it was gradually adopted by journalists and the general public as well. As the term came to be widely applied, it became increasingly obvious that offenders who groom children often groom the parents of those children, the organizations through which they work or volunteer with children, and the communities in which they function. The success of these offenders in doing so makes it all the more difficult for observers to overcome the false belief that such a "nice guy" could not be harming children (Lanning & Dietz, 2014). + +Lanning (2018) points to some of the ways in which the term "grooming" has been misapplied (e.g., to refer to the use of "lures" in stranger cases or what might be expected parental behaviors in intrafamilial cases) but does + +not mention the misuse of the term in civil litigation. Where a victim is suing an employer or organization in connection with the sexual abuse of a minor by an employee or volunteer, it has become commonplace for the victim's advocate to argue that the failure to detect "grooming" was negligent on the part of the employer or organization. If their use of the term "grooming" always encompassed excessive focus on a particular child, time alone with the child, or inappropriate touching, this usage might not be problematic, but when "grooming" is applied to such common and desirable behaviors as being kind or attentive or helpful or caring, there is considerable risk of misleading the fact finder into believing that these latter behaviors are wellestablished predictors of child sexual abuse when there is no evidence whatsoever that they can help discriminate between good employees and volunteers, on the one hand, and risky employees and volunteers, on the other hand. In the litigation context, efforts to expand the concept of "grooming" to encompass desirable behaviors that are not associated with elevated risk is misleading, particularly when coupled with the presumption or suggestion that "grooming" always reflects an intent or plan to offend or, worse, that an offense can be proved by the fact that the accused engaged in "grooming." + +# Seduction + +Although I agree with Lanning (2018) that the term "seduction" is preferable to the term "grooming," at least when there is an opportunity to explain how similar the seduction of a child is to the seduction of an age-appropriate partner, there is ample historical reason to be cautious about the use of the term "seduction" in this context without further explanation. This is because of two archaic usages of "seduction" in the older literature. + +# Archaic Usage #1: Seduction as a Euphemism for the Offense + +One of the archaic usages of "seduction," found often in the older scientific literature, is as a vague euphemism for any occurrence of child sexual abuse or an event that may have been sexually simulating to the child, as in these passages: + +- "[A] shock of some kind is held responsible for the neurosis—an attack by an animal, a threat of castration, a seduction, an actual viewing of parental coitus ..." (Isaacs, 1928, p. 193). +- ". . I wondered whether the precocity of these fantasies and their frequency might not be due to actual seduction that the child had experienced ..." (Rank, 1942, p. 56). + +- ". . . It was expected that a connection would be found between the child's symptom and the seduction, which was assumed to be the traumatic factor ..." (Bornstein, 1946, p. 230). +- ". . . [W]here father or mother, either consciously or unconsciously, elevate the child into a substitute sexual partner or commit real acts of seduction with him ... (A. Freud, 1968, p. 45). +- "If we assume that the term `seduction' refers to any kind of sexual encounter, it can range from milder types, such as exposing oneself and enticing the child to follow suit, all the way to forcible rape" (Finch, 1974, p. 34). +- "She was then able to use the dolls to reveal the drama of her own seduction and the ensuing family chaos ..." (Mrazek, 1980, p. 279). + +Here "seduction" is not referring to the process by which a child is groomed or seduced but to the offensive event itself. Freud's seduction hypothesis ".. . generalized that the roots of all adult neuroses lay in childhood sexual contacts with adults" (Gagnon, 1965, p. 177). The vagueness of this use of "seduction" makes it impossible to determine which child sexual abuse behaviors are and are not encompassed by the term and suggests that "seduction" may mean different specific things to different authors. + +Authors sometimes imply that "seduction" does not include violence, as when they distinguish it from rape or other violent assaults, as in these examples: + +- "Klein has stated that an experience of seduction or rape by a grownup person may have serious effects upon the child's psychic development . .." (Bender & Blau, 1937, p. 500). +- "[T]he possible . . . event of seduction, incest, or rape . . ." (Lewis & Sarrel, 1969, p. 606). +- "Violence is rarely found to accompany the incestuous act, possibly because seduction, passive compliance, or sexual curiosity or exploration promote such relationships" (Singer, 1979, p. 8). +- "Children can be broken much more easily than adults, and the effect on them of torture, hatred, seduction, and rape—or even of indifference, of deprivation of love and care—is the devastating one of developmental arrest ..." (Shengold, 1979, p. 537). + +Although this usage comports with the modem idea of seduction or grooming insofar as it is to be distinguished from the use of force, threats, or violence, we would not today distinguish seduction from rape but rather would view seduction (or grooming) as a means of completing a rape or other sexual offense with minimal resistance or risk of disclosure. + +Cioffi (1976) interpreted Freud as using the concept of seduction to refer only to nonviolent sexual assaults, writing ". . . he duly reported that he had discovered the specific cause of psychoneurotic disorder: A passive sexual experience before puberty. In other words, a seduction" (p. 275). Cioffi's (1976) quotations of Freud in the same article support this interpretation: "Freud later assigned to his patients in phrases like: `hysterics trace back their symptoms to fictitious traumas'—or patients `ascribe their symptoms to passive sexual experiences in early childhood— (p. 277). Even here, however, what constitutes a "passive sexual experience" is unclear, as it could mean the offender did not use violence, that the child did not resist, or that the child was not an active participant. + +# Archaic Usage #2: The Child as Seducer + +A second archaic usage of "seduction" is to refer to the child's tempting of the offender. This is diametrically opposed to our current thinking about child sexual abuse in its suggestion that it is the child who is at fault, as in these examples: + +- ". . . [A] most striking feature was that these children were distinguished as unusually charming and attractive in their outward personalities. Thus, it is not remarkable that frequently we considered the possibility that the child might have been the actual seducer rather than the one innocently seduced" (Bender & Blau, 1937, p. 5 I 4). +- "The majority of pedophiles are harmless individuals and their victims are usually known to be aggressive and seductive children" (Revitch & Weiss, 1962, p. 78). +- "In many [cases] it was highly probable that the child had used his charm in the role of seducer rather than that he had been the innocent one who had been seduced ..." (Bender & Grugett, 1952, p. 826). +- "Abraham (1907) and Bender and Blau (1937) have commented on how charming and seductive these children can be" (Rosenfeld, Nadelson, Krieger, & Backman, 1977, p. 332). + +Three examples of authors attempting to remedy this archaic view are as follows: + +- "... Although there may be a different quality to a seduction than to an attack, it must be remembered that even a seductive child cannot have full adult comprehension of the act she is courting and cannot be viewed as responsible in this area" (Lipton & Roth, 1969, p. 859). + +"Because the affectional needs of the child are not adequately met by the parents, the child may indiscriminately relate to adults in an affection-seeking manner in an effort to ensure her emotional survival. + +Numerous other investigators have characterized this behavior of the child as 'seductive'. However, our study indicates that this behavior is instead the child's often desperate attempt to meet her needs for care and attention . . The child's behavior may often appear sexualized to an adult . . . As a result, it is more appropriate to describe this behavior as affection-seeking rather than seductive" (Johnston, 1979, pp. 948.949). + +- "'Everybody knows' that adults must protect themselves from groundless accusations of seductive or vindictive young people. . . . What everybody does not know, and would not want to know, is that the vast majority of investigated accusations prove valid and that most of the young people were less than eight years old at the time of initiation" (Summit, 1983, p. 178). + +#### Conclusion + +Since its introduction to the peer-reviewed professional literature in 1984, the term "grooming" has become so widely adopted that it will remain in widespread use for decades to come. We can and should clarify the meaning of the term wherever possible to avoid misuse or misleading of our audiences. We could benefit from prospective studies of the frequency of grooming-like behaviors among adults in target-rich environments such as schools, youth sports, and youth groups, which could help distinguish behaviors portending risk from those that do not, though it would require a large sample and a long time to reveal at least some of the offenders in the sample. + +The two archaic uses of the term "seduction" in the context of child sexual abuse identified here arc too recent and too widely known to justify completely abandoning the term "grooming" in favor of "seduction," even if it were possible to do so. Perhaps the best strategy is that adopted by Lanning (2018) of explaining the parallel between the courtship and mating rituals that adults use with one another and the courtship and mating rituals that some use with children. + +#### Declaration of Conflicting Interests + +The author(s) declared no potential conflicts of interest with respect to the research, authorship, and/or publication of this article. + +#### Funding + +The author(s) received no financial support for the research, authorship, and/or publication of this article. + +#### Note + +- 1. The data on which Figure I is based are derived from year-by-year searches of Google Scholar for the combination of the terms "child sexual abuse" and "grooming," excluding citations and patents. One should not assume that the underlying database is complete or that all the publications included in the count use "grooming" in this way or represent peer-reviewed literature, as newsletters, government reports, books, and other documents also make their way into such searches. Nonetheless, the graph gives an adequate representation of the growing use of the term "grooming" for this purpose. + +#### References + +Abraham, K. (1907). The experiencing of sexual traumas as a form of sexual activity. In E. Jones (Ed.), Selected papers on psycho-analysts (pp. 47-63). London, England: Hogarth Press. Bender, L., & Blau, A. (1937). The reaction of children to sexual relations with adults. American Journal of Orthopsychiatty, 7, 500-518. Bender, L., & Grugett, Jr., A. E. (1952). A follow-up study of children who had atypical sexual experience. American Journal of Orthopsychiatry, 22, 825-837. Bornstein, B. (1946). Hysterical twilight states in an eight-year-old child. The Psychoanalytic Study of the Child, 2, 229-240. Cioffi, F. (1976). Was Freud a liar? Orthomolecular Psychiatry, 5, 275-280. Conte, J. R. (1984). The justice system and sexual abuse of children. Social Service Review, 58, 556-568. Finch, S. M. (1974). Effects of adult sexual seduction on children. Journal of Clinical Child Psychology, 3, 33-35. Freud, A. (1968). Indications and contraindications for child analysis. The Psychoanalytic Study of the Child, 23, 37-46. Gagnon, J. H. (1965). Female child victims of sex offenses. Social Problems, 13, 176-192. Grath, A. N., & Birnbaum, H. J. (1979). Men who rape: The psychology of the offender. New York, NY: Plenum Press. Isaacs, S. S. (1928). The mental hygiene of the pre-school child. British Journal of Medical Psychology, 8, 186-193. Johnston, M. S. K. (1979). The sexually mistreated child: Diagnostic evaluation. Child Abuse & Neglect, 3, 943-951. Kris, E. (1950). The significance of Freud's earliest discoveries. The International Journal of Psychoanalysis, 31, 108-116. Laming, K. V. (2018). The evolution of grooming: Concept and term. Journal of Interpersonal Violence, 33, 5-16. + +Laming, K. V., & Dietz, P. (2014). Acquaintance molestation and youth-serving organizations. Journal of Interpersonal Violence, 29, 2815-2838. doi: 10.1177/0886260514532360 Lewis, M., & Sarre!, P. M. (1969). Some psychological aspects of seduction, incest, and rape in childhood. Journal of the American Academy of Child Psychiatry, 8, 606-619. Lipton, G. L., & Roth, E. I. (1969). Rape: A complex management problem in the pediatric emergency room. The Journal of Pediatrics, 75, 859-866. Mrazek, D. A. (1980). The child psychiatric examination of the sexually abused child. Child Abuse & Neglect, 4, 275-284. Rank, B. (1942). Where child-analysis stands today. American Imago; A Psychoanalytic Journal for the Arts and Sciences, 3(3), 41-60. Revitch, E., & Weiss, R. G. (1962). The pedophiliac offender. Diseases °like Nervous System, 23, 73-78. Rosenfeld, A. A., Nadelson, C. C., Krieger. M., & Backman, J. H. (1977). Incest and sexual abuse of children. Journal of the American Academy of Child Psychiatry, 16,327-339. Shengold, L. L. (1979). Child abuse and deprivation: Soul murder. Journal of the American Psychoanalytic Association, 27, 533-559. Singer, M. (1979). Perspective on incest as child abuse. Australian & New Zealand Journal of Criminology, 12, 3-16. Summit, R. C. (1983). The child sexual abuse accommodation syndrome. Child Abuse & Neglect. 7. 177-193. + +#### Author Biography + +Park Dietz, MD, MNI, PhD, was educated at Cornell, Johns Hopkins, and the University of Pennsylvania, and taught for 10 years at Harvard Medical School and the University of Virginia School of Law and School of Medicine. lie is now a clinical professor of psychiatry and biobeltavioral sciences at University of California, Los Angeles (UCLA). As president of Park Dietz & Associates, Inc., he regularly oversees forensic evaluations of psychological damages and expert assessments of liability in child sexual abuse litigation, and as president of Threat Assessment Group, Inc., he regularly participates in the development and implementation of programs to prevent and respond to misconduct in organizations and institutions. + +Journal of Sexual Aggration Routledge + +(November 2006), Vol. 12, No. 3, pp. 287 299 + +Sexual grooming of children: Review of literature and theoretical considerations + +Samantha Craven,''\* Sarah Brown' & Elizabeth Gilchrist2 + +'Department of Psychology, Coventry University, Coventry, UK, and 2Departmenr of Psychology, University of Kent, Canterbury, Kent, UK + +Abstract The current review aims w outline the existing understanding of sexual grooming. Issues + +of poor definition, the adoption of the term "grooming" and the prevalence of sexual grooming will be discussed Consideration will be given to how prominent theories of child sexual abuse often neglect sexual grooming. This will be followed by a detailed account of the existing knowledge within the literature. Three types of sexual grooming were thus identified• self-grooming, grooming the + +environment and significant others and grooming the child. Based on these findings, a new definition of sexual grooming is suggested. Furthermore, the findings correspond well with current models of the sexual offence process. A more comprehensive understanding of sexual grooming is required to facilitate + +a preventative approach to child protection. Keywords Sexual grooming; theory of child sexual abuse + +Introduction + +The complex nature of the tactics used by child sex offenders in their efforts to sexually abuse children is increasingly evident in the accounts of the people affected by this predatory behaviour. Sexual grooming is a pertinent issue evident in society, but there is still little understanding about this phenomenon. This is reflected in problems relating to definition, + +which will be discussed in addition to the evolution of the term "grooming". This review will + +# consider whether present aetiological theories of child sexual abuse can account for "sexual + +grooming" behaviour, and further determines what knowledge has already been established about the phenomenon of sexual grooming. Based on these findings, a new definition is presented and consideration is given to how current knowledge of sexual grooming relate to models of the sexual offence process. + +Definition Professionals are yet to agree on a definition of sexual grooming of children (Gillespie, 2004). Previous literature has provided three specific definitions of grooming. The strengths and + +\*Corresponding author: Samantha Craven, Department of Psychology, Coventry University, Priory Street, Coventry CV1 SFB, UK. Tel: 02476 887 048. Fax: 02476 888300. E-mail: s.craven@coventry•.ac.uk + +weaknesses of these definitions are discussed in turn below. First, O'Connell defines sexual grooming as: + +A course of conduct enacted by a suspected paedophile, which would give a reasonable person cause for concern that any meeting with a child arising from the conduct would be for unlawful purposes. (O'Connell, 2003, p. 6) + +Second, Howitt suggests that: + +Grooming... is the steps taken by paedophiles to "entrap" their victims and is in someways analogous to adult courtship. (Howitt, 1995, p. 176) + +These two definitions are problematic, because they both refer to the term paedophile. Most sexual offenders who target child victims use sexual grooming, not just those classified as paedophiles. The term "paedophile" is a very specific clinical diagnosis, clearly not applicable to all offenders, and the association of grooming behaviour with paedophilia may prevent some offenders from acknowledging their own grooming behaviours. In addition, people known to the offender may not identify the grooming behaviour because they do not consider the individual to fit their image of a "paedophile". The public perception of a paedophile is littered with stereotypes that they are "dirty old men" or strangers; these perceptions may affect an individual's judgement of whether the behaviour they have observed is grooming. These misperceptions distract from the truth that most victims know their abuser. It is important that the wording of a definition does not thwart the identification of sexual grooming and the subsequent prevention or ending of abuse. + +Furthermore, the phrase "a course of conduct" requires subsequent definition. Additional problems include reference to "a reasonable person" and "cause for concern". Although legal precedent defines these phrases, they are ambiguous to the lay reader and hence they are open to misinterpretation and confusion. These definitions are confusing, at best, and at worst they reinforce the myth that strangers are the biggest risk to children. Consequently, this ambiguity may hinder the identification of the full range of sexual grooming behaviours. + +Gillespie (2002) provides the third definition: + +The process by which a child is befriended by a would-be abuser in an attempt to gain the child's confidence and trust, enabling them to get the child to acquiesce to abusive activity. It is frequently a pre-requisite for an abuser to gain access to a child. (Gillespie, 2002, p. 411; based on van Dam, 2001) + +This definition avoids the use of the term paedophile. It also provides some clarity about the purpose of sexual grooming behaviour and identifies some of the stages that it involves. This appears to be the most appropriate published definition to date. Further evaluation of this definition will follow consideration of previous literature and current understanding about sexual grooming. + +#### Prevalence + +Canter, Hughes and Kirby (1998) provide evidence for the prevalence of the sexual grooming phenomenon. They used Small Space Analysis on a behaviour matrix of the interaction benveen 97 incarcerated child sex offenders and their victims. They identified three distinct behaviour repertoires of offender-victim interaction. The different types of offender—victim interaction acknowledged were aggressive, which was identifiable by the use of extreme + +violence, threat and force; criminal-opportunist, which tended to be one-off offences on strangers; and intimate, which was categorized by the identified use of sexual grooming behaviours. + +Forty-five per cent of Canter et al.'s (1998) sample were classified as being intimate offenders. Thus, 45% of the child sex offenders employed an intimate behaviour repertoire and sexual grooming behaviours. This figure is likely to be unrepresentative of the child sex offender population as a whole. Intimate offenders tend to cause less physical harm to their victims than the other categories of offenders and the very nature of the behaviour used to categorize the intimate offenders implies that they would be less likely to be reported, identified and convicted, because these grooming behaviours are used to avoid disclosure and conviction. Hence, it is likely that intimate offenders were under-represented in this prison sample. + +Figures show that eight of 10 sex abuse victims know their abuser (Stop it Now, 2003). In such cases, offenders have substantial interest in preventing disclosure, because in the event of disclosure the victim would be able to easily identify them as their abuser. This is supported by offenders' accounts about the strategies they employed to victimize the children they sexually abused; fear of disclosure affected how and when they victimized their victims (Conte, Wolf & Smith, 1989). + +#### Aetiology of a motivation to abuse + +Before an individual begins to groom a child, some level of motivation to abuse a child needs to be present. Furthermore, adequate theories of sexual offending should be able to account for the phenomenon of sexual grooming. Until recently there have been three dominant theories of child sexual abuse, namely Finkelhor's Pre-condition Model (1984); Marshall and Barbaree's Integrated Theory (1990); and Hall and Hirschman's Quadripartite Model (1992). In 2002, Ward and Siegert proposed a more comprehensive theory of child sexual abuse by "knitting together" the strengths of each of the above theories. They propose that there are five pathways to sexual offending against children; hence, the theory is called The Pathways Model. This review shall consider each of these only briefly, because Ward and colleagues have already provided in-depth reviews (see Ward, 2001, 2002; Ward & Hudson, 2001). Herein, more emphasis will be placed on how these theories relate to the phenomenon of sexual grooming. + +#### Marshall and Barbara's Integrated Theory + +Marshall and Barbaree's (1990) Integrated Theory of the aetiology of sexual offending proposes that the presence of vulnerabilities, which develop as a result of adverse early developmental experiences, leave offenders unprepared to deal with the surge of hormones at puberty, and unable to understand the emotional world. As a resultant, offenders satisfy their emotional and sexual needs inappropriately in deviant ways. This theory suggests that sexual offending occurs as a consequence of an individual's sex and aggression drives becoming fused, as these functions share the same structure in the brain. Ward and Siegert (2002) state that this need not be the case, as there are many functions that are close in proximity but that do not affect each other. Furthermore, this theory suggests that sexual offending would be aggressive. Therefore, it would seem that it does not account for the phenomenon of sexual grooming, because the process of sexual grooming is generally not aggressive in nature. + +However, this criticism may be countered if a definition of aggression were to include indirect aggression, which sexual grooming could be considered to be. + +#### Hall and Hirsehman's Quadripartite Model + +Hall and Hirschman's (1992) Quadripartite Model was first developed as a theory of rape, but it was applied subsequently to child sexual abuse. This model suggests that someone commits an act of child sexual abuse because of four vulnerability factors and the presence of opportunity. The vulnerability factors are physiological sexual arousal, distorted cognitions that act to justify sexual aggression, affective dyscontrol, and personality problems. It is suggested that offending will occur when the presence of these vulnerability factors exceed a threshold, this could include one or all of these vulnerabilities. There are several problems with this model; first, it does not explain why someone chooses to offend against a child rather than an adult. Second, sexual grooming is not an impulsive act and the threshold would need to be maintained over a long period of time in order to explain sexual grooming, because it can occur over weeks, months or even years. Hence, this theory can account for sexual grooming if it is accepted that, for example, sexual arousal persists over long periods of time, so once sexually aroused to children/child the offender would be continually aroused to them. A further problem with this theory relates to the presence of opportunity; offenders often create their own opportunities to offend. + +#### Finkelhor's Pre-condition Model + +Finkelhor's Pre-condition Model (1984) suggests that there are four pre-conditions to sexual offending. The first is the motivation to sexually abuse; it is suggested that this develops as a result of emotional congruence (a fit between the offender's emotional needs and the child's ability to meet them), deviant sexual arousal and blockage (the sexual needs of the offender not being met by appropriate adults). The second is to be able to overcome internal inhibitors; the third is to be able to overcome external inhibitors; and the fourth is to overcome the child's resistance. Before an incidence of abuse would take place, these pre-conditions need to be satisfied. Although Finkeihor does not use the term sexual grooming, others (e.g. Morrison, Erooga & Beckett, 1994; Sampson, 1994) have reviewed his work using this term. They referred to overcoming the child's resistance as grooming. + +#### Ward and Siegert's Pathways Model + +Ward and Siegert's (2002) model is based on the dysfunction of one or more psychological mechanisms—emotional regulation, intimacy deficits, cognitive distortions and sexual arousal (deviant sexual scripts). All the aforementioned psychological mechanisms are involved to some degree. There is evidence of these dysfunctional mechanisms being present typically in child molesters, although to different degrees and for different functions. The five possible pathways are specified by whichever dysfunctional psychological mechanism is the most dominant; in turn this will affect the others. In the case of the fifth pathway, all the psychological mechanisms would be similarly dysfunctional. A sexual offence occurs when the above is present in conjunction with sexual need. In addition, Ward and Siegert still emphasize the importance of there being an opportunity to offend; however, the nature of sexual grooming is to create an opportunity to offend. Successful theory would need to account for this. + +Despite Ward and Siegert presenting their Pathways Model as a comprehensive theory of sexual offending, it still only considers aetiology and no consideration is given to the offence process. In a comprehensive theory it is necessary to consider the whole journey from initial onset to the offence and beyond. In a similar way that the Transtheoretical Model (Prochaska & DiClemente, 1982) of change considers not only the action stage, where the overt behaviour is changed, but also the precontemplation, contemplation, preparation and maintenance stages, a theory of sexual offending against children needs to consider the whole journey. As demonstrated above, it is necessary that theories of aetiology are coherent with the phenomenon they are attempting to explain. While endeavouring to explain sexual offending it is important that sexual grooming is also factored into the equation, because it is part of the sexual offending phenomenon. Of the above theories, only Finkelhor's (1984) Pre-condition Model has taken this approach. + +#### Offence process + +In addition to the Pre-condition Model (Finkelhor, 1984) there is one other model that considers the offence process of sexual offending. This is the Descriptive Model of the Offence Chain (Ward, Louden, Hudson & Marshall, 1995). Ward et al.'s model provides a much more detailed account of the offence process than the Pre-condition Model. While little evidence has been found to support Finkelhor's Pre-condition Model, Ward et al. used a grounded theory approach and developed their model directly from offenders' experiences. They identified nine stages of the offence chain. Stage one relates to the offender's background factors, including their perception of themselves and their life at the beginning of the offence chain and whether these factors caused positive or negative affect. Stage two describes distal planning of access to their victim; this could take the form of implicit, or explicit planning or chance. Contact with the victim takes place in stage three. Stage four involves cognitive restructuring, which will result in either positive or negative affect. Stage five entails proximal planning, which would either be self-focused, victim-focused or a mutual-focus. This leads to stage six and the sexual offence, which is followed by further cognitive restructuring at stage seven. This results in negative or positive evaluation and future resolutions regarding continued offending at stage eight. This resolution will be to either avoid future offending or to persist in an abusive pattern. Stage nine depicts the impact of these resolutions on the offender's life. + +It is important to consider how sexual grooming fits into, and facilitates, the offence process, as this understanding is likely to aid the management of offenders and potential offenders by identifying the offence process prior to an sexual offence taking place. In addition, it is reasonable to suggest that motivation is not static but could be affected by later stages of the grooming and offence process, e.g. cognitive distortions developed later in the process could serve to reinforce prior motivation resulting in an entrenched deviant sexual interest. This may prove valuable to treatment programmes efforts of reducing motivation to offend. + +#### The grooming process + +The current review has identified three types of sexual grooming present in the literature self-grooming, grooming the environment and significant others and grooming the child. Each of these will be discussed to explore current understanding of sexual grooming. Understanding of the grooming process and an ability to identify sexual grooming behaviour is crucial in order to prevent child sexual abuse. However, retrospective identification of sexual grooming, i.e. after a sexual offence has been committed, is much easier than prospective identification, i.e. before a sexual offence. Nevertheless, the latter is necessary in order to prevent the sexual abuse from taking place. The reason for this is because the behaviours used to groom a child for sexual abuse are not dissimilar to innocent behaviour intended to broaden a young person's experiences. The only difference may be the motivation underlying the behaviour. + +#### Self-grooming + +van Dam (2001) reports that during treatment, offenders' talk about "grooming themselves". They were referring to the justification or denial of their offending behaviour. It therefore seems important to consider this as part of the grooming process. However, it may be more agreeable to refer to this phenomenon by another name, avoiding the use of the term "grooming". Nevertheless, self-grooming is likely to play a part in the move from being motivated to sexually abuse a child to the subsequent targeting of a child, through the justification or denial of the steps child sexual offenders take towards abusing a child. Furthermore, self-grooming is likely to be affected by the response from the community and the child, and the success or failure of the efforts to victimize the child. "Success" is likely to result in further justification or denial of their actions and more entrenched sexual interest in children and motivation to offend. "Failure", on the other hand, is likely to result in the desistence of offending or the offender developing/enahancing his skills/strategies to ensure success. + +Justification and denial of offenders' behaviour manifests in cognitive distortions. Ward and Keenan (1999) propose that child sex offenders have cognitive distortions in the form of implicit theories, which relate to themselves, the victim and the world. Implicit theories help individuals to understand the world around them. Problems arise because offenders' implicit theories are maladaptive and supportive of sex with children. These implicit theories subsequently affect encoding and interpretation of future behaviours and events. Ward and Keenan have identified five implicit theories that account for most of the cognitive distortions held by child sex offenders: children as sexual objects; entitlement; dangerous world; uncontrollability; and nature of harm. + +Of course, it is not only offenders who have maladaptive implicit theories. For example, many people have an implicit theory that children are at most risk from strangers, which is not consistent with research findings. However, it is easier to believe that strangers sexually abuse children than accept that friends and family do; hence, this implicit theory helps to shelter people from the harsh nature of reality. Offenders' implicit theories work in a similar way, because it is easier for offenders to believe that the child seduced them than to accept that they sexually abused a child. + +#### Grooming the environment and significant others + +Grooming the child begins with identifying a vulnerable child (van Dam, 2001). Child sex offenders seem to have a special ability in recognizing vulnerable children (Conte et al., 1989). These vulnerabilities may be that the children have a poor relationship with their parents, do not have many friends (Berliner & Come, 1990), or have already been victimized (Leberg, 1997). Alternatively, offenders may target women who were sexually abused as children, because the offender considers them easier to re-victimize. + +In order to gain access to their victim(s), offenders groom the environment and their potential victim's significant others (e.g. parents, carers, teachers, etc). This may mean the offender integrating themselves into society and places where they are likely to meet children. This will often be a position of trust. Offenders then begin grooming the adults in this community, specifically those who are significant to their potential victim, with the aim of creating an opportunity to access and abuse a child or children. van Dam (2001) reports that offenders are frequently charming, very helpful, and have insider status. This is often an important factor in gaining access to potential victim(s). As offenders help out in the community, they are considering how their efforts will be rewarded later when they can then abuse the children in that community. Offenders are often able to "read the community like a book" in that they assess what they "need" and fulfil these needs accordingly (Hare Sr Hart, 1993). They can make themselves indispensable, too good to be true and will freely undertake jobs that others do not want to do (Leberg, 1997). + +A desire on the part of parents to avoid cognitive dissonance may assist offenders' grooming efforts. A parent may suffer cognitive dissonance as a result of concerns about the trustworthiness of the offender alongside their hospitality and acceptance of the offender. When thoughts do not match behaviour, cognitive dissonance manifests, and often thoughts are changed to be consistent with behaviour (van Dam, 2001). Thus, offenders gain insider status long before they start abusing a victim (van Dam, 2001). Grooming is therefore a wellorganized long-term activity (Sanford, 1982). Offenders groom the community so well that if a victim discloses their abuse, the community may support the offender rather than the victim, because they deem the offender to be more believable than the child. + +In the case of intrafamilial child sexual abuse, offenders are already in a position of trust and integrated in an environment where they can access potential victims. Some offenders groom the environment by targeting single-parent families to gain this status (Elliott, Browne & Kilcoyne, 1995). Offenders may do this because they believe that these children are more vulnerable and because they believe it will be easier to create opportunities to be alone with the child. Alternatively, offenders may target children or young people who have absent parents, and hence have less protection. In this incidence there is no need for the offender to groom the parents. They can become the child's friend and more easily arrange to have time alone with the child. + +Intrafamilial offenders often isolate the victim from their non-abusing parent, siblings and the outside world by developing an exclusive relationship with the child. For instance, they may encourage mothers to have more of a life outside the home, which then gives themselves increased opportunities to abuse their victims. Alternatively, they may isolate nonabusing parents from the outside world in order to prevent them from having people in whom to confide about any concerns (Leberg, 1997). Some offenders encourage mothers to develop an alcohol dependency, in part so that any future disclosures made lack credibility (Leberg, 1997). Other similar strategies employed to limit credibility include questioning the mother's parenting ability in front of friends and other family members. This may constitute part of their strategy for grooming the environment and significant others. + +Grooming the environment and significant others can occur as a result of implicit or explicit planning; alternatively, access to a child may occur by chance. Ward and Hudson (2000) have developed a conceptual model of how child sex offenders' implicit planning or seemingly unimportant decisions (SUDs) implicate their offending behaviour by leading them to high-risk situations, i.e. contact with children. This appears to be automatic, because although offenders are conscious of their specific behaviours, they are often unconscious of the effect of implicit goals on these behaviours. + +Gollwitzer and Schaal (1998, cited in Ward & Hudson, 2000) suggest that it is through automatic goal-dependent action plans that these SUDs manifest. Ward and Hudson (2000) propose that there are two such action plans: offence scripts and mental simulations. Offence scripts manifest as a result of associations that have developed between situations and behaviours; subsequently, in the presence of certain cues, offence scripts may be activated without any conscious awareness. This is a possible explanation of continued offending and relapse following treatment. + +Automatic goal-dependent action plans can be activated regardless of whether an individual has committed any previous sexual crimes. This alternative involves mental simulation. Mental simulation is where an individual plans out in detail how he would commit an offence. As with offence scripts, the presence of certain cues may activate this implicit planning, resulting in the enactment of the individual's fantasies. The notion of implicit planning may provide a possible explanation why the majority of victims know their abuser, because the cues that activate the implicit planning are more likely to be present within the family or in relation to children in the immediate locality (i.e. the places where an individual spends the majority of his time). + +It is reasonable to suggest that the fundamental human need to belong may present one possibility to further understand offenders' ability to identify a victim and groom the environment and significant others. Research has shown that a need to belong can affect very basic cognitive functions, e.g. attention and encoding of social information (Pickett, Gardner & Knowles, 2004). Pickett et al. found a positive relationship between a need to belong and sensitivity to social cues. Sexual offenders often come from neglectful, violent and dysfunctional backgrounds (Craissati, McClurg & Browne, 2002). This environment is unlikely to provide an abundance of opportunities for emotional closeness and thus offenders are likely to have a need to belong. In addition, a need to belong is related to low self-esteem (Pickett et al., 2004) and research to date suggests that child sex offenders typically have low self-esteem (Marshall, Anderson & Champagne, 1997). This is supportive of the idea that a need to belong facilitates offenders' identification and access to a victim, because of the associated increased sensitivity to social cues. Children may be approached because the offender perceives them to be less threatening than peers. Alternatively, offenders may be able to identify vulnerabilities in other people because they themselves are vulnerable and thus recognize these signs in others. This explanation would relate to offenders that commit offences following implicit planning. Offenders using explicit planning may also have a need to belong and the associated increased sensitivity to social cues, as a result of a need to belong to the family of community in order to groom and subsequently abuse a child. It is therefore suggested that, in the presence of a motivation to sexually abuse a child, a need to belong often facilitates the identification of a victim and grooming of the environment and significant others. + +#### Grooming the child + +Grooming the child is the most commonly recognized form of sexual grooming. In addition to a desire for sexual gratification, there may or may not be a relational aspect to the grooming process, depending on the offender's motivation to abuse. Sexual grooming has been considered by some to be analogous to adult courtship (e.g. Howitt, 1995). In addition, Herman (1981) and Christiansen and Blake (1990) talk about sexually abusive fathers adopting the role of suitor towards their daughter. In the case of intrafamilial abuse, the offender promotes the child in place of the mother (Leberg, 1997). Alternatively, the offender may interact with the child on the child's wavelength (van Dam, 2001). Wilson (1999) found + +that offenders who abused boys showed a preference for interacting at the child's level, and incest offenders tended to raise the victim's status to that of an adult, while offenders who abused girls were more concerned with sexual gratification. The types of behaviour that constitute grooming the child take two different forms—physical and psychological. + +Physical grooming involves the gradual sexualization of the relationship between the offender and the victim (Berliner & Conte, 1990). Psychological grooming is used to achieve this increased sexualization. At first, the offender may justify the sexual behaviour through providing the child with his version of sex education, which states that sex between children and adults is acceptable and that the offender has a responsibility to train the child for later life (Berliner & Conte, 1990; Leberg, 1997). The abuser builds the child's trust (Christiansen & Blake, 1990; Leberg, 1997; Wyre, 1987, cited in Howitt, 1995; van Dam, 2001), makes him or her feel good (Warner, 2000) and then starts to violate boundaries (Christiansen & Blake, 1990; van Dam, 2001). This may involve intentionally entering the bedroom while the child or young person is undressed, or getting dressed together and exposing himself to the child. + +Offenders often desensitize a child to touch by beginning with non-sexual touching such as tickling or stroking the child's head. Conversation may also become more sexual. Alternatively, offenders may confuse victims by continuing to talk to the child about a positive unrelated issue while they begin touching the child sexually (Leberg, 1997). The child may have no idea that something inappropriate is happening. The aim is to progress to sexual touching, first on top of clothes and later under or without clothes (Berliner & Conte, 1990; Christiansen & Blake, 1990; Leberg, 1997; van Dam, 2001). Thus, the intention is to make the child compliant with the offender's sexual demands and overcome the child's resistance (Finkelhor, 1984; Leberg, 1997; Warner, 2000). + +In addition to using psychological grooming to increase compliance, it is also used to avoid disclosure. Children are groomed to want to be around the adult who is grooming them (Wolf, 1985). Offenders need to maintain the child's cooperation and secrecy to achieve this. One way that the offender does this is by isolating the child and alienating them from others (Warner, 2000). Leberg (1997) refers to this factor as something separate from grooming, others (e.g. van Dam, 2001) consider it to be part of the grooming process. Isolating the child creates a barrier which prevents the child from having a confidant in whom to disclose (Warner, 2000). In addition, the keeping of secrets acts as a source of further isolation (Lerner, 1993, cited in van Dam, 2001). Children are very good at keeping secrets when asked to. Peters (1991, cited in Ceci & Bruck, 1993) found that 82% of children in his study delayed or did not report an event that they had witnessed, because the thief in the scenario asked them not to tell anyone. The thief in this scenario was a stranger, to whom the children had no loyalty, and so it is likely that children would be even more likely to protect a known and loved adult. + +Further strategies used by offenders to maintain the child's compliance include issuing threats and bribes (Berliner & Conte, 1990; Christiansen & Blake, 1990). Bribes may take the form of material gifts or extra privileges (Christiansen & Blake, 1990). In addition, offenders are skilled at using children's natural vulnerabilities against them. For instance, children very often have a strong desire to protect their parents. When the offender informs them that their parents would be very hurt if they found out what they had been doing, children may remain silent (Berliner & Conte, 1990). Offenders may also demonstrate their potential for violence through violence towards others, e.g. other family members. Thereby offenders reinforce the message that they will enact their threats about hurting the child and/or the child's family. + +Offenders frequently make the child feel responsible for the abuse (Leberg, 1997; van Dam, 2001; Warner, 2000). They convince the child that they are to blame for letting the abuse happen and that they should have stopped it (Leberg, 1997). This is reinforced by stereotypes in society, which emphasize that men cannot control their sex drive (Warner, 2000). Additional guilt may be felt if the child has been made to perform sexual acts on the abuser or another child (Warner, 2000). However, this feeling of responsibility and guilt is overshadowed by the self-betrayal the child feels as their body reacts to sexual stimulation against their will (Warner, 2000) which children may interpret as evidence that they are enjoying themselves. This is internalized and resultantly may have an impact on the child's developing identity. Disclosure is avoided because the child feels that it is "all their fault", that he/she is bad and that no one will believe them (Warner, 2000). + +Each victim's experience of grooming is different, because offenders adapt their strategies dependent on the child, whose response during the grooming process is important. It seems reasonable to suggest that offenders require some level of "empathy" during the grooming process to recognize reactions in the child, so that they can adapt their strategy accordingly. For example, during the desensitization process an offender would need to recognize the limits of the victim and to strategically increase those limits. It is proposed that empathy involves four components: (1) emotion recognition; (2) perspective-taking; (3) emotion replication; and (4) response decision (Marshall, Hudson, Jones & Fernandez, 1995). Continuing with the previous example, offenders recognize the distress in their victim and make a decision based on this, because they choose to stop temporarily as a strategic part of the desensitization process. Thus, offenders appear to have ability in components (1) and (4), which are the cognitive components, but not in the affective components (2) and (3). While early research on empathy in sex offenders concluded that they have empathy deficits, more recent research has found that this empathy deficit to be victim-specific (Fernandez, Marshall, Lightbody & O'Sullivan, 1999; Marshall, Hamilton & Fernandez, 2001; Marshall et al., 1995). This is inconsistent with the suggestion that the grooming process requires some level of empathy. However, Fernandez et al. (1999; Marshall et al., 2001) provide a possible explanation for this. They suggest that victim-specific empathy deficits manifest as cognitive distortions, which protect the offenders from negatively evaluating themselves, thus allowing them to continue abusing a child. Based on this suggestion, victim-specific empathy deficits arise as a consequence rather than a cause of the abuse. These cognitive distortions therefore facilitate self-grooming. + +The manifestation of a cognitive distortion relating to a victim-specific empathy deficit may be facilitated by cognitive deconstruction. Cognitive deconstruction (see Ward, Hudson & Marshall, 1995) is a state entered into to escape negative experiences and negative selfevaluation. Cognitive deconstruction involves processing at a lower, more concrete, level, i.e. muscular movements, and rewards of behaviour, rather than social action. Resultantly, the individual has much more focus on feelings of pleasure and less awareness of the consequences of his behaviour. This concrete-level focus may reinforce cognitive distortions such as victims enjoyed the abuse because they became physically aroused, which justifies the offender's lack of empathy toward their victim. + +Self-grooming, grooming the environment and significant others, and grooming the child are relevant to situational and preferential offenders, extra-familial and intrafamilial offences. It is important that the different types of sexual grooming apply to these different typologies and classifications of offenders because sexual grooming is not used solely by one group of offenders and, furthermore, these categories are not mutually exclusive (Itzin, 2001). + +#### Towards a new definition of sexual grooming of children + +The definitions of sexual grooming presented at the start of this review do not reflect the complexity of the sexual grooming of children, which is demonstrated in the previous discussion of the different types of sexual grooming. Based on the above findings it seems necessary to provide a new definition that attempts to encapsulate the complexity of sexual grooming, while still being easy to understand. We propose the following: + +A process by which a person prepares a child, significant adults and the environment for the abuse of this child. Specific goals include gaining access to the child, gaining the child's compliance and maintaining the child's secrecy to avoid disclosure. This process serves to strengthen the offender's abusive pattern, as it may be used as a means of justifying or denying their actions. + +#### Conclusion + +Despite the wide acceptance of the term, sexual grooming of children is not understood clearly, particularly in the public domain. Testimonies from both victims and perpetrators highlight the pertinence of the problem. Furthermore, the government in England and Wales has introduced legislation in the Sexual Offences Act 2003 regarding "meeting a child following sexual grooming" (see Part 1: section 152003). A greater understanding of the meaning, elements and process of sexual grooming is required to effectively utilize this legislation (for review see Craven, Brown & Gilchrist, in press). + +Regardless of the prevalence and pertinence of sexual grooming, most aetiological theories of child sexual abuse neglect the phenomenon. The main reason for this is likely to be because prominent theories of child sexual abuse were devised more than 10 years ago, at a time when sexual grooming was not recognized as it is today. Therefore, it is necessary that theories be reconsidered based on this recent awareness. Ward (2001, 2002; Ward & Hudson, 2001; Ward & Siegert, 2002) has begun the process of theory knitting and development. While Ward and Siegert's Pathways Model is able to account for sexual grooming, it still focuses on the presence of opportunity rather than explicitly recognizing that offenders often create their own opportunities to offend. + +The current review has identified three types of sexual grooming discussed in the literature: self-grooming, grooming the environment and significant others and grooming the child. Based on these findings an alternative definition has been suggested, which includes details about offenders' objectives, e.g. gaining access to a child, gaining the child's compliance, maintaining secrecy and avoiding disclosure. + +A fuller understanding of sexual grooming is required. Consideration needs to be given to offender-victim interaction (before, during and after the offence), micro behaviours that may indicate to significant adults that a child is being sexually groomed, or indeed that they themselves are being groomed by an offender, and the seemingly impossible task of proving beyond reasonable doubt that the ambiguous behaviour of sexual grooming is sexually motivated. This would provide many benefits to child protection and the policing and treatment of child sex offenders with a specific focus on prevention of child sexual abuse rather than reactive responses to it. To optimize the impact of acquired knowledge and understanding, it is necessary to consider how these findings are disseminated to the relevant groups involved with children, e.g. parents, police, and social workers. + +#### References + +- Berliner, L. & Conte, J. R. (1990). The process of victimization: The victims' perspective. Child Abuse and Neglect, 14, 29 40. 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0000000000000000000000000000000000000000..dac342ac6a619896a36803eb3cc9d6d06a960627 --- /dev/null +++ b/marker2/ds9/EFTA00088802/EFTA00088802.md @@ -0,0 +1,687 @@ +#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +UNITED STATES OF AMERICA + +S2 20 Cr. 330 (AJN) + +GHISLAINE MAXWELL, + +Defendant. + +#### THE GOVERNMENT'S OMNIBUS MEMORANDUM IN OPPOSITION TO THE DEFENDANT'S MOTIONS IN LIMINE + +DAMIAN WILLIAMS United States Attorney for the Southern District of New York One St. Andrew's Plaza New York, New York 10007 + +![](_page_0_Picture_8.jpeg) + +Assistant United States Attorneys Of Counsel + +# Table of Contents + +| ARGUMENT A. B. A. B. | PRELIMINARY STATEMENT I. The Court Should Admit the Testimony of Dr. Applicable Law Discussion 1. Dr. )pinions 2. Dr. Abuse is Admissible 3. Dr. MI.Opinion 4. Dr. 5. Dr. Opinion on Delayed Disclosure is Admissible B. The Evidence Contained in the Government's October 11, 2021 Letter is Admissible Applicable Law Discussion I. | 1 4 4 5 9 on Coercion and Attachment are Admissible 10 Opinion on the Relationship Between Trust and Victim Awareness of Their 22 on the Long-Term Consequences of Abuse is Admissible 23 Opinion About the Significance of the Presence of Third Parties is Admissible 25 27 32 33 35 The Evidence is Admissible As Direct Evidence, or in the Alternative, Under Rule 404(b) 35 | +|----------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------| +| 2. | The Government Has Met and Exceeded Its Notice Obligations | 39 | +| III. The Testimony of Minor Victim-3 is Admissible | | 41 | +| A. | Background | 41 | +| B. | Applicable Law | 44 | +| C. | Discussion | 45 | +| IV. There is No Basis to Preclude Co-Conspirator Statements at Trial | | 54 | +| A. | Background | 55 | +| B. | Discussion | 58 | + +| | V. There is No Basis to Suppress Minor Victim-4's Identification of the Defendant | 63 | +|-------|--------------------------------------------------------------------------------------------|----| +| A. | Background | 63 | +| B. | Applicable Law | 65 | +| C. | Discussion | 67 | +| | VI. The Court Should Deny the Defense Motions to Preclude the Government's Exhibits | 71 | +| A. | Applicable Law | 71 | +| B. | Discussion | 72 | +| | VII. There is No Basis to Preclude Discussion of "Victims" or Rape | 76 | +| A. | References to Victims | 76 | +| B. | Evidence of Rape | 79 | +| VIII. | The Remaining Defense Motions are Aimed at Evidence the Government Does Not Plan to Elicit | | +| | CONCLUSION | 83 | + +#### PRELIMINARY STATEMENT + +The Government respectfully submits this memorandum in opposition to the defendant's thirteen motions in limine, dated October 18, 2021. For the reasons that follow, the defendant's motions should be denied. + +First, the Government has given notice of a qualified expert who will provide reliable and relevant opinions, as required by Federal Rule of Evidence 702 and Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 (1993). (See Def. Mot. 3). Second, evidence relating to Minor Victim-3 is admissible both as direct evidence of the charged crimes, and admissible in the alternative under Rule 404(b). (See Def. Mot. 4). Third, the Government has provided adequate notice pursuant to Rule 404(b), and in any event, all evidence for which it has provided such notice is also admissible as direct evidence of the charged crimes. (See Def. Mot. 2). Fourth, there is no basis to preclude the introduction of co-conspirator statements under Fed. R. Evid. 801(dX2)(E). (See Def. Mot. 1). Fifth, Minor Victim-4's confirmatory identification of the defendant was not unduly suggestive, and it should not be suppressed. (See Def. Mot. 9). Sixth, the Government's various exhibits are relevant, and the Government will authenticate them at trial. (See Def. Mots. 7, 8, 13). Seventh, it is entirely proper for the word "victim" and for discussion of rape to be used in a trial about the sexual exploitation of minor victims. (See Def. Mots. 11, 12). Eighth, and finally, the Government does not intend to offer evidence of the defendant's flight, her false exculpatory statements, or law enforcement expert testimony in its case in chief, unless the defendant opens the door or otherwise puts this evidence in issue. (See Def. Mots. 5, 6, 10). + +#### ARGUMENT + +#### I. The Court Should Admit the Testimony of Dr. + +The Government intends to call Dr. as an expert witness. Dr. n the President-Elect of the Division of Trauma Psychology at the American Psychological Association. She is currently a clinical instructor at the Alpert Medical School of Brown University, and she has practiced psychology for approximately 25 years, specializing in treating patients with trauma, including sexual trauma in childhood and adolescence. Dr. has treated hundreds of victims of trauma, including many victims of child sexual abuse, and she has written, presented, and taught about the assessment and treatment of trauma. She has also received continuing education on trauma and the treatment of trauma in a clinical setting. (See generally Curriculum Vitae, Def. Mot. 3 Ex. 2). + +On April 23, 2021, the Government timely notified the defendant of its intent to call Dr. n its case-in-chief. As the notice explains, Dr. is expected to testify, based on her relevant education, training, experience, and research, and offer the following opinions: + +> Individuals with particular vulnerabilities are often targeted by perpetrators of sexual abuse. Sexual abuse of minors frequently occurs through the use of manipulation or coercion in the context of an established relationship that is developed over time, rather than through the use of forcible rape. Minor victims are often subject to a strategic pattern of behaviors, often called grooming, that can take a variety of forms and function to render the victims vulnerable to abuse, to obscure the nature of the abuse, and to build trust and attachment with their abuser. The relationship of trust and attachment can prevent victims from being aware that what they are experiencing is abuse and can prevent disclosure. Minor victims therefore may not identify themselves as victims of abuse while it is ongoing, and may not recognize the consequences of that abuse until adulthood. Repeated exploitation and abuse can increase the likelihood of victimization later in life and can result in long-term + +traumatic and psychological consequences, especially when it occurs in the context of complex trauma. The presence of other individuals can facilitate the sexual abuse of minors. Dr. is also expected to testify that nondisclosure, incremental Ise osure, and secrecy are common among victims of sexual abuse for a variety of reasons, and that memory and disclosure of traumatic or abusive events is impacted by a number of factors, including the circumstances surrounding the trauma. + +(Expert Notice, Def. Mot. 3 Ex. 1 at 2). As the notice also explained, Dr. has not evaluated any of the victims in this case, and the Government does not currently intend to offer Dr. testimony regarding any specific victim. (See id.). + +There is nothing controversial about this testimony. It is well supported by established scientific principles, and it is the kind of testimony frequently admitted in cases involving sexual abuse. This Court should do the same. + +### A. Applicable Law + +District courts have a "gatekeeper function" in analyzing the admissibility of expert testimony. Phelps v. CBS Corp., No. 17 Civ. 8361 (AJN), 2020 WL 7028954, at \*3 (S.D.N.Y. Nov. 30, 2020) (quoting Restivo v. Hessemann, 846 F.3d 547, 575 (2d Cir. 2017)). Although the proponent of the evidence carries a burden of proof to establish its admissibility by a preponderance of the evidence, see, e.g., United States v. Jones, 965 F.3d 149, 161 (2d Cir. 2020), courts apply a "presumption of admissibility of evidence." Felix v. City of New York, No. 16 Civ. 5845 (AJN), 2020 WL 6048153, at \*6 (S.D.N.Y. Oct. 13, 2020) (quoting Borawick v. Shay, 68 F.3d 597, 610 (2d Cir. 1995)). Accordingly, the relevant rule of evidence, Rule 702, reflects "the `liberal thrust' of the Federal Rules and their `general approach of relaxing the traditional barriers to `opinion' testimony.'" Daubert v. Merrell Dow Pharms., Inc., 509 U.S. 579, 588 (1993) (quoting Beech Aircraft Corp. v. Rainey, 488 U.S. 153, 169 (1988)). + +Under Daubers, a district court must first determine whether an expert is qualified. See Fed. R. Evid. 702 ("A witness who is qualified as an expert by knowledge, skill, experience, training, or education may testify in the form of an opinion or otherwise ...."); United States v. Kidd, 385 F. Supp. 3d 259, 263 (S.D.N.Y. 2019) ("At the first step of the Dauber! inquiry, courts are instructed to consider the expert's qualifications."). Courts then must determine whether the testimony "will be not only relevant, but reliable." United States v. Romano, 794 F.3d 317, 330 (2d Cir. 2015); see Dauber!, 509 U.S. at 597 (explaining that courts must ensure "that an expert's testimony both rests on a reliable foundation and is relevant to the task at hand"). On reliability, Rule 702 identifies three "indicia of reliability": (1) "that the testimony is grounded on sufficient facts or data; (2) that the testimony is the product of reliable principles and methods; and (3) that the witness has applied the principles and methods reliably to the facts of the case." United States v. Williams, 506 F.3d 151, 160 (2d Cir. 2007) (quoting Amorgianos v. Nat'l R.R. Passenger Corp., 303 F.3d 256, 265 (2d Cir. 2002)). "[T]hese criteria," however, "are not exhaustive." Id. Daubert itself, which "dealt with a scientific theory," offered additional factors, such as whether the theory "'has been subjected to peer review and publication,"' and the "'known or potential rate of error."' Romano, 794 F.3d at 330 (quoting Daubers, 509 U.S. at 593-94). And "there are many different kinds of experts, and many different kinds of expertise." Kumho Tire Co. v. Carmichael, 526 U.S. 137, 150 (1999). "[W]hether the specific expert testimony focuses upon specialized observations, the specialized translation of those observations into theory, a specialized theory itself, or the application of such a theory in a + +particular case, the expert's testimony will often rest upon an experience confessedly foreign in kind to the jury's own." Id. at 149 (alterations and internal quotation marks omitted); see United States v. Felder, 993 F.3d 57, 71-72 (2d Cir. 2021) ("Such specialized knowledge can be grounded in scientific or other particularized training, but it can also derive from personal observations or experience, see id., so long as those observations or experience are outside the ken of the average person." (internal quotation marks and citations omitted)); Fed. R. Evid. 702, Advisory Committee's Note (2000) (explaining that expert testimony may be based on "experience alone—or experience in conjunction with other knowledge, skill, training or education"). + +The key question is whether "an expert, whether basing testimony upon professional studies or personal experience, employs in the courtroom the same level of intellectual rigor that characterizes the practice of an expert in the relevant field." Kumho Tire, 526 U.S. at 152; see Williams, 506 F.3d at 160 (explaining that the Daubers test is "flexible"). In particular, if an expert's testimony is within "the range where the experts might reasonably differ," the jury, not the trial court, should be the one to decide among the conflicting views of different experts. Kumho Tire, 526 U.S. at 153. So long as the testimony is not "speculative or conjectural or based on assumptions that are so unrealistic and contradictory as to suggest bad faith or to be in essence an apples and oranges comparison . . . any other contentions that the assumptions are unfounded go to the weight, not the admissibility of the testimony." Phelps, 2020 WL 7028954, at \*3 (citations and internal quotation marks omitted). Thus, 'the rejection of expert testimony is the exception rather than the rule.'" Floyd v. City of New York, 861 F. Supp. 2d 274, 287 (S.D.N.Y. 2012) (citing Fed. R. Evid. 702 Advisory Committee's Notes (2000 Amendments)). + +"[T]he law grants a district court the same broad latitude when it decides how to determine reliability as it enjoys in respect to its ultimate reliability determination." Kumho Tire, 526 U.S. at 142 (emphasis in original); see United States v. Requena, 980 F.3d 30, 47 (2d Cir. 2020). Thus a district court may properly exercise its gatekeeping function without the "formality of a separate hearing[.]" Williams, 506 F.3d at 161; see also United States v. Barnes, 411 F. App'x 365, 370 (2d Cir. 2011) (summary order). "This is particularly true if, at the time that the expert testimony is presented to the jury, a sufficient basis for allowing the testimony is on the record." Williams, 506 F.3d at 161 (citing 4 Weinstein's Federal Evidence § 702.02 [2] (2d ed. 2006)). + +Finally, even if the expert testimony is reliable, it must also be relevant. See, e.g., United States v. Torres, No. 20 Cr. 608 (DLC), 2021 WL 1947503, at \*6 (S.D.N.Y. May 13, 2021). In this context, the testimony must "concern matters that the average juror is not capable of understanding on his or her own." United States v. Mejia, 545 F.3d 179, 194 (2d Cir. 2008); see Faulkner v. Arista Records LLC, 46 F. Sup. 3d 365, 375 (S.D.N.Y. 2014) ("Weighing whether the expert testimony assists the trier of fact goes primarily to relevance."). + +Courts have frequently admitted expert testimony on the psychological relationship between perpetrators and victims of sex crimes. For instance, in United States v. Kidd, 385 F. Supp. 3d 259 (S.D.N.Y. 2019), the Government gave notice of expert testimony on "the psychology of the pimp-prostitute relationship," including concepts such as "trauma bonding." Id. at 263. The defendant interposed a Daubert challenge, arguing that the expert's testimony was not based on "studies or empirical data" and so could not "be assessed for reliability." Id. (internal + +quotation marks omitted). The district court rejected that argument, explaining that "case law quite commonly upholds this type of testimony against Daubert challenges," and that the expert's experience writing about, treating, and speaking to prostitutes was sufficiently reliable. Id. at 263- 64; see also, e.g., Letter, United States v. Kelly, No. 19 Cr. 286 (AMD) (E.D.N.Y. July 23, 2021) (Dkt. No. 134); United States v. Torres, No. 20 Cr. 608 (DLC), 2021 WL 1947503, at •6 (S.D.N.Y. May 13, 2021) (permitting expert testimony on "domestic abuse and coercive control"); Feb. 25, 2020 Tr. at 24:1-40:15, United States v. Randall, 19 Cr. 131 (PAE) (S.D.N.Y.), Dkt. No. 335 (permitting expert testimony on "R]rauma and coercive control in the context of sex trafficking, including the psychological relationship between pimps and the women prostituted by them"); Notice and Oct. 17, 2019 Tr. at 27:1-12, United States v. Dupigny, No. 18 Cr. 528 (JMF) (S.D.N.Y.), Dkt. Nos. 180-1, 198 (permitting expert testimony on "the psychological relationship between a pimp and the woman prostituted by him" and "why prostituted women do not leave their pimp"). + +# B. Discussion + +The defendant does not contest that Dr. is a qualified expert. Nor could she: Dr. is a leader in her field, teaching others as a professor at Brown University, and she has approximately twenty-five years of clinical experience. She is testifying in general about core concepts in her field, based on her "extensive study of the relevant data and literature and her clinical experience treating hundreds of trauma and abuse patients over the past twenty years." + +United States v. Raniere, No. 18 Cr. 204 (NGG), 2019 WL 2212639, at \*7 (E.D.N.Y. May 22, 2019). + +Instead, the defendant suggests that Dr. opinions are unreliable, irrelevant, or prejudicial. To the contrary, and as explained in greater detail below, each of the Dr. five challenged opinions is well supported and would aid the jury in understanding the evidence at trial. The Court should permit Dr. a testify. + +#### Ama 1. Dr. pOpinions on Coercion and Attachment are Admissible a. e + +As described in the expert notice, Dr. will testify about the role that trust and attachment play in relationships between a victim and an abuser: + +> Sexual abuse of minors frequently occurs through the use of manipulation or coercion in the context of an established relationship that is developed over time, rather than through the use of forcible rape. Minor victims are often subject to a strategic pattern of behaviors, often called grooming, that can take a variety of forms and function to render the victims vulnerable to abuse, to obscure the nature of the abuse, and to build trust and attachment with their abuser. The relationship of trust and attachment can prevent victims from being aware that what they are experiencing is abuse and can prevent disclosure. + +(Expert Notice, Def. Mot. 3 Ex. 1 at 2). Dr. will opine that victims are often abused in the context of a coercive and manipulative relationship which develops over time through the building of victims' trust and attachment. One aspect of this relationship is "often called grooming." (Def. Mot. 3 Ex. 1 at 2). However, the concepts of attachment and coercion go beyond grooming, and encompass both the trust-building aspect of the relationship and the ways in which + +that bonds victims to their abusers and prevents victims from disclosing that they have been abused.' + +These opinions stem in part from Dr. personal familiarity and experience treating victims of sexual abuse for decades. She is trained in trauma psychology, she has expertise in treating victims of sexual abuse who have been subject to this pattern of behavior, and she teaches residents about trauma psychology. Cl Bosco v. United States, No. 14 Civ. 3525 (JFK), 2016 WL 5376205, at \*11 (S.D.N.Y. Sept. 26, 2016) (expert testimony about "common knowledge among urologists" require the expert to "draw upon the defining characteristics that make him a member of that community: his training as a urological surgeon, his practical experience performing several hundred ureteroscopies, and his knowledge as a clinical instructor of surgery"). + +These opinions also stem from the relevant literature. This pattern of coercive attachment is not a novel or outlier concept in the literature of trauma psychology. For instance, attached as Exhibit A are some of the articles that have been provided by Dr. and inform her testimony. See Dietz, "Grooming and Seduction," 33 J. of Interpersonal Violence 28, 34 (2018) + +The concepts of attachment and grooming encompass a variety of established techniques, including: (1) the use of attention, love, and affection; (2) using bribery and gift giving; (3) sexual desensitization—that is, talking to children about sex and engaging in touching; (4) isolating the victim; and (5) engaging in emotional manipulation. Grooming efforts can also extend to "grooming the environment." Craven et al., "Sexual grooming of children: Review of literature and theoretical considerations," 3 J. of Sexual Aggression 287, 292-93 (2006) ("Some offenders groom the environment by targeting single-parent families to gain [a position of trust].] Offenders may do this because they believe that these children are more vulnerable and because they believe it will be easier to create opportunities to be alone with the child. Alternatively, offenders may target children or young people who have absent parents, and hence have less protection." (citation omitted)). + +("Since its introduction to the peer-reviewed professional literature in 1984, the term `grooming' has become so widely adopted that it will remain in widespread use for decades to come."); Bennett & O'Donohue, "The Construct of Grooming in Child Sexual Abuse: Conceptual and Measurement Issues," 23 J. Child Sexual Abuse 957, 964-68 (2014) (reviewing the literature on the prevalence of various grooming techniques); Craven et al., "Sexual grooming of children: Review of literature and theoretical considerations," 3 J. of Sexual Aggression 287, 292-93 (2006) ("[R]etrospective identification of sexual grooming, i.e. after a sexual offence has been committed, is much easier than prospective identification, i.e. before a sexual offence"). To be clear, however, her review of the literature—and therefore the basis of her testimony—extends beyond these articles. + +Accordingly, Dr. came to her opinions through her clinical experience on this specific issue, as informed by her education and study of the relevant literature. That is a sufficient demonstration of "how the expert came to [her] conclusion and what methodologies or evidence substantiate that conclusion." Riegel v. Medtronic Inc., 451 F.3d 104, 127 (2d Cir. 2006); see Feb. 25, 2020 Tr. at 24:1-40:15, United States v. Randall, 19 Cr. 131 (PAE) (S.D.N.Y.), Dkt. No. 335 (rejecting the notion that "the many studies that have validated trauma bonding and coercive controls as established phenomena are unreliable for want of laboratory-like statistical vetting"); Oct. 17, 2019 Tr. at 27:1-12, United States v. Dupigny, No. 18 Cr. 528 (JMF) (S.D.N.Y.), Dkt. Nos. 180-1, 198 (explaining that "the basis for the testimony—namely, the witness's training and experience—is not such that it would be subject to exclusion on the grounds that it's not based on some sort of empirical scientific testing," and that "those arguments go to the weight, not the admissibility, of her proposed testimony"). + +As noted above, courts have frequently admitted testimony about the psychological relationship between victims of sexual abuse and their perpetrators. See supra pp. 7-8. Courts have also specifically authorized expert testimony on the subject of grooming. See, e.g., United States v. Telles, 6 F.4th 1086, 1097-1098 (9th Cir. 2021) (holding that admission of expert testimony on grooming did not violate Federal Rules of Evidence 702 or 403 nor violate due process and finding that the expert 'merely gave a straightforward account of relevant background information based on [the expert's] own knowledge and experience' (quoting United States v. Johnson, 860 F.3d 1133, 1141 (8th Cir. 2017)); United States v. Halamek, 5 F.4th 1081, 1087-89 (9th Cir. 2021) (holding that expert testimony on grooming was "relevant, reliable, and properly admitted"); United States v. Isabella, 918 F.3d 816, 833 n.15 (10th Cir. 2019) ("Grooming can be established by use of an expert witness who testifies about psychological tactics that are common in cases of child sex abuse."); United States v. Hitt, 473 F.3d 146, 158 (5th Cir. 2006) (affirming expert testimony on the "grooming process"); Morris v. State, 361 S.W.3d 649, 656-69 (Tx. Ct. Crim. App. 2011) (collecting cases showing that "grooming evidence has been received by courts from numerous types of experts"); see also United States v. Brand, 467 F.3d 179, 203 (2d Cir. 2006), abrogated on other grounds by United States v. Cabrera, 13 F.4th 140 (2d Cir. 2021) (noting that evidence of grooming supported the jury's verdict). + +Against this weight of authority, the defendant relies principally on one case from the District of Maine. United States v. Raymond, 700 F. Supp. 2d 142 (D. Me. 2010). The proposed testimony in this case is readily distinguishable from that in Raymond. There, the government gave notice of expert testimony about the "behavior of child molesters" from a veteran FBI agent who had reviewed case studies of child abuse and had written one book and one article. Id. at 143, 145, 147. The purported expert's book, in turn, merely made assertions about the "profile" of child molesters, with no information about how his experiences reliably led to his conclusions. Id. at 147-48. In the same breath, however, the book "disavow[ed] [its] reliability ... for legal use," and his article similarly offered generalized views on what "many" offenders were "more likely or less likely to do." Id. at 148 (emphasis omitted). Accordingly, at bottom, the purported expert's testimony was based only on his subjective conclusions after reviewing case studies. See id. at 147 n.5 (explaining that the expert "troubling[ly]" wrote that "data is not the plural of anecdote," but "the information and opinions are based primarily on the totality of my acquired knowledge and expertise"). + +The situation here is quite different. Dr. conclusions are not anecdotal; they are grounded in the academic literature and her formal and informal education. Moreover, she will be testifying about concepts she regularly employs as a practicing clinician. Again, the defense does not contest that Dr. is qualified to be an expert on this subject. And Dr. opinions are not an attempt to offer a "profile" of perpetrators of child sexual abuse or their activities. Instead, Dr. will testify about the psychological underpinnings of an + +established pattern of victimization—attachment and coercion—experienced by victims of sexual abuse. + +The defense would read Raymond to stand for the proposition that expert testimony is unreliable if it does not explain "what testing was involved, what data she considered, or how her conclusions can be verified." (Def. Mot. 3 at 8). For instance, the defense criticizes Dr. for opining that sexual abuse of minors occurs "frequently," without specifying whether it occurs "half the time" or "two-thirds of the time." (Id. at 7; see id. at 8 (quoting Raymond, 700 F. Supp. 2d at 148-49)). That is not what is required by Daubert in the context of qualitative social science, and it is not what many courts have held in the context of precisely this form of testimony, as explained above. To the extent Raymond stands for such a broad proposition, it is contrary to the law of this Circuit. See United States v. Joseph, 542 F.3d 13, 21-22 (2d Cir. 2008), abrogated on other grounds as recognized by United States v. Ferguson, 676 F.3d 260, 276 n.14 (2d Cir. 2011) (recognizing that social science research "cannot have the exactness of hard science methodologies, and expert testimony need not be based on statistical analysis in order to be probative" (citation and internal quotation marks omitted)).2 + +The defendant's remaining critiques of Dr. opinion miss the mark. First, the defendant asserts that Dr. patients are uncorroborated, and she "simply assumes her + +2 Even in Raymond, the Court left open the possibility that the Government could call the expert in rebuttal to "counter a defense case that victim testimony in this case should not be believed because the victim delayed in reporting the abuse or did not report it consistently." 700 F. Supp. 2d at 156. Even were the Court inclined to follow Raymond rather than the cases in this District, it should similarly revisit permitting Dr. to testify about the opinion at issue if the defense attacks victim credibility. + +patients are telling the truth." (Def. Mot. 3 at 6). The defendant claims that this "fatally undermines the reliability of her opinion" because her conclusion has "no known or identified rate of error . . . nor is there a reliable method or a series of factors guiding 1= conclusion as to whether an individual victim is fabricating her abuse." (Id. (alterations and quotation marks omitted)). Clinical psychologists are not so credulous. As part of Dr. work as a practicing clinician, she examines consistencies and inconsistencies in the information provided by patients and assesses patient self-reporting in the context of literature and knowledge that she has developed in her years of practice. As the Government's expert notice makes clear, Dr. has treated hundreds and hundreds of patients in her decades of experience, and her opinions are based in part on the significant patterns she has observed among the patients she has treated. The Court should reject the defendant's speculative claim that Dr. has been misled by hundreds of patients who sought professional treatment for traumatic events that did not occur. + +In any event, the defendant's argument about error rates misunderstands the nature of a Dauber! inquiry. An error rate is but one of the Dauber! factors that may or may not be applicable in every case. See Romano, 794 F.3d at 330. And in cases such as this, where a social science expert is testifying based on qualitative methodology, that factor is inapplicable. See Torres, 2021 WL 1947503, at \*6 n.8. As the Second Circuit has explained, "Peer review, publication, potential error rate, etc. . . . are not applicable to this kind of testimony, whose reliability depends heavily on the knowledge and experience of the expert, rather than the methodology or theory behind it. In such cases, the place to quibble with [an expert's] academic training is on cross-examination . . . ." Joseph, 542 F.3d at 21-22 (first and second alterations in original) (citations and internal quotation marks omitted). + +That point is particularly true in sex trafficking cases. As Judge Engelmayer explained when evaluating the testimony of a similar expert in a sex trafficking case, analyzing error rates is an "unusually poor fit" in this area: + +> [S]tudying the circumstances and psychological drivers of trafficked women is not like studying diseases or potential cures in laboratory animals. . . . Given the necessarily retrospective nature of such a study, given the small size of the populations under review, and given the inherently individualized circumstances presented by different perpetrators, victims, and contexts in this tumultuous and emotionally fraught area of criminal conduct, the vocabulary of error rates . . . is an unusually poor fit.... The testing that has been done as to trauma bonding and coercive control, instead, necessarily uses more qualitative research methodologies. These involve interviews and case studies and clinical examinations conducted over time." + +Feb. 25, 2020 Tr. at 29:4-30:20, United States v. Randall, 19 Cr. 131 (PAE) (S.D.N.Y.), Dkt. No. 335. Because statistical rigor is not a useful method for evaluating the reliability of qualitative research like Dr. statistical tools like error rates are irrelevant to the Daubert analysis. + +Contrary to the defendant's next claim, these opinions are not "impregnable for purposes of cross examination." (Def. Mot. 3 at 7 (citation and internal quotation marks omitted)). The defendant is free to cross Dr. on how frequently she sees grooming in her patients and how she evaluates whether they are telling the truth. The defendant is also free to explore, in cross examination, the difficulties in assessing whether a patient has been groomed. The defense can also make arguments—in cross examination and in jury addresses—about the lack of quantitative rigor in this qualitative area of science. That is the point: it is for the jury, after hearing the + +evidence, to evaluate what weight to give it. But that does not change whether Dr. opinions are squarely within the mainstream of psychological practice. + +The defendant next argues that Dr. patients are "self-selected," and she has not established the "representativeness of her patients as typical victims of so-called grooming behavior." (Def. Mot. 3 at 7). But the defendant makes no argument that the minor victims in this case are distinctive in some way such that general principles of psychology may diverge as to them. And in any event, that argument is for the jury to evaluate, and not a basis to preclude Dr. testimony. See Feb. 25, 2020 Tr. at 36:13-37:5, United States v. Randall, 19 Cr. 131 (PAE) (S.D.N.Y.), Dkt. No. 335 (rejecting a defense attempt to distinguish between native-born and domestic-born women because, "while a court is to be a gatekeeper as to reliability so as to keep `junk science' away from juries, the Court must not overstep that role. Whether or not the Court would be persuaded that adult native-born women can be subject to trauma bonding, the Court is not to arrogate to itself that judgment.") + +Finally, the defendant argues that Dr. has no experience treating perpetrators of sexual assault, so she cannot testify as to the psychology of perpetrators and their "so-called `grooming' techniques." (Def. Mot. 3 at 7-8). Many of the opinions the defendant challenges concern the experiences of victims, not perpetrators. Dr. will testify about the pattern to which "minor victims are often subject," which makes "victims vulnerable to abuse," and builds their "trust and attachment with their abuser." (Expert Notice, Def. Mot. 3 Ex. 1 at 2 (emphasis added)). Grooming creates in the victims "a relationship of trust and attachment" that "can prevent victims from being aware that what they are experiencing is abuse and can prevent disclosure. (Id. + +(emphasis added)). Dr. testimony will also include discussion of techniques used by perpetrators. Dr. Rocchio's testimony regarding such techniques is supported by Dr. review of the relevant literature, see Exhibit A, and through her clinical work. By virtue of her experience treating victims, Dr. is necessarily informed about perpetrators' actions. See Halamek, 5 F.4th at 1088 ("Extensive experience interviewing victims can qualify a person to testify about the relationships those victims tend to have with their abusers."). Dr. will testify squarely within her expertise and experience.' + +### b. Relevance and Rule 403 + +Dr. opinions will assist the trier of fact in understanding the evidence at trial. This case concerns an "unusual area of human interaction." See Feb. 25, 2020 Tr. at 39:8-9, United States v. Randall, 19 Cr. 131 (PAE) (S.D.N.Y.), Dkt. No. 335. The Minor Victims in this case were trafficked over many years, and none were physically restrained. An average juror, with no experience with sexual abuse victims, may not understand why the Minor Victims continued to + +3 In United States v. Raniere, No. 18 Cr. 204 (NGG), 2019 WL 2212639 (E.D.N.Y. May 22, 2019), Judge Garaufis questioned whether an expert on grooming with experience focused on victims may have been able to testify reliably about how "perpetrators often use 'grooming' techniques on adult and child victims . . ." Id. at \*7. Even then, he did not exclude the testimony—he simply ordered a Daubert hearing. Id. at \*8. The Government ultimately declined to proceed with that testimony rather than conduct a mid-trial Daubert hearing. Here, and as noted above, Dr. proposed testimony concerns the experience of manipulated and coerced victims, rather than the intentions of perpetrators. + +return to Epstein's home for sexual abuse, or why some occasionally expressed affection for the defendant and Epstein. + +Although Dr. will not testify about these specific Minor Victims, her testimony will help the jurors understand the "psychological dynamic often seen in abusive relationships that leads an abuse victim to behave in counterintuitive ways, such as by declining to take opportunities to leave an abusive situation or by expressing gratitude to an abuser." Torres, 2021 WL 1947503, at \*7. This psychological dynamic between a victim of child sexual abuse and her abusers is "beyond the knowledge of the average juror and would or could plainly be helpful in understanding the psychological dynamics at play." Oct. 17, 2019 Tr. at 27:3-7, United States v. Dupigny, No. 18 Cr. 528 (JMF) (S.D.N.Y.), Dkt. No. 198; cf. See Feb. 25, 2020 Tr. at 38:13-20, United States v. Randall, 19 Cr. 131 (PAE) (S.D.N.Y.), Dkt. No. 335 ("[B]y and large the relationship between prostitutes and pimps is not the subject of common knowledge. Jurors are not apt to intuitively understand the mechanisms that may lead a woman who is not physically restrained or confined to heed the demands of a pimp to traffic herself."). Accordingly, Dr. testimony will help the jury understand and contextualize the other testimony it will hear.' + +The defendant expresses concern that a lay jury will be unable to apply Dr. analyses to the facts of this case, stating "[t]hat is not how Rule 702 works." (Def. Mot. at 10). + +Relying again on Raymond, the District of Maine case, the defendant argues that expert testimony about "general principles is helpful only when it `describes widely recognized and highly predictable and verifiable phenomena.' (Def. Mot. 10 (quoting Raymond, 700 F. Supp. 2d at 150 n.12 (alterations omitted)). That proposition comes from footnote 12 of Raymond, which attempted to distinguish that expert's "profile" testimony from the Federal Rules Advisory Committee's observation that the 2000 amendment "does not alter the venerable practice of using + +That is precisely how Rule 702 works in cases where experts testify about general principles, which the Rule contemplates. See Fed. R. Evid. 702 Advisory Committee note ("[I]t might also be important in some cases for an expert to educate the factfinder about general principles, without ever attempting to apply these principles to the specific facts of the case."). Dr. will provide reliable opinions about principles of coercion and attachment in abusive relationships that will help the jury understand the psychological factors underlying the relationships that the jury will learn about at trial. + +Finally, the defendant argues that the Court should preclude Dr. estimony under Rule 403. In so arguing, she expresses concern that Dr. testimony will "'radically simplify' an otherwise complex case" by "`foist[ing] a damning teleology on a series of actions each of which might have been motivated by a variety of ends or no ends at all."' (Def. Mot. at 11 (quoting United States v. Bunts, No. 07 Cr. 556, 2009 WL 3617448, at \*5 (N.D. Ill. Oct. 27, 2009)).5 There is nothing prejudicial or simple about Dr. testimony. The jury will not conclude that the defendant is guilty because Dr. explains that acts which "might have been motivated by a variety of ends" are sometimes part of the process of sexual abuse. Whether + +expert testimony to educate the factfinder on general principles." Raymond, 700 F. Supp. 2d at 150 n.12 (quoting Fed. R. Evid. 702 Advisory Committee note). The defendant cites no place containing this limitation in the text of the Rule, its advisory committee notes, Daubert, or the law of this Circuit or District. Nor does it make sense on its own terms: "how financial markets respond to corporate reports" or the "principles of thermodynamics" are sometimes highly predictable, but not always, depending on the context. + +5 Burns, a case about a district court's application at sentencing of a Guidelines enhancement, says nothing about whether the jury would be confused by learning about grooming. + +they were in this case will depend on the other evidence. That is not a prejudicial simplification that is the trial. + +There is nothing unreliable, irrelevant, or unusual about Dr. opinion on coercion and attachment. Drawing on her decades of clinical experience and her familiarity with the relevant literature, Dr. will give opinion testimony that will help the jury understand witness testimony. That is all Rule 702's gatekeeping requirements demand. + +#### 2. Dr. Opinion on the Relationship Between Trust and Victim Awareness of Their Abuse is Admissible + +At trial, the Government intends to offer Dr. testimony about how victims process their abuse and how that can prevent or delay disclosure. As the Government set forth in its expert notice, Dr. will testify that: + +> The relationship of trust and attachment can prevent victims from being aware that what they are experiencing is abuse and can prevent disclosure. Minor victims therefore may not identify themselves as victims of abuse while it is ongoing, and may not recognize the consequences of that abuse until adulthood. + +(Def. Mot. 3 Ex. 1 at 2). This opinion is part and parcel of Dr. other opinions about the relationship between attachment and coercion. Specifically, and as noted above, victims develop relationships of trust and attachment with their abusers that leave victims vulnerable to coercion. This opinion adds that, as part of this relationship, victims may not recognize that they are experiencing abuse and may not see themselves as victims while they are in this relationship, and therefore may not disclose their abuse or recognize the consequences of their abuse until later in life. As the defense correctly observes, this opinion is intertwined with Dr. opinions about coercion and attachment. (Def. Mo. 3 at 12). Just as those are reliable, so is this one. + +The defense argues that this opinion is outside Dr. expertise because she has "no experience treating alleged perpetrators," so "her view . .. is entirely one-sided." (Id.). As is clear from the above excerpt, her testimony is about largely about trust and attachment built in victims, and the resultant ways in which victims process abuse. But she is also an expert in the actions and techniques of perpetrators through her review of the literature and the lens of what she has learned through victims. This opinion is therefore squarely within Dr. expertise. + +Finally, the defendant argues that this testimony violates Rule 704, because it is an "opinion that the alleged victims in this case are testifying truthfully," and 403, because it "risks jurors accepting her `expert' opinion as gospel at the expense of their duty to evaluate the evidence." (Def. Mot. 3 at 13). Dr. as not evaluated the victims in this case and will not express an opinion as to whether they are testifying truthfully. And the defense motion is entirely unclear on the features of this expert opinion that create risk that the jurors would abdicate their responsibilities. To the contrary, the defense concerns underscore how relevant this opinion will be in aiding the jurors in understanding the testimony at trial. + +3. Dr. Opinion on the Long-Term Consequences of Abuse is Admissible Dr. will also testify that "[r]epeated exploitation and abuse can increase the likelihood of victimization later in life and can result in long-term traumatic and psychological consequences, especially when it occurs in the context of complex trauma." (Def. Mot. 3 Ex. 1 at 2). As Dr. nill explain, and as is detailed in her Jencks Act material', experiencing child + +6 The Government produced Dr. Jencks Act material to the defense at the time of the expert notice. (See Def. Mot. 2 ("The Government is producing notes from the Government's interviews with Dr. oday as well.")). + +sexual abuse can lead to a variety of psychological difficulties, including substance use and participation in risky sexual behavior. Complex trauma—trauma involving repetitive or prolonged exposure to or experiences of multiple traumatic stressors, involving harm or abandonment by trusted adults, and occurring at developmentally vulnerable times—can lead to various psychological consequences, including dysregulation in emotional control, difficulties in relationships or with behavioral control, and distorted perceptions of the self and others. + +This opinion is highly relevant. It is likely that jurors will not be intimately familiar with the consequences of child sexual abuse. Accordingly, the causal connection between these psychological problems and child sexual abuse is outside the experience of the average juror. Yet that information will aid the jury in two respects: First, it will help jurors assess the credibility of Minor Victims, to the extent they have had some of these psychological symptoms or had other difficulties described by Dr. in the years since their abuse. For instance, the Government expects the defense to attack the credibility of a Minor Victim by cross0-examining her about her substance abuse. Dr. testimony will provide the jury with a fuller picture by showing that substance abuse can be a consequence of sexual trauma. Second, experiencing certain psychological difficulties is consistent with past child sexual abuse and complex trauma. It is evidence that Minor Victims in fact experienced child sexual abuse that they suffered known consequences of such abuse. See Raniere, 2019 WL 2212639, at \*3, \*7 (admitting expert + +testimony that "sexual assault can result in severe, long-lasting and wide-ranging psychological consequences and related difficulties"). + +The defendant argues that this evidence is nonetheless prejudicial because it will inflame the passions and emotions of the jury. (Def. Mot. 3 at 14). The Minor Victims, however, will be the ones testifying about the abuse they experienced and observed, and—whether on direct or cross—about the psychological consequences of their experiences. The question is only whether the jury will hear from an expert about the causal connection between those two concepts testimony about concepts not specifically applied to any victim, and testimony about a causal connection whose reliability the defense does not challenge. There is nothing inflammatory about this expert testimony, much less something sufficiently prejudicial to substantially outweigh the probative value of the testimony. See Fed. R. Evid. 403. + +#### 4. Dr. Opinion About the Significance of the Presence of Third Parties is Admissi + +As noted above, Dr. will opine that "[t]he presence of other individuals can facilitate the sexual abuse of minors." (Def. Mot. 3 Ex. 1 at 2). For instance, and as Dr. will explain, the presence of a third party can disarm an intended victim and make perpetrators appear safe and trustworthy, or can create a false sense of security on the part of a minor victim that sexualized situations are normal and acceptable. Based on her experience as a clinician, Dr. will testify that young children in particular often feel more comfortable in the presence of a woman. + +The defendant objects to this testimony on the grounds that it concerns a lay matter "which a jury is capable of understanding and deciding without the expert's help." (Def. Mot. 3 at 14 (citation and internal quotation marks omitted)). Dr. however, is not testifying about common experience or from common experience. Her testimony stems from her clinical experience, and it concerns the psychological experiences of victims when a third person is present during parts of their sexual abuse, as part of her broader opinion on attachment and coercion. The average juror will not have knowledge of or experience in the psychology of abuse victims, and Dr. estimony will aid their understanding. + +The defendant relatedly seeks to preclude Dr. from testifying about "groomingby-proxy," a term which appears nowhere in the Government's expert notice. (Def. Mot. 3 at 9). By that term, the defendant appears to argue that Dr. will opine that an individual can groom a victim for abuse by another perpetrator, and that such an opinion is unreliable and "prejudicial speculation." (Id.). This argument misses the mark in three respects. First, Dr. estimony primarily concerns the experience of victims, not perpetrators, as explained above. If the victim experienced attachment and grooming, it makes no analytical difference whether the perpetrator intends to engage in sexual contact with the victim or, instead, is preparing the victim for abuse by a third party. See Feb. 25, 2020 Tr. at 31:1-34:12, United States v. Randall, 19 Cr. 131 (PAE) (S.D.N.Y.), Dkt. No. 335 (explaining that, where there is a "reliable basis for testi[mony] about trauma bonding and coercive control as phenomena that exist more broadly," the expert may testify, and defendants "are at liberty to vigorously cross-examine [the expert] to attempt to cabin or limit trauma bonding and coercive control to populations predominately outside of the alleged victims in this case"). Indeed, expert testimony is commonly offered in sex trafficking cases on the pimp-prostitute relationship, which is specifically designed to permit the + +pimp to arrange sex acts for third parties. See, e.g., Kidd, 385 F. Supp. 3d at 263; Oct. 17, 2019 Tr. at 27:1-12, United States v. Dupigny, No. 18 Cr. 528 (JMF) (S.D.N.Y.), Dkt. No. 198. Second, in any event, the Government did not provide expert notice on "grooming by proxy." Dr. will give an opinion on grooming, and she will discuss how "[t]he presence of other individuals can facilitate the sexual abuse of minors." (Expert Notice, Def. Mot. 3 Ex. 1 at 2). The former is a reliable opinion, as explained above, and the defendant does not challenge the reliability of the latter opinion. (See Def. Mot. 3 at 14). Third, trial testimony will show that the defendant (I) in fact participated in sexual abuse of minors, (2) facilitated that abuse through her presence, and (3) conspired with a predator who groomed and sexually abused minors. None of that involves "grooming by proxy." + +# 5. Dr. )pinion on Delayed Disclosure is Admissible + +Finally, Dr. will offer the opinion that "nondisclosure, incremental disclosure, and secrecy are common among victims of sexual abuse for a variety of reasons, and that memory and disclosure of traumatic or abusive events is impacted by a number of factors, including the circumstances surrounding the trauma." (Def. Mot. 3 Ex. 1 at 2). + +Much of the basis for this opinion is set forth in Dr. Jencks Act material. For instance, extensive psychological literature supports the idea that individuals who are harmed as children may come to disclose their experiences incrementally or not until much later, as they may only realize that their experiences were abusive later in life, among other reasons. Selected articles from that literature are attached as Exhibit B. See Alaggia et al., "Facilitators and Barriers to Child Sexual Abuse (CSA) Disclosures: A Research Update (2000-2016)," 20 Trauma, Violence & Abuse 260, 276 (2016) ("Disclosure is now generally accepted as a complex and lifelong process, + +with current trends showing that CSA disclosures are too often delayed until adulthood"); McElvaney, "Disclosure of Child Sexual Abuse: Delays, Non-disclosure, and Partial Disclosure," 24 Child Abuse Rev. 159, 160 (2015) (There is consensus in the research literature that most people who experience sexual abuse in childhood do not disclose this abuse until adulthood, and when disclosure does occur in childhood, significant delays are common."); Bicanic et al., "Predictors of delayed disclosure of rape in female adolescents and young adults," 6 Euro. J. of Psychotraumatology 25883 (2015) (listing among the predictors of delayed disclosure "age category 12-17 years"). Children who do disclose may choose to share information with a peer, but are less likely to go to an adult. Especially where a child has been groomed, the perpetrator has become a trusted adult for a child, reducing the likelihood of the child's disclosure. Incremental disclosure depends on a variety of factors, including how safe the victim feels with the recipient of the disclosure, how voluntary the disclosure is, and psychological factors that may prevent the victim from accessing their full memories. Victims may also experience significant shame or self-blame that prevents them from sharing certain information, and they may still be attached to the perpetrators, such that they try to protect the perpetrators. + +Sexual abuse also impacts the way memory is encoded. In traumatic circumstances, often only the most salient details are encoded, and over time, specific details may be lost. With traumatic memory in particular, adrenaline and cortisol responses in the context of fear and trauma cause people to narrow their focus to the most salient and relevant details. If someone is abused multiple times or by multiple people, it is very common for memories of similar occurrences to jumble together, although the victim can remember the perpetrator and maybe some of the locations where the abuse occurred. + +Taken together, Dr. expert testimony explains why victims of child sexual abuse—and especially repeated sexual abuse—may disclose their abuse in a delayed and incremental fashion, and why their memories may lack some level of detail when the disclosure finally occurs. + +The defendant argues that testimony about delayed disclosure is unreliable, repeating some of the defendant's earlier arguments about whether the testimony is "based entirely on her treatment of a self-selected group of individuals she assumes are telling the truth" and how the opinion lacks an error rate. (Def. Mot. 3 at 15). Here, as with her opinions on attachment and coercion, Dr. is testifying based on her training, clinical experience, dnd the academic literature. See Exhibit B. That victims of childhood sexual abuse delay disclosure is a wellestablished phenomenon the fact of which—though not the underlying psychological explanation—is readily visible in the news. See also 2 Mod. Sci. Evid. § 19:15 (explaining that "a large literature over the years has demonstrated that individuals frequently fail to disclose autobiographical information in numerous different settings," including disclosure of "episodes of sexual abuse"). + +Courts have specifically authorized experts to provide testimony on delayed disclosure. See, e.g., United States v. Gaudet, 933 F.3d 11, 15-16 (1st Cir. 2019) ("Moreover, the government provided expert testimony from Dr. Ann Burgess .. . in which she testified that delayed disclosures are `[v]ery common' in abuse victims and stem from the way the brain processes, stores, and recalls traumatic experiences" (second alteration in original)); Raniere, 2019 WL 2212639, at \*3, \*7 (admitting expert testimony that "disclosure by sexual assault victims often unfolds over time, and the process of disclosure is influenced by multiple and changing factors including, but not limited to, the specific characteristics of the experience, the victim's psychological vulnerabilities, the victim's relationship to her perpetrator and her pattern of recovery and coping"); United States v. Young, 623 F. App'x 863, 865-66 (9th Cir. 2015) ("[The expert] testified that . . delayed disclosures, piecemeal disclosures and/or even recanted disclosures are coping mechanisms. . . . [The expert]'s testimony was helpful and probative because [the defendant] had attacked the victims' credibility based on their delayed and incomplete reports of abuse." (citations and internal quotation marks omitted)); United States v. Belcher, 534 F.3d 820, 826 (8th Cir. 2008) ("In this case, Dr. Levitt's testimony as to delayed disclosure helped the jury understand why the girls did not reveal they had been photographed until they were confronted with the images."). + +The defendant suggests that Dr.a opinions on delayed disclosure are not helpful to the jury because they are too generic. As set forth here and more fully in Dr. .lencks Act material, Dr. has elaborated on her opinions about the relationship between child sexual abuse and traumatic memory.' The defendant adds that, because Dr.M opinion is that delayed disclosure is consistent with sexual abuse but not a necessary consequence of sexual abuse, jurors have no means to determine whether a Minor Victim is lying or telling the truth + +7 The defendant also argues that Dr. GM is not an expert in "the human brain or memory generally." (Def. Mot. 3 at 17). The overnment agrees. But Dr. s an expert in trauma psychology, which includes related issues of memory. + +(Def. Mot. 3 at 16). This argument misunderstands the role of the jury. Jurors are not tasked merely with applying Dr. expertise to facts. The jury will hear testimony that some Minor Victims did not immediately disclose their sexual abuse. When evaluating the credibility of those delayed disclosures, they will have the benefit of observing the Minor Victims' testimony, including their cross-examination which is sure to address their delayed disclosure, and the Minor Victims' explanation for those delays. The July will also hear general testimony from Dr. about various circumstances that may lead victims of sexual abuse to delay disclosure. In the totality of the circumstances, the jury can then decide who it finds credible. + +The defendant also argues it is prejudicial to her that Dr. suggests "that delayed reporting is more consistent with truthfulness than fabrication, a determination which the jury must make for itself." (Def. Mot. 3 at 17). It is unclear how the defendant can simultaneously argue that (1) Dr. \_testimony improperly assumes the role of the jury by suggesting that delayed reporting is "more consistent" with child sexual abuse (id.); and (2) Dr. -testimony would only help the jury if she resolved any ambiguity by saying that delayed reporting is a necessary consequence of child sexual abuse (id. at 15-16). + +Finally, according to the defendant, Dr. arguments will only prejudice the defendant, because it will serve to bolster the witnesses' credibility. As the defense acknowledges, however, Dr. will not offer an opinion regarding any specific victim, and she has not evaluated any victims in this case. (Cf. Def. Mot. 3 at 16 (citing United States v. Charley, 189 F.3d 1251, 1266-67 (10th Cir. 1999), in which the expert opined that the victims were in fact abused based "largely on crediting the girls' account," thereby "vouching for their truthfulness"). + +Instead, the Government will seek to offer Dr. testimony as background in this case. "Dauber! instructs that vigorous cross-examination and the presentation of contrary evidence are the central tools available to an adversary who wishes to debunk an expert's testimony." Randall, 19 Cr. 131 (PAE), Dkt. No. 335 at 37 (internal quotation marks omitted) (citing Dauber'', 509 U.S. at 594-595). Thus, to the extent the defendant wishes to cast doubt on the applicability of Dr. background testimony, she is free to do so through cross-examination or by offering contrary evidence. As discussed above, Dr. testimony is relevant to helping the jury understand key issues in the case, like why the Minor Victims may have returned to the defendant and Epstein without being physically forced to do so, and why they delayed disclosure. + +\* \* \* + +The parties agree that Dr. is a qualified expert. Her opinions are well within the range of reasonable expert opinions, and so are sufficiently reliable to go to the jury. And they will aid the jury in evaluating other testimony in this case. That is enough for the Court to admit Dr. Rocchio's testimony. + +#### H. The Evidence Contained in the Government's October 11, 2021 Letter is Admissible + +On October 11, 2021, the Government notified the defense of certain evidence it may offer at trial. In particular, the letter addressee and the expected testimony of one potential witness. (See October 11, 2021 Letter, Def. Mot. 2 Ex. A). As the Government explained in its letter to the defense, the evidence constitutes direct evidence of the charged offenses, but the Government provided notice under Rule 404(b) in the alternative. That same day, the Government provided the defense with along with copies of all other marked Government + +exhibits, all of which were in the Government's discovery productions. The Government also provided the defense with Jencks Act materials for all trial witnesses that same day, including detailed notes and reports of the Government's interviews of the witness referenced in the letter. + +The defendant now moves to exclude this evidence, arguing, among other things, that the Government has not provided sufficient notice of the evidence it intends to offer at trial under Rule 404(b). For the reasons set forth below, the defendant's motion lacks merit, and should be denied. The Government has provided detailed notice, well in advance of trial. This evidence is admissible on multiple grounds, and the jury should be permitted to consider it. + +### A. Applicable Law + +Relevant evidence is "not confined to that which directly establishes an element of the crime." United States v. Gonzalez, 110 F.3d 941, 942 (2d Cir. 1997). As the Second Circuit has explained, "[t]o be relevant, evidence need only tend to prove the government's case, and evidence that adds context and dimension to the government's proof of the charges can have that tendency." Id.; accord United States v. Coonan, 938 F.2d 1553, 1561 (2d Cir. 1991). The Second Circuit has repeatedly held that actions and statements are admissible as direct evidence of the crimes charged, and are "not considered other crimes evidence under" Federal Rule of Evidence 404(b), if (a) they "arose out of the same transaction or series of transactions as the charged offense," (b) they are "inextricably intertwined with the evidence regarding the charged offense," or (c) they are "necessary to complete the story of the crime on trial." Carboni, 204 F.3d at 44; see also United States v. Quinones, 511 F.3d 289, 309 (2d Cir. 2007); United States v. Baez, 349 F.3d 90, 93-94 (2d Cir. 2003). In those circumstances, the uncharged crimes evidence is "appropriately treated + +as part of the very act charged, or, at least, proof of that act." Quinones, 511 F.3d at 309 (internal citations and quotations marks omitted). + +Federal Rule of Evidence 404(b) allows for the admission of uncharged crimes, wrongs, or other acts for purposes other than proving criminal propensity, "such as proving motive, opportunity, intent, preparation, plan, knowledge, identity, absence of mistake, or lack of accident." Fed. R. Evid. 404(b). The Second Circuit "has long adopted an inclusionary' approach to the admission of uncharged crime evidence, under which evidence of prior crimes, wrongs, or acts is admissible for any purpose other than to show a defendant's criminal propensity." United States v. Paulin, 445 F.3d 211, 221 (2d Cir. 2006) (internal quotation marks omitted). Where the defendant claims her conduct has an innocent explanation, the admission of such evidence of other acts is particularly appropriate. See, e.g., United States v. Zackson, 12 F.3d 1178, 1182 (2d Cir. 1993) ("Where a defendant claims that his conduct has an innocent explanation, prior act evidence is generally admissible to prove that the defendant acted with the state of mind necessary to commit the offense charged."). Where evidence is offered for a proper purpose under Rule 404(b), it may only be excluded if the probative value of the evidence is "substantially outweighed" by the danger of unfair prejudice. Id. at 1182; see Fed. R. Evid. 403. + +Until December I, 2020, the Government was required to provide "reasonable notice of the general nature of any such evidence that the prosecutor intends to offer at trial." Fed. R. Evid. 404(b)(2)(A) (2011). On December 1, 2020, the rule was amended (the "2020 Amendments") to require the Government to also "articulate in the notice the permitted purpose for which the prosecutor intends to offer the evidence and the reasoning that supports the purpose." Fed. R. + +Evid. 404(b)(3)(B) (2020). The 2020 Amendments also removed language permitting notice of the "general nature" of the evidence. + +These amendments are "relatively modest." Wright & Miller, "2020 Amendments to Rule 404(b)," 22B Fed. Prac. & Proc. Evid. § 5242.1 (2d ed.). They simply require the prosecutor to "articulate a non-propensity purpose for which the evidence is offered and the basis for concluding that the evidence is relevant in light of this purpose." Id. (quoting Fed. R. Evid. 404(b) Advisory Committee note). The other act evidence should also be "described with helpful specificity." Id. + +### B. Discussion + +To be clear, in the Government's view, the exhibits and testimony discussed in the Government's October 11, 2021 letter are direct evidence of the offenses charged, such that they do not need to be admitted pursuant to Rule 404(b). And although notice was not required under Rule 404(b), the Government has provided the defense with notice substantially in advance of trial. The Court should admit this evidence, regardless of whether Rule 404(b) applies. + +#### 1. The Evidence is Admissible As Direct Evidence, or in the Alternative, Under Rule 404(b) + +The Government's October I 1 letter identified seven exhibits and one witness whose statements are admissible as direct evidence, or in the alternative under Rule 404(b). (See October I1, 2021 Letter, Def. Mot. 2 Ex. A at 1). More specifically, the letter explained that the Government may offer at tria marked as Government Exhibits 401 through 404, 409 through 410, and 413. In addition, the Government notified the defense that it may call as a witness an individual ("Employee-1") who worked for Jeffrey Epstein immediately 35 + +following the charged conduct. Both categories of evidence are admissible as direct evidence of the charged conduct, or in the alternative under Rule 404(b). + +**a. Government Exhibits 401 through 404, 409 through 410, and 413** + +Turning first to the exhibits, the Government has notified the defense that it intends to offer + +[REDACTED] + +[REDACTED] (October 11, 2021 Letter, Def. Mot. 2 Ex. A at 1). + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] + +[REDACTED] + +[REDACTED] But the jury could easily draw different inferences from these exhibits. The exhibits go directly to the defendant's intent and motive, because they show [REDACTED] + +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] + +Accordingly, these exhibits are probative of the issues the jury will be asked to resolve at trial and should be admitted as direct evidence of the charged crimes.9 In the alternative, this evidence is probative of the defendant's motive, intent, plan, and knowledge, and should be admitted pursuant to Rule 404(b)(2). [REDACTED] + +--- + +8 The remaining exhibits identified in the Government's October 11, 2021 letter are necessary to identify the parties to the emails. + +9 This evidence would also be admissible to rebut defense arguments concerning similar topics, and in cross-examination of the defendant. + +only highlights that this evidence does "not involve conduct any more sensational or disturbing than the crimes with which [the defendant] was charged," which weighs in favor of admitting these exhibits under Rule 404(b)(2). United States v. Roldan-Zapata, 916 F.2d 795, 804 (2d Cir. 1990). + +#### b. Testimony of Employee-1 + +Employee-1 worked as a personal assistant for Epstein for approximately (October 11, 2021 Letter, Def. Mot. 2 Ex. A at 1). During that time, Employee-1 reported directly to another employee ("Employee-2"), who worked for Epstein during the timeframe of the charged conspiracy, and who is referenced in the Second Superseding Indictment (the Indictment"). (ECF No. 187, ¶r 6, 7(b)). The Government expects that Employee-1 will testify about Employee-1's observations of the close relationship between the defendant and Epstein. Indeed, Employee-1 will testify that Employee-1 worked out of the defendant's townhouse in Manhattan during the weeks that Employee-1 worked in New York City. The Government also expects Employee-1 to testify about her observations at Epstein's properties, including observations of minor girls at the properties, as well as her knowledge of Epstein's practice to arrange multiple sexualized massages per day. In addition, although Employee-1's employment post-dates the defendant's conduct with the victims in this case, Employee-1 became familiar with certain items in Epstein's residences during her tenure there, and thus Employee-1 will authenticate certain exhibits relating to the Minor Victims. Finally, the Government expects Employee-1 to testify that in or about October 2005, Epstein and her supervisor directed her to gather the computers and contact books in the house and hand them over to a specified individual. + +Employee-I's testimony is admissible for multiple permissible purposes. Her testimony shows the relationship between Epstein and the defendant shortly after the end of the conspiracy period, including the defendant's role in Epstein's affairs. Similarly, it provides background information about the operation of Epstein's homes and lifestyle. Employee-1's testimony will also show the defendant and Epstein's plan and preparation, because it will describe the process and frequency of obtaining masseuses, including the fact that the masseuses were often underage girls, and that some of the massages developed into sexual abuse. And Employee-1's testimony tends to show the defendant's knowledge, because it describes the visibility of Epstein's abuse to individuals at his properties. Finally, Employee-1's testimony will authenticate exhibits that are direct evidence of the charged crimes. Accordingly, Employee-I 's testimony is direct evidence of the crimes charged. Moreover, this evidence is admissible in the alternative under Rule 404(b), for substantially the same reasons. + +# 2. The Government Has Met and Exceeded Its Notice Obligations + +Even if Rule 404(b) applies here, the Government's October 11, 2021 letter—and the corresponding Jencks Act disclosures—have satisfied any notice obligations that apply here. + +The defense claims that the Government's October 11, 2021 notice was inadequate in light of the 2020 amendments to Rule 404(b). The Government provided the defense with a letter, and corresponding disclosures, seven weeks before trial. In fact, the defense has had the seven exhibits for much longer, since they were part of the Government's Rule 16 discovery productions. The defense now also has this briefing, five weeks before trial. Thus, any alleged gap in the Government's notice is remediated by this brief. This is ample notice of the possible Rule 404(b) evidence in this case. Indeed, the Rule only requires that the defense receive notice "before trial," or even "during trial... for good cause." Fed. R. Evid. 404(b)(3)(C). + +The defense claims, without supporting authority, that Rule 404(b) requires heightened notice that cannot be satisfied here without, essentially, a script of all of the proposed testimony at trial accompanied by detailed expositions of the Government's case-in-chief. (Def. Mot. 2 at 4- 5). But the Government has provided the defense with marked exhibits and comprehensive Jencks Act materials of the single witness subject to this motion (approximately 400 pages) "unusually early" (Endorsed Letter at 3, Dkt. No. 353), along with a letter specifically highlighting the proffered evidence at trial. That is all that is required, and the defendant cannot leverage the notice requirements of Rule 404(b) to preclude this evidence at trial. Indeed, the "Second Circuit generally disfavors the exclusion of otherwise relevant evidence on technical grounds." Hart v. BHH, LLC, No. 15 Civ. 4804 (WHP), 2019 WL 1494027, at \*3 (S.D.N.Y. Apr. 4, 2019) (citing Rodriguez v. Vill. Green Realty, Inc., 788 F.3d 31, 47 (2d Cir. 2015)). Accordingly, the only judge in this District to consider a similar situation concluded that the Government's Rule 404(b) notice was sufficient in combination with the Government's motion papers. See United States v. Chandler, No. 19 Cr. 867 (PKC), 2021 WL 1851996, at \*2 n.2 (S.D.N.Y. May 10, 2021). + +The defense vaguely asserts that it cannot perform an independent investigation into the Rule 404(b) evidence due to the inadequacy of the Government's notice. (Def. Mot. 2 at 5-6). That conclusory assertion cannot support a motion to preclude the jury from hearing evidence of the defendant's guilt. The defense has not identified any specific way that they have been hampered + +in their ability to investigate or move in limine. The Government's Rule 404(3) notice—and this brief—have been provided far in advance of trial. In many cases, the Government gives Rule 404(b) notice two weeks before trial, and here the Government's notice concerns a small number of exhibits and only one witness. See, e.g., United States v. Tranquillo, 606 F. Supp. 2d 370, 383 (S.D.N.Y. 2009) ("The Government has indicated that it will make the required disclosure two weeks prior to trial, a practice that typically comports with Rule 404(b)."); United States v. Fennell, 496 F. Supp. 2d 279, 284 (S.D.N.Y. 2007) ("The government has in good faith noted its obligations under Rule 404(b), and indicated that it intends to provide notice of the 404(b) evidence it intends to introduce two weeks before the beginning of trial. There is therefore no need to issue the order Defendant seeks."). The Government has identified the specific evidence it will seek to admit not just the types of evidence—and has explained the connection between that evidence and nonpropensity purposes for which it will be offered. That is all Rule 404(b) requires. + +### III. The Testimony of Minor Victim-3 is Admissible + +The defendant has moved to exclude evidence related to Minor Victim-3. This is nothing more than an attempt to seek reconsideration of the Court's pretrial order denying the defense's motion to strike Minor Victim-3 from the Indictment. Evidence of the defendant and Jeffrey Epstein's abuse of Minor Victim-3 is direct evidence of the offense charged in the Indictment, including the overt acts in the Indictment that pertain to Minor Victim-3. And in any event, her testimony would easily satisfy the requirements of Rule 404(b). + +### A. Background + +Both the first and second superseding indictments described the defendant and Epstein's sexual abuse of Minor Victim-3. As set forth in the Indictment, the defendant "groomed and + +befriended Minor Victim-3 in London, England between approximately 1994 and 1995, including during a period of time in which [the defendant] knew that Minor Victim-3 was under the age of 18." (Indictment ¶ 9(c)). The defendant "introduced Minor Victim-3 to Epstein and arranged for multiple interactions between Minor Victim-3 and Epstein," during which the defendant "encouraged Minor Victim-3 to massage Epstein, knowing that Epstein would engage in sex acts with Minor Victim-3 during those massages." (Id.) Minor Victim-3 provided those massages, during which Epstein sexually abused Minor Victim-3. (Id.) Two overt acts in those Indictments concerned the defendant and Epstein's sexual abuse of Minor Victim-3 in London. (Id. ¶¶ 13(d), 19(d)). + +The defendant moved to strike the portions of the S 1 Indictment involving Minor Victim-3, arguing that the events involving Minor Victim-3 were unrelated to the conspiracies charged in Count One and Count Three. (See generally Mem. of Law, Dkt. No. 146). In response, the Government explained that the defendant and Epstein's "interactions with Minor Victim-3 were part of a broader scheme and agreement to entice and transport minor victims with the intent to commit illegal sex acts," and in any event, admissible under Rule 404(b) as evidence of the defendant's knowledge, intent, and modus operandi. (Gov't Opp. at 157-169, Dkt. No. 204). The Government expects Minor Victim-3 to testify, in substance and in part, that she met the defendant when she was The defendant befriended Minor Victim-3 by, among other things, discussing Minor Victim-3's life and family with Minor Victim-3. + +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] + +The Court denied the defendant’s prior motion to strike portions of the Indictment related to Minor Victim-3 (Op. & Order at 33, Dkt. No. 207), explaining that it was premature to strike any language from the Indictment, because Minor Victim-3’s allegations “may reflect conduct + +undertaken in furtherance of the charged conspiracy or be relevant to prove facts such as Maxwell's state of mind." (id. at 26-27). + +### B. Applicable Law + +It is axiomatic that the Government may offer proof of acts included within the indictment. Those are the very acts the Government seeks to prove at trial. See United States v. Dugue, 763 F. App'x 93, 94 (2d Cir. 2019) (summary order) ("[A]n act that is alleged to have been done in furtherance of the alleged conspiracy is not an `other' act within the meaning of Rule 404(b); rather, it is part of the very act charged." (alterations and citation omitted)); Quinones, 511 F.3d at 308 ("While Rule 404(b) identifies various rationales ... for which evidence of bad acts other than those charged in the indictment may be admitted at trial, the rule has no bearing on the admissibility of acts that are part of the charged crime." (emphasis in original) (footnote omitted)). + +As discussed above, see supra Section II, direct evidence is "not confined to that which directly establishes an element of the crime." Gonzalez, 110 F.3d at 942, see id. at 942 (rejecting a claim that the evidence fell under Rule 404(6)). It also includes actions or statements that (a) "arose out of the same transaction or series of transactions as the charged offense," (b) are "inextricably intertwined with the evidence regarding the charged offense," or (c) are "necessary to complete the story of the crime on trial." Carboni, 204 F.3d at 44. + +In addition, in a conspiracy case, "the Government need not set out with precision each and every act in furtherance of the conspiracy." United States v. LaSpina, 299 F.3d 165, 182 (2d Cir. 2002) (citation, alterations, and internal quotation marks omitted). Instead, "where the Government must prove a conspiracy existed, evidence of acts committed in furtherance of the conspiracy is ... direct evidence of the acts charged in the Indictment." United States v. Townsend, + +No. Si 06 Cr. 34 (JFK), 2007 WL 1288597, at ■1 **(S.D.N.Y. May I, 2007) (citing United States v.** + +**Concepcion, 983 F.2d 369, 392 (2d Cir. 1992)); United States v. Van Putten, No. 04 Cr. 803 (PKL),** + +**2005 WL 612723, at •3 (S.D.N.Y. Mar. 15, 2005) (similar).** + +**As also discussed in Section II, supra, evidence of "other acts" is admissible under Rule 404(b) if it is (1) advanced for a proper purpose, such as to prove "motive, opportunity, intent, preparation, plan, knowledge, identity, absence of mistake, or lack of accident"; (2) relevant to the crimes for which the defendant is on trial; and (3) has probative value which is not substantially outweighed by any unfair prejudicial effect. See Zackson, 12 F.3d at 1182. If requested, such evidence must be admitted with limiting instructions to the jury. See United States v. Edwards, 342 F.3d 168, 176 (2d Cir. 2003). The Second Circuit "ha[s] adopted an inclusionary approach to evaluating Rule 404(b) evidence, which allows evidence to be received at trial for any purpose other than to attempt to demonstrate the defendant's criminal propensity." Id. (internal quotation marks and citations omitted).** + +# **C. Discussion** + +**Minor Victim-3's testimony is direct evidence of the charged criminal conduct specifically, the conspiracies in Counts One and Three of the Indictment.** + +**The Government expects that Minor Victim-3's testimony, which concerns a period of time overlapping with or in close proximity to other Minor Victims' experiences with the defendant and Epstein and concerns teenagers of similar ages, will significantly overlap with the testimony of those other Minor Victims. Put simply, Minor Victim-3's account is** + +corroborative of the accounts of the other Minor Victims. It is also direct evidence of the operation of the conspiracy that is probative of the defendant's intent at the time of the offense. See Op. & Order at 10, Dkt. No. 106 ("[I]t is anticipated that the three witnesses will provide detailed and corroborating accounts of the Defendant's alleged role in enticing minors to engage in sex acts."); see also United States v. Curley, 639 F.3d 50, 59 (2d Cir. 2011) (explaining in an interstate stalking case that evidence of earlier abuse that was "similar in nature and severity" demonstrated a "pattern of activity that was probative of [the defendant's] intent"). + +Minor Victim-3's testimony is also direct evidence of the offense because it concerns acts taken by the defendant in furtherance of the conspiracies. In particular + +Indeed, at a minimum, the defense motion should be denied because the Government's proffered evidence relating to Minor Victim-3 is admissible to prove the overt acts involving Minor Victim-3 contained in the Indictment. (Indictment ¶¶ 13(d), 19(d)). Evidence proving overt acts in the Indictment is direct evidence of the offense, and not other-acts evidence. See United States v. James, 520 F. App'x 41, 45 (2d Cir. 2013) (summary order) ("James's possession of five pounds of marijuana on December 22, 2005, and December 2, 2010, were charged as overt acts in the indictment. Accordingly, evidence of James's possession of marijuana on these occasions was not subject to the structures of Rule 404(6)."). The Court previously denied the defense's motion to strike the overt acts involving Minor Victim-3 as surplusage, explaining that it "may reflect conduct undertaken in furtherance of the charged conspiracy or be relevant to prove facts such as Maxwell's state of mind." (Op. & Order at 26-27, Dkt. No. 207 ("Courts in this district generally delay ruling on any motion to strike until after the presentation of the Government's evidence at trial, because that evidence may affect how specific allegations relate to the overall charges.")). Having concluded that it should delay striking these overt acts until after presentation of the Government's evidence, the Court should not now effectively reverse its decision by precluding that very evidence. If the Government's proof at trial does not establish the relevance of Minor Victim-3's testimony, if anything, the proper course is for the defense to move to strike the relevant overt acts and Minor Victim-3's testimony at that time. + +Even if evidence of Minor Victim-3 were uncharged criminal activity, it would still be necessary to understand the other aspects of the charged conspiracies. Minor Victim-3 experienced the pattern of abuse in close temporal proximity to the other Minor Victims: the conduct involving Minor Victim-1 spans 1994 to 1997, the conduct involving Minor Victim-3 spans 1994 to 1995, and the conduct involving Minor Victim-2 occurred in 1996. The defendant's acts toward Minor Victim-3 show (1) the defendant's relationship with Epstein, including her willingness to procure teenagers to give Epstein massages, (2) the defendant's knowledge of both the sexual nature of those massages and the need to procure additional victims, and (3) her willingness to transport minors to further their abuse. This evidence is therefore direct proof of the defendant's state of mind and agreement to participate in a conspiracy with Epstein. Moreover, her relationship with Minor Victim-3 was "part of [her] continued effort" to commit the offenses charged in Counts One and Three. Carboni, 204 F.3d at 44; see United States v. Romero-Padilla, 583 F.3d 126, 130 (2d Cir. 2009) ("We reject Romero-Padilla's contention that evidence of his + +previous plans with Ferro to import narcotics . . . was evidence of `other crimes' . . . . [I]t corroborated the charge that Ferro and Romero-Padilla were partners during the charged conspiracy and established that Romero-Padilla's participation in the charged conspiracy was at least in part motivated by his desire to acquire [certain] funds ...")." + +Minor Victim-3's testimony is also necessary to complete the story of the offense conduct in light of expected defenses at trial. To the extent that the defense argues, for instance, that the defendant played no role in obtaining girls to massage Epstein or was unaware that Epstein's + +II The cases the defendant cites (Def. Mot. 4 at 8-9) conclude that the admission of evidence about distinct criminal incidents are not direct evidence of the conspiracy. See United States v. Cummings, 60 F. Supp. 3d 434, 438 (S.D.N.Y. 2014), vacated on other grounds, 858 F.3d 763 (2d Cir. 2017) (evidence of prior narcotics arrest and firearms conviction in narcotics and firearms case "could be . . . connected to the charged conspiracy, but the Government has not provided enough detail"); Townsend, 2007 WL 1288597, at \*2 (stating that the Government did not show that uncharged firearm and drug transactions involving the same confidential informant outside the time period of the charged conspiracy, described "rather generically" as a sale of firearms and "narcotics transactions," are "part and parcel of the charged conduct or sufficiently similar to them); United States v. Mahe, 477 F. Supp. 2d 560, 566 (E.D.N.Y. 2007) (stating that, although the facts between two fraud schemes were "quite similar," the other acts were "a separate, discrete offense that may be conceptually segregated from the charged offenses without impairing the jury's ability to understand the facts underlying the schemes alleged in the indictment"), vacated in part on other grounds 285 F. App'x 797 (2d Cir. 2008); United States v. Nektalov, 325 F. Supp. 2d 367, 370 (S.D.N.Y. 2004) ("[T]he transactions took place as early as three years prior to the charged conspiracy and appear to involve a series of distinct cash for gold transactions . . . ."). That is not the case here, where the abuse of Minor Victim-3 occurred during the charged conspiracy period, overlaps temporally with the testimony of other Minor Victims, whose admissibility the defendant does not contest, and is direct proof of the operation of the conspiracy. But in any event, in each case, the Court admitted at least some evidence under Rule 404(b). See Cummings, 60 F. Supp. 3d at 438 (evidence admissible under Rule 404(b)); Townsend, 2007 WL 1288597, at \*5-6 (some evidence admissible under Rule 404(b), some evidence "far too vague" for the Court to resolve, evidence of later marijuana possession irrelevant); Mahe, 477 F. Supp. 2d at 566 (evidence admissible under Rule 404(b)); Nektalov, 325 F. Supp. 2d at 372 (evidence admissible under Rule 404(b)). + +massages were sexualized, evidence that she did so in the case of Minor Victim-3—at roughly the same time as Epstein was abusing Minor Victim-1 and Minor Victim-2—is "necessary to complete the story of the crime on trial." United States v. Robinson, 702 F.3d 22, 37 (2d Cir. 2012) ("Robinson argued at trial that Jane Doe was his `girlfriend' and that he had no control over her prostitution activities. Evidence that Robinson was in the prostitution business and controlled prostitutes other than Jane Doe was therefore `necessary to complete the story of the crime on + +The defense focuses on allegations involving Minor Victim-3 in isolation. In its attempt to confuse the issues, the defense argues that the defendant's conduct with Minor Victim-3 was lawful in the United Kingdom, and that Minor Victim-3 was an adult when she ultimately traveled to the United States and was abused by Epstein. The defense states that "[a]s to [Minor Victim-3], the completed endeavor—i.e., her alleged sex acts with Epstein—was not a substantive criminal offense." (Def. Mot. 4 at 8 (emphasis in original)). The defense then claims—without any basis that the allegations relating to Minor Victim-3 in the Indictment are "of no consequence," because "the government evidently charged the conduct under the mistaken belief that [Minor Victim-3] was a minor when she engaged in sex acts with Epstein." (Id. at 9-10). According to the defense, the government "did not know that [Minor Victim-3] was above the [age] of consent in the U.K. The government presented [Minor Victim-3]'s allegations to the grand jury incorrectly assuming that she was a minor and that the alleged sex acts between Epstein and [Minor Victim-3] were illegal." (Id. at 1-2). + +Not so. The defendant's argument entirely misunderstands the charges in the Indictment and the jury's task at trial. The defendant is charged with conspiring to transport and entice minors for the purpose of sexual abuse. The question at trial will be whether the defendant took steps to provide Jeffrey Epstein with access to girls under the age of 18, knowing that Epstein intended to have sexual contact with those girls. The defendant's acts involving Minor Victim-3 were part of that scheme and are highly relevant to demonstrating the existence of the conspiracy and the defendant's role in the scheme. That is all that is required for evidence relating to the defendant's exploitation of Minor Victim-3 to be direct evidence of the charged offenses. The defendant is not charged with an offense under United Kingdom law, and the age of consent in the United Kingdom is irrelevant. The defendant is also not charged with any substantive offenses with respect to Minor Victim-3, and thus it makes no difference whether the defendant could have, attempted to, or did successfully transport Minor Victim-3 in violation of those statutes.'? + +In any event, this evidence is all admissible under Rule 404(b).13 Testimony regarding the defendant's efforts to recruit and encourage Minor Victim-3 to engage in sex acts with Epstein in the context of massages establishes that the defendant knew of Epstein's attraction to minor girls + +12 Indeed, there is no risk at trial that the jury will convict the defendant based on the testimony of Minor Victim-3 alone. As the Government has made clear, the jury may not convict the defendant of the conspiracy offense solely based on Minor Victim-3 due to the statute of limitations. (Gov't Opp. at 157-58, 163, Dkt. No. 204). The jury should be appropriately instructed at the conclusion of the trial. + +13 To the extent this evidence is properly admissible under Rule 404(b) rather than as direct evidence, the Government's detailed memorandum in opposition to the defense pretrial motions, which described theories of 404(b) admissibility (Gov't Opp. at 165-69, Dkt. No. 204), and this memorandum, filed five weeks before trial, is more than sufficient notice for the defense. + +and knew that Epstein used massage to initiate sexual contact with minor girls. Minor Victim-3's testimony shows the defendant's intent, through her acts befriending Minor Victim-3, encouraging Minor Victim-3 to provide Epstein massages, and asking Minor Victim-3 to find other girls. And it shows the defendant's specific modus operandi of the conspiracies in the Indictment. For these and the other reasons described above, Minor Victim-3's testimony easily satisfies Rule 404(b)'s requirements. Evidence of other acts involving the grooming or abuse of minor victims is regularly admitted for similar purposes in cases where charges allege sexual activity with minors. See, e.g., United States v. Vickers, 708 F. App'x 732, 737 (2d Cir. 2017) ("As to the testimony concerning Vickers' grooming' of his victims, we conclude that such evidence was admissible even under Rule 404(b), because it was probative of Vickers' knowledge of how to secure adolescent boys' trust so that he could sexually abuse them. We identify no abuse of discretion in the district court's decision to admit all of the challenged testimony [regarding uncharged acts of sexual abuse] under Rule 403."); United States v. McDarrah, 351 F. App'x 558, 563 (2d Cir. 2009) (affirming admission pursuant to Rule 404(b) of defendant's "e-mail responses to the Craigslist advertisements" for erotic services because the e-mails "were relevant to his knowledge and intent, because he wrote those emails to girls he knew could be minors (he enthusiastically indicated that girls younger than 18 are acceptable) and his e-mails showed his interest in actual sexual conduct"); United States v. Brand, No. 04 Cr. 194 (PICL), 2005 WL 77055, at \*5 (S.D.N.Y. Jan. 12, 2005) (admitting "evidence that Brand exhibited an interest in child erotica and child pornography on the intemet in the period leading up to the charged conduct" under Rule 404(b) because evidence was "pertinent to whether he used the Internet in an attempt to engage in sexual conduct with" putative victim). + +The defense argues that this testimony will be unfairly prejudicial to the defendant. See Fed. R. Evid. 403. According to the defense, if Minor Victim-3 testifies that she had sex with a "much older man when she was 17 years old" or that she was sexually abused, the jury will assume that Epstein engaged in illegal conduct, which will somehow prejudice the defendant. (Def. Mot. 4 at 13). The Court should not assume that the jury will speculate about principles of United Kingdom law and apply them to this case. The Court will properly instruct the jury on the elements of the offenses charged in the Indictment and the evidence that the jury can—and cannot consider. Those instructions will not ask the jury to consider or pass upon any aspect of United Kingdom law, which will not be in evidence at trial. And in any event, as discussed in the Government's opposition to the defendant's pretrial motion to strike references to Minor Victim-3 in the Indictment, evidence regarding Minor Victim-3's experiences with the defendant and Epstein are no more inflammatory or upsetting than those of Minor Victim-1 and Minor Victim-2. The risk of unfair prejudice is therefore minimal. + +In the alternative, the defense seeks three rulings: (1) precluding the Government from referring to Minor Victim-3 as a "minor," (2) precluding the Government and Minor Victim-3 from representing that she was "sexually abused" by Epstein, and (3) giving a limiting instruction about United Kingdom law. The defense's requested rulings are not grounded in law or reason. + +First, the defense claims that Minor Victim-3 should not be referred to as a "minor" because she was above the age of consent in the relevant jurisdictions at the times she had sexual contact with Epstein. When Minor Victim-3 began having sexual contact with Epstein, she was The issue at trial will be the defendant's knowledge of Epstein's preference for girls under the age of 18. Under federal law, there is a term for individuals under the age of 18: minors. There is nothing inappropriate about using that term at trial. + +Similarly, the phrase "sexual abuse" is accurate, and the Government should be permitted to use it. Minor Victim-3 is expected to testify about her experiences with the defendant and Epstein, including that she was sexually abused by Epstein numerous times. Regardless of whether she uses the term "sexual abuse," her testimony will capture her experience—that she was exploited sexually. And it is fair for the Government to argue that those acts were sexual abuse. The defense argues that the phrase "sexual abuse" is misleading because it suggests to the jury that Epstein engaged in "criminal sexual activity" with Minor Victim-3. (Def. Mot. 4 at 14-15). To justify that proposition, the defense cites a single Supreme Court case in which (1) the parties were engaged in the task of statutory interpretation, not argument in a jury address or description of a victim's lived experience, and (2) the Court rejected that proposed definition of "sexual abuse of a minor" as "flatly inconsistent with the definition of sexual abuse contained in th[at] very dictionary." Esquivel-Quintana v. Sessions, 137 S. Ct. 1562, 1569 (2017). Again, the Government is confident that the Court will properly instruct the jury regarding the elements of the crimes in the Indictment. + +Finally, there is no basis for an instruction about United Kingdom law. The defense has demonstrated no unfair prejudice that might warrant a limiting instruction, and the defense's proposed instructions would only confuse the jury. The jury will be instructed to consider only + +the elements of the crimes the Court provides them, so any assumptions the jury might make about United Kingdom law are irrelevant.14 See United States v. Vasquez, 82 F.3d 574, 577 (2d Cir. 1996) (appropriate to reject defense request for an instruction if it does not "represent[] a theory of the defense with a basis in the record that would lead to acquittal"). And the proposed jury instruction that the sexual activity involving Minor Victim-3 "cannot be considered `illegal' or 'criminal' or `unlawful' for purposes of the crimes charged in the indictment" (Def. Mot. 4 at 15), is wrong on the law. The sexual activity involving Minor Victim-3 can be considered criminal for purposes of the crimes charged in the Indictment, because it is probative proof of the defendant's guilt of those crimes. The instruction the defense proposes, in contrast, creates serious risk that the jury will think the Court is telling them that the conduct is lawful and therefore irrelevant to the case. It is not irrelevant: it is direct evidence of the crimes charged, and it should be put before the jury. + +# IV. There is No Basis to Preclude Co-Conspirator Statements at Trial + +On October 11, the Government provided the defense with comprehensive Jencks Act material for trial witnesses and its exhibits, along with a letter telling the defense, consistent with the Court's order, the identities of the individuals the Government intends to argue are coconspirators at trial. The defense nonetheless asks the Court to enter an order precluding the Government from introducing any co-conspirator statements under Federal Rule of Evidence + +14 In the event the Court instructs the jury on the age of consent in the United Kingdom, the Government requests that the Court also instruct the jury that the United Kingdom's age of consent is irrelevant and they should not consider it. + +802(d)(2)(E) because it claims the Government failed to comply with the Court's September 3, 2021 Order. (Def. Mot. 1 at 1). The defense misreads this Court's September 3, 2021 Order to require the Government to do something unprecedented: identify and itemize for the defense each and every co-conspirator statement it plans to use at trial, seven weeks in advance of trial. Then, complaining that the Government has not complied with the defense's peculiar reading, the defense seeks an extraordinary remedy: precluding the Government from offering any coconspirator statements at trial. Each step of this analysis is erroneous, and the Court should deny the motion. + +### A. Background + +The defendant first sought to compel the Government to identify the co-conspirator statements it plans to use at trial in its initial round of pretrial motions. There, the defendant argued that the Second Circuit's practice of conditional admission of co-conspirator statements at trial would prejudice her because "any cautionary instruction would be of doubtful utility." (Mem. of Law at 13, Dkt. No. 148). She therefore asked the Court to order a "proffer from the government or conduct a pretrial hearing to determine if the statements are admissible." (Id. at 13-14). + +In response, the Government observed that the practice of conditional admission of coconspirator statements is the law of the Circuit, notwithstanding the defense's preference to the contrary. (Gov't Opp. at 192, Dkt. No. 204). The Government also explained that "the Second Circuit has rejected the suggestion that non-exculpatory co-conspirator statements are discoverable under Rule 16 or by any means other than the Jencks Act." (Id.). See In re U.S., 834 F.2d 283, 284-87 (2d Cir. 1987) (issuing a writ of mandamus reversing District Court's order directing the Government to "produce all oral statements made by the defendants and coconspirators that the Government planned to offer at trial as admissions of a defendant" under Fed. R. Evid. 801). Accordingly, the Government argued that "the defense will receive notice of any co-conspirator statements that the Government may seek to introduce through witness statements" in its Jencks Act production. (Gov't Opp. at 192, Dkt. No. 204). + +The Court denied the motion, explaining that the Court lacked the power to order pretrial disclosure of non-exculpatory co-conspirator statements. (Op. & Order at 30, Dkt. No. 207). The Court also explained that the "[c]o-conspirator statements may often be admitted at trial on a conditional basis," and to the extent that "can pose a problem, a pretrial hearing is unnecessary here because the Government has committed to producing co-conspirator statements at least six weeks in advance of trial to allow Maxwell to raise any objections." (Id. at 30-31). + +The defendant's second bite at the apple came in the parties' joint scheduling letter. (Letter, Dkt. No. 291). There, the defense requested that the Government "identify any co-conspirator's names and statements (whether via witness testimony or documentary evidence) at the same time as it discloses []3500 material," so it could "litigate their admissibility before trial." (Id. at 11-12). The Government responded that it is "entirely appropriate for defense counsel to receive notice of any co-conspirator statements through Jencks Act materials and marked exhibits," because any coconspirator statements will be contained therein. (Id. at 5). The Government also noted that the defendant cited no cases "directing separate notice of coconspirator statements that the Government may introduce at trial." (Id.) + +On June 2, 2021, the Court adopted the "Government's proposal" and set a deadline of October 11, 2021, for the "disclosure of Jencks Act and Giglio material, Rule 404(b) evidence and + +notice, co-conspirator statements, and Government witness list," as well as the "Defendant's proposal" that the Government disclose its proposed exhibit list that same day. (Order at 1, Dkt. No. 297). This order did not expressly require the Government to specifically identify coconspirator statements within its other productions. + +In the defendant's second round of pretrial motions, she asked the Court to order the Government to disclose a series of information about the Indictment. That list contained a renewed request for the Government to identify uncharged co-conspirators, but it did not contain a new request for the Government to separately identify co-conspirator statements within its discovery production. (Mem. of Law at 23-24, Dkt. No. 293). On August 13, 2021, the Court denied the defense's motion, but in a footnote, explained that it "presume[d] the Government intends to disclose" the "identi[ties of] the unnamed co-conspirators who allegedly participated in the conspiracies charged in the S2 Indictment," since the Government had not previously opposed that request. (Op. & Order, Dkt. No. 317 at 12 n.1). The order said nothing about identifying coconspirator's statements. (Id.). + +The Government filed a letter opposing the request for the Government to "identify [the defendant]'s unnamed co-conspirators." (Letter at 1, Dkt. No. 320). The defendant filed a new letter in response, raising "two issues." (Letter at 1, Dkt. No. 331). First, the defendant sought the identities of co-conspirators. (Id. at 1-2). Second, the defendant took a third bite at the apple, once again seeking "disclosure of the purported co-conspirator statements [the Government] intends to offer at trial." (Id. at 3). The defendant also argued that the Court's scheduling order had already required the Government to specifically identify co-conspirator statements. (Id. at 3-4). + +On September 3, 2021, the Court ordered the Government to "disclose to the Defendant the identities of all unnamed co-conspirators alleged in the S2 indictment to whom it will refer at trial." (Order at 1, Dkt. No. 335). The Court further ordered the Government to "disclose all coconspirator statements it intends to offer at trial no later than October II, as consistent with this Court's scheduling order." (Id. at 2). + +Accordingly, on October 11, 2021, the Government produced its exhibit list and Jencks Act material to the defendant. The Jencks Act materials and exhibits contained the only coconspirator statements in the Government's possession that will be offered at trial. It also disclosed the identities of the individuals to whom it may refer at trial as co-conspirators and informed the defendant that it "has produced all co-conspirator statements which it intends to offer at trial . . . in the Government's production [that day] or in its previous productions." (Def. Mot. 1 Ex. 1 at I). The Government further noted that "[t]o the extent the Government learns of additional coconspirator statements as it continues to prepare for trial, it will produce those statements in connection with its ongoing obligation to produce Jencks Act material." (Id.). + +# B. Discussion + +The Government has complied with its pre-trial disclosure obligations, consistent with the Court's orders and on a schedule with deadlines well in advance of trial. As of October 11, the Government produced all co-conspirator statements in its possession that it intends to offer at trial. To the extent that the Government learns of additional co-conspirator statements as it prepares for trial—such as in a session preparing a witness for trial—it will produce those statements as part of its ongoing Jencks Act obligations. + +The defense ens when it suggests that the Court ordered the Government to specifically itemize any co-conspirator statements contained in its disclosures. When the Court first set a disclosure schedule for Jencks Act material, it adopted the "Government's proposal," which opposed any requirement that the Government isolate co-conspirator statements from other witness statements. (Order at 1, Dkt. No. 297). When the Court ordered the Government to produce the identities of co-conspirators, it again ordered the Government to "disclose" all co-conspirator statements, citing the Court's earlier order. (Order at 2, Dkt. No. 335). Neither order expressly directed the Government to produce a set of co-conspirator statements it would offer at trial separately from the other evidence it would offer at trial. + +A requirement to "disclose statements" is not a requirement to isolate statements. For one, the Court denied the defense request for effectively that relief in the first round of pretrial motions. (Op. & Order at 30-31, Dkt. No. 207). For another, in the defense's many rounds of briefing on this issue, it has cited no case—not from this District, nor any other—in which a Court ordered the Government to segregate and itemize co-conspirator statements from other statements for the convenience of the defense. The Government is aware of no such case—likely because such an order would be in considerable tension with Circuit precedent, see In re U.S., 834 F.2d at 286. For a third, the guiding principle of the defense's justification for its request is to facilitate litigation of those statements' admissibility pre-trial. But the law of the Second Circuit is that such statements can be conditionally admitted during the trial, and their admissibility litigated thereafter. See, e.g., United States v. Ferguson, 676 F.3d 260, 273 n.8 (2d Cir. 2011) (citing United States v. Geaney, 417 F.2d 1116, 1120 (2d Cir. 1969)); Op. & Order at 30, Dkt. No. 207. As much + +as the defense might like the Government to create such an index, that is simply not how the litigation of co-conspirator statements is handled. And it is not what the Court's order, requiring "disclos[ur]e" of co-conspirator statements, required. + +The Government's obligation is to make disclosures. The Government is not obligated to serve as members of the defense team, reviewing Jencks Act materials for the defense and itemizing and indexing disclosures for them. The Government is no more obligated to itemize Jencks Act materials containing co-conspirator statements than it is obligated to exhaustively detail for the defense the basis for offering any other type of witness statement contained in the Jencks Act material it has produced. Such an obligation would extremely burdensome and is both without precedent and entirely unnecessary. The defense team has ample resources to review the Government's disclosures and file any motions they wish to make regarding the admission of certain testimony. And there is ample time before trial for the defense to do so, and no basis in the record to believe the defense will be unable to raise these issues and seek a ruling before trial. + +The defense argues that the Court did order the Government to itemize co-conspirator statements contained in its Jencks Act production. In support, however, the defense cites to orders relating to the disclosure of the identities of co-conspirators. (Compare Def. Mot. 1 at 2 (citing Dkt. No. 317 at 12 n.1) and Def. Mot. 1 at 3 (citing Dkt. No. 335 at 3) (stating that the Court rejected the defendant's arguments "because of `the need for the parties to litigate co-conspirator issues in advance of trial" (emphasis in Def. Mot. I)), with Op. & Order at 12 n.1, Dkt. No. 317 ("Additionally, Maxwell includes in her motion for a bill of particulars a request to require the government to identify the unnamed co-conspirators who allegedly participated in the conspiracies charged in the S2 indictment."), and Order at 3, Dkt. No. 335 (following the above sentence with "In light of the interests discussed above .. . the Court will require the Government to disclose the identities of any unnamed co-conspirators . . . ."). + +The defense also argues that failure to provide an index of co-conspirator statements permits "the presentation of false testimony" and is "an invitation to manufacture evidence," because a witness will offer a co-conspirator statement for the first time. (Def. Mot. 1 at 4). This argument is nonsensical and offensive. It is deeply unfortunate that defense counsel would so casually resort to baseless allegations that the Government would manufacture evidence and present false testimony at trial. And in any event, the Government produced to the defense Jencks Act material containing co-conspirator statements in its possession on October 11 and will continue to make Jencks Act productions as it prepares for trial. To the extent the defense is concerned that a witness will say something on the stand for the first time, the Government cannot disclose that in advance because no lawyer can know a witness's verbatim answer in advance. But were that to occur, the defense would be well positioned to cross-examine the witness.15 + +15 The defendant's motion also makes the puzzling argument that co-conspirator statements are problematic in this case because the defense is limited in its ability to call co-conspirators to testify as defense witnesses. (De£ Mot. 1 at 4). That is true in essentially every criminal case, as the Court has previously noted. (See Op. & Order at 17-18, Dkt. No. 207 ("There are also serious doubts under all of the relevant circumstances that a jury would have found testimony from Epstein credible even if he had waived his right against self-incrimination and testified on her behalf.")). In any event, to the extent the defense takes issue with the rule that co-conspirator statements can be admitted without requiring the declarant to testify, that complaint is properly directed to the drafters of the Federal Rules of Evidence. + +Even if the Government has misread the Court's order, the defense's claims of prejudice are exaggerated. Although the defense complains that the Government seized "multiple electronic devices" containing "hundreds of thousands of statements spanning decades" (Def. Mot. 1 at 3), any statements contained in emails or other documents that the Government plans to use at trial have been marked as Government exhibits and produced to the defense. The defense need look no further than the Government's exhibit list to discover what documents will be offered at trial. Similarly, although the defense complains of "document dumps" (id. at 2) and the need to review "thousands of pages of newly provided discovery material" (id. at 7), any witness testimony containing co-conspirator statements is contained in the Government's Jencks Act production and specifically, the Government's production of material for testifying witnesses. Although the Government produced as a courtesy prior statements of non-testifying witnesses, by definition the Government does not plan to call those individuals at trial. And the Government has informed the defense of the limited number of co-conspirators to whom it may refer at trial, so the defense knows exactly which declarants' statements are possibly subject to the co-conspirator exception. See Fed. R. Evid. 801(d)(2)(E).16 + +Finally, and in any event, suppression is not a proper remedy. The defense relies principally on Taylor v. Illinois, 484 U.S. 400 (1988), in which the Supreme Court upheld an order + +16 To be clear, the defendant's motion concerns the admission of statements under Rule 801(d)(2)(E). The majority of the statements made by co-conspirators that will be offered at trial have other bases for admissibility. For example, witnesses will testify regarding promises, offers, instructions, and directions they received from Epstein. Those statements are not factual assertions subject to hearsay rules. Rather, they are offered for the effect on the listener, among other reasons. + +excluding the testimony of a defense witness as a sanction for counsel's (i) noncompliance with a discovery rule that required notice of intention to call the witness, and (ii) misleading the court concerning his knowledge of the witness's whereabouts. The Supreme Court found the discovery violation was "both willful and blatant." Id. at 416. Taylor does not support the defense's position. The defense, citing Taylor, accuses the Government of willfully violating the Court's September 3, 2021 Order. (See Def. Mot. 1 at 6-7; see id. at 3 (accusing the Government of "attempting to overstuff an already full sandbag")). The Government did no such thing. The Government has simply read the word "disclose" to mean "disclose," consistent with the uniform practice in this District. The defense's accusations are baseless and offensive. + +The defense has all of the co-conspirator statements the Government plans to use at trial. They have these records "unusually early"—seven weeks before trial. (Endorsed Letter at 3, Dkt. No. 353). The defense also knows the identities of the limited number of co-conspirators to whom the Government may refer at trial, a highly unusual circumstance that makes the defense's task even easier. And they are free to litigate the admissibility of any such statement during trial. The Government has complied with its obligations, and the defense is fully equipped to prepare for trial. The Court should deny the motion. + +### V. There is No Basis to Suppress Minor Victim-4's Identification of the Defendant + +The defendant claims that Minor Victim-4's identification of her was unduly suggestive and should be suppressed. (Def. Mot. 9). That argument finds support in neither fact nor law. Minor Victim-4 knew the defendant personally, and she has consistently described the defendant for decades. The identification was not suggestive, and the motion should be denied. + +# A. Background + +As set forth in Counts Five and Six of the Indictment, Minor Victim-4 was trafficked by the defendant and Jeffrey Epstein from approximately 2001 to 2004. (Indictment ¶¶ 22-27). During that time, Minor Victim-4 personally interacted with the defendant—for instance, the defendant paid Minor Victim-4 following Minor Victim-4's sexual encounters with Epstein. (Id. 25(a)). + +In 2007, Minor Victim-4 was interviewed by the Federal Bureau of Investigation. In that interview, she described meeting "an older lady with short black hair and an unknown accent"—a description that is consistent with the defendant's appearance—at her first meeting with Epstein. In\_ Minor Victim-4 was deposed, during which she explained that she sometimes called the house to get work, and she would talk to an employee or "Maxwell." Later in the deposition, she added that the same employee or "Maxwell" would contact her when Epstein wanted her to come. + +This Office first interviewed Minor Victim-4 in July 2020. During that meeting, Minor Victim-4 spoke about her many interactions with the defendant. She did so again at the Government's meetings with her in August 2020, and at multiple meetings in January 2021. + +The Government met Minor Victim-4 again in June 2021 for several meetings. During one of those meetings, the Government showed Minor Victim-4 a photo book containing 20 photos. The Government asked Minor Victim-4 to review each photograph in the book and to indicate whether she recognized anyone in the book. The Government explained that just because someone is in the book, it does not mean that Minor Victim-4 knowns that person or that the person is in trouble. The Government instructed Minor Victim-4 just to let the Government know if she recognized anyone. + +Minor Victim-4 identified photots possibly depicting the defendant, but indicated that she was not sure. When she reached photo'. Minor Victim-4 said it depicted the defendant. After completing her review of the book, Minor Victim-4 returned to compare photosil and she confirmed that she believed photalwas a photo of the defendant, and she was not sure whether she knew the person in photon-- + +### B. Applicable Law + +As a general matter, the Constitution "protects a defendant against a conviction based on evidence of questionable reliability, not by prohibiting introduction of the evidence, but by affording the defendant means to persuade the jury that the evidence should be discounted as unworthy of credit." Perry v. New Hampshire, 565 U.S. 228, 237 (2012). Eyewitness identifications should therefore be excluded only where "improper police conduct" occurred that was "so unnecessarily suggestive as to give rise to a very substantial likelihood of irreparable misidentification." Id. at 238-39; see Manson v. Brat Waite, 432 U.S. 98,112-14 (1977); Simmons v. United States, 390 U.S. 377, 384 (1968). + +Federal courts follow a two-step analysis in ruling on the admissibility of identification evidence. Perry, 565 U.S. at 238-40; Brisco v. Ercole, 565 F.3d 80, 88 (2d Cir. 2009). First, the defendant must show that the identification was "so unnecessarily suggestive and conducive to irreparable mistaken identification that [the defendant] was denied due process of law." United States v. DiTommaso, 817 F.2d 201, 213 (2d Cir. 1987) (citation and internal quotation marks omitted); see Raheem v. Kelly, 257 F.3d 122, 134 (2d Cir. 2001). This is a high threshold to meet, as the defendant must show that, under the totality of the circumstances, there is "a very substantial + +likelihood of irreparable misidentification." United States v. Maldonado-Rivera, 922 F.2d 934, 973 (2d Cir. 1990). If the defendant cannot make such a showing, "the trial identification testimony is generally admissible without further inquiry into the reliability of the pretrial identification. In that circumstance, any question as to the reliability of the witness's identifications goes to the weight of the evidence, not its admissibility." Id. + +Second, an unduly suggestive identification procedure does not alone require suppression of the identification evidence. See Brathwaite, 432 U.S. at 110-14. Instead, the court must then determine whether the identification evidence is nevertheless "independently reliable" based on the totality of the circumstances. Brisco, 565 F.3d at 89; United States v. Simmons, 923 F.2d 934, 950 (2d Cir. 1991) ("[E]ven a suggestive out-of-court identification will be admissible if, when viewed in the totality of the circumstances, it possesses sufficient indicia of reliability."). Among the factors to be considered are: "the opportunity of the witness to view the criminal at the time of the crime, the witness' degree of attention, the accuracy of the witness' prior description of the criminal, the level of certainty demonstrated by the witness at the confrontation, and the length of time between the crime and the confrontation." Neil v. Biggers, 409 U.S. 188, 199-200 (1972). No single factor is dispositive. See Kelly, 257 F.3d at 135. + +#### C. Discussion + +There was nothing unduly suggestive about the identification procedure used here. Accordingly, there is no basis to suppress Minor Victim-4's identification of the defendant, and Minor Victim-4 should be permitted to identify the defendant at trial.17 + +First, the identification procedure was not suggestive because it was merely a "confirmatory identification" of a person Minor Victim-4 had known and identified by name over the years. There is no "improper police conduct" creating a "substantial likelihood of identification" by showing a person in that position even a single photograph, much less a photo array or photo book. See, e.g., United States v. Hardy, No. 10 Cr. 1123 (JSR), 2011 WL 7782582 (S.D.N.Y. Jan. 25, 2011) ("Displaying a confirmatory photograph of a person the witness has indicated that he already knows is perfectly acceptable."); Gilbert v. Sup't of Collins Corr. Fac., No. 03 Civ. 3866 (LBS), 2004 WL 287683, at \*8 (S.D.N.Y. Feb. 11, 2004) (upholding confirmatory identification following street canvass on the grounds that 'police suggestiveness does not require suppression of an identification if the witness was not thereby influenced, as, for example, when the witness's identification was already positive.'" (quoting Jarrett v. Headley, 802 F.2d 34, 41-42 (2d Cir. 1986))); see also, e.g., Franco v. Lee, No. 12 Civ. 1210 (SJF), 2013 WL 704655, at \*10 (E.D.N.Y. Feb. 26, 2013) ("In cases in which the defendant's identity is not in issue, or those in which the protagonists are known to one another, suggestiveness is not a concern + +17 Even if the Minor Victim-4's identification of the defendant were suppressed, that would not preclude Minor Victim-4 from testifying about her abuse and the name and physical description of the person involved. + +and the identification is merely confirmatory." (citation and internal quotation marks omitted)); Stallings v. Wood, No. 04 Civ. 4714 (RLM), 2006 WL 842380, at \*11 (E.D.N.Y. Mar. 27, 2006) (collecting cases). + +Minor Victim-4's personal knowledge of the defendant is well established. The defendant and Minor Victim-4 met in person and interacted multiple times between 2001 and 2004. Minor Victim-4 then mentioned the defendant by description or by name in 2007, 2009, 2020, and 2021, all prior to being shown the photo book. And the circumstances of the identification were not suggestive. Minor Victim-4 was shown 20 photos + +She was not asked to locate the defendant, or asked whether a particular photo depicted the defendant, but just whether she recognized anyone, although she was told that she was not expected to recognize someone just because their photo was in the book. And, indeed, Minor Victim-4 said she did not recognize some photos in the book. Regarding the defendant specifically, Minor Victim-4 carefully considered whether a different photo depicted the person she believed to be the defendant before seeing and selecting a photo of the defendant. This procedure was cautious and not suggestive—much less unduly suggestive. + +The reality is straightforward: Minor Victim-4 knows exactly who the defendant is and confirmed that the person in the photograph was the defendant. In response, the defense argues that the photo "looks like a mug shot" and "is different than the others." (Def. Mot. 9 at 3). Of course, as is often the case with photo arrays or photo books, all of the photos generally resemble mug shots, so there is nothing suggestive about the fact that the defendant's photo does. And it is not in fact different from the others: While the defendant's photo is lower resolution than some, + +there are several similar quality photos in the book. (See Ex. A, photosi ). In any event, these highly conclusory statements fall well short of transforming the careful confirmatory identification used in this case into an unduly suggestive procedure. The motion to suppress should be denied on this basis, and the identification should be admitted at trial, where the defendant will have a full opportunity to contest the persuasiveness of that evidence through cross-examination and attorney argument. See Maldonado-Rivera, 922 F.2d at 973 (where there has been no showing of suggestiveness, "any question as to the reliability of the [identification] goes to the weight of the evidence, not its admissibility"). + +Even if the "confirmatory identification" procedure was impermissibly suggestive as the defendant claims, which it was not, Minor Victim-4's identification had clear independent reliability because Minor Victim-4 stated that she knew the defendant by name from previous interactions. For example, in Wiggins v. Greiner, the Second Circuit declined to address a disputed question about a confirmatory identification's suggestiveness because the independent basis for the in-court identification was so clear. See Wiggins, 132 F. App'x 861, 864-66 (2d Cir. 2005) (witness saw defendant at distance of 50 feet under "streetlight illumination" but was familiar with defendant from seeing him previously in neighborhood); accord United States v. Lumpkin, 192 F.3d 280, 288 (2d Cir. 1999) (officers' in-court identifications reliable where officers had unobstructed views of the defendant selling narcotics on two occasions, one of which was during daylight at close range); United States v. Crumble, No. 18 Cr. 32 (ARR), 2018 WL 1737642, at \*2 (E.D.N.Y. Apr. II, 2018) (collecting cases finding that "in-court identification is [] admissible, despite an improper pre-trial identification procedure, if the witness is familiar with the defendant + +prior to the incident," or alternatively, if "if a witness gets a good look at the defendant during the course of a crime"); United States v. Reed, No. II Cr. 487 (RJS), 2012 WL 2053758, at \*5 (S.D.N.Y. June 6, 2012) (noting that a "witness's familiarity with a suspect may establish that the identification . . . is independently reliable"). + +This is not a crime in which a victim captures a fleeting glance of the perpetrator. Minor Victim-4 interacted with the defendant personally on multiple occasions between 2001 and 2004. She knew the defendant by name and gave a description. In the totality of the circumstances, it is plain that Minor Victim-4's identification of the defendant is sufficiently independently reliable to permit the jury to decide its persuasiveness. + +The defense merely replies, again in conclusory fashion, that Minor Victim-4 (1) never identified the defendant as an abuser, (2) did not have an opportunity to view her during the crime because the defendant was not involved in a crime, (3) never described the defendant, and (4) the time between the abuse and the identification was extraordinarily long. (Def. Mot. 9 at 4). The first three of these points are inaccurate, as set forth above. And the delay in time is untroubling given Minor Victim-4's contacts with the defendant and consistent references in the intervening time. The defense is free to attempt to argue these points to the jury, but none of these arguments supports a motion to suppress Minor Victim-4's identification of the defendant. + +Minor Victim-4 knows who participated in the sexual abuse she experienced, as she has for the decades since it happened. This Court should deny the motion. + +#### VI. The Court Should Deny the Defense Motions to Preclude the Government's Exhibits + +The defense has filed several motions to preclude certain Government exhibits. (Def. Mots. 7, 8, and 13). The Court should deny the defense authentication arguments without prejudice because the Government expects its witnesses will be able to authenticate the exhibits at trial before it offers them. The defendant's arguments regarding relevance and Rule 403, however, are meritless, and the Court should deny them. + +### A. Applicable Law + +In general, "[t]o satisfy the requirement of authenticating or identifying an item of evidence, the proponent must produce evidence sufficient to support a finding that the item is what the proponent claims it is." Fed. R. Evid. 901(a). The Second Circuit has made clear that "the bar for authentication of evidence is not particularly high." United States v. El Gamma!, 831 F. App'x 539, 542 (2d Cir. 2020) (summary order) (quoting United States v. Gagliardi, 506 F.3d 140, 151 (2d Cir. 2007)). Rule 901 is "satisfied if sufficient proof has been introduced so that a reasonable juror could find in favor of authenticity or identification," El Gamma!, 831 F. App'x at 542 (quoting United States v. Tin Yat Chin, 371 F.3d 31, 38 (2d Cir. 2004)), and such "proof of authentication may be direct or circumstantial," United States v. Al-Moayad, 545 F.3d 139, 172 (2d Cir. 2008) (citations and internal quotation marks omitted). + +For instance, in United States v. Al Farekh, 810 F. App'x 21 (2d Cir. 2020) (summary order), the defendant challenged the authenticity of "handwritten letters that were found in a USB drive that was handed to an agent of the Federal Bureau of Investigation in Afghanistan." Id. at 24. The Second Circuit rejected the challenge. "Although the Government did not present + +evidence regarding the circumstances surrounding the seizure of the USB drive, Federal Rule of Evidence 901(b)(4) permits authentication based on `[t]he appearance, contents, substance, internal patterns, or other distinctive characteristics of the item, taken together with all the circumstances.'" Id. (alteration in original) (quoting Fed. R. Evid 901(b)(4)). Witness testimony about the content of the letters was "sufficient to pass the relatively low bar for authentication of evidence," and "any remaining questions as to the reliability of the letters go to their evidentiary weight, not their admissibility." Id. at 24-25. + +Similarly, although physical evidence may be authenticated through a chain of custody, "any flaws in the chain of custody bear only on the weight of the evidence, and not on its admissibility." United States v. Stuckey, No. 06 Cr. 339 (RPP), 2007 WL 2962594, at \*7 (S.D.N.Y. 2007) (citing United States v. Morrison, 153 F.3d 34, 57 (2d Cir. 1998)); see also United States v. Hemmings, 482 F. App'x 640, 643 (2d Cir. 2012) (summary order) (similar). "Evidence should be excluded on a motion in limine only when the evidence is clearly inadmissible on all potential grounds." United States v. Cilins, No. 13 CR. 315 (WHP), 2014 WL 173414, at \*2 (S.D.N.Y. Jan. 15, 2014) (citation and internal quotation marks omitted). + +### B. Discussion + +The defense's challenges to the Government's exhibits largely turn on the Government's ability to authenticate them. Those arguments are premature. At trial, the Government expects that witnesses familiar with the exhibits will testify that the items are what the Government claims they are. The defendant is not entitled to a preview of the Government's case-in-chief at this juncture. + +First, the defendant moves to exclude Government Exhibit 52, which it says was obtained by the Government "as part of discovery in v. Maxwell civil litigation . . . with no explanation about its origin." (Def. Mot. 7 at 1). The defendant misidentifies the exhibit. Government Exhibit 52 is a physical contact book belonging to the defendant. The records attached by the defense as Exhibit 1 appear to be a scan of Government Exhibit 52 that was produced in discovery in v. Maxwell. But the Government will not offer that scan at trial. It will offer the physical book itself, along with scans taken by the Government of the physical book. A witness with personal knowledge of the physical book is expected to testify to its authenticity. + +The defendant takes issue with the history of the Government's acquisition of Government Exhibit 52. The defendant is correct that the Government came into custody of this exhibit after a former employee of Jeffrey Epstein attempted to sell it to a civil lawyer suing Epstein. (Id.). The defense calls this "particularly troubling" (Def. Mot. 7 at 2), but that argument is misplaced. How the Government acquired the exhibit goes, if anything, to its weight and not its admissibility. If a witness can identify the exhibit based on its contents, that is sufficient to pass the relatively low bar for authentication of evidence." See AI Farekh, 810 F. App'x at 24-25. + +Finally, the defendant argues that the contents of Government Exhibit 52 are hearsay because they are not a business record. (Def. Mot. 7 at 4-6). The exhibit is separately admissible not for the truth of the matters asserted therein (such as the accuracy of the contact information for victims), but to establish that the defendant kept contact information for relevant individuals at trial, including victims. The exhibit has evidentiary value in showing that the defendant + +maintained a contact book containing what purports to be this list of names and associated contact information. + +*Second*, the defendant moves to preclude any items seized during the 2005 search of Epstein’s home in Palm Beach, Florida. The defense claims, in a conclusory fashion, that “no witness has sufficient personal knowledge about the proposed exhibits” to demonstrate authenticity, because “the evidence collection and retention in this matter is an unreliable mess.” (Def. Mot. 8 at 3-5). The defense further speculates that the Government intends to offer these exhibits without any testimony about their authenticity, in part because the original custodian—Detective [REDACTED]—is dead. (*Id.* at 4-5). The defense is mistaken. The Government intends to call live witnesses to establish the authenticity of the evidence at trial.18 + +*Third*, the defendant argues that the photographs in Government Exhibit 251 and 288 are irrelevant. (Def. Mot. 13 at 2). [REDACTED] + +[REDACTED] + +--- + +18 As to Government Exhibit 295 specifically, that exhibit was written by both Detective [REDACTED] and another witness who is expected to testify at trial. The exhibit is primarily marked for identification, although portions of that document may be offered as a past recollection recorded by that other witness. See Fed. R. Evid. 803(5). The Government will not offer statements from Detective [REDACTED] + +Fourth, the defendant argues that Government Exhibit 294 is irrelevant. (Def. Mot. 13 at 2-3). Government Exhibit 294 displays a box containing "Twin Torpedos"-sex toys-seized during the search of Epstein's Palm Beach house. This photograph is corroborative of witness testimony, which is expected to describe the presence of sex toys and that the defendant and Epstein used sex toys during their abuse. + +Fifth, the defendant argues that Government Exhibit 313 is irrelevant. (Def. Mot. 13 at 2- 3). Government Exhibit 313 is a photograph of the defendant and Epstein swimming together while nude. This evidence corroborates witness testimony expected at trial, which will describe topless swimming in the pool at Epstein's Palm Beach House. It is also relevant to the relationship between the defendant and Epstein. For instance, to the extent the defense at trial argues that the defendant was merely an employee of Epstein's, this photograph is evidence to the contrary. + +Sixth, the defense argues that Government Exhibit 606 lacks evidentiary foundation, is hearsay, and is irrelevant because it was created after the events alleged in the Indictment. (Def. Mot. 13 at 2-3). Government Exhibit 606 is a manual governing the operations of the Palm Beach house. A witness at trial is expected to authenticate this document and explain that it was the version in effect at the house in 2005. Another witness is expected to testify about the rules in effect in the Palm Beach household during the time period of the charged conduct; those rules are + +consistent with the rules in this exhibit.19 The relevance of the document is self-evident: among other things, it directs employees to "see nothing, hear nothing, say nothing." (GX 606 at 4). It is not prejudicial as to her "lifestyle" (Def. Mot. 13 at 3), because the July will already hear testimony about her and Epstein's various properties, private jet, and employees. And the document is not hearsay, because the statements are being offered as instructions to staff, not for the truth of the matter asserted. + +As described above, each of these exhibits is highly relevant, not hearsay or subject to a hearsay exception, and can be authenticated at trial. The Court should deny the defense's motion regarding relevance and Rule 403, and deny the motion regarding authentication with leave to renew it at trial. + +# VII. There is No Basis to Preclude Discussion of "Victims" or Rape + +Citing no case in the federal system, the defendant moves to preclude any trial participants from referring to the Minor Victims as Victims. The defendant also moves to preclude testimony concerning a rape committed by Jeffrey Epstein against one of the Minor Victims. Both of these motions lack merit, and they should be denied. + +### A. References to Victims + +° Here and elsewhere (see, e.g. Def. Mot. 2 at 3-4), the defense argues that evidence that postdates the time period of the conspiracy is irrelevant. That is incorrect. What matters is whether the evidence tends to make a fact of consequence more or less probable. If, for instance, there is evidence showing that Epstein and the defendant were extremely close partners in 2005, that tends to make it more probable that they had such a relationship in 2004, during the time period of the conspiracy. It is therefore highly relevant. + +The defendant moves to preclude any trial participants from using the word "victim" to refer to any of the Minor Victims. The Government expects that it will use the word "victim," particularly in jury addresses, but such use is not improper vouching or prejudicial to the defense. The Government also expects its expert to use the word "victim," but she will testify about victims generally and not any victims in this case specifically. The Government does not otherwise expect its witnesses to use the word - victim." To the extent they do, however, it is not prejudicial to the defense.2° + +The defendant cites no federal case that has accepted its argument. Nor does this argument make sense. The erroneous premise in the defense argument is that referring to someone as a "victim" "necessarily conveys the speaker's opinion that a crime in fact occurred and that the accusers are credible." (Def. Mot. 12 at 1). That is incorrect. The Government's references to "victims" are part of its theory of the case. Use of that term in a jury address is not an expression of counsel's opinion; it is the Government's litigating position, just like referencing someone as the "shooter" in a shooting case or the "dealer" in a narcotics case. See United States v. Arias-Javier, 392 F. App'x 896, 898 (2d Cir. 2010) (summary order) ("The prosecutor is permitted vigorously to argue for the jury to find its witnesses credible as long as it does not link its own credibility to that of the witness or imply the existence of extraneous proof supporting the witness's + +2°Notably, the defense motion is entirely premised on the notion that the parties disagree about whether the Minor Victims are in fact victims of any crime. If the defense concedes at any point that the Minor Victims are victims of any crime—for example, if the defendant concedes the victims were abused by Epstein but disclaims knowledge or involvement—their argument in support of this motion collapses entirely. (Del Mot. 12 at 1 (contrasting this case with cases in which "there is no dispute that the person was a victim of something")). + +credibility."). Prosecutors are simply using a term that is consistent with the Government's theory of the case. See United States v. Edwards, No. CR 16-103-BLG-SPW-1, 2017 WL 4159365, at \*I (D. Mont. Sept. 19, 2017) (explaining that "use of the term `victim' is not prejudicial to the defendant's rights when the presentation of evidence taken as a whole clarifies the government's burden of proving all of the elements of the crime" and finding that the "jury will not be unduly prejudiced against [the defendant] if the government refers to certain witnesses as victims"); (citing United States v. Washburn, 444 F.3d 1007, 1013 (8th Cir. 2006) ("[A] number of courts have determined that the use of the term "victim" in jury instructions is not prejudicial to a defendant's rights when, as is the case here, the instructions taken as a whole clarify the government's burden of proving all elements of the crime")); Server v. Mizell, 902 F.2d 611, 615 (7th Cir. 1990) ("No logical argument can be made that the mere use of the term `victim' [injury instructions] somehow shifted the burden of proof."). In addition, "[t]he term `victim' is not inherently prejudicial. It is a term commonly used in the English language that does not by its nature connote guilt." United States v. Lussier, No. 18-CR-281 (NEB), 2019 WL 2489906, at \*5 (D. Minn. June 15, 2019).2' And just as the defense may make arguments attacking the credibility of victims, the Government is free to argue that these witnesses are, in fact, victims of a crime. Cl United States v. Thai, 29 F.3d 785, 807 (2d Cir. 1994) (explaining that prosecutors may also "respond to an argument that impugns its integrity or the integrity of its case"). + +21 The same is true with references by the Government to "minor victims." (Cf. Def. Mot. 12 at 4- 5). The Government does not expect any other trial participant to use the phrase "minor victims." + +Witnesses may also reference "victims." But the only witness the Government expects to use the term "victim" is its expert, Dr. And Dr. will not be testifying about the defendant or the Minor Victims in this case, but about victims of sexual abuse generally. Accordingly, she is not vouching for the credibility of anyone in this case, or presuming anything about the truth or falsity of any accusations. + +To the extent other Government witnesses use the term "victim," however, it would not be prejudicial to the defense. The limitation on improper vouching applies to the prosecutor, not to Government witnesses, as even one of the defendant's cases acknowledges. See Jackson v. State, 600 A.2d 21, 25 (De. 1991) ("The opinion does not state, nor does it imply, that the use of the term `victim' by witnesses, as a term of art or in common parlance, is a basis for objection."). In particular, some of the witnesses who may use the word "victim" are the Minor Victims themselves, who are testifying about their subjective experiences. It is not prejudicial to the defense for someone who considers herself a victim to testify as much? + +Here, as with other motions, the defendant requests an extraordinary order not seen in other cases in this District. That request lacks merit, and the Court should deny it. + +### B. Evidence of Rape + +The Government expects that at least one minor victim may describe being raped by Jeffrey Epstein. If that testimony is offered, it is directly relevant to issues before the jury. The defendant and Epstein are charged with transporting minors, enticing minors, or trafficking minors with the + +22 The Government defers to the Court on how it would like to refer to the Minor Victims. It notes, however, that "Accuse?' is an alternative that is prejudicial to the Government. + +intention that they would engage in illegal or commercial sex acts, and conspiring to do, and aiding and abetting, the same. These events occurred during an ongoing course of conduct, in some instances during multi-year relationships. The ongoing relationships between the defendant, Epstein, and the victims is directly relevant, and the victims' accounts of these events are necessary to complete the story of the crime on trial. Indeed, given the complex relationships between victims and their abusers, these events are integral to the relationships that will be at the heart of the trial. The defendant repeatedly claims that there is no evidence she participated in or was aware of a rape specifically (Def. Mot. 11 at 1-2), but defense arguments about her knowledge and involvement are for the jury. + +The defense argues that the Indictment does not allege that Epstein raped anyone, and so the rape is irrelevant. (Def. Mot. 11 at 2). That is a non sequitur. Indictments are not documents that contain all of the Government's evidence, and the defense cites no authority for the puzzling argument that witnesses cannot testifying using words that are not contained in an indictment. To the extent the defense understands the Indictment to allege only conspiracies to arrange for sexualized massages for Epstein (id. at 3), the defense is mistaken. The Indictment charges the defendant with conspiracies to arrange for "sexual activity" (Indictment ¶¶ 12, 18) and "a commercial sex act" (Id. ¶ 24). + +The defense also argues that evidence of a rape does not satisfy Rule 403 balancing, because evidence of a rape is "highly emotional and inflammatory." (Def. Mot. 11 at 3). This conclusory claim is insufficient to show prejudice to the defense. Testimony from victims in sex crimes trials can be very emotional when describing their abuse and the perpetrator. But that evidence—including evidence of rape, where it occurs-is the core conduct in the case. See, e.g., United States v. English, No. 18 Cr. 492 (PGG), 2020 WL 7773606, at \*10 (S.D.N.Y. Dec. 30, 2020) (describing evidence of rape in a trial for sex trafficking of minors); United States v. Graham, No. 14 Cr. 500 (NSR), 2015 WL 6161292, at \*8 (S.D.N.Y. Oct. 20, 2015) (concluding, in response to the argument that "rape" is a legal term, "there is a "critical distinction between a patient telling a physician that she `had intercourse with three men' and a patient telling the physician that she was 'raped' by three men."). Its probative value is certainly not outweighed by any unfair prejudice. Nor is it the case that evidence of a rape—especially at the level of abstraction described by the defense-is significantly more inflammatory than the charged crime: the sexual abuse of minors. + +In the event that a Minor Victim testifies that Epstein raped them, it is part of the charged conspiracy in this case, and it should be admitted. + +### VIII. The Remaining Defense Motions are Aimed at Evidence the Government Does Not Plan to Elicit + +Three of the defense motions are aimed at precluding the Government from offering evidence it does not intend to offer at trial. + +First, the defense seeks to preclude the Government from arguing that the defendant was hiding from, evading, or fleeing from law enforcement between Epstein's arrest and her own. (Def. Mot. 5 at 1). The Government's view remains that such conduct reflects the defendant's consciousness of her guilt (see id. at 2 (citing multiple Government filings)), and the Government does not agree that such evidence lacks an adequate factual basis or is inadmissible under Rule 403. (See id. at 6-9). However, the Government does not intend—and so will agree not to offersuch evidence in its case-in-chief, unless the defendant opens the door to this evidence or otherwise puts it at issue at trial. Furthermore, if the defendant testifies, the Government may cross-examine the defendant about this conduct, depending on the scope of her direct examination. But the Government will not affirmatively offer this evidence in its case-in-chief. + +The same is true for the defense motion to exclude evidence of the defendant's false statements in her 2016 depositions. (Def. Mot. 6 at I). Although false exculpatory statements are admissible as proof of a defendant's consciousness of guilt (see Gov't Opp. at 142-43, Dkt. No. 204 (citing, e.g., United States v. Anderson, 747 F.3d 51, 60 (2d Cir. 2014)), the Government does not intend—and so will agree—not to offer this information as part of its case-in-chief, unless the defense opens the door or otherwise puts these statements at issue. However, the Government may offer these statements in rebuttal to defense arguments. Moreover, the defendant's prior statements are of course appropriate material for cross-examination of the defendant. The Government also consents to the defense request to redact the perjury counts from the Indictment. (Def. Mot. 6 at 6). + +Finally, the defense seeks to preclude the Government's law enforcement witnesses from offering expert testimony. (Def. Mot. 10 at 5). The defense appears to take an improperly broad view of the scope of expert testimony.23 However, the Government has not noticed the three law + +23 For instance, the defense, citing United States v. Garcia, 413 F.3d 201 (2d Cir. 2005), makes the sweeping claim that "any opinion testimony" based on those three law enforcement witnesses' "specialized 'training and experience' is expert opinion testimony subject to Rule 702 and Rule 16(1)(G) and is inadmissible at trial." (Def. Mot. 10 at 4 (emphasis in original)). But in Garcia, the Second Circuit simply held that an undercover law enforcement agent could not testify as lay opinion that, based on his knowledge from other drug interdiction cases, the defendant was a + +enforcement officers identified by the defense as experts and will not elicit expert testimony from them. Those witnesses are being called as fact witnesses to describe, for instance, the execution of a search and evidence seized during that search.' + +#### CONCLUSION + +For the reasons set forth above, the Government respectfully requests that the Court deny the defendant's motions in limine. + +Dated: October 25, 2021 New York, New York + +Respectfully submitted, + +DAMIAN WILLIAMS United States Attorney for the Southern District of New York + +By: /s/ + +MIE + +Assistant United States Attorneys + +partner in the narcotics distribution conspiracy. Garcia, 413 F.3d at 216. That is distinguishable from cases where, as expected here, witnesses testify based on their personal involvement in certain investigative steps. + +24 It bears noting that the defense's motion is expressly concerned about testimony from case agents (Def. Mot. 10 at 5 n.2), and testimony about "the case, its origins, and the investigation" (id. at 3), which it considers to be improper expert testimony. The Government has moved to preclude the defense from offering such evidence, including by calling the case agents identified in its Touhy notice. (See Gov't Motions in Limine Section III). Accordingly, if the defense plans to call case agents for such testimony—which the Court should preclude—the defense must provide expert notice of such testimony. \ No newline at end of file diff --git a/marker2/ds9/EFTA00088802/EFTA00088802.metadata.json b/marker2/ds9/EFTA00088802/EFTA00088802.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..d9d0b352b71d3c363285c945d249544dc6137f99 --- /dev/null +++ b/marker2/ds9/EFTA00088802/EFTA00088802.metadata.json @@ -0,0 +1,3664 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00088802.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 84, + "chars": 158238, + "elapsed_seconds": 152.86, + "image_assets": [ + "_page_0_Picture_8.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 67.932, + 70.47 + ], + [ + 281.41961669921875, + 70.47 + ], + [ + 281.41961669921875, + 99.603515625 + ], + [ + 67.932, + 99.603515625 + ] + ] + }, + { + "title": "THE GOVERNMENT'S OMNIBUS MEMORANDUM IN OPPOSITION \nTO THE DEFENDANT'S MOTIONS IN LIMINE", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 111.384, + 332.90999999999997 + ], + [ + 500.6633605957031, + 332.90999999999997 + ], + [ + 500.6633605957031, + 362.85357666015625 + ], + [ + 111.384, + 362.85357666015625 + ] + ] + }, + { + "title": "Table of Contents", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 249.696, + 95.58 + ], + [ + 363.3164978027344, + 95.58 + ], + [ + 363.3164978027344, + 112.1214599609375 + ], + [ + 249.696, + 112.1214599609375 + ] + ] + }, + { + "title": "PRELIMINARY STATEMENT", + "heading_level": null, + "page_id": 3, + "polygon": [ + [ + 220.93199999999996, + 72.08999999999999 + ], + [ + 392.671630859375, + 72.08999999999999 + ], + [ + 392.671630859375, + 86.2330322265625 + ], + [ + 220.93199999999996, + 86.2330322265625 + ] + ] + }, + { + "title": "ARGUMENT", + "heading_level": null, + "page_id": 4, + "polygon": [ + [ + 268.05600000000004, + 72.08999999999999 + ], + [ + 345.3679504394531, + 72.08999999999999 + ], + [ + 345.3679504394531, + 86.103515625 + ], + [ + 268.05600000000004, + 86.103515625 + ] + ] + }, + { + "title": "I. 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0000000000000000000000000000000000000000..caaa42c08a17563db9f77b3511983911f888ca6e --- /dev/null +++ b/marker2/ds9/EFTA00088886/EFTA00088886.md @@ -0,0 +1,55 @@ +From: To: ' (USANYS)" <1 (USANYS)" <1 + +Subject: FW: U.S. v. Maxwell, Case No. 20 Cr. 330 (AJN) [Ms. Maxwell's Response to Government's Omnibus Motions in Limine] + +Date: Tue, 26 Oct 2021 13:08:29 +0000 + +Attachments: 2021.10.25\_Maxwell's\_Respons\_to\_Governmenes\_Omnibus\_Motions\_in\_Limine.zip; Govt\_Omnibus\_Opp\_[Unredacted].pdf; Govt\_Exhibit\_A.pdf; Govt\_Exhibit\_B.pdf + +Inline-Images: unage001.jpg + +From: + +Sent: Tuesday, October 26, 2021 12:00 AM + +To: (USANYS) >; (USANYS) + +Cc: < (USANYS) < + +Subject: FW: U.S. v. Maxwell, Case No. 20 Cr. 330 (AJN) [Ms. Maxwell's Response to Government's Omnibus Motions in Limine] + +Hi Chiefs, + +Attached are their motions and the final version of ours, in case you'd like to see that. + +Thanks, + +From: Nicole Simmons + +Sent: Monday, October 25, 2021 11:50 PM + +To: 'Nathan NYSD Chambers' < + +Cc: Jeff Pagliuca Laura Menninger 2Centre for Research on Children and Families. School of Social Work, McGill University. Montreal. Qubec. Canada + +CSA to authorities and the high rates reported in prevalence studies. For example, a meta-analysis conducted by Stoltenborgh, van LIzendoom, Euser, and Bakermans-Kranenburg (2011) combining estimations of CSA in 217 studies published between 1980 and 2008 revealed rates of CSA to be more than 30 times greater in studies relying on self-reports (127 in 1,000) than in official report inquiries, such as those based on data from child protection services and the police (4 in 1,000) (Julian, Cotter, & Perreault, 2014; Statistics Canada 2013). In other words, while 1 out of 8 people retrospectively report having experienced CSA, official incidence estimates indicate only 1 per 250 children. In a survey of Swiss child services, Maier, Mohler-Kuo, Landholt, Schnyder, and Jud (2013) further found 2.68 cases per 1,000 of CSA disclosures, while in a recent comprehensive review McElvaney (2015) details the high prevalence of delayed, partial, and nondisclosures in childhood indicating a persistent trend toward withholding CSA disclosure. + +It is our view that incidence statistics are likely an underestimation of CSA disclosures, and this drives the rationale for the current review. Given the persistence of delayed disclosures with research showing a large number of survivors only disclosing in adulthood (Collin-Vezina et al., 2015; Easton, 2013; Hunter, 2011; McElvaney, 2015; Smith et al., 2000), these issues should be a concern for practitioners, policy makers, and the general public (McElvaney, 2015). The longer disclosures are delayed, the longer individuals potentially live with serious negative effects and mental health problems such as depression, anxiety, trauma disorders, and addictions, without receiving necessary treatment. This also increases the likelihood of more victims falling prey to undetected offenders. Learning more about CSA disclosure factors and processes to help advance our knowledge base may help professionals to facilitate earlier disclosures. + +Previous literature reviews examining factors influencing CSA disclosure have served the field well but are no longer current. Important contributions on CSA disclosures include Paine and Hansen's (2002) original review covering the literature largely from the premillennium era, followed by London, Bruck, Ceci, and Shuman's (2005) subsequent review, which may not have captured publications affected by "lag to print" delays so common in peer-reviewed journals. These reviews are now dated and therefore do not take into account the plethora of research that has been accumulated over the past 15 years. Other recent reviews exist but with distinct contributions on the dialogical relational processes of disclosure (Reitsema & Grietens, 2015), CSA disclosures in adulthood (Tener & Murphy, 2015), and delayed disclosures in childhood (McElvaney, 20I5). This literature review differs by focusing on CSA disclosures in children, youth, and adults from childhood and into adulthood—over the life course. + +# Method + +Kiteley and Stogdon's (2014) systematic review framework was utilized to establish what has been investigated in CSA + +disclosure research, through various mixed methods, to highlight the most convincing findings that should be considered for future research, practice, and program planning. This review centered on the question: What is the state of CSA disclosure research and what can be learned to apply to future research and practice? By way of clarification, the term systematic refers to a methodologically sound strategy for searching literature on studies for knowledge construction, in this case the CSA disclosure literature, rather than intervention studies. The years spanned for searching the literature were 2000-2016, building on previous reviews without a great deal of overlap. Retrieval of relevant research was done by searching international electronic databases: PsycINFO, PsycARTICLES, Educational Resources Information Center, Canadian Research Index, International Bibliography of the Social Sciences, Published International Literature on Traumatic Stress, Sociological Abstracts, Social Service Abstracts, and Applied Social Science Index and Abstracts. This review searched peerreviewed studies. A search of the gray literature (unpublished literature such as internal agency documents, government reports, etc.) was beyond the scope of this review because unpublished studies are not subjected to a peer-review process. Keyword search terms used were child sexual abuse, childhood sexual abuse, disclosure, and telling. + +A search of the 9 databases produced 322 peer-reviewed articles. Selected search terms yielded 200 English publications, I French study, and 1 Portuguese review. The search was further refined by excluding studies focusing on forensic investigations, as these studies constitute a specialized legal focus on interview approaches and techniques. As well, papers that focused exclusively on rates and responses to CSA disclosure were excluded, as these are substantial areas unto themselves, exceeding the aims of the review question. Review articles were also excluded. Once the exclusion criteria were applied, the search results yielded 33 articles. These studies were subjected to a thematic analysis as described by Braun and Clarke (2006). This entailed (I) multiple readings by the three authors; (2) identifying patterns across studies by coding and charting specific features; (3) examining disclosure definitions used, sample characteristics, and measures utilized; and (4) major findings were extrapolated. Reading of the articles was initially conducted by the authors to identify general trends in a first level of analyses and then subsequently to identify themes through a deeper second-level analyses. A table of studies was generated and was continuously revised as the selection of studies was refined (see Table 1). + +# Key Findings + +First-level analysis of the studies identified key study characteristics. Trends emerged around definitions of CSA disclosure, study designs, and sampling issues. First, in regard to definitions, the term "telling" is most frequently used in place of the term disclosure. In the absence of standardized questionnaires or disclosure instruments, telling emerges as a practical term more readily understood by study participants. Several + +**Table 1.** Ch d Sexua Abuse (CSA) D sc osure Stud es: 2000–2016. + +| Study | Purpose | Des gn | Samp e | Fnd ngs | Summary | +|-----------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------| +| Gagn er and Co n-Véz na (2016) | To exp ore d sc osure processes for ma e v ct ms of CSA | Phenomeno og ca methodo ogy used to interv ew ma e CSA surv vors. The Long Interv ew Method (LIM) gu ded data co ect on and ana yses. | 17 men ranged n age from 19 to 67—average age 47. Purpos ve samp ng strategy was used | The major ty of the men n the study wa ted unt adu thood to d sc ose the r abuse, w th negat ve stereotypes contr but ng to the r de ayed d sc osures. Negat ve stereotypes contr buted to de ayed d sc osure w th try ng to forget. Break ng so at on was c ted as a mot vator to d sc osure a ong w th the a d of var ous forms of med a on d sc osure. Important contextua ssues such as negat ve stereotyp ng of ma es, sexua ty, and v ct ms were noted. Soc a med a was seen as a fac tator of d sc osures | A part c pants had d sc osed and rece ved serv ces before part c pat ng n the study. Member check ng cou d not be done w th the part c pants to check themes. Sma but suff c ent s ze for a qua tat ve nqu ry. Otherw se, h gh eve of r gor n estab sh ng trustworth ness of the data and ana ys s. Retrospect ve study cou d mp y reca ssues | +| Braze ton (2015) | To exp ore the mean ng Afr can Amer can women make of the r traumat c exper ences w th CSA and how they d sc osed across the fe course | Co ect ve case study des gn w th us ng narrat ve trad t on (storyboard) for data co ect on and ana ys s. Qua tat ve interv ew ng | 17 Afr can Amer can women n m d- fe between 40 and 63 who exper enced ntrafam a CSA. Purpos ve, snowba ng strategy | CSA onset was arge y between the ages 5 and 9. No one ever ta ked to them about sex, so they d di'n have anguage to d sc ose. Barr ers: fear of fam y breakdown and remova, not want ng to tarn sh the fam y's name, and fear of retr but on by fam y members f they d sc osed. Pattern of st f ed and d sm ssed d sc osures dent f ed over the fe course. A 17 part c pants dent f ed sp r tua ty as a pr mary source of strength throughout the fe course | One of few stud es to focus exc us ve y on Afr can Amer can women. Sma but suff c ent s ze for a qua tat ve nqu ry. Important cu tura and contextua ssues were brought forward. Retrospect ve study that may have been affected by reca ssues. Use of a fe-course perspect ve as a theoret ca ens for understand ng CSA n the m dd e to ater years of fe that shou d be cons dered n further nvest gat ons | +| Co n-Véz na, Sab onn, Pa mer, and M ne (2015) | To prov de a mapp ng of factors that prevent CSA d sc osures through an eco og ca ens from a samp e of CSA adu t surv vors. | Qua tat ve des gn us ng LIM. | 67 ma e and fema e CSA adu t surv vors (76% dent f ed as fema e and 24% as ma e). Age ranges from 19 to 69 years (M = 44.9). Purpos ve samp ng strategy | Three broad categor es were dent f ed as barr ers to CSA d sc osure. Barr ers from w th n- nterna zed v ct m b am ng, mechan sms to protect onese f, and mmature deve opment at t me of abuse; barr ers n re at on to others—v o ence and dysfunct on n the fam y, power dynam cs, awareness of the mpact of te ng, and frag e soc a network; barr ers n re at on to the soc a wor d abe ng, taboo of sexua ty, ack of serv ces ava ab e, and cu ture or t me per od. | Ha f of the part c pants had not d sc osed the r CSA exper ences before the age of 19. Retrospect ve aspect of the study cou d mp y reca ssues. A part c pants had d sc osed and rece ved counse ng at some before part c pat ng n the study. H gh eve of r gor n estab sh ng trustworth ness of the data and ana ys s | +| Lec erc and Wort ey (2015) | Study object ves nvest gated the factors that fac tate CSA d sc osures | Adu t ma e ch d sexua offenders were interv ewed to exam ne pred ctors of | 369 adu t ma es who had been conv cted of a sexua offense aga nst a ch d aged between 1 | D sc osure increased w th the age of the v ct m: f penetrat on had occurred, f the v ct m was re ated to the offender, f the v ct m was not v ng w th the offender at | Offender generated data through se f-reports cou d be subject to cogn t ve d stort ons—m n m zat on or exaggerat ons. | + +Table I. (cont nued) + +| Study | Purpose | Design | Sample | Findings | Summary | | +|----------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------| +| McEvaney and Cuhane (2015) | To investigate the feasibility of using child assessments as data sources of information for CSA discipline. To assess fitness reports provide substantive data on disciplines | Field reports of children seen for assessment a child sexual abuse until na children's hospital were reviewed | Content analysis was completed on 39 fes (32 females and 7 males) based on a coding framework. Parents were asked to consent to have their child's field reviewed for the study. Victims assessed were 12–18 years of age | Majority of children to dither mothers (43%) and peers (33%) first. Three major themes were dentified as influencing the discipline process: (1) feeling distressed, (2) opportunity to tell, and (3) fears for self. Additional themes of being believed, shame/self-blame, and peer influence were also dentified | The sample size is small but we contribute to a large multitude of study in lire and. Serves as an important exploratory pilot bringing forward discipline themes for consideration interventions | Perspectives of offenders on vulnerability of victims in relation to discipline source could be important information to inform interventions | +| Dumont, Messerschmitt, Vila, Bohu, and Rey-Salmon (2014) | This study alluded to explore how the relationship between the perpetrator and the victim, especially whether these relations are intrafamilial or extrafamilial, impact CSA discipline | Field reports of children seen for assessment a child sexual abuse until na children's hospital were reviewed | 220 million victims—78.2% female victims, 41.8% aged between 14 and 18 (most prevalent age range), and 48.2% were abused by a family member | Discipline processes were more complex when the concerned sexual abuse committed by intrafamilial perpetrator: 60% of the victims reveal the facts several years after, and most often to individuals outside the family (78.6% of the disciplines done at school); on the contrary, extrafamilial disciplines take place more spontaneously and quickly: 80% of the victims reveal the facts a few days after, most often to their mother or peers | The relationship with the perpetrator has a significant impact on both timing and recipient of discipline, with intrafamilial abuses leading to beliefs disclosed promptly and within the family system | The perspectives of offenders on vulnerability of victims in relation to discipline source could be important information to inform interventions | +| Easton, Saltzman, and Wilson (2014) | Study focus was on dentification of barriers to CSA discipline with male survivors | Using qualitative content analysis, researchers conducted a secondary analysis of one interview data, the 2010 Health and Well-Being Survey, that included men with self-reported CSA histories with an open-ended term on discipline barriers | 460 men with CSA histories completed an anonymous, linternet-based survey. Recruited from survivors' organizations. Age range of 18–84 years. Two thirds of respondents reported clergy-related abuse. Majority of respondents were White | Vast majority of participants (94.6%) were sexually abused by another male. Duration of sexual abuse broke down into: 30.2% estimated at 32.3% months to 3 years, and 34.3% more than 3 years. Ten years old was average age of CSA onset. Ten categories of barriers were cassified into three domains: (1) sociopolitical: masculinity, military resources; (2) interpersonal: mistrust of others, fear of being able to "gay," safety and protection issues, past responses; and (3) personal: internal emotions, seeing the experience as sexual abuse, and sexual or emotion. | At time of the study, this was the largest qualitative data set to have been analyzed with an explicit focus on adult male survivors' perceptions of barriers to CSA discipline. Because the sample was militarian terms of the own percentage of racial mortalities (9.3%), discipline differences based on race or ethnicity were not discerned. The majority of abuse reported was by clergy which might present a unquestion of barriers to discipline | | + +Pt' Table I. (cont nued) + +| Study | Purpose | Design | Sample | Findings | Summary | +|--------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------| +| Easton (2013) | Study purpose was to describe male CSA discourse processes using a felspan approach examining differences based on age. A so, to explore relationships between discourse attributes and men's mental health | Cross-sectional survey design. Eligible participants were screened and completed an anonymous, Internet-based survey during 2010. Measures used: General Mental Health Distress Scale and General Assessment of Individual Needs. Questions related to CSA discourse and supports were included | Purpose velocity of men from 487 men from three national organizations devoted to ralising awareness of CSA among men. Age range: 19–84 years. Mean age for onset of CSA was 10.3 years | Older age and being abused by a family member were both related to delays in discourse. Most participants who told someone during childhood did not receive emotional support velocity or protective responses and the helpfulness of responses across the felspan was mixed. Delays in teling were significant periods of time (over 20 years). Approximately one half of the participants first told about the sexual abuse to a spouse/partner (27%) or a mental health professional (20%); 42% of participants reported that the remote helpful discussion was with a mental health professional. However, unhelpful responses caused most mental distress. Child recommendations included more of a fel-course perspective be adopted, understanding impact of unhelpful responses and the importance of expanding networks for male survivors | Purpose velocity of men from awareness ralising organizations may have attracted particular participants who had a ready discoused and received help. Participants needed to have access to Internet which would have eliminated men's ower SES groups and required proficiency in English which would eliminate mental health problems. However, the sampling strategy gained access to a predominantly hidden population. Important child recommendations are made with an emphasis on a fel-course focus | +| McEvaney, Greene, and Hogan (2012) | Qualitative study asked the central research question: "How do children tell?" Objective was to develop theory of how children tell of the research question as discourse experiences. Parents were interviewed. | Grounded theory method study. Interviews were conducted. Line-by-line open and axial coding was conducted on verbatim transcripts | Sample of 22 young people; 16 girls and 6 boys; age range: 8–18 years; 22 interviewed in total between the ages of 8 and 18. Mixed sample of some enduring nutritional CSA, some extrafamilial CSA, and two endured both forms | A theoretical model was developed that conceptualizes the process of CSA discourse as one of containing the secret (1) the active withholding of the secret on the part of the child; (2) the experience of a "pressure cooker effect" reflecting a conflict between the wish to tell and the wish to keep the secret; and (3) the confliding tise fill which often occurs in the context of a trusted relationship. These were derived from even categories that were developed through open and axial coding | Modest but sufficient sample for an exploratory qualitative inquiry. High level of trustworthiness rigor. A subsample of randomly selected transcripts was independently coded. Very young children and young adults were not captured in this sample. Transferability of findings can only be made to the age range sampled in the context of lire and | +| Schonbucher, Maler, Mohler-Kuo, Schnyder, and Lando t (2012) | To investigate the process of CSA discourse with adolescents from the general population who had experienced CSA. How many discoused, who did | Data collection was through face-to-face qualitative interviews. Standardized questions and measures were administered on family stuation, sociodemographic | Convenience sample of 26 sexually victimized adolescents. 23 girls and 3 boys. Age range: 15–18 years. On line advertisements and filers were used to recruit youth from | Less than one third of participants immediately discoused CSA to another person. In most cases, recipients of both immediate and delayed discourse were to peers. More than one third of participants had never discoused the abuse to a parent. Participants reported reluctance to discouse to parents so as | Two thirds of the sample did not discouse right away. Strengthening parent-child relationships may be one of the most important ways to increase discourse to parents. Discourse to peers has been found a common trend in other | + +Table I. (cant nued) + +| Study | Purpose | Des gn | Samp e | Fnd ngs | Summary | +|---------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------| +| Hunter (2011) | they d sc ose to, and what were the r mot ves for d sc os ng | data, sexua v ct m zat on, genera and menta hea th. | commun ty and counse ng serv ces | not to burden them. Ear er d sc osures were re ated to extrafam a CSA, s ng e occurrence CSA, age of v ct m at abuse onset, and parents who were v ng together. H gher eve s of reported gu t and shame were re ated to de ayed d sc osures. Peers were v ewed by th s samp e as more re ab e conf dants | research and bears more exam nat on | +| | A m of th s study was to deve op a fu er understand ng of CSA d sc osures | Narrat ve nqu ry methodo ogy. Face-to-face n-depth interv ews were conducted w th part c pants. Data were ana yzed us ng Rosentha and F scher-Rosentha 's (2004) method. | Purpos ve samp ng was emp oyed. Samp e cons sted of 22 part c pants aged 25-70 years; 13 women and 9 men. Part c pants were sexua y abused at 15 years or under w th someone over the age of 18. | On y 5 out of 22 part c pants to d anyone about the r ear y sexua exper ences as ch dren. Fear, shame, and se f-b ame were the ma n nh b tors to d sc osure. These factors are further deta ed through subthemes. Te ng as a ch d and as an adu t was further expanded upon us ng A agg a's (2004) framework ver fy ng behav ora nd rect attempts to te and purposefu d sc osure as categor es. Themat c ana ys s supported that CSA d sc osure shou d be conceptua zed and v ewed as a comp ex and fe ong process | De ayed d sc osure was common n th s qua tat ve samp e. Most part c pants d d not make a se ect ve d sc osure unt adu thood. These fnd ngs support A agg a's (2004) mode of d sc osure but a so h gh ghts the importance of fe stage. Modest but suff c ent samp e s ze for a qua tat ve nqu ry. We -des gned study w th deta ed ana ys s for transferab ty of f nd ngs | +| Schaeffer, Leventha, and Asnes (2011) | Th s study a med to: (1) add d rect nqu ry about the process of a ch d's CSA d sc osure; (2) determ ne f ch dren w d scuss process that ed them to te ; and (3) descr be factors that ch dren dent fy that ed them to te about or caused them to de ay CSA d sc osure | Study sought to f nd out f process ssues of d sc osure cou d be dent f ed n the context of forens c interv ews. Forens c interv ewers were asked to ncorporate quest ons about "te ng" nto an ex st ng forens c interv ew protoco . Interv ew content re ated to the ch dren's reasons for te ng or wa t ng was extracted, transcr bed, and ana yzed us ng grounded theory method of ana ys s | 191 interv ews of CSA v ct ms aged 3-18 over a 1-year per od were used for the study. Inc us on cr ter a nc uded ch dren who made a statement about CSA pr or to referra , reasons for te ng or wa t ng to te , and those who spoke Eng sh. Part c pants were ch dren who were interv ewed at a ch d sexua abuse c n c. 74% were fema e and 51% were Caucas an grounded theory method of ana ys s | Reasons the ch dren dent f ed for te ng were c ass f ed nto three doma ns: (1) d sc osure as a resu t of interna st mu (e.g., the ch d had n ghtmares); (2) d sc osure fac tated by outs de nf uences (e.g., the ch d was quest oned); and (3) d sc osure due to d rect ev dence of abuse (e.g., the ch d's abuse was w tnessed). The barr ers to d sc osure dent f ed fe nto f ve groups: (1) threats made by the perpetrator (e.g., the ch d was to d she or he wou d get n troub e f she or he to d), (2) fears (e.g., the ch d was afra d someth ng bad wou d happen f she or he to d), (3) ack of opportun ty (e.g., the ch d fe t the opportun ty to d sc ose never presented), (4) ack of understand ng (e.g., the ch d fa ed to recogn ze abus ve behav or as unacceptab e), and (5) re at onsh p w th the perpetrator (e.g., the ch d thought the perpetrator was a fr end) | An movat ve study to try to assess f forma nvest gat ve interv ews can fac tate d sc osures of CSA. Data were based on a arge number of interv ews. Deta ed ana ys s produced deta ed fnd ngs support ng other study fnd ngs on CSA d sc osure | + +Table I. (coin nued) cr. P + +| Study | Purpose | Design | Sample | Findings | Summary | | | | +|-----------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------| +| Aagg a (2010) | The study aimed to dentify factors impeding or promoting CSA disciplines. Overarching research question: What individual, interpersonal, environmental, and contextual influences impede or promote CSA disciplines. | A qualitative phenomenology called gri, LIM, was used to interview adult CSA survivors about the risk of discipline experiences to provide retrospective accounts of CSA discipline and meaning-making of these experiences. Thematic analysis was done through a socio-ecology called ens. | Purposive sampling was employed. Snowba sampling was also used to recruit more male survivors. 40 adult survivors of CSA were interviewed: 36% men and 64% women. Age range of 18–65 with a mean age of 40.1 years. Average age of abuse onset was 5.3 years old. 36% of the sample was non-White. Diverse socioeconomic backgrounds | Themes fell into four domains: (1) individual and developmental factors, developmental factors as to whether they comprehended what was happening, personality traits also had some bearing on the risk to tell, and categorized the risk by age and science pattern believed; (2) discipline nihilitied by family characteristics such as rigidity fixed gender roles with dominating fathers, chaos and aggression, other forms of child abuse, domestic violence, dysfunctional communication, and social socialization; (3) neighborhood and community context, that is, ackliff interest from neighbors and teachers not pursuing troubling behavior; and (4) cultural and societal attitudes, media messages and societal attitudes, feeling unheard as kilds, gender socialization for males, and cultural attitudes influencing parent's reactions. Purposeful discipline situations that reported in other studies because of the sampling attempts to purposefully illicitate disciplines | The study presents a comprehensive socio-ecology called analysis to CSA discipline survival in gibiting the multifaceted influences. Of note, 42% had disciplined abuse during childhood; 26% had not disciplined because they had repressed the memory, or the abuse had occurred in preschool years and they had difficulty with recall. The remainder had attempted some form of discipline in indirect ways during childhood. A retrospective approach that could be affected by recall issues | The study presents a comprehensive socio-ecology called analysis to CSA discipline survival in gibiting the multifaceted influences. Of note, 42% had disciplined abuse during childhood; 26% had not disciplined because they had repressed the memory, or the abuse had occurred in preschool years and they had difficulty with recall. The remainder had attempted some form of discipline in indirect ways during childhood. A retrospective approach that could be affected by recall issues | The study highlights that discipline survival in gibiting the multifaceted influences. Of note, 42% had disciplined abuse during childhood; 26% had not disciplined because they had repressed the memory, or the abuse had occurred in preschool years and they had difficulty with recall. The remainder had attempted some form of discipline in indirect ways during childhood. A retrospective approach that could be affected by recall issues | The study highlights that discipline survival in gibiting the multifaceted influences. Of note, 42% had disciplined abuse during childhood; 26% had not disciplined because they had repressed the memory, or the abuse had occurred in preschool years and they had difficulty with recall. The remainder had attempted some form of discipline in indirect ways during childhood. A retrospective approach that could be affected by recall issues | +| Fontes and Pillmeier (2010) | The study aimed to dentify factors impeding or promoting CSA disciplines. Overarching research question: What individual, interpersonal, environmental, and contextual influences impede or promote CSA disciplines. | Using published terature with cincaldata, the study conducted an analysis to provide a culturally competent framework for CSA discipline questioning internationally | Data consisted of published terature on discipline and culture that was triangulated with cincaldata material | Cultural and structural factors affecting CSA discipline are dentified in in-depth detail. Recommendations made include (1) discipline interviewing should be tallored to the child's cultural context, (2) questioning should also take into consideration age and gender factors, and (3) culture stands as an important factor in a cases in which children are considering discipline or being asked to discipline, and not solely in cases in which children are from not cealed minority groups. Presents a comprehensive interview framework integrating cultural considerations | One of the few works that adds knowledge to culturally contextual discipline interviewing. Unquestionable terature findings with cincaldata. Anecdota accounts may preclude transferability of findings. Overall adds to an impoverished area of CSA discipline information | The study highlights that discipline survival in gibiting the multifaceted influences. Of note, 42% had disciplined abuse during childhood; 26% had not disciplined because they had repressed the memo | | | + +**Table 1.** (continued) + +| Study | Purpose | Design | Sample | Findings | Summary | +|-----------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------| +| | (1) What are the hidden experiences of abuse among Canadian youth? (2) What impact does participation in abuse prevention programs have on youth to express their abuse experiences? (3) What disciplinary barriers do youth face? (4) What are young people's disciplinary patterns? and (5) Who do they tell? | programming by the Canadian Red Cross (RespectED). A series of focus groups and observations of the workshops were used to help contextualize the findings. Evaluation forms were analyzed from two video encipe prevention programs: (1) It's not your fault and (2) What's overgot to do with it? | anonymously disclosed abuse experiences. Respondent's ages: 13 and under (27%), 14–15 (37%), 16–17 (25%), 18 and older (4%), and unknown (7%) | at a nurse or provider interviewing the peer for information and providers to complete the programming statement. Results suggest disclosure interactive process, with expectations regarding consequences to disclosure. Patterns of incremental sharing abuse experiences are shaped by young people's interactions with peers, educators, and caregivers. About three-quarters of females previously disclosed; significantly less males disclosed | niteractive models of disclosure such as those detailed by Aagga (2004) and Stailer and Nelson-Garde (2005). This makes sample of youth who experienced different forms of abuse and video encipe exposure were participants—not mated to CSA survivors | +| Ungar, Tutty, McConne, Barter, and Farlhoim (2009b) | This study explored abuse disclosure strategies with a national sample of Canadian youth who participated in video encipe prevention programming. One of the goals of the study was to document not previously dentified experiences of abuse and youth attitudes toward disclosure of abuse experiences | Exploratory design with a nonrepresentative sample. Qualitative analysis of 1,099 evaluation forms completed by video encipe prevention programming. Red Cross RespectED video encipe between 2000 and 2003 | Purposeful sample of 1,099 evaluation forms completed by video encipe prevention programming. Red Cross RespectED video encipe between 2000 and 2003 | Findings suggest high rates of hidden abuse, with less than one quarter of youth reporting a disclosure. 244 of the 1,099 youth who disclosed abuse on the review until forms dentified specific dividuals they told about their abuse. Disclosure patterns vary with boys, youth aged 14–15, victims of physical abuse, and those abused by a family member being most likely to disclose to professionals or the police. One third of disclosures were directed toward professionals and the east, 5% percent each, were directed toward friends, parents, and others. Participants were most likely to disclose sexual abuse to parents/family, professionals, and the police/courts, with fewer choosing friends. | Innovative design of this study provides nating to young people's perceptions of disclosure experiences. High level of rigor with trustworthiness of the data analysis ensured through use of youth focus groups, interviews, and observational data. The study results are somewhat mated to the thickness of the descriptions that offer because most of the data are survey based. Regional differences may not have been predicted. Scope of the study is broad and approach is creative | +| | | | | | | +| | | | | | | +| | | | | | | +| | | | | | | +| | | | | | | + +Table I. (cont nued) + +| Study | Purpose | Design | Sample | Findings | Summary | | | +|----------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------| +| Priebe and Svedin (2008) | This study aimed to investigate disclosure rates and disclosure patterns and examine predictors of nondisclosure in a sample of male and female adolescents with self-reported experiences of sexual abuse | | The sample consisted of 65-templet onnaire that included questions about background, consensual sex, sexual abuse experiences (noncontact, contact or penetrating abuse, including peer abuse), disclosure of CSA, own sexual abuse behavior, sexual attitudes, and experiences with pornography and sexual exploitation. The questionnaire included 6 modified tems from the SCL-90 and 9 of 25 tems from the Parental Bonding Instrument. The data for girls and boys were analyzed separately | The sample consisted of 4,339 high school students in Sweden (2,324 girls and 2,015 boys). The mean age of the participants was 18.15 years. This study used a subsample of 1,962 participants who reported CSA and who answered disclosure questions | The sample consisted of 4,357 girls (65%) and 457 boys (23%) reported CSA. The disclosure rate was 81% (girls) and 69% (boys). Girls and boys disclosed most often to a first end of their own age. Few had disclosed to professionals, and even fewer had reported to the authorities. There were higher rates of disclosure to a professional with more severe abuse (contact abuse with or without penetration) for girls, but owner rates for boys. The more severe the sexual abuse was, the less likely both girls and boys had talked to their mother, father, or a sibling. Girls were less likely to disclose fithey had experienced contact sexual abuse with or without penetration, less frequent abuse, abuse by a family member, or fithey had perceived their parents as less caring and less overprotective and highly overprotective. Boys were less likely to disclose fithail family member abused them, they were studying a vocational program (vs. an academic program), lived with both parents or had perceived their parents as less caring and not overprotective. | This study highlighted that sexual abuse is a risk factor for disclosure from adult society, especially from professionals and the egg system. However, the appeal to disclosure was not reported. Since first ends appeared to be the main risk points of sexual abuse disclosures, practice implications of this could be to find ways to give young people better information and guidance about how to support a sexually abused peer. A qualitative component to the study would have provided a broader understanding of disclosure processes. Study materials include a significant amount of boys who did not complete the questions regarding disclosure on; the timing of disclosures (whether they were delayed or not) was not measured; possibility of recall bearing the retrospective studies based on self-reports; and youth participants may not have understood a lithe questions | Since the vast majority of men in the sample had not disclosed in the childhood, they may have been predisposed to dentify ng barriers to disclosure more | +| Sorso, Ka-Keating, and Grossman (2008) | Study focused on disclosure challenges for male survivors of CSA to understand three issues: (1) To | | Male survivors of CSA were interviewed about their disclosure experiences. Analytic techniques included | The sample consisted of 16 male survivors of the childhood sexual abuse; 11 Caucasian, 2 African American, 1 | Barriers to disclosure were found to be operant in three interrelated domains: (1) personal (e.g., acklogicity view awareness, intentional avoidance, emotional readiness, and shame); (2) | Since the vast majority of men in the sample had not disclosed in the childhood, they may have been predisposed to dentify ng barriers to disclosure more | | + +Table I. (cont nued) + +| Study | Purpose | Design | Sample | Findings | Summary | +|-------------------------------------|-----------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------| +| Hershkow tz, Lanes, and Lamb (2007) | The goal of the present study was to examine how child victims of extrafamiliar sexual abuse disclosed the abuse experience | Aged victims of sexual abuse and their parents were interviewed. Children were interviewed using the NICHD Investigative Interview Protocol by experienced youth investigators. Information on disclosure processes was obtained in the first formal interview, before any police investigation or child we fare intervention | Thirty aged victims of CSA; 18 boys and 12 girls. Child sample was 7- to 12-year-olds with an average age of 9.2 years. Twenty mothers and 10 fathers were also interviewed for a total of 30 parent interviews. A content analysis was conducted on child and parent interviews | Disclosure categories were dentified as follows: (1) delayed 53% of the children delayed disclosure for between 1 week and 2 years; (2) recipient of disclosure: 47% of children first disclosed to bings or friends, 43% first disclosed to their parents, and 10% first disclosed to another adult. 57% of the children spontaneously disclosed abuse, but 43% disclosed only after they were prompted. 50% of the children reported feeling afraid or ashamed of their parents' responses. Parents' reactions: support vie (37%) and unsupport vie (63%). There was a strong correlation between predicted and actual parent reactions suggesting children anticipated the irreparable reactions accurately. Disclosure processes varied depending on the children's ages (e.g., younger children disclosed to parents), severity and frequency of abuse, parents' expected reactions, suspects' dentities, and strategies used to foster secrecy | reading vi. Retrospect vie accounts are subject to recall susses. Investigators made significant efforts to gather a diverse sample. High level of irrigor was executed in the dependability of the data and terraine process of the interpretation of findings was conducted | +| Hershkow tz, Lanes, and Lamb (2007) | The goal of the present study was to examine how child victims of extrafamiliar sexual abuse disclosed the abuse experience | Aged victims of sexual abuse and their parents were interviewed. Children were interviewed using the NICHD Investigative Interview Protocol by experienced youth investigators. Information on disclosure processes was obtained in the first formal interview, before any police investigation or child we fare intervention | Thirty aged victims of CSA; 18 boys and 12 girls. Child sample was 7- to 12-year-olds with an average age of 9.2 years. Twenty mothers and 10 fathers were also interviewed for a total of 30 parent interviews. A content analysis was conducted on child and parent interviews | Disclosure categories were dentified as follows: (1) delayed 53% of the children delayed disclosure for between 1 week and 2 years; (2) recipient of disclosure: 47% of children first disclosed to bings or friends, 43% first disclosed to their parents, and 10% first disclosed to another adult. 57% of the children spontaneously disclosed abuse, but 43% disclosed only after they were prompted. 50% of the children reported feeling afraid or ashamed of their parents' responses. Parents' reactions: support vie (37%) and unsupport vie (63%). There was a strong correlation between predicted and actual parent reactions suggesting children anticipated the irreparable reactions accurately. Disclosure processes varied depending on the children's ages (e.g., younger children disclosed to parents), severity and frequency of abuse, parents' expected reactions, suspects' dentities, and strategies used to foster secrecy | Innovative design to gather disclosure data from young children. Focus is on extrafamiliar CSA which may differ than disclosure patterns of intrafamiliar CSA. Two thirds of the parents registered unsupport vie responses which is high | + +**Table 1.** (continued) + +| Study | Purpose | Design | Sample | Findings | Summary | +|-----------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------| +| A agg and Kirshenbaum (2005) | The objectives of the current study were to dentify a broad range of factors, including family dynamics that contribute to or hinder a child's ability to discipline CSA. | A qualitative phenomenological design—LIM—was used to elicit discipline experiences; facilitators and barriers; and relevant circumstances. Interviews were transcribed verbatim. Line-by-line open coding was conducted to capture family-eve factors. Axial and selective coding facilitated dentification of themes | Purposive sampling was employed to recruit 20 adult survivors between the ages of 18 and 65 who were sexually abused by a family member. Average age of participants was 40.1 years; 60% of participants were female and 40% male. Average age of onset of abuse was 6.7 years. Mixed cinical and noncinical sample. The majority had received treatment for CSA at some point in their ves | Four major themes emerged suggesting that CSA discipline can be significantly compromised when certain family conditions exist: (1) lightly fixed, gender role based on a patriarchy-based family structure; (2) presence of family violence; (3) closed, indirect family communication patterns; and (4) social attion of the family as whole, or specific members, played a part in CSA victimism feeling they had no one safe to tell. Family systems formulations through a feministic enslave important in understanding children and families at risk of discipline barriers | Over half the participants had not disciplined the abuse during childhood. Of the nondiscipline participants, six did not discipline because they had repressed or forgotten the memory. A most one third within discipline intentionally. More data are needed on early disciplines to garner more information on facilitators of discipline. Retrospective approach implies recall sisters. High level of trustworthiness of the data and interpretations were achieved through credibility, dependability, and confirmability through direct quotes | +| A agg a (2005) | The study purpose was to qualify explore dynamics that impede or promote discipline by examining a range of factors including gender as a dynamic—how disciplines of females and males are similar and different, and in what ways gender affects CSA discipline | Survivors of CSA were interviewed about their discipline experiences using LIM. Analysis of 30 participant narratives was used for theme development regarding impact of gender on discipline. Interviews were transcribed verbatim for open, axial, and selective coding. Categories and subcategories were collapsed and refining into theme areas | Purposive sampling of women and men, along with those who disciplined during the abuse and those who did not. 19 females and 11 males; 18–65 (mean 40.1) years who were sexually abused by a family member or a trusted adult. Average age of abuse onset was 5.3 years; 36% were nonwhite, and 58% had not disciplined during childhood | Three themes emerged for men that inhibited or precipitated discipline for reasons related to gender: (1) fear of being viewed as homosexual; (2) profound feelings of stigmatization or solicition because of the belief that boys are rarely victimized; and (3) fear of becoming an abuser, which acted as a precipitant for discipline. Two predominant themes with female participants related to difficulties disciplining: (1) they felt more conflicted about who was responsible for the abuse and (2) they more strongly anticipated being blamed and/or not believed | One in a dearth of studies that conduct gender analysis. Comparative analysis draws out important practice implications. Retrospective design of the study which implies possibility of sisters. High level of trustworthiness of the data and interpretations were achieved through credibility, dependability, and confirmability through direct quotes | +| Collings, Griffiths, and Kumalo (2005). | Study examined patterns of discipline in a large representative sample of South African CSA victims. Two study objectives to: (1) examine how and | Field reviews of a social work and medical case field for CSA victims seen at the crisis center where a case of CSA reported to the North Durban | 1,737 cases of CSA reported in the North Durban area of KwaZulu-Nata, South Africa, during January 2001 to December 2003. 1,614 girls and no theme areas | Content analysis dentified two broad dimensions of discipline: (1) agency: child-initiated discipline versus detection by a third party and (2) temporal duration: an event versus a process. These discipline dimensions defined four discrete categories of | These results find two broad discipline framework. Through data analysis two raters coded discipline categories using author's discipline framework, which proved to be both exhaustive and mutually exclusive | + +Table I. (cone nued) + +| Study | Purpose | Design | Sample | Findings | Summary | +|----------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------| +| Hershkowitz, Horowitz, and Lamb (2005). | This study aimed to dental characteristics of suspected child abuse victims that are associated with discissorian and formal nevestigations | Large database of suspected cases of physician and sexual abuse investigated in Israel between 1998 and 2002 was analyzed. Interviews were also conducted using standardized NICHD linestigative Interview Protocol. Archival data were analyzed | The sample was comprised of 26,446 of 3- to 14-year-old abuse victims of sexual and physical abuse interviewed in Israel in the 5-year period from 1998 to 2002. 140 experienced trained youth investigators conducted interviews | Overall, 65% of the 26,446 children made a legal ons when interviewed. Rates of discissorian were greater for sexual abuse (71%) over physical abuse (61%). Children of a legal were less likely to discisse/abuse when a parent was the suspected perpetrator. Discissorian rates increased as children grew older; 50% with 3- to 6-year-olds, 67% of the 7- to 10-year-olds, and 74% of the 11- to 14-year-olds discissed abuse when questioned | Overall findings indicated that rates of discissorian varied systematically depending on the nature of the legal offences, the relationship between a legal victims and suspected perpetrators, and the legal of the suspected victims. Analysis only involved cases that had come to the attention of official agencies, making it difficult to determine how many of abuse take place without ever triggering any kind of official investigation. Evidence for delayed discissories. | +| Jensen, Guibrandisen, Mossige, Reicheit, and Tjers and (2005). | This study investigated the context in which children were able to report their child sexual abuse experiences; their views as to what made it difficult to talk about abuse; what he ped them in the discissing process; and their parent's perceptions of their discissorian processes | Qualitative approach to data collection and analysis was used. Therapeutic interviews of the children and mostly their mothers were analyzed through a qualitative approach. Follow-up interviews were held 1 year after the study investigated | 20 families with a total of 22 children participated. A children had to diabout children had to diabout experiences that created concerns for care-givers about CSA. Children's ages ranged between 3 and 16 years (average age 7.5 years); 15 girls and 7 boys. Sexual abused by someone in the family or a citizen | None of the children to diabouse immediately after it occurred. Children exposed to repetitive abuse kept this as a secret for up to several years; 17 to die their mothers first, 3 first to diafriend, 1 to die their father, and 1 their uncle. Majority of remarks that led to the suspiction of CSA were made in situations where someone engaged the child in a diagnose about what was bothering them, resulting in a referral. The children felition was difficult to find situations containing enough privacy and prompts that they could share their experiences. When the children died | The results indicate that discissorian situational fundamentally dialogical process that becomes less difficult if children perceive that there is an opportunity to talk, a purpose for speaking and a connection has been established to what they are talking about. Strengthening parent-child relationships is an important practice implication | +| | | | | | | + +ICOtitinUed) + +**Table 1.** (continued) + +| Study | Purpose | Des gn | Samp e | F nd ngs | Summary | +|--------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------| +| Sta er and Ne son-Garde (2005) | The purpose of th s study was to understand the fu process of CSA d sc osure and how th s unfo ded for preado escent and ado escent g r s. Exam ned what fac tated and h ndered d sc osure and subsequent consequences | Secondary ana ys s of qua tat ve focus group data. Or g na project cons sted of four focus groups conducted w th n the context of ongo ng therapy for g r s who had exper enced CSA. Secondary ana ys s cons sted of wr tten narrat ve summar es of each sess on group ng these conceptua y, and exam n ng the r nterconnectedness | Samp e cons sted of 34 part c pants from four groups. Sess ons ana yzed were between 60 and 90 m n ong; aud otaped and ater transcr bed for content ana ys s | F nd ngs are reported n three major doma ns: (1) se f-phase: where ch dren come to understand v ct m zat on nterna y; (2) conf dant se ect on-react on phase: where they se ect a t me, p ace, and person to te and then whether that person's react on was support ve or host e; and (3) consequences phase: good and bad that cont nued to nform the r ongo ng strateg es of te ng. The act ons and react ons of adu ts were s gn f cant and nformed the g r s' dec s ons. The consequences phase was further subd v ded nto four aspects: (1) goss p ng and news networks, (2) chang ng re at onsh ps, (3) nst tut ona responses and the after fe of te ng, and (4) ns der and outs der commun t es | Th s study prov ded a contextua exam nat on of the ent re d sc osure process, c oser to the po nt n t me when the abuse and d sc osure occurred. Sma groups of preado escent and ado escent g r s who had surv ved sexua abuse a so served as consu tants and were encouraged to share the r know edge for the benef t of profess ona pract t oners | +| A agg a (2004) | The study sought to exam ne nf uences that nh b t or promote ch dren's d sc osure of CSA to address gaps n know edge about how, when, and under what c rcumstances v ct ms of CSA d sc ose | The study emp oyed LIM—a phenomeno og ca des gn. Intens ve nterv ew ng that were 2 hr ong on average generated data for a themat c ana ys s. The nterv ew gu de was | Us ng purpos ve samp ng 24 adu t surv vors of ntrafam a abuse between ages of 18 and 65 (average age 41.2) were recru ted from agenc es and one un vers ty; 57% ma e and 43% fema e; | Through ana ys s of the nterv ew new categor es of d sc osure were dent f ed to add to ex st ng types. Three prev ous y dent f ed were conf rmed n these data: acc denta , purposefu , and prompted/e c ted accounted for 42% of d sc osure patterns n the study samp e. Over ha f the d sc osure patterns descr bed by the study samp e d not f these | Th s study expanded types of CSA d sc osures to more fu y understand how ch dren and adu ts d sc ose. And under what c rcumstances. Ask ng peop e to recount events that occurred n ch dhood s suscept b e to memory fa ure, espec a y when memor es were forgotten, | + +Table I. (tont nued) + +| Study | Purpose | Design | Sample | Findings | Summary | | +|---------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------| +| Crisma, Basce, Pac, and Rom to (2004) | The main goals of this study were to understand impediments that prevent adolescents from disciosing CSA and seeking help from the risk of a network and/or the services | In-depth telephone (anonymous) interviews were conducted after informed consent was explained and CSA and seeking help from the risk of a network and/or the services | The sample was comprised of 36 young people who experienced sexual abuse in adolescence; 35 females and 1 male; aged 12–17. Some of the sample experienced sexual violence in a dating relationship | The main impediments to disciose to a family member were: fear of not being believed, shame, and fear of causing trouble to the family. The main impediments for not seeking services were: unaware of appropriate services, wish to keep the secret, acklof awareness of being abused, mistrust of adults and professionals, and fear of the consequences of disciosing sexual abuse. When they did disciose to professionals, teens received very limited support as many professionals were not trained on sexual abuse and could not offer appropriate interventions to victims | This study represented the findings of a mixed sample of survivors of child sexual abuse and nitmate partner violence. The study was conducted in litaly and this is not clear what sexual abuse response training is available. There may have been a selection basis as the most dissatisfied survivors responded to the research categories | delayed, or repressed and ater recovered. Distortion and revision of events are a so potential problems in recall. High degree of trustworthiness of the data was achieved and quotes provided supported the categories | +| Jonzon and Lindbad (2004) | Study purpose was to explore how abuse traits, openness, reactions to CSA disciosure, and social support were related. Differences based on severity of abuse, timing and outcomes of disciosure, social support, and predicting factors of positive and negative reactions were probed | Adult women reporting CSA by someone close were interviewed using semi-structured guides together with questionnaires. Data on victim zation and current social support were retrieved through the questionnaires, and data on disciosure and reactions were gathered through the interviews with participants | 122 adult women between 20 and 60 years old (average age of 41 years) reporting exposure to child sexual abuse by someone close before the age of 18 and had to disomeone about at east one abuse event. 90% were Swedish subjects. Purposive sampling strategy was used | Abuse characteristics: abuse by multiple perpetrators was more common than by a single perpetrator. Age of onset was often before age of 7, with an average duration of 7 years. Severely abused women had taked to more of their social network, especially to professionals. Disciosures: 32% disciosed during childhood (before the age of 18) with an average of 21 years delay. Women who had disciosed in childhood reported more instances of physical abuse, multiple perpetrators, use of violence, and were more likely to have confronted a perpetrator, and had received a negative first reaction. Factors received a negative first reaction. | 68% delayed disciosure until adulthood. At the time of the study, this was one of the first studies to focus on the interplay between social support networks and disciosure of child sexual abuse. The study results are somewhat limited by an overrepresentation of severely abused women. Retrospective study and self-report of information could imply recall sistes and thus limits the accuracy of the information obtained on abuse and disciosure | | + +;el a. Table I. (cont nued) + +| Study | Purpose | Design | Sample | Findings | Summary | | +|--------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------| +| Kogan (2004) | The purpose of this study was to dentify factors that influence the discosures made by female survivors of USE in childhood and adolescence. The predictors of both the timing of discosure and the recipient of the discosure were investigated | Data were gathered from a subsample of female adolescents that participated in the NSA, which consisted of structured phone interviews. USEs reported in the NSA were assessed using a modified version of the Incident Cassification Interview. They were then asked a series of questions about each episode of unwanted sexual contact including event characteristics and perpetrator characteristics | A subsample of 263 adolescent females between 12 and 17 years old, mean age of 15.2 years old, who reported at east one experience of unwanted sexual contact in the NSA. Participant characteristics, USE characteristics, and family contextual attributes were explored | Children under the age of 7 were at a higher risk for delayed discosures. Participants whose USE occurred between the ages of 7 and 13 were most between the ages of 7 and 13 were most less likely to tell an adult. Adolescents (14–17) were more likely to tell only peers than children aged 7–10 years. Children under 11 were more likely to tell an adult, but were at risk for delaying discosure beyond a month. Children aged 11–13 tended to discose within a month. Coloser relationship to the perpetrator or a family member was associated with delayed discosure. Immediate discosure was more likely with stranger perpetration. Fear for one's fellduring and penetration were associated with discosure to adults. Family factors inked to discosure were (1) drug abusing household member, which made survivors more likely to discose more promptly and (2) never ving with both parents was associated with nondiscosure | This study examined factors including discosures of USEs in childhood and adolescence in a nationally representative sample of female adolescents who participated in the NSA. Surveys for investigations of victimization experiences may be based due to underreporting. Adolescents who refused to report or discuss an USE may represent a source of systematic bias and would make the results generalizable only to adolescents who are wing to discose USE via survey. A thought data may be retrospective, recall bias may have been minimized in this study since participants were adolescents, and so the time age between the USE and the interview were presumably shorter than a study of adult participants recalling CSA experiences | design does not allow for definition conclusions of cause and effect on the relationships found | +| | Ede stein, Goodman, Jones, and Gordon (2003) | The purpose of this study was to investigate variables associated with delay of discosure of CSA and test a mode for factors that influence how quickly children discose sexual abuse | Case flier reviews of data obtained from prosecution flies, as well as from structured interviews with the children's caretaker and observations of child interviews. Trained graduate students and one victim advocate completed the Sexual Assault Profile | Sample consisted of 218 children referred to prosecutors' offices for a leged CSA. A children in the sample had discosed their abuse in some manner. Children ranged in age from 2 to 16 years at the beginning of abuse; 3–16 years at the end of the abuse, and 4–16 years at the time of the years | 64% discosed within a month and 29% within 6 months. Five variables for the mode were tested. (1) age: children who were older took onger to discose and older children feared more negative consequences to others than younger children; (2) type of abuse: victims of nitrafamilial families took onger to discose—victims of nitrafamilial abuse feared greater negative consequences to others compared to victims of extrafamilial abuse; (3) fear of negative consequences: children who feared | This study represents a higher rate of discosers within a month. These cases had been reported to authorities and were in process of prosecution with chill may explain higher rate of early discosures. Legal sample with higher rate of extrafamilial abuse (52%) may also account for earlier discosures. Mode suggests that older children, victims of nitrafamilial abuse; felt greater responsibility for the abuse, and perceiving | + +Table 1. (coot nued) + +| Study | Purpose | Design | Sample | Findings | Summary | +|-----------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------| +| Smith, Letourneau, Saunders, Kpatrick, Resnick, and Best (2000) | The study focus was to gather data from a large sample of women about the ength of time women who were raped before age 18 deayed discosure who they discosed to, and variables that predicted discosure within 1 month | Structured telephone interviews that asted approximately 35 min were used to collect data using a computer-assisted telephone interview system. A telephone interviews were conducted with who were conducted with each question on a computer screen. The survey consisted of several measures designed to elicit demographic information, psychiatric symptoms, substance use, and victim zation history. The present study reports on data from the demographic and child rape victim zation | Two probability samples. Wave 1 was a random sample of 2,009 respondents selected from stratified samples of defined jurisdictions. Random digital dialog was used to solicit households for sted and united telephone numbers. Second random sample of 2,000 women between the ages of 18 and 34 was selected. Both Wave 1 and Wave 2 data were weighted to conform to the 1989 Census statistics | The study reported that the study's definition of the first rape was 10.9 years. Of the 288 women who reported a child rape, 28% stated that they had never to dialyone about this sexual assault until specifically queried by the interviewer for this study. 58% did not discose for over 1 year and up to 5 years post-rape. 27% discosed within a month. Among women who discosed prior to their NWS interview cose friends were the most common person to whom victims made discosures, followed by mothers and other nimed ate family members. Fewer than 10% of victims reported making their nital discosure to social workers or awlenforcement personnel. Only 12% of child rape victims stated that their assaults were reported to authorities at some point | The time frame of this survey may have had contextual implications. The majority of child rapes reported by this sample occurred prior to the arge-scale child assault prevention education programs that were begun in the 1980s that teach children that assaults (including CSA) are wrong and should be discosed to responsible adults. This information may have influenced (and may currently be influencing) young women's discosure patterns. For Wave 1, comparison of these data with the population parameters obtained from the U.S. Census Bureau indicated that the sample cosely matched the demographic attributes of the population of U.S. women | +| | | | nital police report; 77% female, 70% Caucasian, 17% Hispanic, and 11% African American. Predominantly middle to ow SES. Approximately 47% nitraliamila abuse | negative consequences of discosure took onger to discose, children who believed that their discosure would bring harm to others took onger to discose, fear of negative consequences to the self or the perpetrator was unrelated to time of discosure, and girls more than boys feared negative consequences to others; (4) Perceived responsibility for the abuse took onger to discose and older children felt more responsibility for the abuse; and (5) gender was not significantly correlated with time to discosure | negative consequences to discosing took onger to discose. We -designed study with high eveloped rigor. Produced a valuable mode of discosure for further investigations. However, researchers were not able to interview children directly | + +quest ons + +Note. SCL-90 = Symptom Check List-90: SES = socioeconomic status: L N = ong interview method: CA = chi d sexua abuse: N CHD = Nationa nstitute of Chi d Heath and Human Deve opmenc USE = unwanted sexua experiences: NSA = Nationa Survey of Ado escents: NWS = Nationa Women's Study: Q DS = Questionnaire informattse sur es dE inquants sexeu s. examples of this usage were found in the research questions, interview guides, and surveys examined: "How and when do people decide to tell others about their early sexual experiences with adults?" (Hunter, 2011, p. 161); "Some men take many years to tell someone that they were sexually abused. Please describe why it may be difficult for men to tell about/discuss the sexual abuse" (Easton, Saltzman, & Willis, 2014, p. 462). "Participants were asked a series of open-ended questions to elicit a narrative regarding their experiences of telling..." (McElvaney, Greene, & Hogan, 2012, p. 1160). "Who was the first person you told?" (Schaeffer, Leventhal, & Anes, 2011, p. 346). + +There was sound consistency between studies, defining disclosure in multifaceted ways with uniform use of categories of prompted, purposeful, withheld, accidental, direct, and indirect. However, defining the period of time that would delineate a disclosure as delayed varied widely across studies, wherein some studies viewed I week or I month as a delayed disclosure (i.e., Hershkowitz et al., 2007; Kogan, 2004; Schembucher, Maier, Moher-Kuo, Schnyder, & Lamdolt, 2012). Other studies simply reported average years of delay sometimes as long as from 20 to 46 years (Easton, 2013; Jonzon & Linblad, 2004; Smith et al., 2000). + +Second, the number of qualitative studies has increased significantly over the last 15 years. This rise is in response to a previous dearth of qualitative studies. Based on Jones's (2000) observation that disclosure factors and outcomes had been well documented through quantitative methods; in a widely read editorial, he recommended "Qualitative studies which are able to track the individual experiences of children and their perception of the influences upon them which led to their disclosure of information are needed to complement ... " (p. 270). + +Third, although a few studies strived to obtain representative samples in quantitative investigations (Hershkowitz, Horowitz, & Lamb, 2005; Kogan, 2004; Smith et al., 2000), sampling was for the most part convenience based, relying on voluntary participation in surveys and consent-based participation in file reviews (Collings, Griffiths, & Kumalo, 2005; Priebe & Svedin, 2008; Schembucher et al., 2012; Ungar, Barter, McConnell, Tutty, & Fairholm, 2009a). Therefore, generalizability of findings is understandably limited. The qualitative studies used purposive sampling as is deemed appropriate for transferability of findings to similar populations. Some of those samples contained unique characteristics, since they were sought through counseling centers or sexual advocacy groups. These would be considered clinical samples producing results based on disclosures that may have been delayed or problematic. This might presumably produce data skewed toward bathers and bring fonvard less information on disclosure facilitators. + +Through an in-depth, second-level analysis, this review identified five distinct themes and subthemes beyond the general trends as noted earlier. + +Theme 1: Disclosure is viewed as an ongoing process as opposed to a discrete event—iterative and interactive in nature. A subtheme was identified regarding disclosure as being facilitated within a dialogical and relational context is being more clearly delineated. + +Theme 2: Contemporary disclosure models reflect a social—ecological, person-in-environment perspective to understand the complex interplay of individual, familial, contextual, and cultural factors involved in CSA disclosure. Subthemes include new categories of disclosure and a growing focus on previously missing cultural and contextual factors. + +Theme 3: Age and gender are strong predictors for delaying disclosure or withholding disclosure with trends showing fewer disclosures by younger children and boys. One subtheme emerged that intrafamilial abuse/family-like relationship of perpetrator has a bearing on disclosure delays or withholding. + +Theme 4: There is a lack of a cohesive life-course perspective. One subtheme includes the lack of data within the 18 to 24-year-old emerging adult population. + +Theme 5: Significantly more information is available on barriers than on facilitators of CSA disclosure. Subthemes of shame, self-blame, and fear are uniformly identified as disclosure deterrents. + +# Disclosure as an ongoing process: Iterative and interactive in nature. + +Disclosure is now generally accepted as a complex and lifelong process, with current trends showing that CSA disclosures are too often delayed until adulthood (Collin-Vezina et al., 2015; Easton, 2013; Hunter, 2011). Knowledge building about CSA disclosure has moved in the direction of understanding this as an iterative and interactive process rather than a discrete, onetime event. Since the new millennium, disclosure is being viewed as a dynamic, rather than static, process and described "not as a single event but rather a carefully measured process" (Alaggia, 2005, p. 455). The catalyst for this view originates from Summit (I 983) who initially conceptualized CSA disclosures as process based, although this notion was not fully explored until several years later. Examinations of Summit's (1983) groundbreaking proposition of the CSA accommodation (CSAA) model produced varying results as to whether his five stages of secrecy, helplessness, entrapment and accommodation, delayed, conflicted, and unconvincing disclosures, and retraction or recantation, hold validity (for a review, see London, Bruck, Ceci, & Shuman, 2005). However, the idea of disclosure as a process has been carried over into contemporary thinking. + +Recently, McElvaney, Greene, and Hogan (2012) detailed a process model of disclosure wherein they describe an interaction of internal factors with external motivators which they liken to a "pressure cooker" effect, preceded by a period of containment of the secret. Moreover, this and other studies strongly suggest disclosures are more likely to occur within a dialogical context—activated by discussions of abuse or prevention forums providing information about sexual abuse (Hershkowitz et al., 2005; Jensen, Gulbrandsen, Mossige, Reichelt, & Tjersland, 2005; Ungar et al., 2009a). The term + +dialogical simply means to participate in dialogue. Key dialogical vehicles identified in these studies were providing sexual abuse information through prevention programs, being asked about sexual abuse, and being prompted to tell (McElvaney et al., 2012; Ungar et al., 2009a). + +Contemporary models of CSA disclosure reflect a social cological perspective. Knowledge on CSA disclosure has been steadily advancing toward a holistic understanding of the complex interplay of individual, familial, contextual, and cultural factors (Alaggia & Kirshenbaum, 2005; Brazelton, 2015; Fontes & Plummer, 2010). Where at one time factors examined and identified were predominantly of intrapersonal factors of child victims, knowledge construction has shifted to fuller social ecological, person-in-environment explanations (Alaggia, 2010; Collin-Vezina et al., 2015; Easton et al., 2014; Hunter, 2011; Ungar, Tutty, McConnell, Barter, & Fairholm, 2009b). Social-ecological explanations open up more opportunities to intervene in facilitating earlier disclosures. Alaggia (2010) proposes an ecological mapping of what individual, interpersonal, environmental, and contextual influences impede or promote CSA disclosures based on analysis of in-depth interview data of 40 adult survivors. Subsequently, based on a sample of 67 adult survivors, Collin-Vezina, Sablonni, Palmer, and Milne (2015) identified three broad categories, closely aligned with an ecological framework that impede CSA disclosure: (1) barriers from within, (2) barriers in relation to others, and (3) bathers in relation to the social world which can be aligned to intrapersonal, interpersonal, and contextual factors. + +A summary of knowledge building using a social—ecological framework follows. Knowledge gained in the intrapersonal domain includes expanded conceptualization of disclosure by building on previous categories of accidental, purposeful, and prompted disclosure to also include behavioral and indirect attempts to tell, intentionally withheld disclosure, and triggered and recovered memories (Alaggia, 2004). Categories of indirect behavioral disclosure patterns have been further verified in follow-up research by Hunter (2011), and through an extensive file review that used Alaggia's (2004) disclosure framework to analyze their data (Collings et al., 2005) for verification. + +Interpersonal factors have also emerged in regard to certain family characteristics as disclosure barriers. Families with rigidly fixed gender roles, patriarchal attitudes, power imbalances, other forms of child abuse and domestic violence, chaotic family structure, dysfunctional communication, and social isolation have been found to suppress disclosure (Alaggia Kirshenbaum, 2005; Collin-Vezina et al., 2015; Fontes & Plummer, 2010). In addition, relationship with perpetrator is a factor whereby research indicates that disclosure is made more difficult when the perpetrator is a family member or close to the family (Dumont, Messerschmitt, Vila, Bohu, & Rey-Salmon, 20 I 4;Easton, 2013; Goodman-Brown et al., 2003; Hershkowitz et al., 2005; Priebe & Svedin, 2008; Schanbucher et al., 2012). This is especially a barrier when the perpetrator lives with the victim (LeClerc & Wortley, 2015). + +In terms of environmental factors, one study revealed that neighborhood/community conditions can hinder disclosure when there is lack of school involvement in providing a supportive environment, such as in following up on troubling student behavior (Alaggia, 2010). Additionally, a child victim's anticipation of a negative response to disclosure, especially that they may not be believed by others outside their family such as neighbors or other community members, has shown to deter disclosure (Collin-Vezina et al., 2015). + +Cultural factors influencing CSA disclosure have been studied to a much lesser degree. Despite this, a few important studies examining critical sociocultural factors now exist for better understanding CSA disclosure within a cultural context (Brazelton, 2015; Fontes & Plummer, 2010). Among these important contributions, Brazelton's (2015) research has delineated CSA disclosure processes as "shaped by relational, racial, socio-cultural, historical, and developmental factors" (p. 182). In a unique study using culturally focused research literature as data triangulated with clinical case material, culturally based belief systems in many cultures have been found to foster family climates that can silence children from disclosing abuse (Fontes & Plummer, 2010). Taboos about sexuality, patriarchal attitudes, and devaluation of women are among some of the cultural barriers that inhibit disclosure (Fontes & Plummer, 2010). + +Clearly, disclosure conceptualizations are being integrated into a social—ecological model of individual and developmental factors, family dynamics, neighborhood, and community context as well as cultural and societal attitudes toward better understanding disclosure barriers and facilitators (Alaggia, 2010), although more data are needed on cultural and contextual factors. + +# Age and gender as predictors of disclosure + +Age. Age is consistently found to be an influential factor in CSA disclosure, making the life stage of the victim/survivor a critical consideration. Studies draw distinctions in age-groups falling into either under or over 18 years of age. Eighteen years of age was the common age cutoff point that investigators chose in order to distinguish child/youth populations from adult samples. Sixteen of the studies drew on samples of children and youth, while the other 15 studies sampled adults over the age of 18, and a further two studies used mixed age-groups (refer to Table I). Among the child and youth samples, the age ranges spanned from preschool to late adolescence (3-17 years of age), with varying methodological approaches implemented across age cohorts. For younger cohorts, file reviews and secondary data analyses of CSA reports were typically undertaken. Adolescents were most often given surveys. Sometimes children and youth were interviewed as part of administering a survey or as a follow-up (Crisma et al., 2004; Hershkowitz et al., 2005; Ungar et al., 200%). In the majority of child and adolescent samples, sexual abuse concerns were already flagged to investigative authorities. However, the work of Ungar, Barter, McConnell, Tutty, and Fairholm (2009a, 200%) is one exception, whereby their survey elicited new disclosures. + +Adult studies typically had a mean age between 40 and 50 years. Interviews were the main data collection method with a few exceptions using survey designs (i.e., Easton, 2013; Kogan, 2004; Smith et al., 2000) and case file reviews (i.e., Collings et al., 2005; Goodman-Brown et al., 2003). Results show a clear trend toward increased likelihood of disclosure in older youth, and findings from adult samples showing a preponderance of disclosures in adulthood, with the large majority of participants of adults reporting never having had a sexual abuse complaint filed with investigative authorities as a child or an adolescent (i.e., Hunter, 2011; Gagnier & Collin-Vezina, 2016; Sorsoli, Kia-Keating, & Grossman, 2008; Ungar et al., 200%). + +With children and youth under the ages of 18 distinct patterns emerged. First, accidental detection, rather than purposeful disclosure, is more likely to occur with younger children. For example, in one large-scale study of over 1,737 file reviews, over half of the CSA-related cases were identified through accidental and eyewitness detection (61%), while less than one third were purposeful disclosures initiated by the child victim (Collings et al., 2005). A second pattern which emerged is that rates of disclosure increase with age, especially into adulthood, which is supported by persistent findings of high rates of delayed disclosure reported later in the life course by adult survivors (Collings et al., 2005; Collin-Vezina et al., 2015 ; Easton, 2013; Jonzon & Linblad, 2004; Kogan, 2004; Leclerc & Wortley, 2015; Sorsoli et al., 2008). While gender and relationship with the perpetrator are considerable factors in CSA disclosure, age is consistently a stronger predictor of disclosure (or nondisclosure) (Hershkowitz et al., 2005; Leclerc & Wortley, 2015). Third, younger children who disclose are more likely to do so in an interview situation or other environment that provides prompts or questions about sexual abuse (Hershkowitz et al., 2005; McElvaney, Greene, & Hogan, 2014; Schaeffer et al., 2011), but this trend can also be seen in older youth (Ungar et al., 2009a, 2009b). + +Gender. A number of studies have recently focused on CSA disclosures with male victims, since males have been an understudied population (Alaggia, 2005; Easton, 2013; Easton et al., 2014; Gagnier & Collin-Vezina, 2016). Most investigations that sampled both sexes show females outweighing male participants. Although women are at double the risk of being subjected to CSA, the ratio of women to men in most disclosure studies has not been representative. This finding may be indicative of male victims more likely delaying disclosing their CSA experiences, leaving male disclosure in child and youth samples underrepresented (Hebert, Tourigny, Cyr, McDuff, & Joly, 2009; Ungar et al., 2009b). + +Easton, Saltzman, and Willis (2014) have been developing gender-specific modeling of disclosure examining male disclosures. Their proposed model groups male disclosures into barrier categories as determined by individual factors, interpersonal issues, and factors that are sociopolitical in nature. These authors suggest that predominant gender norms around masculinity reinforce the tendency for male victims of CSA to blame themselves + +for the abuse, resulting in no disclosure. Male participants in a subsequent study also relayed that gender norms and stereotypes contributed to them concealing the abuse because they were abused by a woman (Gagnier & Collin-Vezina, 2016). In the one study that compared male and female disclosures, investigator found that men's fears of being viewed as homosexual; profound feelings of stigmatization or isolation because of the belief that boys are rarely victimized; and fear of becoming an abuser acted as disclosure barriers. Whereas females felt more conflicted about who was responsible for the abuse and more strongly anticipated being blamed and not believed (Alaggia, 2005). + +Lack of a life-course perspective. Given that the study of CSA disclosure draws on age-groups ranging from samples of very young children to retrospective studies of adult survivors, with significant developmental considerations, this area of study lacks an intentional cohesive life-course perspective. Most data are derived from either cross-sectional or retrospective designs, with few longitudinal studies. There are a series of sound, yet disconnected, studies focusing on specific age-groups of children and adolescents, along with adult retrospective studies. Thus, the available knowledge base does not allow for a cohesive picture of CSA disclosure processes and pathways over the life course to emerge. + +The life-course perspective has long been recommended as a critical lens for the study of child abuse (Browning & Laumann, 1997; Williams, 2003). For example, a life-course perspective has been utilized to understand the immediate- and long-term effects of CSA on the developing child victim (Browning & Laumann, 1997). Further, a life-course perspective is important in terms of examining age of onset of CSA to explain the differential effects of sexual victimization and developmental impacts in terms of understanding their ability to disclose—effects that need to be understood within a developmental context, especially for designing appropriate interventions for disclosure at critical transitions from early childhood through to adolescence and into adulthood. In addition, important "turning points" in life may facilitate disclosures. For example, entry into adulthood given that delayed disclosure occurs more often in adulthood. Alaggia (2004, 2005) found that being in a committed relationship or the birth of children acted as facilitators for some survivors to disclose, especially to their spouses. These significant life events, as contributing to disclosures, bear further examination. + +Summary of barriers and facilitators. Research over the past 15 years continues to uncover barriers to CSA disclosure at a higher frequency than that of facilitators. As stated previously, this might be the result of sampling methods whereby participants who volunteer for disclosure research may have had more negative disclosure experiences, especially since many report delays in disclosure. The following section outlines the major trends in both barriers and facilitators (see Table 2). + +Barriers. Age and gender were found to contribute to barriers as covered in Theme 3. Disclosures generally increase with age + +Table 2. Factors Influencing Child Sexual Abuse Disclosures. + +| Barriers | Facilitators | +|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------| +| Age: The younger the child victim, the less likely they will purposefully disclose. | Age: Disclosures increase with age, especially in adulthood. | +| Gender: Males may be less likely to disclose in childhood/adolescence, fear of being seen as homosexual and as a victim, females experience more self blame and anticipation of being blamed and/or not believed | Gender: Slight trend toward females who are older (adolescent) to disclose before adulthood | +| Relationship to perpetrator: If the perpetrator is a family member or in a family like role, disclosure is less likely to happen | Relationship to perpetrator: If the perpetrator is not living with the victim, disclosure rates increase | +| Internal: Shame, self blame, and fear are psychological barriers. In addition, fear of negative consequences on the family and for self safety inhibits disclosure | Dialogical context: Opportunities to disclose through discussion, therapeutic relationship, information sessions on sexuality, and sexual abuse prevention programs | +| Family relations: Families with a patriarchal structure, rigidly fixed gender roles, dysfunctional communication, other forms of abuse (i.e., domestic violence), and isolation inhibit disclosure | Family relations: Supportive parent-child relationship. | +| Environmental and cultural context: Lack of discussion about sexuality; passive acceptance that unwanted sexual experiences are inevitable; not wanting to bring shame to the family by admitting sexual abuse; lack of involvement from neighbors, school personnel; and stigma perpetuated by societal perceptions | Involvement of others: Eyewitnesses coming forward and reporting; detection through community members, professionals | +| | Environmental and cultural context: Promotion of open discussion of sexuality; community member involvement | + +as children gain more developmental capacity, understanding of sexual abuse as victimization, and increased independence. Males are somewhat less likely to disclose, but this is often in interaction with other factors in the environment such as societal attitudes that promote hypermasculinity as desirable, attitudes that perpetuate negative views of boys and men who are victims, and homophobic attitudes (Alaggia, 2010; Easton et al., 2014; Gagnier & Collin-Vezina, 2016). + +Victims of intrafamilial abuse when the offender is a parent, caregiver, significant family member, or someone in a familylike role are less likely to disclose immediately or at all in childhood/adolescence because of obvious power differentials and dependency needs (Collings et al., 2005; Dumont et al., 2014; Hershkowitz et al., 2005; Kogan, 2004; Leclerc & Wortley, 2015; Paine & Hansen, 2002; Schaeffer et al., 2011). + +Further, the perpetrator residing with their victim(s) increases the likelihood of no disclosure (Leclerc & Wortley, 2015). + +Internalized victim-blaming, mechanisms to protect oneself (such as minimizing the impact of the abuse), and developmental immaturity at the onset of abuse constituted internal barriers. Further, shame, self-blame, and fear have been identified as significant factors deterring disclosure (Collin-Vezina et al., 2015; Crisma et al., 2004; Goodman-Brown et al., 2003; Hunter, 2011; Kogan, 2004; McElvaney & Culhane, 2015; McElvaney et al., 2014). However, aspects of shame, self-blame and fear, and have not been fully explored in research. Since these are strong predictors of disclosure suppression, they bear further examination in future research to understand more fully how they operate in disclosure processes. + +In terms of interpersonal and environmental factors, family dynamics can play a part in deterring disclosure. As previously mentioned, families characterized by rigidly defined gender roles, patriarchal attitudes that perpetuate power imbalances between men and women, parents and children, presence of other forms of child abuse and/or domestic violence, chaotic family structure, dysfunctional communication, and social isolation have been found to suppress disclosure (Alaggia & Kirshenbaum, 2005; Collin-Vezina et al., 2015; Fontes & Plummer, 2010). In regard to broader environmental factors, disclosure can be hindered when involved and supportive community members are not available, or not trained in sensitive responses, or when child victims anticipate not being believed by neighbors and other people outside the family (Alaggia, 2010; Collin-Vezina et al., 2015). Further, barriers in relation to the social world were identified as stigmatization, the negative labeling of sexual abuse victims, and taboos surrounding sexuality and talking about sex as driven by cultural norms (Collin-Vezina et al., 2015; Fontes & Plummer, 2010). + +Identification of cultural barriers is important recent contribution to understanding disclosure processes—and in particular to the obstacles. Findings related to cultural barriers included themes of children's voices not being heard leading to silencing, the normalization of the sexualization and objectification of girls and women, and the perpetuation of hypermasculinity in men—all acting as barriers in terms of stigma to disclosure (Alaggia, 2005, 2010; Easton et al., 2014). Brazelton (2015) similarly found that lack of discussions about sex, young age at the onset of sexual abuse, therefore not having the language to express what was happening to them, and preserving the family good name by not talking about abuse in the family were also barriers to disclosure. + +Finally, it may be the case that more barriers continue to be identified over facilitators of CSA disclosure perhaps because of the methods employed in studies—particularly those drawing on adult populations who delayed disclosure. These samples may not be representative of the overall population of CSA victims, since they may have had more negative disclosure experiences, consequently more readily identifying barriers. On the other hand, these findings may speak to the actual imbalance between facilitating factors and barriers for disclosure, the latter carrying more weight in the victims/survivors' experiences, thus, explaining the high rates of disclosures delayed until adulthood. + +Facilitators. Although fewer disclosure facilitators are identified in this review, very important facilitators were nonetheless uncovered—ones that should be noted for professionals in this field of practice. Internal factors that facilitate disclosures include symptoms that become unbearable, getting older with increased developmental efficacy, and realizing that an offence was committed (Collin-Vezina et al., 2015; Crisma et al., 2004; Easton, 2013; Hershkowitz et al. 2007; McElavaney, Greene, & Hogan, 2014; Schaeffer et al., 2011). Circumstantial facilitators are those where the child discloses because there has been evidence provided, eye-witnessing has occurred, and a report has been made. Environmental factors include settings that provide opportunities such as counseling, interviews, information sessions and educational forumsAvorIcshops, and prevention programs for children and youth to disclose. + +To elaborate, dialogical contexts about CSA for children and youth can provide opportunities for discussion that may facilitate disclosures (Jensen et al., 2005). The research shows creating open dialogue in relationship contexts, to offset the power and influence of the perpetrator, can facilitate earlier disclosure. Among disclosure facilitators is being asked about abuse and given the opportunity to "tell" (McElavaney et al., 2014); workshops on abuse and sexual abuse, in particular, can facilitate disclosures (Ungar et al., 2009b); and using culturally sensitive probes and questions (Fontes & Plummer, 2010). In Gagnier and Collin-Vezina's (2016) study, positive disclosure experiences were described by participants as those where they felt that they had been listened to, were safe, were believed, and were not judged by the person they disclosed to. Further, family members and friends (peers) of the child victim can act as key supports to creating an open relational context and fostering positive responses (Jensen et al., 2005; Priebe & Svedin, 2008; Schonbucher et al., 2012; Ungar et al., 20096). In particular, as children grow older, they are more likely to disclose to a peer, as shown in a number of studies, and this is an important reality for counselors and educators to be aware of (Dumont et al., 2014; Kogan, 2004; Sclainbucher et al., 2012; Ungar et al., 2009b). + +# Discussion + +Through examination of 33 studies published since the year 2000, this review identified five distinct themes regarding CSA disclosure: (1) Disclosure is best viewed as an iterative, interactive process rather than a discrete event done within a relational context; (2) contemporary models reflect a social—ecological, person-in-environment framework for understanding the complex interplay of individual, familial, contextual, and cultural factors involved in CSA disclosure; + +(3) age and gender are significant disclosure factors; (4) there is a lack of a life-course perspective; and (5) barriers to disclosure continue to outweigh facilitators. Based on these themes, a number of conclusions are drawn from this review. First, disclosure as a process is emphasized throughout contemporary research. Advances have been made in understanding these complex processes. However, the disclosure process over time—for example, how the first detection of CSA or attempts to disclose in childhood impact later disclosures—are not well understood. This is the result of the absence of a cohesive lifecourse perspective in investigations, although age consistently surfaces as significantly influencing CSA disclosure. Using a life-course perspective through the use of longitudinal studies is recommended. + +The use of varied methodological designs, depending on the developmental stage of the victims/survivors, influences the data generated and subsequent findings. For example, most studies on children and youth are based on file reviews of cases that have been brought to the attention of authorities, or surveys, with only a few studies using interviewing of younger children. Therefore, there is less information available on process issues with children and youth. In contrast, research on adult populations largely favors the use of qualitative interview methods for retrospective inquiry producing important process findings. In addition, investigations have not yet captured the disclosure experiences of adults in the "emerging adult" stage given that adult studies have failed to recognized that the age range of 18-24, which is now considered a developmental phase defined by neurobiological developmental uniqueness. As well, late adulthood has not been given attention as shown by the absence of participants representing this age-group in current research (70+). With a swelling geriatric population in North America, issues of historic CSA can be expected to surface and, with that, new disclosures. This trend is also anticipated due to attitudinal shifts that have presumably occurred over the last two generations about revealing such traumas and changing views about discussing sexual victimization. + +Interview guides used in a number of studies intentionally probed for facilitators, producing notable findings. For example, one such finding focuses on the importance of creating a contextually supportive environment to promote disclosure across the life course. These include developing therapeutic relational contexts for disclosure by providing information about sexuality, sexual abuse, prevention programming, and by asking directly. Disclosures to professionals are positive outcomes of how therapeutic contexts work; however, for forensic purposes prompting such disclosures would be viewed as problematic in legal settings, seriously compromising testimonies for trial proceedings. This is one example that speaks to the structural barriers victims and survivors run up against time and time again. Facilitators that show evidence to promote disclosure in one domain (therapeutic) are seen to work against CSA survivors in another domain—such as legal settings when perpetrators face prosecution. Defense attorneys will use this as evidence that the disclosure was prompted, and therefore the disclosure is potentially seen as not credible. Broadcasting of the frequency of acquitted cases or rulings in favor of the perpetrator through media outlets, often sensationalized, become a further compounding barrier. Given the review findings, we conclude that barriers and facilitators to CSA disclosures are nuanced and clearly embedded within intrapersonal, interpersonal, environmental, contextual, and cultural domains—often interlocked in complex ways. + +# Limitations + +Although comprehensive in nature with its life-course coverage, this review may be limited by its qualitative, thematic focus rather than providing an evaluative, quantitative accounting of CSA disclosures. However, because of the recent focus on disclosure processes, the authors chose a suitably compatible approach—qualitative in nature. As well, a traditional checklist approach in rating the studies was not employed for interrater reliability, since two of the authors hold expertise in CSA disclosure research and are well versed with the literature. This expertise, and through closely following a systematic review framework (Kiteley & Stogdon, 2014), assures that a thorough adjudication of the research literature was completed. + +# Implications for Research and Practice + +These review findings have implications that can be useful in guiding future research and practice: + +- Solid strides are being made in the use of a social—ecological framework to underpin investigations in the CSA disclosure investigations. Research efforts and practice considerations should continue in this vein. Investigating environmental factors and contextual and cultural forces is understudied, necessitating more research in these areas to more fully fill out understanding of CSA disclosure from a social—ecological perspective. +- There is good evidence that CSA disclosures are more likely to occur in a dialogical context—formal helping relationships but as well as other relationships such as peers and trusted adults. Providing information and education on topics of sexuality in general, and sexual abuse specifically, can help children and youth to disclose. Raising awareness and prevention programs can promote disclosures of sexual violence committed against children and youth. +- Goals of therapeutically supported disclosures (i.e., through therapy) may need to take precedence over forensic approaches, if well-being of child victims and adult survivors is to be made paramount. Legal processes may act to facilitate disclosures but can also act as barriers because of the negative outcomes experienced in the court process. +- Practitioners need to keep in mind that the legal system is lagging far behind in knowledge uptake of recent evidence on CSA disclosures so that victims and + +survivors continue to be systemically and structurally disadvantaged in legal proceedings. + +- Health-care practitioners (i.e., child abuse pediatricians, family practice doctors, clinical nurse specialists, and public health nurses) should be made aware of the evidence in the CSA disclosure literature to create environments for facilitating therapeutic disclosures. +- Given that age is a stable predictor of disclosure of CSA, more studies are needed that make use of a life-course perspective. More longitudinal studies are needed to better identify trends over different life stages. +- The emerging young adult as a developmental age group needs specific investigation. Neuroscience research has established that ages 18-24 is a distinct developmental phase. Late adulthood is another life stage that deserves to be researched. +- Gender needs to be more fully investigated in relation to impact on disclosure. Awareness that boys and girls have unique challenges and barriers in disclosing CSA should be paramount for practitioners. +- Intervention planning should take note that disclosures increase when perpetrators no longer reside with victims, and this finding should be heeded by policy and law makers. +- Shame, self-blame, and fear are intrapersonal factors that persistently emerge as barriers to CSA disclosures and warrant more research to understand how to redress these barriers for earlier disclosures. + +# Conclusion + +There are still a substantial number of children and youth who are subjected to sexual abuse, despite preventative efforts. Just as concerning is the fact that many victims continue to suffer in silence as evidenced by the high numbers of delayed disclosure. These hidden cases should not be overlooked, and these victims should not be forgotten. Despite significant progress in bringing the issue of CSA to the forefront, improving facilitation of disclosure and increasing positive influences on disclosure processes are still critical in order to protect current and future generations of children and youth from the grave effects of sexual violence. Further, the focus should not be simply on strengthening and shoring up intrapersonal resources of victims to disclose but rather to change environmental conditions to create a more supportive and safer context for CSA victims and survivors to disclose. + +# Declaration of Conflicting Interests + +The author(s) declared no potential conflicts of interest with respect to the research, authorship, and/or publication of this article. + +# Funding + +The author(s) received no financial support for the research. author ship, and/or publication of this article. + +- References Alaggia, R. (2004). Many ways of telling: Expanding conceptualiza tions of child sexual abuse disclosure. Child Abuse & Neglect, 28, 1213 1227. Alaggia, R. (2005). Disclosing the trauma of child sexual abuse: A gender analysis. Journal of Loss and Trauma, 10, 453 470. Alaggia, R. (2010). An ecological analysis of child sexual abuse dis closure: Considerations for child and adolescent mental health. 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She holds the Nicolas Steinmetz and Gilles Julien Chair in Social Pediatrics in Community and the Canada Research Chair (Tier II) in Child Welfare. Her work focuses on research and clinical topics related to child maltreatment, child sexual abuse, and trauma. Rusan Lateef, MSW, is a social worker employed in the criminal justice system with adult male offenders in Ontario, Canada. She specializes in the intersection of health and mental health, child sexual abuse disclosures, and she is a researcher on the "Make Resilience Matter" project examining childhood exposure to domestic violence with Dr. Alaggia at the Factor Inwentash Faculty of Social Work, University of Toronto. + +# Disclosure of Child Sexual Abuse: Delays, Non-disclosure and Partial Disclosure. What the Research Tells Us and Implications for Practice + +This paper reviews the research on disclosure of child sexual abuse with specific reference to delays in disclosing, non-disclosure and partial disclosure of experiences of child sexual abuse. Findings from large-scale national probability studies highlight the prevalence of both non-disclosure and delays in disclosure, while findings from small-scale qualitative studies portray the complexity, diversity and individuality of experiences. The possible explanations regarding why children are reluctant to disclose such experiences have significant implications for addressing the issue of child sexual abuse from the perspectives of child protection, legal and therapeutic professionals. The importance of understanding the dynamics of disclosure, in particular the needs of young people to maintain control over the disclosure process, the important role that peers play in this process, the responses of adults in both informal and formal networks, and the opportunities to tell, is key to helping young people speak more promptly about their experiences of sexual abuse. Copyright O 2013 John Wiley & Sons, Ltd. + +#### KEY PRACTITIONER MESSAGES: + +- Children typically delay disclosing experiences of abuse. +- Asking children questions about their wellbeing gives them the opportunity to tell when they are ready. +- The challenge is to find the right questions at the right time. +- Peers can be the right people to ask these questions. +- Adolescents need to know about how to ask and what to do if someone tells. + +KEY WORDS: child sex abuse; disclosure; research to practice + +A n issue of increasing concern in recent years is the phenomenon of delayed disclosure of childhood sexual abuse and the need to understand the process of how children and adults disclose their experiences of child sexual abuse, given the implications for child protection, social justice and + +Rosaleen McElvaney + +School of Nursing and Human Sciences. Dublin City University, Dublin. Ireland + +`The importance of understanding the dynamics of disclosure' + +'Adolescents need to know about how to ask and what to do if someone tells' + +•Correspondence to: Rosaleen McElvaney. School of Nursing and Human Sciences. Dublin City University. Glasnevin, Dublin 9. Ireland. E-mail: rosaleen.mcelvaneygdcu.ie + +`This paper reviews + +the research on + +disclosure patterns of + +childhood sexual + +abuse' + +'Most people who experience sexual + +abuse in childhood do + +not disclose this + +abuse until adulthood' + +mental health outcomes. This paper reviews the research on disclosure patterns of childhood sexual abuse, specifically delays in disclosure, non-disclosure (as evident through adult retrospective studies) and partial disclosures, and discusses implications for practice. Literature searches of the online databases PSYCINFO and Social Sciences Citation Index, in addition to manual searches of texts published since 2000, were conducted using the search terms 'child + +sexual abuse', 'sex abuse' and 'disclosure'. + +The research to date on disclosure patterns is based on two sampling methodologies — studies of adults reporting retrospective experiences and studies of children. The former group of studies has the benefit of drawing on large-scale national probability samples which can be considered to be representative of the general population. The latter group with some small exceptions (predominantly adolescent studies) uses samples of young people who have disclosed sexual abuse but would not be considered as representative + +of all children who have been abused: + +'children who decide to tell someone about being sexually abused and whose cases therefore come to court are not representative of sexually abused children in general' + +(Olafson and Lederman, 2006, p. 29). + +Patterns of Disclosure: Delays and Non-disclosure + +There is consensus in the research literature that most people who experience sexual abuse in childhood do not disclose this abuse until adulthood, and when disclosure does occur in childhood, significant delays are common. Table 1 summarises two large-scale studies to highlight the extent of delays in disclosure and the percentage of those who did not disclose to anyone prior to the study. Kogan (2004) examined the timing of disclosure of unwanted sexual experiences in childhood or adolescence in a sub-sample (n = 263 adolescent women, aged 12 to 17) of the National Survey of Adolescents (Kilpatrick and Saunders, 1995) in the USA — a nationally representative study. Kogan's results can be summarised as follows: immediate disclosure (within 1 month) 43 per cent, delayed disclosure (less than 1 year) 31 per cent and non-disclosure (disclosed only during the survey) 26 per cent. Smith and colleagues (2000) examined a sub-sample (n = 288) of the National Women's Study in the USA (Resnick a al., 1993, cited in Smith et at, 2000) who had reported a childhood rape prior to the age of 18. Smith el al.'s findings can be summarised as follows: immediate disclosure (within 1 month) 27 per cent, delayed disclosure (more than a year) 58 per cent and non-disclosure (survey only) 28 per cent. Those who had never disclosed prior to the survey constitute comparable proportions in these two studies while the rates for immediate + +Table I. Panerns of disclosure delay and non-disclosure + +Kogan (2004) Smith a a). (2000) (n 263 adolescents) (n 288 adults) + +Told within 24 hours 24% 18% Told within 1 month 19% 9% Told within 1 year 12% 11% Delayed telling more than I year 19% 47% Never told before survey 26% 28% + +disclosure are higher in the adolescent study than in the adult study, a reassuring finding given the increased awareness of sexual abuse in society during the past 20 years. + +Goodman-Brown and colleagues (2003) examined USA district attorney files of 218 children. Their categories were slightly different from the previous two studies but in summary, immediate disclosers (within 1 month) constituted 64 per cent of the sample while 29 per cent disclosed within six months. This study is unusual insofar as the sample studied had reported their experience of abuse to the authorities and a prosecution was in progress. Goodman-Brown et at also pointed out that families who participated in this study were more likely to represent those children who experienced abuse by someone outside the family. Research has found that delays in disclosure are longer for those abused within the family and Lindblad, 2002; Goodman-Brown et at, 2003; Kogan, 2004; Hershkowitz a at, 2005). Therefore, children who disclose more promptly may be overrepresented in legal samples. + +In Sweden, Priebe and Svedin (2008) conducted a national survey of 4339 adolescents, of whom 1962 reported some form of sexual abuse (65% of girls and 23% of boys). Details of the time lapse in disclosing were not available from this study. However, of those who had disclosed and answered the questions on disclosure (n = 1493), 59.5 per cent had told no-one of their experiences prior to the survey. Of those who did disclose, 80.5 per cent mentioned a 'friend of my own age' as the only person who they had told. In this study, 6.8 per cent had reported their experiences to the social authorities or police. A further Swedish study of 122 women who had experienced childhood sexual abuse (Jonson and Lindblad, 2004) found that 32 per cent disclosed during childhood (before the age of 18) while the majority told in adulthood (68%). The delay was up to 49 years, with an average of 21 years (SD = 12.9). Of those who told in childhood, 59 per cent told only one person. In Ireland, the SAVI study (n = 3118, McGee et al., 2002) found that 47 per cent of those respondents who had experienced some form of sexual assault prior to age 17 had told no-one of this experience until the survey. McElvaney (2002) investigated delay in a legal sample of ten adults who had made formal complaints of childhood sexual abuse in Ireland and found delays ranging from 20 years to 50 years. + +Studies of children in the context of forensic/investigative interviews where children are interviewed by professionals due to concerns that the child has been sexually abused also point to high non-disclosure rates, particularly striking in cases where there is corroborative evidence that abuse has occurred — medical evidence (Lyon, 2007), or confessions from the abuser or videotaped evidence/witness reports ( and Lindblad, 2002). Lyon (2007) reported his findings from a review of studies published between 1965 and 1993 of children diagnosed with gonorrhoea where the average disclosure rate among 579 children was 43 per cent (n = 250). In a study where the evidence for the abuse was available on videotape, children have denied abuse when interviewed by the police and Lindblad, 2002). + +In summary, significant numbers of children do not disclose experiences of sexual abuse until adulthood and adult survey results suggest that significant + +The rates for immediate disclosure are lower in the adolescent study than in the adult study' + +'Children who disclose more promptly may be overrepresented in legal samples' + +`Delays ranging from 20 years to 50 years' + +# `High numbers of respondents disclosing to researchers for the first time' + +# `They found that interviewers behaved differently with the two groups' + +# 'A parent described how her teenage son told her over a period of days' + +proportions of adults have never disclosed such abuse, as evidenced by the high numbers of respondents disclosing to researchers for the first time. Patterns of Disclosure — Partial Disclosure Information on how children disclose over time can be obtained from studies of children who participated in forensic/investigative interviews where children are interviewed by professionals due to concerns that the child has been sexually abused. The issue of partial disclosures was highlighted by earlier studies such as those by DeVoe and Faller (1999) of five- to ten-year olds (i.e. making detailed informal disclosures that were not replicated in formal interviews) and Elliott and Briere (1994) of children aged eight to 15 years (i.e. disclosing only partial information until confronted with external evidence that led to more complete disclosures). More recently, investigators have examined the role of the interviewer and questioning styles in the forensic interview and how this impacts on children's disclosures and the level of detail provided in interview. Hershkowitz et at (2006) compared tapes of interviews with children who disclosed sexual abuse and those who did not (but about whom there was `substantial' reason to believe that they had been abused). They found that interviewers behaved differently with the two groups, using different types of prompts with children who presented as somewhat uncooperative, offered fewer details and gave more uninformative responses at the beginning of the interview. It would appear that interviewers responded to less communicative children by increasing the proportion of closed questions which in turn led to children being less forthcoming. Lamb el al. (2002) have found that the use of a protocol that emphasises the use of prompts that elicit free narrative (e.g. 'tell me about that') as compared with closed questions (those requiring a yes/no response) has resulted in more detail and more accuracy in children's accounts. Although few studies exist that examine the phenomenon of disclosure in informal settings (when disclosure is made to a friend or family member), some qualitative studies have described this process. McElvaney (2008) quoted one teenage girl who described hinting to her mother prior to disclosing the experience: 'I didn't tell her what happened but I was saying things that made her think it made her think that it happened but I didn't tell her' (p. 127). A parent described how her teenage son told her over a period of days, keeping the most difficult parts of the story until last: 'Ile came out with like it came out over two or three days so you know.. \_he'd say well I've something else to tell you... the bad stuff last... what hun him most and what he's saying what hurt him most' (p. 92) And finally, one young person described how she told her social worker: 'I couldn't tell her most things but I just gave things to her to read... I told her at first I told her bits of it and em then just the others. I finished writing and then I gave them to her... later I told her that it was the father as well.' (p. 93) This young person had been abused by both a father and son in a family with whom she was staying. + +In reviewing the literature on this subject, London and colleagues (2005) noted, `when children do disclose, it often takes them a long time to do so' (p. 204). + +# Reasons for Patterns of Delay, Partial Disclosure and Non-disclosure + +There are many influences on disclosure that have been identified in the research literature to help explain why it is that children delay disclosure, are reluctant to disclose, provide details of their experiences over time or do not disclose at all. Age has been identified as a significant predictor of disclosure in that younger children are less likely to disclose than older children. Children who are abused by a family member are less likely to disclose and more likely to delay disclosure than those abused by someone outside the family (Smith a at, 2000; Goodman-Brown a at, 2003; Kogan, 2004). Children who do disclose during forensic interviews compared to children who do not disclose in such contexts (yet concerns remain that they have been abused) are more likely to have parents (particularly mothers) who are more supportive (Lawson and Chaffin, 1992). In Priebe and Svedin's (2008) study of young people, parental bonding (positive relationship with parent who was not overprotective) was identified as the most significant predictor of disclosure for both boys and girls. However, close relationships can also act as an inhibitor to disclosure. McElvaney (2008) found that many young people in her study were reluctant to disclose due to concerns of upsetting their parents while others were concerned about the consequences for others of their disclosure. One 13-year-old girl described her concern that if she told, her uncle would go to jail and her small cousins would be left without a father: + +'I didn't want them to grow up with no Dad and just looking at ... their other little friends having their Dad holding their hand I felt like I was taking their Dad away from them' (p. 130) + +Gender has been found to influence disclosure in that boys appear to be more reluctant to disclose than girls (Goodman-Brown a at, 2003; Hershkowitz a at, 2005; Ungar a al., 2009a). Mental health difficulties on the part of the child have also been found to be relevant, particularly when children experience dissociative symptoms or other post-traumatic stress symptomatology (Priebe and Svedin, 2008). + +Some studies have found that the severity of abuse (e.g. penetrative abuse) predicts earlier disclosure while other studies have found no relationship between different types of abuse and disclosure timing. Similarly, the relationship between the duration of abuse — one-off incidents of abuse compared with abuse that takes place over a significant period of time — and timely disclosure has been investigated with mixed findings. Fear of the consequences of disclosure has been identified as a predictor of delayed disclosure and this in turn is associated with the age of the child (Goodman-Brown a at, 2003). Older children are more cognitively competent in terms of being able to reflect on and anticipate possible reactions to their disclosure. This can act then as an inhibitor to disclosure, although as noted above, most studies have found that older children are more likely to disclose than younger children. Fears of not being believed have been described by young people as inhibiting their disclosure and these fears are often "When children do disclose, it often takes them a long time to do so" + +`Younger children are less likely to disclose than older children' + +`Many young people in her study were reluctant to disclose due to concerns of upsetting their parents' + +`Fear of the consequences of disclosure has been identified as a predictor of delayed disclosure' + +`Investigating the precise circumstances that led to disclosures for children' + +`Significant proportions of disclosure have been prompted by questions by caregivers, friends or others' + +`The implications of these findings can be considered in interrelated contexts' + +justified. Hershkowitz a at (2007) interviewed children about their initial disclosures prior to formal interview and 50 per cent of the sample (n = 30) reported feeling afraid or ashamed of their parents' reaction. The authors reported that parents did show a tendency to blame their children and react angrily to the disclosure. + +Recent research has highlighted the need for children to be asked direct questions to facilitate their disclosure. Of those children who did disclose, significant proportions disclosed following prompts rather than it being initiated by the child (Kogan, 2004). Qualitative studies drawing on interviews with children that focus on the disclosure process are important in investigating the precise circumstances that led to disclosures for children. McElvaney (2008) found that parents' questioning of children was prompted by their concern about the young person's emotional distress. On occasion, young people were communicating that something was not right in their world but were not able to articulate this verbally. Signs of psychological distress were, however, evident and questions targeted at the reasons for this distress were identified by McElvaney as a factor that helped young people to tell. Thus, many children may not have told about their experiences of abuse because they were not asked. McGee a al. (2002) followed up a sample of their respondents who had disclosed childhood abuse for the first time in their survey. When asked why they had not disclosed prior to the survey, many respondents noted that it was because they had not been asked. Increasingly, research studies are finding that significant proportions of disclosure have been prompted by questions by caregivers, friends or others in the child's educational and social milieu that in themselves provide an opportunity for the young person to tell (Jensen et at, 2005; Hershkowitz a at, 2007; McElvaney et al., 2012). + +Finally, some children need time to tell. Mudaly and Goddard (2006) quote a 13-year-old girl: `she (mother) helped by not making me, not rushing me to get it out, which, um, I think it's a really stupid idea to make kids get it out A.S.A.P.' (p. 91). + +# Implications for Practice + +The consensus in the research literature at the present time is that disclosure is multi-determined, influenced by a complex range of factors that may influence each child in a different way. Large-scale national probability studies confirm that non-disclosure and delays in disclosure are significant problems facing society and in particular for those professionals tasked with safeguarding the wellbeing of children. Children's fears and anxieties in relation to telling need to be understood and contained by those in their environment so that early disclosure can be encouraged and facilitated. + +The implications of these findings can be considered in interrelated contexts: the legal context where action can only be taken if the child is able to give a clear, credible account of his/her experiences; child protection and therapeutic contexts where a comprehensive account is required to enable child protection professionals to intervene and where the psychological sequelae can be addressed to minimise the long-term impact of the experiences; and family and community contexts where early disclosure needs to be encouraged, and other family issues addressed in the aftermath of disclosure and where peers play an important role. + +Studies have confirmed the importance of professionals asking children and young people in a sensitive, open manner about possible experiences of abuse using non-leading questioning styles to minimise inaccurate accounts or contaminate children's narratives. It is clearly important for professionals to remain open to the possibility of abuse and further disclosure. It is equally important for professionals to be able to avoid persisting with questioning those children who are 'reluctant disclosers'. Similarly, professionals engaged with children in therapeutic work need to be open to the possibility of both initial and further disclosures. + +Contradiction in witness statements is a well-known feature of false statements and giving additional detail to original formal statements can be interpreted within child protection, therapeutic and legal contexts as a contradiction of an earlier account. Listening to children's accounts of their experiences of disclosure helps us understand why it is that disclosure can be delayed and that when they do feel ready to tell this is not an 'all or nothing' decision. As one young person in Staller and Nelson-Gardell's (2005) study noted, 'it's never finished, never' p. 1426. This understanding in turn helps us identify those circumstances and reactions that may encourage the child to disclose. + +The importance of asking children questions, thus giving them an opportunity to tell, has been identified. While parents, teachers and those in daily contact with children are often reluctant to question children, it is clear that many children do not disclose unless given this opportunity. Education and increased awareness are needed on how to question children in an appropriate manner. McElvaney (2008) noted that questions did not need to be about sexual abuse per se, but rather questions prompted by the young person's psychological distress, asking after the young people's wellbeing. This questioning in effect acted as an external pressure for the young person to tell his/her secret (McElvaney et al., 2012). In Ungar el at's (2009a) study of Canadian youth, they found that young people used a range of disclosure strategies ranging from less direct strategies (such as risk-taking behaviours, not talking about the abuse) to direct strategies (such as seeking support from peers, turning to non-professional adult supports, disclosing to formal service providers), representing a process that relied heavily on others to 'build the bridges between the youth and formal care providers' (p. 352). + +The tendency to delay disclosing and the partial nature of many disclosures are not conducive to successful legal investigations and prosecutions. In addition, the knowledge base that exists within the legal sphere is limited if only a percentage of the children who experience sexual abuse engage with this system. The disproportionately high 'immediate disclosure' rate found in Goodman-Brown a al.'s (2003) legal sample compared to Kogan's (2004) community sample raises the question of the representation of delayed disclosers in the legal system. Are children who delay in disclosing less likely to engage with the legal system? Are delays in disclosing contributing to decisions not to prosecute child sexual abuse crimes? In Ireland, the 1990s saw a significant increase in the numbers of complainants coming before the courts reporting experiences of childhood sexual abuse. Many of these cases were referred to the higher courts for judicial review proceedings to establish whether the cases could proceed without prejudicing the accused given the + +# 'Contradiction in witness statements is a well-known feature of false statements' + +# 'Education and increased awareness are needed on how to question children in an appropriate manner' + +# 'Are children who delay in disclosing less likely to engage with the legal system?' + +'Concerns that engagement with the legal system will lead to further psychological trauma need to be considered' + +'Many young people who delayed disclosure to an adult had told a friend' + +'An adaptive strategy on the part of the young person to contain the experience' + +delay in the complaint being made and giving due regard to the accused's right to a speedy trial. Psychological expert testimony was sought as part of these proceedings to explain the delay in disclosure in each individual case to enable the courts to adjudicate on whether the delay in reporting was reasonable (see McElvaney, 2002). This legal mechanism provided an opportunity to enhance the knowledge base within the legal profession as to the complexities involved in disclosing and formally reporting experiences of childhood sexual abuse for adults. While one might expect that the legal system would be more sympathetic to children's difficulties in making disclosures, it may also be the case that the belief that 'if the child was really sexually abused, why would they not tell?', as articulated by Summit (1983), still prevails. + +In addition, concerns that engagement with the legal system will lead to further psychological trauma need to be considered. A prospective longitudinal study conducted by Quas et al. (2005) indicated that the consequences of legal involvement change over the course of development and as a function of the child's reactions to and experiences during the legal case. The associations between legal involvement and outcomes varied with age. The authors suggested that although younger children may be at increased risk for some adverse outcomes such as mental health problems, older children may be at increased risk for other undesirable sequelae such as the negative attitudes of others toward them. Quas and Goodman's (2011) recent review notes that older children are more at risk in developing poor mental health outcomes. Thus, as noted earlier, young people's fears of the consequences of disclosure may well be justified. Raised awareness of both the prevalence of non-disclosure of sexual abuse and the importance of supporting children to disclose may go some way to addressing children's fears. + +One interesting finding in recent studies is that many young people who delayed disclosure to an adult had told a friend. McElvaney (2008) and Ungar et al. (2009b) identified peer influence as significant in encouraging disclosure among adolescents. There is some suggestion from the research that regardless of the age at the time of abuse, adolescence may be a 'critical period' for disclosure. It may be that targeting adolescents in general (rather than those at risk of abuse) may be a powerful prevention tool in encouraging early disclosure. Evaluations of child abuse prevention programmes have shown significant improvements in the levels of awareness of child abuse in children and young people (Rispers et al., 1997; Zwi el al., 2007). It may be that the increasing trend towards peer disclosure is a by-product of such educational and awareness-raising programmes. There is evidence that public awareness campaigns when implemented as part of a multi-dimensional strategy that involves targeting children, parents and communities (see Lalor and McElvaney, 2010, for a review of child abuse prevention programmes) are an effective tool in the prevention of child abuse. + +McElvaney et al. (2012) describe the importance for young people of containing the secret of abuse and their need for confidentiality following disclosure as representing an adaptive strategy on the part of the young person to contain the experience and his/her emotional reaction to it. The conflict between wanting/needing to keep the secret and wanting/needing to tell is mediated by what they term the 'pressure cooker effect'. Young people in their study described influences from within and without that led to a build up of pressure, ultimately leading to disclosure. They suggest that building up the + +pressure for young people by providing opportunities to tell may be needed to help young people tell more promptly. However, the lack of control that young people experience following disclosure remains an issue (Ungar et al., 2009b; Quayle a al., 2012). This highlights the need for dissemination of information directly to young people about the legal process, the possible consequences of disclosure, as well as ongoing developments in legal proceedings when young people and their families interface with the legal system. + +The more recent focus on investigating those strategies that children use in making disclosures rather than solely on identifying bathers to disclosure is perhaps more helpful in informing awareness-raising campaigns and professional interventions. The author is involved in a large-scale review of children's files in an assessment service to ascertain those factors that helped children tell about their experiences of sexual abuse. A pilot study has suggested that this is an appropriate methodology for gathering data on children's experiences of informal disclosure, acknowledging the limitations of such an approach. Ungar a al. (2009a) describe the optimal conditions for disclosure as follows: being directly asked about experiences of abuse; having access to someone who will listen, believe and respond appropriately; having knowledge and language about what constitutes abuse and how to access help; having a sense of control over the process of disclosure both in terms of their anonymity (not being identified until they are ready for this) and confidentiality (the right to control who knows); and effective responses by adults both in informal and formal contexts. + +Ungar etal. (2009b) support recent developments in prevention programmes that target supportive formal and informal caregivers in being better able to detect the possibility of abuse and support disclosures rather than focusing on empowering children themselves in making disclosures. Their findings in relation to the importance of bridge building for young people to access formal supports are supported by Jensen et at's (2005) emphasis on the dialogical nature of disclosure, and the important role that trusted adults and peers play in the disclosure process through noticing signs of psychological distress and asking young people about their psychological wellbeing (Collings a al., 2005; Jensen et at, 2005; McElvaney et at, 2012). More emphasis is therefore needed on providing opportunities for children and young people to disclose. The challenge for professionals and those who care for children is how to do this in a way that protects children and promotes their wellbeing. + +# References + +Collings SJ, Griffiths S, Kumalo M. 2005. Patterns of disclosure in child sexual abuse. South African Journal of Psychology 35(2): 270 285. DeVoe ER, Faller KC. I 999.The characteristics of disclosure among children who may have been sexually abused. Child Maltreatment 4: 217 227. Elliott DM, Briere 1 1994. Forensic sexual abuse evaluations of older children: Disclosures and symptomatology. Behavioral Sciences & the Law 12: 261 277. Goodman Brown TB, Edelstein RS, Goodman GS, Jones DP14, Gordon DS. 2003. Why children tell: A model of children's disclosure of sexual abuse. Child Abuse & Neglect 27: 525 540. Hershkowitz I, Horowitz D, Lamb ME. 2005. Trends in children's disclosure of abuse in Israel: A national study. Child Abuse & Neglect 29(11): 1203 1214. Ilashkowitz I, O,bach Y, Lamb ME, Sternberg KJ, Ilorowitz D. 2006. Dynamics of forensic interviews with suspected abuse victims who do not disclose. Child Abuse & Neglect 30: 753 769. + +'More recent focus on investigating those strategies that children use in making disclosures' + +'Having a sense of control over the process of disclosure both in terms of their anonymity and confidentiality' + +llershkowitz I, Lanes O, Lamb ME. 2007. Exploring the disclosure of child sexual abuse with alleged victims and their parents. Child Abuse & Neglect 31: Ill 123. Jensen TK, Gulbrandsen W, Mossige S, Reichelt S, Tjersland OA. 2005. Reporting possible sexual abuse: A qualitative study on children's perspectives and the context for disclosure. Child Abuse & Neglect 29(12): 1395 1413. Jonson E, Lindblad F. 2004. Disclosure, reactions and social support: Findings from a sample of adult victims of child sexual abuse. Child Maltreatment 9(2): 190 200. Kilpatrick DG, Saunders BE. 1995. The National Survey of Adolescents in the United States [Computer File]. Medical University of South Carolina [producer], 1999. Inter university Consortium for Political and Social Research [distributor], 2000: Ann Arbor, MI. Kogan SM. 2004. Disclosing unwanted sexual experiences: Results from a national sample of adolescent women. Child Abuse & Neglect 28: 147 165. Lalor K, McElvaney R. 2010. Child sexual abuse, links to later sexual exploitation/high risk sexual behavior, and prevention/treatment programs. Trauma, Violence & Abuse 11(4): 159 177. DOI: 10.1177/1524838010378299 Lamb ME, Orbach Y, Sternberg KJ, Esplin PW, Hershkowitz I. 2002.The effects of forensic interview practices on the quality of information provided by alleged victims of child abuse. In Children's Testimony: A handbook of Psychological Research and Forensic Practice, Westcon ILL, Davies GM, Bull R (eds). John Wiley & Sons Ltd: Chichester, England; 131 145. Lawson L, Chaffin, M. 1992. False negatives in sexual abuse disclosure interviews: Incidence and influence of caretaker's belief in abuse in cases of accidental abuse discovery by diagnosis of STD. Journal of Interpersonal Violence 7(4): 532 542. London K, Bruck M, Ceci SJ, Shuman D. 2005. Disclosure of child sexual abuse: What does the research tell us about the ways that children tell? Psychologn Public Policy, and Law 11(1): 194 226. Lyon TD. 2007. False denials: Overcoming methodological biases in abuse disclosure research. In Child sexual abuse: Disclosure, delay and denial, M Pipe, M Lamb, Y Orbach, AC Cederborg (eds). Lawrence Erlbaum Associates: London; 41 62. McElvaney R. 2002. Delays in reporting childhood sexual abuse and implications for legal proceedings. In Sex and Violence: The Psychology of Crime and Risk Assessment, Farrington DP, Rollin CR, McMurran M (eds). Routledge: London; 138 153. McElvaney R. 2008. How children tell: containing the secret of child sexual abuse. Unpublished doctoral dissertation, Trinity College, Dublin. McElvaney R, Greene S, Hogan D. 2012. Containing the secret of child sexual abuse. Journal of Interpersonal Violence 27(6):I 155 1175. DOI: 10.1177/0886260511424503 McGee H, Caravan R, deBarra M, Byrne J, Conroy R. 2002. The SAVI Report: Sexual Abuse and Violence in Ireland. The Liffey Press: Dublin. Mudaly N, Goddard C. 2006. The truth is longer than a lie: Children's experiences of abuse and professional interventions. Jessica Kingsley Publishers: London. Olafson E, Lederman CS. 2006. The state of the debate about children's disclosure patterns in child sexual abuse cases. Juvenile and Family Court Journal 57(1): 27 40. Priebe G, Svedin CG. 2008. Child sexual abuse is largely hidden from the adult society: An epidemiological study of adolescents' disclosures. Child Abuse & Neglect 32: 1095 1108. Quas JA, Goodman GS. 2011. Consequences of criminal court involvement for child victims. Psychology, Public Policy and Law 18, 392 414 10.1037/a0026146 Quas JA, Goodman GS, Ghetti SA, Kristen W, Edelstein RR, Allison D, Cordon IM, Jones, DPII. 2005. Childhood sexual assault victims: Long term outcomes after testifying in criminal court: VII. General discussion. Monographs oldie Society for Research in Child Development 70(2): 104 117. Quayle E, Jonsson L, Loaf L. 2012. Online Behaviour related to Child Sexual Abuse: Preliminary Version. ROBERT Project. Available: http://www.innocenceindangendeffileadmin/user upload/ Downloads/ROBERT/Interview analysis PRELIMINARIpdf [18 June 2012]. Resnick HS., Kilpatrick DG., Dansky BS, Saunders BE, & Best CL. 1993. Prevalence of civilian trauma and posttraumatic stress disorder in representative national sample of women. Journal of Consulting and Clinical Psychology 61: 984 991. Rispers 1, Aleman A, Goudena PP. 1997. Prevention of child sexual abuse victimization: A meta analysis of school programs. Child Abuse & Neglect 21: 975 987. RL, Lindblad F. 2002.Limited disclosure of sexual abuse in children whose experiences were documented by videotape. The American Journal of Psychiatry• 159: 312 314. + +Smith DW, Letoumeau EJ, Saunders BE, Kilpatrick DG, Resnick, HS, Best CL. 2000. Delay in disclosure of childhood rape: Results from a national survey. Child Abuse & Neglect 24: 273 287. Staller KM, Nelson Gardell D. 2005. "A burden in your heart": Lessons of disclosure from female preadolescent and adolescent survivors of sexual abuse. Child Abuse & Neglect 29: 1415 1432. Summit R. 1983. The child sexual abuse accommodation syndrome. Child Abuse & Neglect 7(2): 177 193 Ungar M, Barter K, McConnell S, Tutty L, Fairholm I 2009a. Patterns of disclosure among youth. Qualitative Social Ifbrk 8(3): 341 356. DOI: 10.1177/1473325009337842. Ungar M, linty LM, McConnell S, Barter K, Fairholm J. 2009b. What Canadian youth tell us about disclosing abuse. Child Abuse & Neglect, 33: 699 708. Zwi KJ, Woolfenden SR, Wheeler DM, O'Brien TA, Tait P, Williams KW 2007. School based education programmes for the prevention of child sexual abuse (Review). Cochrane Database of Systematic Review 3: CD004380. + +# CLINICAL RESEARCH ARTICLE + +# Predictors of delayed disclosure of rape in female adolescents and young adults + +Iva A. E. Bicanicl ", Lieve M. Hehenkampl , Elise M. van de Puttee, Arjen J. van Wijk3 and Ad de Jongh3•4 + +Background: Delayed disclosure of rape has been associated with impaired mental health; it is, therefore, important to understand which factors are associated with disclosure latency. The purpose of this study was to compare various demographics, post rape characteristics, and psychological functioning of early and delayed disclosers (i.e., more than I week post rape) among rape victims, and to determine predictors for delayed disclosure. + +Methods: Data were collected using a structured interview and validated questionnaires in a sample of 323 help seeking female adolescents and young adults (12 25 years). who were victimized by rape, but had no reported prior chronic child sexual abuse. + +Results: In 59% of the cases, disclosure occurred within I week. Delayed disclosers were less likely to use medical services and to report to the police than early disclosers. No significant differences were found between delayed and early disclosers in psychological functioning and time to seek professional help. The combination of age category 12 17 years [odds ratio (OR) 2.05, confidence intervals (CI) 1.13 3.73], penetration (OR 2.36, CI 1.25 4.46), and closeness to assailant (OR 2.64, CI 1.52 4.60) contributed significantly to the prediction of delayed disclosure. + +Conclusion: The results point to the need of targeted interventions that specifically encourage rape victims to disclose early, thereby increasing options for access to health and police services. + +Keywords: Adolescents; young adults: rape: sexual assault: disclosure; latency to disclosure; posurauniatic stress disorder + +Responsible Editor: Rita Rosner, KU Eichstaett Ingolstadt. Germany. + +For the abstract or full text in other languages, please see Supplementary files under Article Tools' + +Received: 31 August 2014; Revised: 30 Mardi 2015: Accepted: 13 April 2015; Published: 11 May 2015 + +p revious studies have shown that disclosure of rape to formal agencies, such as police or mental health services, is uncommon (Fisher, Cullen, & Turner, 2000; Wolitzky-Taylor et al., 2011), especially when the rape has been committed on a date or by an acquaintance and involves the victim's use of drugs and/or alcohol (Resnick et al., 2000; Wolitzky-Taylor et al., 2011). There is evidence to suggest that victims believe that professionals will not be helpful to them because their rape experience does not match stereotypical conceptions of rape, such as involving a stranger, a weapon, and severe injury (Patterson, Greeson, & Campbell, 2009; Resnick et al., 2000). Accordingly, adolescents and young adults, who are more at risk to be victimized by rape than other age + +groups (De Haas, Van Berlo, Bakker, & Vanwesenbeeck, 2012; Tjaden & Thoennes, 2006), may not receive targeted mental health care and may not report the crime to the police (Ruch, Coyne, & Perrone, 2000). + +For reasons of mental health and public safety, it is important to understand the potential factors that are related to disclosure. Timing of disclosure may be a crucial factor, as early disclosers are more likely to utilize appropriate medical care and report to the police than delayed disclosers (Ahrens, Stansell, & Jennings, 2010; Ullman & Filipas, 2001). In contrast, adults who wait longer than month to disclose the rape are more likely to suffer from posttraumatic stress disorder (PTSD) and depression compared to early disclosers (Ruggiero et al., 2004). + +&#x27;National Psychotraumacenter for Children and Youth, University Medical Center Utrecht, Utrecht The Netherlands; 2Department of Paediatrics, University Medical Center Utrecht, Utrecht, The Netherlands; 3Department of Behavioral Sciences, ACTA, University of Amsterdam and VU University, Amsterdam, The Netherlands; °School of Health Sciences, Salford University, Manchester, United Kingdom + +&#x27;Correspondence to: Iva A. E. Bicanic, National Psychotrauma Center for Children and Youth, University Medical Center Utrecht, P.O. Box 85090, NL 3508 AB Utrecht, The Netherlands, Email: i.a.e.bicanio@rencutrecht.n1

In addition, adolescents who disclose their rape experience at least I month after the incident took place are found to be at higher risk for major depressive disorder and delinquency (Broman-Fulks et al., 2007) compared to those who disclosed within I month.

Victim—assailant relationship is crucial in disclosure latency, with victims being at higher risk for delayed disclosure if there is a close relation with the assailant (Kogan, 2004; Koss, 1988; Rickert, Wiemann, & Vaughan, 2005). In contrast, delayed disclosure is less common in victims of a stereotypical rape, i.e., rape by a stranger including a weapon and injury (Smith et al., 2000). Victims of prior sexual trauma are more likely to postpone disclosure of a subsequent assault than those without prior victimization (Smith et al., 2000; Ullman, 1996). This is in contrast with the findings of Ahrens et al. (2010), who report no difference in rates of prior sexual trauma between early and delayed disclosers. In addition, the victim's age appears to be an important variable in predicting disclosure. Evidence suggests that young children are at higher risk for delayed disclosure than adolescents (Kogan, 2004; Schonbucher, Maier, Mohler-Kuo, Schnyder, & Landolt, 2012). Thus, various rape and victim-related characteristics have been found to be associated with timing of disclosure.

The majority of the aforementioned studies included college and adult female rape victims. It is important to examine rape disclosure latency in an age and sex group that is most at risk for rape victimization. There is only one prior quantitative study in adolescents (those aged 12-17 years) that identified factors that might influence disclosure latency (Kogan, 2004). He found that identity of the assailant, a familial relationship with the assailant, and a history of drug abuse in the household were related to the timing of disclosure. The results suggested that a familial relationship with the assailant will postpone disclosure, whereas a history of drug abuse in the household, albeit this seems counterintuitive, makes prompt disclosure more likely. This study had some limitations, including the fact that the interviews were conducted by telephone and that the description of the relationship with the assailant was limited. Therefore, in the present study, we investigated a sample of female adolescent and young adult victims of rape who were admitted to a specialized mental health centre for victims of sexual assault. The first aim of this study was to compare demographics, post-rape characteristics, and psychological functioning between early and delayed disclosers in this group. The second aim, based on the exploratory findings of Kogan (2004), was to determine the predictors for delayed disclosure in adolescents and young adults, including age, prior trauma, and victim—assailant relationship using logistic regression analyses. Insight into the predictors for delayed disclosure for adolescents and young adults may reveal not only potential causal mechanisms but also possible targets for

interventions that increase victims' opportunities to receive timely post-rape services.

Methods

Subjects and data collection

Rape was defined as "an event that occurred without the victim's consent that involved the use or threat of force in vaginal, anal, or oral intercourse" (Tjaden & Thoennes, 2006). The definition includes both attempted and completed rape; the term "completed" referring to vaginal, oral, anal, or multiple penetrations. Victims who disclosed within 1 week were defined as "early disclosers," whereas those who disclosed at least after 1 week were defined as "delayed disclosers." This dichotomization of the variable "disclosure latency" was based on the study of Ahrens et al. (2010) and the national standard criteria for admission to a Rape Centre in the Netherlands, i.e., a maximum of 7 days post-rape.

The study was conducted in the Dutch National Psychotrauma Centre, which provides psychological services for rape victims aged 12-25 years and their parents. Between May 2005 and December 2011, the centre received 621 phone calls concerning alleged rape victims from police authorities, mental health services, and selfreferrals. In 178 cases, the phone call did not result in admission at the centre because of age limitations, or motivational reasons. In 108 cases, referrals were made to other institutions because the index trauma was chronic childhood sexual abuse rather than rape in adolescence/ young adulthood. Of the 335 cases admitted to the centre, 12 were not included in this study because of male gender, resulting in a final sample of 323 females with the index trauma being single rape. Referral sources for this final sample included the police (33.7%), mental health services (40.7%). and self-referrals, i.e., victims or parents (25.6%).

Procedure

During admission, all patients underwent a psychological assessment, consisting of 1) a structured interview for obtaining demographic and post-rape characteristics and 2) self-report questionnaires to obtain information about mental health functioning. Information from the interview was transcribed onto a form designed for this purpose. The following variables were obtained and dichotomized or categorized for the purpose of the study:

Demographic and victim characteristics

We asked patients about their current age, educational level (lower, middle, or higher), and whether they were of Dutch origin (i.e., in case of having parents born in the Netherlands). Those between 12 and 17 years of age were defined as adolescents and those between 18 and 25 years of age as young adults. We also asked whether the patient was living with their parent(s) (yes/no), and whether the

family structure was complete, i.e., whether the biological parents were living together (yes/no). Patients were then asked to confirm the presence of prior negative sexual experiences (yes/no), and whether they had a current sexual relationship (yes/no).

Rape characteristics

Information about date and time of the rape was obtained to calculate the time since rape at admission. Next, patients were requested to describe the rape. Their response was categorized into use of penetration (yes/no), group rape (yes/no), use of physical violence (yes/no), and use of threats verbally and/or with a weapon (yes/no). Also, information regarding the victim's relationship to the assailant was obtained. The assailant was defined as a stranger when the victim had never been in contact with the assailant before the rape. Responses were used to form a closeness category (yes in case of family, (boy) friend, or mentor). Patients were also asked about the (estimated) age of the assailant (categorized into 12-17 years or > 18 years), and whether the victim had used alcohol prior to the rape (yes/no).

Post-rape characteristics

Patients were asked when they first talked about the rape. The response was used to calculate the disclosure time and the help-seeking time. At the end of the interview, patients were asked whether they had reported to the police after the incident (yes/no), and whether they had received any medical care after the incident (yes/no).

The study was performed in accordance with the precepts and regulations for research as stated in the Declaration of Helsinki, and the Dutch Medical Research involving Humans Subjects Act concerning scientific research. According to the Ethical Medical Committee of the University Medical Centre Utrecht, this act was not applicable to the present study. Written informed consent was obtained from both patients and parents.

Measures

Posttraumatic stress

The Children's Responses to Trauma Inventory (CRTI; Alisic, Eland, & Kleber, 2006) was used for participants aged 12-18 years. This is a 34-item questionnaire assessing severity of PTSD symptoms according to DSM-IV. Patients are asked to indicate to what extent a reaction to a traumatic event was present during the past week. Scores range from I to 5, with higher scores indicating more symptomatology. The four subscales: Intrusion, Avoidance, Arousal, and Other Child-Specific Reactions consist of 7, 11, 6, and 10 items, respectively. The reliability of this instrument is good to excellent (Cronbach's a 0.92 for total score, 0.79 for Intrusion, 0.77 for Avoidance, 0.71 for Arousal; Alisic & Kleber. 2010).

For the purpose of the study, only the total score was analysed.

Depression

Children Depression Inventory (CDI; Kovacs, 1992; Timbremont & Braet, 2002) was used for participants aged 12-17 years of age. The CDI is a 27-item questionnaire, assessing cognitive, affective, and behavioural symptoms of depression. The Dutch CDI has a satisfactory internal consistency, with Cronbach's a ranging between 0.71 and 0.89 (Timbremont & Braet, 2002).

Behavioural problems

The Youth Self-Report (YSR; Achenbach & Rescorla, 2001) was used for participants aged 12—I8 years. This questionnaire evaluates the teenager's perception of behavioural and emotional problems. YSR has shown to be internally reliable (Cronbach's a's ranging from 0.71 to 0.95), and convergent and discriminant validity is reported to be satisfactory (Berube & Achenbach, 2006). The YSR includes four broadband scales and nine narrow-band scales to assess behaviour problems. For the purpose of the study, only the total score on behaviour problems was included in the analyses.

General psychopathology

The Symptom Checklist-90-R (SCL-90-R; Arrindell & Ettema, 1986) was used for participants aged 12-25 years. This is a 90-item self-report inventory to assess psychosocial distress. Patients were instructed to indicate the amount they were bothered by each of the distress symptoms during the preceding week. Patients rated 90 distress symptoms on a five-point Liken scale with being "not at all" and 5 being "extremely." The statements are assigned to eight dimensions, reflecting various types of psychopathology: anxiety, agoraphobia, depression, somatization, insufficiency, sensitivity, hostility, and insomnia. The Global Severity Index (GSI) can be used as a summary of the test and reflects the severity of all answered statements as a global measure of distress. Cronbach's a has been found to range from 0.73 to 0.97. For the purpose of the study, only the GSI was analysed.

Data analyses

To compare demographic and post-rape characteristics between the early and delayed disclosers, chi-square tests were used. To compare multiple continuous psychological scores, MANCOVA was used with "time since trauma" as a covariate to correct for the potential influence of time since trauma.

Delayed disclosure was used as a dependent variable. The strength of the univariate associations between each potential risk factor and delayed disclosure was estimated by calculating the odds ratio (OR) along with 95% confidence intervals (95% CI). To determine the strongest risk factors for delayed disclosure, each potential risk

factor identified in the univariate analyses with a significant OR (p <0.05) was entered as a predictor variable into the multivariable model, using a stepwise forward logistic regression (LR) analysis with delayed disclosure as the outcome variable. The Hosmer—Lemeshow goodnessof-fit chi-square was used to calculate how well the data fit the model. For all statistical analyses, a p-value of <0.05 was considered statistically significant.

All statistical analyses were conducted using SPSS (IBM SPSS Statistics for Windows, Version 20.0, IBM Corp., Armonk, NY).

Results

Socio-demographic characteristics

Socio-demographic characteristics of the sample are presented in Table I. Victims' age ranged from 12 to 25 years, with a mean age of 16.7 years (SD =2.7) and a median age of 16.1 years. Victims' mean age at time of rape was 14.3 years (SD =2.7) and a median age of 13.9 years. Penetration occurred in 79.6% of the cases. None of the victims reported prior chronic child sexual abuse. Data about victim—assailant relationship are presented in Table 2. Victims first disclosed after a mean 20.8 weeks (SD =56.8, range 1-624 weeks), although 58.5% of the cases told within 1 week. First disclosure was to a friend (45.8%), parent(s) (17.1%), (ex) boy-friend (9.4%), family member (6.8%), professional (5.8%), or other adult (15.2%). With regard to post-rape services, 53.8% of all victims consulted a doctor for medical care and 51.4% reported to the police. On average, victims were admitted to the centre 59.8 weeks post-rape (SD =93.7, range 1-676). The mean GSI of the rape victims on the SCL-90- R (Al = 209.7, SD = 61.8) was comparable with previously reported data of psychiatric populations [M=203.55, SD = 61.60; 4269) =1.629, p = 0.104] and was substantially

Table I. Demographic characteristics of rape victims (N-323) in valid percentages

N44
Dutch origin° Education lever27484.8
Low18258.0
Medium7624.2
High5617.8
Parents divorced10231.9
Lives at parental home27385.3
Current relationship8126.5
Prior negative sex4614.8

'Dutch origin was defined as being a child from parents born in the Netherlands: °after 6 years of general primary school, at the age of 12 years. students enter low (4 years). medium (5 years). or high (6 years) secondary education level.

Table 2. Victim assailant relationship (N-323) in valid percentages

Stranger9429.5
(Ex-)Boyfriend3210.0
Friend3310.3
Acquaintance6119.1
Person met during nightlife309.4
Second-degree relative154.7
Person seen only once154.7
Person from school144.4
Person met on the intemet123.8
Colleague103.1
Mentor31.0

higher [4269) =24.297, p <0.001] compared to the general population (M=118.28, SD =32.38; Arrindell & Ettema, 1986). For the CDI, mean scores were in the clinical range (M=17.2, SD =4.6) and rape victims had significantly higher mean scores (1(230)=15,923, p <0.001), in comparison to previously reported data of the general population of adolescent girls (Timbremont, Braet, & Roelofs, 2008; M=9.01, SD =6.45).

Differences between early and delayed disclosers

Fifty-nine percent of the sample consisted of early disclosers (disclosure within I week). No significant differences in demographic characteristics were found between early and delayed disclosers, except that there were more delayed disclosers in the age category 12-17 years compared to the early disclosers group (x2 (1) =6.96; p = 0.008). For rape characteristics, significant differences between groups were found for the use of penetration, with more victims of penetration in the delayed disclosers group compared to the early disclosers group (x2 (I) = 5.37; p =0.02). Also, the delayed disclosers group presented more victims of verbal and/or weapon threats than the early disclosers group (x2 (I)=5.35; p =0.02). Furthermore, among the delayed disclosers more victims identified the assailant as a close person compared to the early disclosers (x2 (I) =10.84; p =0.001). Alcohol was used more often in the early disclosers group compared to the delayed disclosers group (x2 (I) =20.24;p <0.001).

With respect to post-rape characteristics, a significantly smaller proportion of the delayed disclosers (15.9%) utilized medical services following the rape compared to the early disclosers (30.3%; z2 (1)=5.32; p =0.02). Similarly, a significantly smaller proportion of the delayed disclosers (14.6%) compared to the early disclosers (34.3%) reported the rape to the police (x2 (I) =16.15; p <0.001). The time since trauma at admission was significantly lower for early disclosers (M=41.1 weeks, SD =79.4) than for delayed disclosers (M =82.9 weeks,

SD =103.3: 4314) =4.06, p <0.001). Mean and median time to seek help were 37.7 and 12.0 weeks, respectively. Mean time to seek help did not differ between groups (1(309)=2.54, p <0.48). Excluding outliers (M±3 SD, N = II) did not change the outcome of this analysis. Both early and delayed disclosers scored in the highest level of psychological distress when compared to previously reported norm scores (CRTI, Alisic, Eland, Huijbregts, & Kleber, 2012; CDI, Timbremont et al., 2008; YSR, Achenbach & Rescorla, 2001; SCL-90, Arrindell & Ettema, 1986), but the MANCOVA results showed that when comparing multiple continuous psychological scores, the overall psychological functioning (posttraumatic stress, depression, behavioural problems, and general psychopathology) did not differ significantly between early and delayed disclosers (F(6,I98) = 0.88, p =0.51).

Table 3 shows the ORs with 95% Cls for the associations between potential risk factors and delayed disclosure. Delayed disclosers, when compared to early disclosers, were significantly more likely to be in the age category of 12-17 years (OR =2.10), to have experienced rape by a close person (OR = 2.35), to have been threatened verbally and/or with a weapon (OR =1.75), and to have experienced penetration (OR = 1.99). Delayed disclosers were also found less likely to have used alcohol prior to the rape (OR = 0.22). None of the other factors were found to be significant risk factors for delayed disclosure.

Predicting delayed disclosure

A stepwise forward LR analysis was conducted to predict delayed disclosure, using "age category," "close assailant," "use of threats," and "penetration" as predictors. Victims' alcohol use was not entered in the analysis because of missing values for 33.4% of the cases. The use of threats was not a significant predictor in the model. A test of the full model against a constant-only model was statistically significant, indicating that the predictors (i.e., age category 12-17 years, close assailant, penetration) reliably distinguished between early and delayed disclosers (2 2 (3) = 23.09, p <0.000). There were no significant interactions between the predictors. Nagelkerke's R2 of 10.5% suggests only a modest association between the predictors and delayed disclosure, although the model did show an adequate fit to the data (Hosmer-Lemeshow x 2 (4) = 2.77, p <0.60). In total, 62% of the respondents were categorized correctly, when using the three predictors that contributed significantly to the prediction of delayed disclosure: age category 12-17 years (OR 2.05, CI 1.13- 3.73), penetration (OR 2.36, CI 1.25-4.46), and closeness to the assailant (OR 2.64, CI 1.52-4.60).

Discussion

The results of this study show that, although no differences were found between delayed and early disclosers in psychological functioning and time to seek help,

delayed disclosers were less likely to use medical services and to report to the police than early disclosers. Furthermore, this study identified a number of factors related to the timing of rape disclosure, showing that delayed disclosers represented significantly more adolescents than young adults, significantly more victims of penetration than assault, significantly more victims who were threatened than not threatened, and significantly more victims who were close with the assailant.

The finding that delayed disclosers are less likely to utilize medical services and report to the police than early disclosers is in line with previous studies in adult women (Ahrens et al., 2010; Ullman, 1996; Ullman & Filipas, 2001). It suggests that disclosure latency is important for public health and safety, as delayed disclosure may not only impede reception of proper medical care, such as treating anogenital injuries and preventing the onset of STDs and unwanted pregnancy (Linden, 2011), but also impede the forensic investigation and apprehension of the assailant (Lacy & Stark, 2013).

Three variables were identified that successfully predicted delayed disclosure: age category 12-17 years, penetration, and the assailant being a close person. The finding that the victim's age significantly predicts disclosure latency is in line with previous research showing that adolescents are at a greater risk for delayed disclosure when compared to their older counterparts (Kogan, 2004; Smith et al., 2000). Adolescents may be less able to overcome the barriers to disclose, including factors such as assailant tactics for maintaining secrecy, stigma that often accompanies rape, and fear that their parents would consequently limit their freedom (Crisma, Bascelli, Paci, & Romito, 2004). Also, as victims approach adulthood, they may possess more information about their rights and options after victimization, and have more possibilities for whom to disclose. In our study, most adolescents disclosed the rape event to peers, in line with prior research (Crisma et al., 2004; Priebe & Svedin, 2008).

The use of penetration was found to make victims more likely to postpone disclosure, opposite to the results from Priebe and Svedin (2008), but in line with an older study by Arata (1998), who found that more severe forms of sexual abuse were associated with less disclosure. Penetration may influence disclosure latency through a variety of mechanisms. It could be argued that more severe rape, indicated by the use of penetration, is more likely to be accompanied by extensive coercive use of tactics to maintain the victim's silence, with fear of reprisal possibly contributing to the finding of delayed disclosure (Kogan, 2004). Also, adolescents may think that social reactions in response to disclosure are more negative in case of completed rape compared to assault.

Another factor that seems to make immediate disclosure of rape less likely is closeness to the assailant, as indicated by the assailant being a (boy)friend, family

lithie 3. Demographic and (post )rape characteristics by disclosure time (early vs. delayed disclosers) and odds ratios for delayed disclosure

Demographic and (post-)rape characteristics Age category (years)Early disclosure (N=185)Delayed disclosure (i.e., >1-week post-rape), N=131OR95% CI
18 255517.4227.0
12 17 Dutch origin13041.110934.52.101.20 3.65'
No278.5227.0
Yes Living with parent(s)15850.010934.50.850.46 1.56
No299.2165.1
Yes Complete family structure15549.211536.51.350.70 2.59
No5818.44213.3
Yes Current sexual relationship12740.38827.90.960.59 1.55
No1274119731.9
Yes Prior negative sexual experience(s)5317.4278.90.670.39 1A4
No15249.411035.7
Yes Known assailant3210.4144.50.610.31 1.19
No5617.73611.4
Yes Close to assailant12940.89530.11.150.70 1.88
No15047.68426.7
Yes Group rape3511.14614.62.351.40 3.9r
No16050.811636.8
Yes Age of assailant (years)247.6154.80.860.43 1.71
12 176320.65417.6
>18 Use of penetration11738.27223.50.720.45 1.14
No4614.7196.1
Yes Use of threats13643.511235.81.991.10 3.60'
No9031.64816.8
Yes Use of physical violence7626.77124.91.751.09 2.82'
No13042.68226.9
Yes5116.74213.81.310.80 2.14
No7233.56932.1
Yes6128.4136.00.220.11 0.44'

'p <0.05.

Seven participants were dropped from analyses due to missing disclosure time data.

member, or mentor. This finding is consistent with previous studies showing that the closer the relationship between the victim and assailant, the less likely the young

woman was to report this victimization to anyone (Koss, 1988; Rickert et al., 2005; Wolitzky-Taylor et al., 2011). The dynamics of intrafamilial abuse is often proposed as

the explanation for delayed or non-disclosure (Kogan, 2004; Smith et al., 2000). In the present study, however, only 5% of the assailants were identified as a family member. Most close relationships referred to (boy)friends, suggesting that a significant percentage of the sample experienced peer-to-peer victimization. This type of victimization is most likely to occur during adolescence, as compared to childhood or young adulthood, and greatly increases the risk of revictimization (Humphrey & White, 2000). Hence, victims of rape by peers may be a target group for interventions promoting early disclosure.

Clearly, there are many variables working in tandem to affect the timing of victim's disclosure. A closer look at the final model, which identified three unique variables that contributed significantly to the prediction of delayed disclosure, can help us to better understand the phenomenon of initial disclosure in adolescents and young adults. Younger adolescent victims who are raped by a close person are more likely to delay disclosure than older victims of attempted rape by a stranger or acquaintance. Perhaps, they struggle with the notion that someone close to them performed such a violent act against them, which confuses them about what might happen in terms of safety if they would disclose (or not). This finding is especially important in the light of the fact that approximately 80% of victims had some sort of relationship with their perpetrator prior to the assault (Basile, Chen, Black, & Saltzman, 2007). With regard to rape types, it would intuitively seem that less severe forms of sexual assault are associated with delayed disclosure and that completed rape would be easier to identify as clearly inappropriate and wrong. Victims of completed rape, however, may be more likely to experience negative psychological reactions, e.g., self-blame and avoidance coping. It is conceivable that they delay their disclosure as a result of rape-induced psychological distress (Starzynski, Ullman, Filipas, & Townsend, 2005), not necessarily the severity of the assault.

Although the final model showed acceptable goodness of fit, the percentage of explained variance of delayed disclosure was modest. Thus. there must be other variables predictive of delayed disclosure, such as the assailant's use of alcohol or weaker support systems, that we did not assess in this study. Besides this limitation, there are other drawbacks of this study that should be mentioned. First, a clinical sample was used with patients reporting high mean levels of psychological distress. This ceiling effect may explain why no differences were found between early and delayed disclosers on psychological functioning, contrary to prior studies (Broman-Fulks et al., 2007; Ruggiero et al., 2004). Second, posttraumatic stress was only assessed for children up to 18 years, and for young adults additional suitable measures were not used. Third, information could have been lost due to dichotomizing the variable disclosure latency. Fourth, results may not be

generalizable to all rape victims, because the percentage of victims that consulted a medical professional and reported to the police was higher in our sample than in most studies (Hanson et al., 2003; Resnick et al., 2000; Zinzow, Resnick, Bare, Danielson, & Kilpatrick, 2012). Perhaps, these differences could, at least partially, be explained by the fact that stranger rape, representing 30% of our sample, leads to higher likelihood of help-seeking and police reporting because of its association with higher acknowledgment of victim status (Resnick et al., 2000; Smith et al., 2000). The fact that this is a help-seeking sample is critical for the reasons cited in the discussion, but also because the generalizability of these data to rape victims who never tell anyone—perhaps the group most at risk—simply cannot be known. Besides these limitations, several strengths of the current study need to be noted. One strength is the unique set of adolescents and young adults who presented at a mental health care centre after a single rape event, but who reported no prior chronic sexual abuse in childhood. For 85% of the sample, the index trauma was a first time rape. Moreover, data were collected at a designated referral centre for victims of rape and, therefore, the sample is likely to represent the clinical population of Dutch victims in the age group of 12-25 years.

The findings of the current study, suggesting that delayed disclosers are less able to benefit from emergency medical care and evidence collection, have a number of practical implications. One of the strategies to enhance victims' willingness to disclose within the first week postrape may be sexual education campaigns in school and media, as being uninformed is one of the reasons for them not to disclose (Crisma et al., 2004). Education may include medical information on rape-related pregnancy and STDs, as well as the need for timely emergency contraception and prophylaxis, given that these concerns appear to be facilitators of seeking medical help (Zinzow et al., 2012). Also, practical information about DNA evidence and how to best protect it, e.g., related to showering, clothing, eating, and drinking, may increase the awareness of opportunities in the early-phase post-rape. Moreover, facts about the potential psychological impact of rape, such as PTSD and revictimization, but also information about evidence-based treatments (Elwood et al., 2011; Littleton & Ullman, 2013; McLaughlin et al., 2013), may increase help-seeking behaviour in an early stage. Furthermore, efforts to encourage early disclosure must consider peer-to-peer victimization as a primary factor, as most participants in this study experienced this type of victimization, and may initially not have defined or acknowledged the incident as rape because they rationalize such experiences as normal (Hlavka, 2014), leading to the finding of delayed disclosure.

In conclusion, the results of the present study suggest that adolescent victims of rape with penetration by

someone close are at increased risk for delayed disclosure, and that delayed disclosers are less likely to use medical services and to report to the police. These findings may assist clinicians and policymakers in understanding rape and help to develop interventions (Unterhitzenberger & Rosner, 2014), specifically targeted to support adolescents and young adults to disclose in an early-phase postrape. Although the vast majority of the participants was living at their parental home, many of the sample did not first disclose to their parents. Therefore, it could be argued that in prevention programs specific attention should be given to the strengthening of the child—parent relationship, to facilitate disclosure to parents (Schonbucher et al., 2012). Next, as victims tend to disclose mostly to peers, prevention programmes may need to aim at teaching adolescents how they can help a peer victim if they become a recipient of disclosure (Schonbucher et al., 2012). In addition, education may increase victims' willingness to disclose early, thereby increasing opportunities for access to health and police services. It is more likely to reach adolescents with direct, active, and online outreach programs via communication channels that are frequently used by adolescents and young adults particularly social media (i.e., Facebook, Twitter, YouTube, etc.), forums, and mobile apps. Such programmes, wherein adolescents and young adults are being treated as agents and decision makers (Hlavka, 2014), should focus on information concerning what rape actually is—not only the stereotypical idea of rape and what (not) to do in the aftermath of rape especially in the first week postrape. Another way to help improve the support of victims of rape is the implementation of multidisciplinary sexual assault centres (Bicanic, Snetselaar, De Jongh, & Van de Putte, 2014; Bramsen, Elklit, & Nielsen, 2009), as these may be the most suitable places to organize education campaigns and offer integrated post-rape services in one location. Future research should investigate whether the availability of such centres increases the prevalence of police reporting and use of medical care. Moreover, as discussed, previous research concerning the topic of disclosure has focused on the disclosure process, mainly the effect of negative social reactions, and not the latency. In future research, social reactions in relation to disclosure (latency) should be assessed by using the Social Reactions Questionnaire, as well as the victim's perception of their own experience being defined as rape, as many girls and young women do not report or seek help because they regard sexual violence against them as normal (Hlavka, 2014).

Conflict of interest and funding

There is no conflict of interest in the present study for any of the authors.

References

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sha256:a9f160d1600a0a7ccfa8c158e72259c4e960436418e6ae18feb933c9b8542314 +size 1383 diff --git a/marker2/ds9/EFTA00088933/EFTA00088933.md b/marker2/ds9/EFTA00088933/EFTA00088933.md new file mode 100644 index 0000000000000000000000000000000000000000..b0eb6ed8c18141052f621204c7b850f3c3c3b48e --- /dev/null +++ b/marker2/ds9/EFTA00088933/EFTA00088933.md @@ -0,0 +1,145 @@ +**From:** "Stoddart, Allison" <[REDACTED]> +**To:** "[REDACTED]" <[REDACTED]> +**Cc:** "Sahni, Anjan" [REDACTED], "[REDACTED]" (USANYS) <[REDACTED]>; [REDACTED], "[REDACTED]" <[REDACTED]>; [REDACTED] <[REDACTED]>, +**Subject:** RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) +**Date:** Wed, 27 Oct 2021 14:18:13 +0000 + +--- + +Great. Thanks. Yes, that works. I'll send an invite for 3 PM. + +Allison + +--- + +**From:** [REDACTED] <[REDACTED]> +**Sent:** Wednesday, October 27, 2021 9:02 AM +**To:** Stoddart, Allison [REDACTED] +**Cc:** Sahni, Anjan [REDACTED], [REDACTED] (USANYS) <[REDACTED]>; [REDACTED] +[REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> +**Subject:** RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +**EXTERNAL SENDER** + +Hi Allison, + +Thanks— would 3 p.m. work for a call today? + +--- + +**From:** Stoddart, Allison [REDACTED] +**Sent:** Wednesday, October 27, 2021 7:48 AM +**To:** [REDACTED] <[REDACTED]> +**Cc:** Sahni, Anjan [REDACTED], [REDACTED] (USANYS) <[REDACTED]>; [REDACTED] +[REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> +**Subject:** RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +Hi [REDACTED], + +We wanted to provide an update on the trial witness topic. Do you have any time this afternoon or tomorrow for a brief call? + +Thanks, +Allison + +--- + +**From:** Stoddart, Allison +**Sent:** Monday, October 18, 2021 9:05 PM +**To:** [REDACTED]' <[REDACTED]> +**Cc:** Sahni, Anjan [REDACTED], [REDACTED] (USANYS) <[REDACTED]>; [REDACTED] +[REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> +**Subject:** RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +**From:** [REDACTED] <[REDACTED]> + +**Sent:** Monday, October 18, 2021 8:58 PM + +**To:** Stoddart, Allison [REDACTED] + +**Cc:** Sahni, Anjan <[REDACTED]>; [REDACTED] (USANYS) <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> + +**Subject:** RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +**EXTERNAL SENDER** + +Hi Allison, + +Thanks, that's not a problem. I'm attaching a broadly worded subpoena to the bank, but please let me know if you'd like me to direct this more specifically to a particular entity or officer. + +Thanks, + +**From:** Stoddart, Allison [REDACTED] + +**Sent:** Monday, October 18, 2021 8:57 AM + +**To:** [REDACTED] <[REDACTED]> + +**Cc:** Sahni, Anjan [REDACTED] (USANYS) <[REDACTED]>; [REDACTED] [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> + +**Subject:** RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +Following up on our last discussion, JPMorgan is working on identifying a witness for trial. Are you able to provide JPMorgan with a trial appearance subpoena? + +Thanks very much, + +Allison + +**Allison Stoddart | WilmerHale** + +[REDACTED] + +**From:** [REDACTED] <[REDACTED]> + +**Sent:** Friday, October 8, 2021 12:15 PM + +**To:** Stoddart, Allison <[REDACTED]> + +**Cc:** Sahni, Anjan [REDACTED] [REDACTED] (USANYS) <[REDACTED]>; [REDACTED] [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> + +**Subject:** Re: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +I'm traveling for work for much of next week, but I'm available for a call anytime on Monday, or at 9 a.m. on Tuesday. I'm also available for a call this afternoon anytime from 4 pm onwards if that's easier. + +Thanks. + +On Oct 8, 2021, at 11:18 AM, Stoddart, Allison [REDACTED] wrote: + +Thanks, [REDACTED]. Could we find some time early next week to discuss? Are there certain windows that would work on your end? + +Thanks, +Allison + +**Allison Stoddart | WilmerHale** + +![](_page_2_Picture_116.jpeg) + +--- + +**From:** [REDACTED] <[REDACTED]> + +**Sent:** Friday, October 8, 2021 10:01 AM + +**To:** Sahni, Anjan <[REDACTED]>; Stoddart, Allison <[REDACTED]>; [REDACTED] + +**Cc:** [REDACTED] (USANYS) <[REDACTED]>; [REDACTED] + +<[REDACTED]>; [REDACTED] <[REDACTED]> + +**Subject:** United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +**EXTERNAL SENDER** + +Anjan, Allison, + +Hope you're both doing well. Following up on our last conversation, we wanted to send along a few documents in order to facilitate our conversation about identifying an appropriate witness from JP Morgan. Attached is a zip file containing a few draft exhibits. We are still working on finalizing exhibits, but we thought it made sense to start the conversation about this sooner rather than later. 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Message Pad Esccrpt | SDNY_GM_00165740 | 2021 10 II | +| GX-34DD | Message Pad Es.-rist | SDNY_G3,4_00165741 | 2021 10 II | +| GX•3•EE | Message Pad E-Waili | SDNY GM 00165742 | 2021 10 ll | +| GX-3•FF | Message Pad Es.-rpt | SDNY_GM_00165743 | 2021 10 ll | +| GX•3•GG | Message Pad Es.-rist | SDNY_GIVE00165744 | 2021 10 ll | +| GX-3411I | Message Pad E-Waili | SDNY GM 00165745 | 2021 10 ll | +| GX•341 | Message Pad Ea.o.-rpt | SDNY_G3,4_00165747 | 2021 10 II | +| GX-341.1 | Message Pad Ea.o.-rpt | SDNY_G3,4_00165749 | 2021 10 II | +| GX-3•KK | Messmer Pad Ea.o.-rpt | SDNY GM 00165750 | 2021 10 II | +| GX-4 | Phyntal Sic ao. Pad- | | 2021 10 11 | +| GX.I.A | Slessaas: Pad ( ma | SDNY_GM_0016575I | 2021 10 II | +| GX-441 | Mcw.ibs: Pad Essapt | SDNY GM 00165752 | 2021 10 II | +| GX-4-C | Message Pad Esscrpt | SDNY_G3,4_00165754 | 2021 10 II | +| GX-443 | Message Pad Essopt | SDNY_GM_00163759 | 2021.10.11 | +| GX-4-E | Message Pad Eacerpt- | SDNY GM 00165761 | 2021.10.11 | +| GX-4-F | Message Pad Excerpt | SDNY_GM_00163776 | 2021.10.11 | +| GX.441 | Message Pad Ewerpt | SDNY_GM_00163790 | 2021 10.11 | +| GX-441 | Message Pad Excerpt | SDNY GM 00165791 | 2021 10.11 | +| GX-44 | Message Pad Esccrpt | SONY_GM_0016511I | 2021 10 II | +| GX-14 | Message Pad Ewe:pi | SDNY_GM_00165115 | 2021 10 11 | +| GX-44C | Message Pad EAccrpia | SDNY GM 00165117 | 2021 10 11 | + +### 10 Series + +| | | Birth Certificates | | +|-------|------------------------------------------------|--------------------------------------------|----------------------------| +| SA | DtitriplION | Batt. Numberildenttlier | Source Produced to Defense | +| OX-11 | Certified Bath foursome of Shnor Victim-4- | SUN\ (iNI 02765030 | 2021 10 II | +| GX-12 | Certified Birth Ceinficate of Slum/ Victim.' h | SDNYJIM02760681 | 2021 10 11 | +| GX-13 | Cenified Birth Certificate of Minor Victim-2e | SDNY_GS1_02753693 | 2021 10 II | +| GX-14 | Certified Birth Catificate of Minor Victim4e | SDNY GM 02765767 | 2021 10.28 | +| GX-15 | Certified Birth Certificate of Mince Vicum•Cir | SDNY _ G .sil _ 02760679•SDNY 0.1_027606SO | 2021.10 II | +| GX-16 | Certified Birth Certificate of Minor Victim-3N | SDNY_GAl_02766961 | 2021.10.28 | + +#### 50 Series + +| — | | Other Physical Exhibits | | +|----------|--------------------------------------------------|------------------------------------|---------------------------| +| CX | Description | Bates Number/Identifier | Smartt Produced to Defrou | +| GX-51 | Honda Marsrge I able | | 2021 10 II | +| OX-51-A | Photograph of Underside of Florida Message lahk | SONY Ohl 02763005 | 2021 10 I I | +| GX-51-B | Photo a h of Sticker on Honda Mass Table | SDNY Ohl 02763006 | 2021.1011 | +| GX-51-C | Photograph of Sucker on Honda Massage Table | SONY_CSIE02763007 | 2021.10H | +| GX-52 | Mask Contact Book | | 2021.1011 | +| GX-52-A | Scanned Page Iron, HMI Contact Backe | SDNY GM 02763001-SONY GM 02763008 | 2021.1011 | +| GX-52-B | Scanned Pegg 'nun Black Contact Book | SDNY_GM_02763009-SDNY_GM_02763009 | 2021.1011 | +| GX-52-C | Scanned Pegg 'nun Black Contact Book | SDNY_GM_02763010-SDNY_GM_02763010 | 2021.1011 | +| GX-524D | Scanned Nee Imo, Black Contact Book | SONY GM 0276301 ESIDNY GM 02763011 | 2021.1011 | +| GX-52-E | Scanned Peg.: Inn Black Contact Book | SDNY_GM_02763013SDNY_GM_02763014 | 2021.10 II | +| GX-52-F | Scanned PAN horn HMI Contact Book | SONY_GM_02763015SDNY_GM_02763015 | 2021 10 II | +| GX-32-G | Scanned Page from Black Contact Book | SDNY GM 02763016%10NY GM 02763016 | 2021.10 II | +| GX-32-II | Scanned Page from Black Contact Book | SONY G11_02765761 | 2021.1011 | +| GX-53 | Box of firecostumes | | 202110.11 | +| GX-54 | Hard Drive NYCO24330 | | 202110.11 | +| GX-55 | Hard Dnve NYCO24349 | | 2021.10.11 | +| GX-M | Hard Drne NYCO24313 | | 2021.10.11 | +| GX-57 | New York Marmite Table | | 2021.10.11 | +| GX-57-A | Photograph of Undeiside of New Yak Massage Table | SDNY_GM_02763019-SDNY_GM_02763019 | 2021.10.11 | +| GX-57-S | Photograph of Sucker on New Volt Massage Table | SDNY_GM_02763011-SDNY_GM_02763011 | 2021.10.11 | +| GX-51 | Paw of Boots | | 202110.11 | + +| | | 100 Series Photographs of People | | +|----------|--------------------------------------------------|----------------------------------|-------------------------| +| OX | DeterWin | Bain Numlwrildentilier | Source Produced to Dame | +| GX-101 | Photograph of Minor %lama. | SDNY_GM_00166005 | 2021 10 11 | +| GX-102 | Photograph of Minor Mamma. | SDNY GM 02750527 | 2021.10.11 | +| GX-103 | Photograph of MIDOt Magna. | SDNY_GM_02760624 | 2021.10.11 | +| GX-104 | Photograph of MIMI' Vicum-le | SDNY_GM_02753398 | 2021 10.11 | +| GX-105 | Photograph of Females, Including Minor Vicuimitt | SDNY GM 02753398 | 2021 10.11 | +| GX-106 | Photograph of MIRO! Victem•le | SDNY_GM_00165992 | 2021 10 11 | +| GX-107 | Photograph of ?Vilna Victinule | SDNY_GM_00165995 | 2021 10 11 | +| GX-101 | Photograph of Minor Victimd • | SDNY GM 00165999 | 2021 10 11 | +| GX-109 | Photop h of MIRO. Victim.3o7 | SDNY_GM_00166002 | 2021 l0 ll | +| OX-I10 | Photograph of | SDNY_GM_02753621 | 2021 10 11 | +| GX-Ill | Photograph of Ghisliune Maxwell | SDNY GM 02753632 | 2021.10.11 | +| 0X-112 | Photograph olleffery Ermein | SDNY_GM_02753623 | 2021.10.11 | +| OX-113 | Photograph of Minor Victun•Sa | Made Avaabble for Review | 2021.10.11 | +| GX-1 lot | Photograph of Minor Vittun•Sa | SONY CM 02753629 | 2021.10 11 | + +| | | 200 Series Photographs and Videos from PVPD Search | | +|---------|------------------------------------------------------------------------|----------------------------------------------------|----------------------------| +| S.X | Unmindful | Bain Number/identifier | Source Produced to Defesse | +| OX•201 | Photograph of Exteing at 35K El Bulb Way | SONY GNI 00174459 | 2021 10 11 | +| GX-202 | Photograph of Luang a 15,1 el Bulb Way | SDNY_GM_00174160 | 2021.10 11 | +| GX-203 | Photograph of lixtunic at 358 el Bulb Way | SDNY_GM_00174161 | 2021.10 11 | +| GX-204 | Photo. a • h of Exicnoc at 358 El Bulb Wa | SDNY GM 00174470 | 2021 10 11 | +| GX-205 | Photograph of EX0.1101 at 358 El Hullo Way | SDNY_GM_00174471 | 2021 10 11 | +| GX-206 | Photograph of Exiting at 358 El Bulb Way | SDNY_GM_00174472 | 2021 10 11 | +| GX-207 | Photograph of Exiting at 358 El Bulb Way | SDNY_GM_00174473 | 2021 10 11 | +| GX-7.08 | Photograph of Exit. at 358 El Bulb Way | SDNY_GM_00174381 | 2021 10 11 | +| GX-209 | Photograph of koacing at 358 El Bull° Way | SDNY_GM_00174474 | 2021 10 11 | +| GX-210 | Photograph of Exiting Jr 35K El Wino Way | SDNY GM 00174476 | 2021 10 11 | +| GX-211 | Photograph of lixtonor at 35K El Bid° Way | SDNY_GM_00174477 | 2021 10 11 | +| GX-212 | Photograph of timinor at 35K El lin llo Way | SDNY_GM_00174478 | 2021 10 11 | +| GX-213 | Photograph of Encino at 15K El lin llo Way | SDNY GM 00174479 | 2021 10 11 | +| GX-214 | Photograph of Luting at 15K El lin llo Way | SDNY_GM_00174480 | 2021 10 11 | +| GX-215 | Photograph of Luting at 15K El 15n llo Way | SDNY_GM_00174481 | 2021 10 11 | +| GX-216 | Photograph of Engine at 15K El 15n1lo Way | SDNY GM 00174482 | 2021 10 11 | +| GX-217 | Photograph of Engine J1 1 33 El 15,illo Way | SDNY_GM_00174483 | 2021 10 11 | +| GX-218 | Photograph of F3J0110C J1 1 33 El Bulb Way | SDNY GM 00174481 | 2021 10 11 | +| GX-219 | Photograph in Fnoinor at 15K El Brillo Way | SDNY GM 00174490 | 2021 10 11 | +| GX-220 | Photograph in E3J0110C J1 1 33 El Hullo Way | SDNY GM 00174491 | 2021 10 11 | +| GX-221 | Photograph in Engine J1 1 38 El Hullo Way | SDNY_GM_00174492 | 2021 10 11 | +| GX-222 | Photograph in Entonor J1358 El Bulb Way | SDNY GM 00174493 | 2021 10 11 | +| GX-223 | Photomap!, of hot Hour Office & laving Room at 358 El Hullo Way | SDNY GM 00174366 | 2021 10 11 | +| GX-224 | Photomap!, ol Fint Floor Office & 1 u. mg Room at 358 El Bulb Way | SDNY_GM_00174367 | 2021 10 11 | +| GX-225 | Photograph ol Fint Floor Office & 1 n mg Room 31358 El Hullo Way | SDNY_GM_00174368 | 2021 10 11 | +| GX-226 | Photograph of lint Floor Office & Living Ramat 35K El Bulb Way | SDNY GM 00174518 | 2021.10 11 | +| GX-227 | Photograph of Fast Floor Office & Living Room at .15K El Bulb Way | SDNY_GM_00174521 | 2021.10 11 | +| GX-228 | Photograph or First Floor Office & Living Room at 358 El Bulb Way | SDNY_GM_00174524 | 2021.10 11 | +| GX-229 | Photograph of Fast Floor Office & i.1%fill: Room at 358 El Bulb Way | SDNY GM 00174575 | 2021 10 11 | +| GX-230 | Photograph of Fins Floor Office & Lin HIV Room at 358 El Bulb Way | SDNY_GM_00174526 | 2021 10 11 | +| GX-231 | Photograph or Fast Floor Office & Ln1110 Room at 358 El Bulb Way | SDNY_GM_00174527 | 2021 10 It | +| GX-232 | Photograph or Fast Floor Office & LI‘fill: Room at 358 El Bulb Way | SDNY GM 0017452K | 2021 10 11 | +| GX-233 | Photograph or First Floor Office & LI‘fill: Room at 358 El Bo lb Way | SDNY_GM_00174530 | 2021 10 11 | +| GX-234 | Photograph or First Floor Office & 1.44,1111:Room at 35K El Bo llo Way | SDNY_GM_00174532 | 2021 10 11 | +| GX-235 | Photograph or First Floor Office & Lii mg Room at 15h El lin llo Way | SDNY GM 00174533 | 2021 10 11 | +| GX-236 | Photograph of First Floor Office & Lii mg Room at 351, El Bo llo Way | SDNY_GM_00174535 | 2021 10 11 | +| GX-237 | Photograph of Furs Floor Office & Lii mg Room at 358 El Bulb Way | SDNY_GM_00174536 | 2021 10 11 | +| OX-238 | Photograph of Firs: Floor Office & twang Room at 358 El Hullo Way | SDNY GM 00174545 | 2021 10 11 | +| GX-239 | Photograph of Firsi Floor Office & Living Room at 358 El Hullo Way | SDNY_GM_00174617 | 2021 10 11 | +| GX-210 | Photograph of Arm Floor Office & Living Room at 358 El Hullo Way | SDNY_GM_00174611 | 2021 10 11 | +| OX-211 | Photograph of Fling Floor Office & Living Room at 358 El Hullo Way | SDNY GM 00174691 | 2021 10 11 | +| GX-242 | Photogra i of Elrli Floor Office & Loa • Room at 358 El Bulb Wa • | SDNY GM 00174442 | 2021 10 11 | +| GX-243 | Phonograph 01F10M Floor Office & Living Room at 358 El Hullo Way | SDNY_GM_00174444 | 2021 10 11 | + +| GX-244 | Photograph of Farm Floor Office & laving Warm A 358 El Hullo Way' | SDNY_GM_00174445 | 2021.10.11 | +|---------|--------------------------------------------------------------------------|--------------------------------|------------| +| GX-245 | Photograph of End Floor Office & 1.1\ 1110 Room at .15tt H Bulb Ways | SDNY_GM_00174699 | 2021.10.11 | +| GX-246 | Photograph ol First Floor Office & 1.1\ 11101100111.035K El Bulb Way | SDNY GM 00174446 | 2021.10.11 | +| GX-247 | Photograph of hid Floor Office & lar. mg Room at 35K El Bulb Way' | SDNY GM 00174447 | 2021 10.11 | +| GX-24i | Photograph of Fad Floor Office & Living Room at 358 El Bulb Way | SDNY_GM_00174700 | 2021 10 II | +| GX.249 | Photograph of First Floor Office & 'Sang Room A 358 El Bello Way | SDNY GM 00174704 | 2021 10 II | +| GX.2.50 | Photograph of First Floor Office & Lir mg Room A 358 El Bello Way | SDNY GM 00171448 | 2021 10 II | +| GX.2.51 | Photograph of First Floor Office & lai HIV Room at 158 El Bello Way' | SDNY_GM_00174449 | 2021 10 II | +| GX.252 | Photograph of First Floor Office & l r1110,1100111 .111511 El Brill° Way | SDNY_GM_00174450 | 2021 10 II | +| GX.253 | Photograph of lira Floor Office & Lir mg Room J1158 El Bello Way' | SDNY GM 00174451 | 2021 10 11 | +| GX.254 | Photograph of Firm Floor Office & Lir mg Room at 758 | El 'Milo Way' SDNY_GM_00174452 | 2021 10 11 | +| GX.255 | Photograph of First Floor Office & Lir mg Room at 158 El [Into Way | SDNY_GM_00174707 | 2021 10 11 | +| GX.256 | Photograph of Ara Floor Office & bring Room at 158 El Wino Way | SDNY GM 00174726 | 2021 10 11 | +| GX.257 | Photograph of Ara Floor Office & bring Room s 158 El Wino Way | SDNY_GM_00174727 | 2021 10 11 | +| GX.7.5* | Photograph of Ant Floor Office & bring Room at 158 El Wino Way' | SDNY 0.1_00174369 | 2021 10 II | +| GX-260 | Photograph of Firm Floor Office & 1.mit • Room at 158 El Wino Wa • | SDNY GM 00174425 | 2021 10 II | +| GX.261 | Photograph of Firm Floor Office & Living Room at 358 El Milo Way | SDNY GM_00174426 | 2021 10 II | +| GX-262 | Photograph of Firm Floor Office & Living Room it 358 El Wino Way | SONY GM_00174427 | 2021 10 II | +| GX-263 | Photograph ol Firm Floor Office & Living Room at 358 El BSI° Way | SONY CM 0017442i | 2021 10 II | +| GX-264 | Photograph ol Kitchen at 358 El BSI° Way | SDNY_GM_00174504 | 2021 10 II | +| GX-265 | Photograph of Kitchen at 358 El Wino Way | SDNY_GM_00174505 | 2021 10 II | +| GX-266 | Photograph of Kitchen at 358 El BI1110 Way | SDNY GM 00174506 | 2021 10 II | +| GX-267 | Photograph of Kitchen at 358 El Bnllo Way | SDNY_GM_001746t5 | 2021 10 II | +| GX-24t | Photograph of Kitchen at 358 El Brill° IA dy | SDNY_GM_00174616 | 2021 10 II | +| GX-269 | Photograph of Master Ikdroom A .LSX Fr Indio Way | SDNY GM 00174594 | 2021.10.11 | +| GX-270 | Photograph of Master Bedroom A 351s H1711110 Way | SDNY GM 00174432 | 2021.10.11 | +| GX-271 | Photograph of Master Bedroom A .151s H Wino Way | SDNY_GM_00174596 | 2021.10.11 | +| GX-272 | Photograph of adagio Iltdrogen A .151s H Wino Way | SDNY GM 00174599 | 2021 10.11 | +| GX-273 | Photograph of !Waster Iltdrogen A .151s H Wino Way | SDNY GM 00174600 | 2021 10.11 | +| GX-274 | Photograph of Maslen 11011100111A .151s El lin Ho Way' | SDNY_GM_00174601 | 2021 10 II | +| GX-277 | Photograph (Whistler Bedroom A 151s El Wino Way | SDNY GM 00174602 | 2021 10 II | +| GX.27S | Photograph of Master Bedroom A 151s El Wino Way' | SDNY GM 00174603 | 2021 10 II | +| GX.279 | Photograph of Klima Badman A 15% El Bello Way | SDNY_GM_00174604 | 2021 10 II | +| GX.2S0 | Photograph of Mauer Bedroom at 158 El Bello Way | SDNY_GM_00174605 | 2021 10 II | +| GX.2S1 | Photograph of hIJMOI Bedroom J1358 El Nino Way | SDNY GM 00174433 | 2021 10 11 | +| GX.282 | Photograph of 5.7.15101 Bedroom J1358 El an Ho Way | SDNY_GM_00174434 | 2021 10 11 | +| GX.2S3 | Photograph 01111.15101 Bedroom J135\$ El Milo Way | SDNY_GM_00174435 | 2021 10 11 | +| GX.2S4 | Photon/ s r 01111.151011/88/700111J135\$ El Milo Way | SDNY GM00174436 | 2021 10 11 | +| GX.215 | Photograph of !Auger Belif1/0111J135\$ El Milo Way' | SDNY_GM_00174440 | 2021 10 11 | +| GX-2t6 | Photograph of Maser H88400111 J135\$ El Wino Way | SDNY_GM_00174453 | 2021 10 II | +| GX-2t7 | Photograph of ?Auger Het/700111 J13514 El Bulb Way | SDNY GM00174454 | 2021 10 II | +| GX-21li | Photograph of Abater Bedroom at 358 El Milo Way' | SDNY_GM_00174456 | 2021 10 II | +| GX-2S9 | Photograph of Second Floor at 358 El Bnllo Way | SDNYGM_00174557 | 2021 10 II | +| GX-290 | Photograph ol Second Floor at 352 El Bnllo Way | SDNY GM 0017455t | 2021 10 II | +| CiX-291 | Photograph ol Second Floor at 352 El Bnllo Way | SDNY_GM_00174559 | 2021 10 II | +| GX-292 | Photograph ol Second Floor at 352 El Bnllo Way | SDNY_GM_00174540 | 2021 10 II | +| GX-293 | Photograph ol Second Floor at 352 El Bnllo Way | SDNY GM 00174543 | 2021 10 II | +| GX-294 | Photograph of Second Floor at 352 El Bnllo Way | SDNY_GM_00174419 | 2021 10 II | +| GX-295 | Property Receipts | SDNY GM 0275363t-02753443 | 2021.10.11 | +| GX-296 | Video of Wallahrough at 35S El Bulb Way' | SDNY CM 00332*73 | 2021.10.11 | + +### 300 Series + +## ESI Photographs + +| Ca | Dmenpbos | Bates Number/identifier | Source | Produced to Defense | +|--------|--------------------------------------------------|----------------------------|-------------|---------------------| +| GX.301 | Photograph of Jet | SDNY UM 02753644.2753692 | 1126 | 2021 10 11 | +| GX-302 | Photograph of Jet | SDNY_GM_02753644.2753692 | 1126 | 2021.10II | +| GX-303 | Photograph of lei Interior | SDNY_OM 02753444.2753692 | 117t Book 3 | 2021.1011 | +| GX-304 | Photograph of GhisLune Maxwell and/erre) Eptiein | SDNY_GM 02753444.2753692 | 1126 | 2021.10II | +| GX-305 | Photograph or Ghislaine Maxwell | SDNY_ GM_ 02753444.2753692 | 1126 | 2021.10II | +| GX-306 | Photograph of Cihiskine Maxwell | SDNY_GM 02753644.2753692 | 1126 | 2021.10II | +| GX.307 | Photograph of Ghiskine Maxwell and/erre) Eptiein | SDNY_GM 02753644.2753692 | 1126 | 2021.1011 | +| GX.308 | Photograph of Wald | SDNY GM 02753644.2753692 | 1126 | 2021.1011 | +| GX.309 | Photograph of him, VicturePu | Made Available for Review | 1B26 | 2021.1011 | +| GX.310 | Photograph of /effigy Epstein and | SDNY_GM_02753644.2753692 | IB75 | 2021.1011 | +| 0(.31I | Photograph of Plane (N404CE) | SDNY CM 02753644.2753692 | IB75 | 2021.1011 | + +| GX-312 | Photograph of Plane (N908JE) | SDNY_GM_02753644-2753692 | 1B75 | 2021.10.11 | +|--------|-------------------------------------------------------------|---------------------------|--------------|------------| +| GX-313 | Photograph of Ghislaine Maxwell and Jeffrey Epstein* | Made Available for Review | 1B75 | 2021.10.11 | +| GX-314 | Photograph of Ghislaine Maxwell and Jeffrey Epstein | SDNY_GM_02753644-2753692 | 1B75 | 2021.10.11 | +| GX-315 | Photograph of Jeffrey Epstein and Plane | SDNY_GM_02753644-2753692 | 1B75 | 2021.10.11 | +| GX-316 | Photograph of Ghislaine Maxwell, [REDACTED], and [REDACTED] | SDNY_GM_02753644-2753692 | 1B19 Book 20 | 2021.10.11 | +| GX-317 | Photograph of Ghislaine Maxwell and Jeffrey Epstein | SDNY_GM_02753644-2753692 | 1B75 | 2021.10.11 | +| GX-318 | Photograph of Ghislaine Maxwell and Jeffrey Epstein | SDNY_GM_02753644-2753692 | 1B75 | 2021.10.11 | +| GX-319 | Photograph of Ghislaine Maxwell and Jeffrey Epstein | SDNY_GM_02753644-2753692 | 1B75 | 2021.10.11 | +| GX-320 | Photograph of Ghislaine Maxwell and Jeffrey Epstein | SDNY_GM_02753644-2753692 | 1B75 | 2021.10.11 | +| GX-321 | Photograph of Ghislaine Maxwell and Jeffrey Epstein | SDNY_GM_02753644-2753692 | 1B75 | 2021.10.11 | +| GX-322 | Photograph of Ghislaine Maxwell and Jeffrey Epstein | SDNY_GM_02753644-2753692 | 1B78 | 2021.10.11 | +| GX-323 | Photograph of Ranch | SDNY_GM_02753644-2753692 | 1B75 | 2021.10.11 | +| GX-324 | Photograph of Ghislaine Maxwell and Jeffrey Epstein | SDNY_GM_02753644-2753692 | 1B19 Book 5 | 2021.10.11 | +| GX-325 | Photograph of Ghislaine Maxwell and Jeffrey Epstein | SDNY_GM_02753644-2753692 | 1B75 | 2021.10.11 | +| GX-326 | Photograph of Island | SDNY_GM_02753644-2753692 | 1B19 Book 20 | 2021.10.11 | +| GX-327 | Photograph of [REDACTED] | SDNY_GM_02753644-2753692 | 1B75 | 2021.10.11 | +| GX-328 | Photograph of Zorro Ranch Entryway | SDNY_GM_02753644-2753692 | 1B75 | 2021.10.11 | +| GX-329 | Photograph of Jeffrey Epstein and [REDACTED] | SDNY_GM_02753644-2753692 | 1B19 Book 17 | 2021.10.11 | +| GX-330 | Photograph of [REDACTED] | SDNY_GM_02753644-2753692 | 1B19 Book 16 | 2021.10.11 | +| GX-331 | Photograph of Ghislaine Maxwell, [REDACTED], and [REDACTED] | SDNY_GM_02753644-2753692 | 1B19 Book 20 | 2021.10.11 | +| GX-332 | Photograph of Minor Victim-5*# | Made Available for Review | 1B26 | 2021.10.11 | +| GX-333 | Photograph of Ghislaine Maxwell and Jeffrey Epstein | SDNY_GM_02753644-2753692 | 1B78 | 2021.10.11 | +| GX-334 | Photograph of Ghislaine Maxwell and [REDACTED] | SDNY_GM_02753644-2753692 | 1B78 | 2021.10.11 | +| GX-335 | Photograph of Ghislaine Maxwell and [REDACTED] | SDNY_GM_02753644-2753692 | 1B78 | 2021.10.11 | +| GX-336 | Photograph of Planes | SDNY_GM_02753644-2753692 | 1B63 | 2021.10.11 | +| GX-337 | Photograph of Ghislaine Maxwell on Plane | SDNY_GM_02753644-2753692 | 1B63 | 2021.10.11 | +| GX-338 | Photograph of Ghislaine Maxwell | SDNY_GM_02753644-2753692 | 1B19 Book 10 | 2021.10.11 | +| GX-339 | Photograph of Ghislaine Maxwell | SDNY_GM_02753644-2753692 | 1B19 Book 10 | 2021.10.11 | +| GX-340 | Photograph of Ghislaine Maxwell | SDNY_GM_02753644-2753692 | 1B63 | 2021.10.11 | +| GX-341 | Photograph of Ghislaine Maxwell and Jeffrey Epstein | SDNY_GM_02753644-2753692 | 1B63 | 2021.10.11 | +| GX-342 | Photograph of Ghislaine Maxwell and Jeffrey Epstein | SDNY_GM_02753644-2753692 | 1B63 | 2021.10.11 | +| GX-343 | Photograph of Ghislaine Maxwell and Jeffrey Epstein | SDNY_GM_02753644-2753692 | 1B63 | 2021.10.11 | +| GX-344 | Photograph of Helicopter | SDNY_GM_02753644-2753692 | 1B63 | 2021.10.11 | +| GX-345 | Photograph of Helicopter | SDNY_GM_02753644-2753692 | 1B19 Book 19 | 2021.10.11 | +| GX-346 | Photograph of Island | SDNY_GM_02753644-2753692 | 1B19 Book 5 | 2021.10.11 | +| GX-347 | Photograph of Ghislaine Maxwell and Jeffrey Epstein | SDNY_GM_02753644-2753692 | 1B19 Book 5 | 2021.10.11 | +| GX-348 | Photograph of Ghislaine Maxwell and Jeffrey Epstein | SDNY_GM_02753644-2753692 | 1B19 Book 5 | 2021.10.11 | + +| 400 Series | | | | | +|---------------------|----------------------------------------------------------------------------|-----------------------------------|-----------|---------------------| +| ESI from Relativity | | | | | +| GX | Description | Bates Number/Identifier | Source | Produced to Defense | +| GX-401 | Email | SDNY_GM_02736489-SDNY_GM_02736489 | NYC024350 | 2021.10.11 | +| GX-402 | Email Chain | SDNY_GM_02736488-SDNY_GM_02736488 | NYC024350 | 2021.10.11 | +| GX-403 | Email Chain | SDNY_GM_02736597-SDNY_GM_02736598 | NYC024350 | 2021.10.11 | +| GX-404 | Email Chain | SDNY_GM_02736491-SDNY_GM_02736491 | NYC024350 | 2021.10.11 | +| GX-405 | NYC024349 System Information | SDNY_GM_02762473 | | 2021.10.11 | +| GX-406 | Email Chain between Jeffrey Epstein and Minor Victim-3# | SDNY_GM_00631742-SDNY_GM_00631742 | NYC024383 | 2021.10.11 | +| GX-407 | Email Chain between Jeffrey Epstein and Ghislaine Maxwell | SDNY_GM_00623470-SDNY_GM_00623470 | NYC024383 | 2021.10.11 | +| GX-408 | Email from Ghislaine Maxwell to Jeffrey Epstein | SDNY_GM_00579091-SDNY_GM_00579091 | NYC024383 | 2021.10.11 | +| GX-409 | Email | | NYC024350 | 2021.10.11 | +| GX-410 | Email | SDNY_GM_02736735-SDNY_GM_02736735 | NYC024350 | 2021.10.11 | +| GX-412 | Email Chain | SDNY_GM_02741883-SDNY_GM_02741884 | NYC024350 | 2021.10.11 | +| GX-413 | Email | SDNY_GM_02741405-SDNY_GM_02741405 | NYC024350 | 2021.10.11 | +| GX-415 | Email Chain | SDNY_GM_02741441-SDNY_GM_02741442 | NYC024350 | 2021.10.11 | +| GX-416 | List of Women | SDNY_GM_02736115-SDNY_GM_02736115 | NYC024350 | 2021.10.11 | +| GX-416-B | List of Women - Metadata | | | 2021.10.28 | +| GX-417 | List and Contact Info of Masseuses# | SDNY_GM_02735985-SDNY_GM_02735991 | NYC024349 | 2021.10.11 | +| GX-417-B | List and Contact Info of Masseuses - Metadata | | | 2021.10.11 | +| GX-418 | List and Contact Info of Palm Beach House Workers & Maintenance | SDNY_GM_02736160-SDNY_GM_02736166 | NYC024350 | 2021.10.11 | +| GX-418-B | List and Contact Info of Palm Beach House Workers & Maintenance - Metadata | | | 2021.10.11 | +| GX-419 | NYC024350 System Information | SDNY_GM_02762473 | | 2021.10.11 | +| GX-420 | List of PB New Shampoo and Massage Products | SDNY_GM_02736212-SDNY_GM_02736212 | NYC024350 | 2021.10.11 | +| GX-420-B | List of PB New Shampoo and Massage Products - Metadata | | | 2021.10.11 | +| GX-421 | Massage Therapist Help Wanted Ad | SDNY_GM_02736260-SDNY_GM_02736260 | NYC024350 | 2021.10.11 | +| GX-421-B | Massage Therapist Help Wanted Ad - Metadata | | | 2021.10.11 | + +SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 + +| GX422 | Ghislaine Maxwell and Jeffrey Epstein Relationship Essay | SDNY_GM_02736272•SDNY_GM_02736272 | NYCO24350 | 2021.10.11 | +|---------|---------------------------------------------------------------------|-----------------------------------|-----------|------------| +| GX42243 | Ghislaine Maxwell and Jeffrey Epstein Relationship Essay • Metadata | | | 2021.10.11 | +| GX-423 | Jeffrey Epstein Amazon Order Confirmation | SONY _ (iM 00567862 | NYCO24383 | 2021.10.11 | + +#### 00 Series + +#### Financial Exhibits + +| CX | Description | Bates Number/Identifier | Solute Produced to Defense | +|-------|----------------------------------------------------|-----------------------------------|----------------------------| +| GX401 | lune 2007 JPMC Statement for Air Ghislaine | SDNY_GM_00277986•SDNY_GM_00277989 | 2021.10.11 | +| GX402 | lune 2007 JPMC Statement for Ghislaine Maxwell | SDNY GM 003213564DNY GM 00321363 | 2021.10.11 | +| GX403 | LP. Morgan Entity &wont Application | SDNY_GM_00271135•SDNY_GM_00271137 | 2021.10.11 | +| GX404 | September 2002 JPMC Account Activity | SDNY_GM_00274703•SDNY_GM_0027471I | 2021.10.11 | +| GX405 | 1PMC October 1999 Asset Account Portfolio Records | SDNY GM 00306061SONY GM 00306067 | 2021.10.11 | +| GX406 | Air Umlaut: Account Document | SDNY_GM_00271605•SDNY_GM_00271610 | 2021.10.11 | +| GX407 | Ghislamc Maxwell J.P. Morgan Account and Signature | SDNY_GM_00068254 | 2021.10.11 | + +### 550 Series + +### Phone Records + +| GX-551 | Description | Gates Number/Identifier | Source | Original Defense | +|--------|--------------------------------------------------------------|-----------------------------------|--------|------------------| +| | May 2004 AT&T Wireless Monthly Statement for Jeffrey Epstein | SDNY GM 00365036-SDNY GM 00365049 | | 2021.10.11 | + +### 600 Series + +### Miscellaneous Documents + +| CX | Description | Barn Numberldcinilicr | Source Produced to Defense | +|--------|-------------------------------|-------------------------------------|----------------------------| +| GX401 | Journal Front Cover | SDNY GM 001659s7 | 2021.10.11 | +| GX-602 | Journal Entry | SONY_GM_00165986 | 2021.10.11 | +| GX-603 | January 7. 1996 Journal Entry | SDNY_CM_00165984 | 2021.10.11 | +| GX-604 | January 25,1996 Journal Entry | SDNY_CM_00165982 | 2021.10.11 | +| GX-605 | Journal Back Cover | SDNY_CM_00 165988 | 2021.10.11 | +| GX-606 | flousehok1 Manual | SDNY_GM_00516864•SDNY_GM_005 16922 | 2021.10.11 | +| GX-607 | Work Flours Documan | SDNY GM 00515785 • SDNY GM 00515787 | 2021.10.11 | + +## 660 Series + +# Eli ht Records + +| CX | Description | Bate Number/Identifier | Source | Produced to Defense | +|--------|------------------------------------------------------|----------------------------------|--------|---------------------| +| GX-661 | book from January 23, 2006 to September 19. 20131 | SDNY GM 00005650SDNY GM 00005676 | | 2021.10.11 | +| GX-662 | Flight Logbook from Ape! 25 1991 to January 19.20061 | SDNY_GM_000055324DNY_GM_00005649 | | 2021.10.11 | + +# 700 Series + +## Photographs of Places + +| CX | Description | Brie. Nombre hiemilier | Source Produced to Defense | +|--------|--------------------------------------|------------------------|----------------------------| +| GX•701 | Ghislaine Maxwell New York Townhouse | SDNY (XI 02760615 | 2021.10.11 | +| GX•702 | Ghislaine Maxwell London Townhouse | SDNY GM 02762477 | 2021.10.11 | +| GX•703 | Little Saint James | SDNY GM 02760646 | 2021.10.11 | +| GX.704 | Jeffrey Epstein New York Townhouse | SDNY GM 02760647 | 2021.10.11 | +| GX•705 | Paris Apartment Building | SDNY GM 02760648 | 2021.10.11 | +| GX•706 | New Mexico Ranch | SDNY GM 02760649 | 2021.10.11 | + +## /20 Series + +# Maps + +| CX | | Desolation | Bate Numberadentifier | &Mt | PindlintelldLith&W | +|--------|-------------------|------------|-----------------------|-----|--------------------| +| GX•721 | Map of Palm Beach | | SONY _CA1_02762184 | | 2021.10.11 | +| GX•722 | Map of Palm Beach | | SI)NY_CAl_02762185 | | 2021.10.11 | + +# 740 Series + +## Interlochen Records + +| CX | | Description | Bate Numbeeldentiller | Source | Produced to Defense | +|--------|---------------|-------------|-----------------------|--------|---------------------| +| GX•741 | Donor Records | | | | | +| | | | SDNY GM 00005018 | | 2021.10.11 | + +| GX-742 | Interlochen Application# | SDNY_GM_02753443-SDNY_GM_02753444
SDNY_GM_02753433-SDNY_GM_02753435,
SDNY_GM_02753523-SDNY_GM_02753524,
SDNY_GM_02753480-SDNY_GM_02753481 | 2021.10.11 | | +|--------------------------------------------------|-------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------|------------|---------------------| +| GX-743 | Minor Victim-1 Application# | 2021.10.11 | | | +| GX-744 | Student Roster# | SDNY_GM_00005077-SDNY_GM_00005103 | 2021.10.11 | | +| 760 Series | | | | | +| Records | | | | | +| GX | Description | Bates Number/Identifier | Source | Produced to Defense | +| GX-761 | Records for Minor Victim-1# | SDNY_GM_00005511-SDNY_GM_00005514 | | 2021.10.11 | +| 780 Series | | | | | +| Palm Beach County School District Records | | | | | +| GX | Description | Bates Number/Identifier | Source | Produced to Defense | +| GX-781 | Minor Victim-5 Enrollment Records for 1989-2002 | SDNY_GM_02753596 | | 2021.10.11 | +| GX-782 | Minor Victim-5 Enrollment Records for 2001-2002 | SDNY_GM_02753597-SDNY_GM_02753598 | | 2021.10.11 | +| GX-783 | Minor Victim-5 Registration Records | SDNY_GM_02753608-SDNY_GM_02753610 | | 2021.10.11 | +| 800 Series | | | | | +| FedEx Records | | | | | +| GX | Description | Bates Number/Identifier | Source | Produced to Defense | +| GX-801 | December 16, 2002 Invoice# | SDNY_GM_00525676-SDNY_GM_00525690 | | 2021.10.11 | +| GX-802 | December 23, 2002 Invoice# | SDNY_GM_00525700-SDNY_GM_00525720 | | 2021.10.11 | +| GX-803 | October 14, 2002 Invoice# | SDNY_GM_00431553-SDNY_GM_00431561 | | 2021.10.11 | +| 820 Series | | | | | +| Mar-A-Lago Records | | | | | +| GX | Description | Bates Number/Identifier | Source | Produced to Defense | +| GX-821 | Human Resources Correspondence Regarding Minor Victim-5's Records | SDNY_GM_00120681 | | 2021.10.11 | +| GX-822 | Mar-A-Lago Termination List | SDNY_GM_00120686-SDNY_GM_00120702 | | 2021.10.11 | +| 900 Series | | | | | +| New York Search Photos | | | | | +| GX | Description | Bates Number/Identifier | Source | Produced to Defense | +| GX-901 | Photograph of Stairwell and Nude Portrait* | SDNY_GM_00166249 | | 2021.10.11 | +| GX-902 | Photograph of Hallway and Nude Portrait* | SDNY_GM_00166251 | | 2021.10.11 | +| GX-903 | Photograph of Massage Room* | SDNY_GM_00166252 | | 2021.10.11 | +| GX-904 | Photograph of Massage Room* | SDNY_GM_00166253 | | 2021.10.11 | +| GX-905 | Photograph of Bathroom* | SDNY_GM_00166258 | | 2021.10.11 | +| GX-906 | Photograph of Massage Table* | SDNY_GM_00166260 | | 2021.10.11 | +| GX-907 | Photograph of Nude Portrait* | SDNY_GM_00166265 | | 2021.10.11 | +| GX-908 | Photograph of Stairwell and Nude Portrait | SDNY_GM_00166273 | | 2021.10.11 | +| GX-909 | Photograph of Townhouse Exterior | SDNY_GM_00166275 | | 2021.10.11 | +| GX-910 | Photograph of Interior and Stairwell | SDNY_GM_00166327 | | 2021.10.11 | +| GX-911 | Photograph of Interior | SDNY_GM_00166328 | | 2021.10.11 | +| GX-912 | Photograph of Interior | SDNY_GM_00166386 | | 2021.10.11 | +| GX-913 | Photograph of Interior | SDNY_GM_00166417 | | 2021.10.11 | +| GX-914 | Photograph of Black Binders in Closet | SDNY_GM_00166594 | | 2021.10.11 | +| GX-915 | Photograph of Stairwell | SDNY_GM_00166719 | | 2021.10.11 | +| GX-916 | Photograph of Desk | SDNY_GM_00166731 | | 2021.10.11 | +| GX-917 | Photograph of Massage Table | SDNY_GM_00166746 | | 2021.10.11 | +| GX-918 | Photograph of Vanity Drawers | SDNY_GM_00166761 | | 2021.10.11 | +| GX-919 | Photograph of Costumes | SDNY_GM_00166767 | | 2021.10.11 | +| GX-920 | Photograph of Costumes | SDNY_GM_00166768 | | 2021.10.11 | +| GX-921 | Photograph of Desk | SDNY_GM_00166771 | | 2021.10.11 | +| GX-922 | Photograph of Interior | SDNY_GM_00167663 | | 2021.10.11 | +| GX-923 | Photograph of Female Portrait | SDNY_GM_00166776 | | 2021.10.11 | +| GX-924 | Photograph of Nude Sculpture | SDNY_GM_00166778 | | 2021.10.11 | +| GX-925 | Photograph of Black Binders in Closet | SDNY_GM_00166779 | | 2021.10.11 | +| GX-926 | Photograph of Drawer Contents | SDNY_GM_00166782 | | 2021.10.11 | +| GX-927 | Photograph of Nude Sculpture | SDNY_GM_00166784 | | 2021.10.11 | +| GX-928 | Photograph of Interior | SDNY_GM_00166907 | | 2021.10.11 | + +SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 + +| GX-929 | Photograph of !manor | SDNY_GM_00167081 | 2021.10.11 | +|--------|------------------------------------------------|--------------------|------------| +| GX-930 | Photograph of Nude POrtlail in Bathroom• | SDNY_GM_00167094 | 2021.10.11 | +| GX-931 | Photograph of Nude Portrait in Bathroom' | SDNY GM 00167095 | 2021.10.11 | +| GX-932 | Photograph of Townhouse Exterior | SDNY GM 00167102 | 2021.10.11 | +| GX-933 | Photograph of Intetior | SDNY_GM_001671 I 1 | 2021.10.11 | +| GX.936 | Photograph of Interior | SDNY_GM_0016721 I | 2021.10.11 | +| GX.935 | Photograph of Bookshelves and Cabinet Contents | SDNY GM 00167251 | 2021.10.11 | \ No newline at end of file diff --git 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Registration district [REDACTED] | | Administrative area | | +| Sub-district [REDACTED] | | [REDACTED] | | +| 1. Date and place of birth CHILD | | | | +| 2. Name and surname [REDACTED] 3. Sex Female | | | | +| 4. Name and surname FATHER | | | | +| 5. Place of birth [REDACTED] | | | | +| 6. Occupation [REDACTED] | | | | +| 7. Name and surname MOTHER | | | | +| 8. Place of birth [REDACTED] | | | | +| 9. (a) Maiden surname (b) Surname at marriage if different from maiden surname | | | | +| 10. Usual address (if different from place of child's birth) [REDACTED] | | | | +| 11. Name and surname (if not the mother or father) 12. Qualification Mother | | | | +| 13. Usual address: (if different from that in 10 above) | | | | +| 14. I certify that the particulars entered above are true to the best of my wishes and belief | | | | +| 15. Date or registration 1972 | | | | +| 16. Signature of registrar R. M. 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DATE SIGNED | | +| ATTENDANT'S CERTIFICATION | 1. CERTIFY THAT I ATTENDED THIS BIRTH AND THAT THE CHILD WAS BORN ALIVE AT THE HOUR, DATE AND PLACE STATED | | 12A. PITY'S AFFILIATION ATTENDANT—SINGLE, TWIN, I SB. IF MULTIPLE, THIS CHILD | | 12B. LICENSE NUMBER | 13C. DATE SIGNED | | +| LOCAL REGISTRAR | 14. | | 15D. TYPED NAME AND ADDRESS | | 15B. LICENSE NUMBER | 16. DATE ACCEPTED FOR REGISTRATION | | +| | 15. DEATH—ENTER DATE OR DEATH | | 16. LOCAL REGISTRAR—SIGNATURE | | 17. DATE ACCEPTED FOR REGISTRATION | 18. 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NATHAN, District Judge: + +As noted in its previous order, the Court will hold an in-person pretrial conference on November 1, 2021 at 11:00 a.m. Dkt. No. 330. The conference will take place in Courtroom 518 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 any members of the Defendant's family. Dkt. No. 344. Two pool reporters will be permitted in the courtroom proper. + +In order to comply with the District's COVID-19 protocols, the public will be able to access the proceeding in overflow Courtrooms 110, 506, 619, 905, and 906 of the Thurgood Marshall U.S. Courthouse. These overflow rooms will have live video and audio feeds of the proceeding. The use of any electronic devices during the proceeding in the overflow rooms is strictly prohibited. + +The Court anticipates seating capacity in the overflow rooms for at least 100 members of the public. If capacity is reached, no additional persons will be admitted. 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 . + +SO ORDERED. + +Dated: October 28, 2021 +New York, New York + +![]() + +--- + +ALISON J. NATHAN +United States District Judge \ No newline at end of file diff --git a/marker2/ds9/EFTA00088947/EFTA00088947.metadata.json b/marker2/ds9/EFTA00088947/EFTA00088947.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..7605e1d9575bdfaf4816a9d10a115341c95402c1 --- /dev/null +++ b/marker2/ds9/EFTA00088947/EFTA00088947.metadata.json @@ -0,0 +1,130 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00088947.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2299, + "elapsed_seconds": 3.72, + "image_assets": [ + "_page_0_Picture_6.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 72.08999999999999 + ], + [ + 281.419189453125, + 72.08999999999999 + ], + [ + 281.419189453125, + 99.7330322265625 + ], + [ + 68.544, + 99.7330322265625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 67 + ], + [ + "Line", + 33 + ], + [ + "Text", + 10 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "SectionHeader", + 1 + ], + [ + "Picture", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 29 + ], + [ + "Line", + 15 + ], + [ + "Text", + 8 + ], + [ + "PageFooter", + 4 + ], + [ + "PageHeader", + 2 + ], + [ + "Caption", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00088947" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00088947/_page_0_Picture_6.jpeg b/marker2/ds9/EFTA00088947/_page_0_Picture_6.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..0c44805304f7b761ecec4534a31cc763c097a253 --- /dev/null +++ b/marker2/ds9/EFTA00088947/_page_0_Picture_6.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:695c71de77501a0042165fc0b889714581228aac44006892f92a261053d9142b +size 12435 diff --git a/marker2/ds9/EFTA00088949/EFTA00088949.md b/marker2/ds9/EFTA00088949/EFTA00088949.md new file mode 100644 index 0000000000000000000000000000000000000000..2842749c98a6b84172d935e48c70c4daa6c1c52c --- /dev/null +++ b/marker2/ds9/EFTA00088949/EFTA00088949.md @@ -0,0 +1,59 @@ +**To:** "Berman, Geoffrey (USANYS)" <[REDACTED]>, "[REDACTED] (USANYS)" + +<[REDACTED]>, "[REDACTED] (USANYS)" <[REDACTED]>, "[REDACTED] (USANYS)" <[REDACTED]>, "[REDACTED] (USANYS)" <[REDACTED]>, "[REDACTED] (USANYS)" + +**Subject:** Re: DAG Memos/call with [REDACTED] + +**Date:** Fri, 24 May 2019 15:15:14 +0000 + +**Importance:** Normal + +[REDACTED] called back to report briefing of DAG went well. She kept it high level. She says he says he is a reader and she thinks he had not had time to read the memos, but may well do so now. + +No concerns expressed. + +Sent from my iPhone + +On May 24, 2019, at 9:31 AM, [REDACTED] (USANYS) <[REDACTED]> wrote: + +See below. Memos received and conveyed to DAG. + +[REDACTED] called this morning and had me walk through with her almost all the cases in both memos to prep for meeting with DAG. + +No issues. + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +Sent from my iPhone + +Begin forwarded message: + +**From:** "[REDACTED] (ODAG)" <[REDACTED]> + +**Date:** May 23, 2019 at 9:17:17 PM EDT + +**To:** "[REDACTED] (USANYS)" <[REDACTED]> + +**Subject:** Re: DAG Memos + +Thank you, and have conveyed the memos. + +On May 23, 2019, at 11:10 AM, [REDACTED] (USANYS) <[REDACTED]> wrote: + +[REDACTED], + +![](_page_1_Picture_1.jpeg) + + + + \ No newline at end of file diff --git a/marker2/ds9/EFTA00088949/EFTA00088949.metadata.json b/marker2/ds9/EFTA00088949/EFTA00088949.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..d0b2271891033f29be5823152ab1c7be44029ef9 --- /dev/null +++ b/marker2/ds9/EFTA00088949/EFTA00088949.metadata.json @@ -0,0 +1,90 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00088949.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 1367, + "elapsed_seconds": 6.67, + "image_assets": [ + "_page_1_Picture_1.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 53 + ], + [ + "Span", + 51 + ], + [ + "Line", + 26 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 7 + ], + [ + "Line", + 4 + ], + [ + "Text", + 3 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00088949" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00088949/_page_1_Picture_1.jpeg b/marker2/ds9/EFTA00088949/_page_1_Picture_1.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..7142ff745332d597cdad25d764382c6a6de6fdc2 --- /dev/null +++ b/marker2/ds9/EFTA00088949/_page_1_Picture_1.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:b079012a779e9162703b4ec6b95bdb947c8fffecff9199920cd1eda10fc20bdb +size 942 diff --git a/marker2/ds9/EFTA00088951/EFTA00088951.md b/marker2/ds9/EFTA00088951/EFTA00088951.md new file mode 100644 index 0000000000000000000000000000000000000000..0dcfa7fe3872985fb719d831c422191e75a47030 --- /dev/null +++ b/marker2/ds9/EFTA00088951/EFTA00088951.md @@ -0,0 +1,95 @@ +**To:** "[REDACTED] (USANYS)" <[REDACTED]>, "[REDACTED] +(USANYS)" <[REDACTED]> + +**Subject:** RE: can you send me a CP report + +**Date:** Thu, 09 Jan 2020 21:28:16 +0000 + +**Attachments:** Child\_Exploitation--Charges\_from\_Date\_III\_for\_Janis.pdf + +--- + +Janis, is this what you're looking for? + +**From:** [REDACTED] (USANYS) <[REDACTED]> + +**Sent:** Thursday, January 9, 2020 3:56 PM + +**To:** [REDACTED] (USANYS) <[REDACTED]> + +**Subject:** FW: can you send me a CP report + +Hell [REDACTED] + +[REDACTED] + +[REDACTED] + +-Drew + +**From:** [REDACTED] (USANYS) <[REDACTED]> + +**Sent:** Thursday, January 09, 2020 3:35 PM + +**To:** [REDACTED] (USANYS) <[REDACTED]> + +**Subject:** RE: can you send me a CP report + +[REDACTED] + +**From:** [REDACTED] (USANYS) <[REDACTED]> + +**Sent:** Thursday, January 9, 2020 3:26 PM + +**To:** [REDACTED] (USANYS) <[REDACTED]> + +**Subject:** RE: can you send me a CP report + +[REDACTED]? + +**From:** [REDACTED] (USANYS) <[REDACTED]> + +**Sent:** Thursday, January 09, 2020 2:45 PM + +**To:** [REDACTED] (USANYS) <[REDACTED]> + +**Cc:** [REDACTED] (USANYS) <[REDACTED]> + +**Subject:** RE: can you send me a CP report + +Drew, + +[REDACTED] + +**From:** [REDACTED] (USANYS) <[REDACTED]> +**Sent:** Thursday, January 9, 2020 1:09 PM +**To:** [REDACTED] (USANYS) <[REDACTED]> +**Cc:** [REDACTED] (USANYS) <[REDACTED]> +**Subject:** Re: can you send me a CP report + +[REDACTED] + +[REDACTED] +[REDACTED] + +[REDACTED] + +[REDACTED] + +Sent from my iPad + +On Jan 9, 2020, at 12:36 PM, [REDACTED] (USANYS) <[REDACTED]> wrote: + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] Olsen Clancy +Victim Witness Coordinator +United States Attorney's Office +Southern District of New York +1 St. Andrews Plaza +New York, New York 10007 +Tel. [REDACTED] 8 \ No newline at end of file diff --git a/marker2/ds9/EFTA00088951/EFTA00088951.metadata.json b/marker2/ds9/EFTA00088951/EFTA00088951.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..eeb24d4b31cebdb076e0bba7d2d47478465fd823 --- /dev/null +++ b/marker2/ds9/EFTA00088951/EFTA00088951.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00088951.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 1737, + "elapsed_seconds": 6.48, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 64 + ], + [ + "Span", + 59 + ], + [ + "Line", + 28 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 31 + ], + [ + "Text", + 26 + ], + [ + "Line", + 15 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00088951" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00088953/EFTA00088953.md b/marker2/ds9/EFTA00088953/EFTA00088953.md new file mode 100644 index 0000000000000000000000000000000000000000..ff2f466dba4f89297f480313b3f5f6ec28fda675 --- /dev/null +++ b/marker2/ds9/EFTA00088953/EFTA00088953.md @@ -0,0 +1,23 @@ +From: To: + +Subject: RE: https://app.criticalmention.com/appllilreport/13bd706a-5524-427c-ae46-57c3f473e775 + +Date: Fri, 10 Jan 2020 21:08:02 +0000 + +Thanks. How does this viewership compare to other network investigative shows? + +From (USANYS) •\* > + +Sent: Friday, January 10, 2020 2:59 PM + +To: + +Subject: https://app.criticalmention.com/app/Vreport/13bd706a-5524-427c-ae46-57c3f473e775 + +Truth and Lies: Jeffrey Epstein got about 3.5 million viewers last night. Report attached. + +United States Department of Justice + +U.S. Attorney's Office I Southern District of New York + +'Mobile: \ No newline at end of file diff --git a/marker2/ds9/EFTA00088953/EFTA00088953.metadata.json b/marker2/ds9/EFTA00088953/EFTA00088953.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..5996261ffd34de4d437eca211d1dea78ce1e67af --- /dev/null +++ b/marker2/ds9/EFTA00088953/EFTA00088953.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00088953.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 577, + "elapsed_seconds": 0.63, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 29 + ], + [ + "Line", + 14 + ], + [ + "Text", + 13 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00088953" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00088954/EFTA00088954.md b/marker2/ds9/EFTA00088954/EFTA00088954.md new file mode 100644 index 0000000000000000000000000000000000000000..dbfdf29857c3e884ee6c77afd5ab314410827aa4 --- /dev/null +++ b/marker2/ds9/EFTA00088954/EFTA00088954.md @@ -0,0 +1,49 @@ +To: + +Subject: Final Voucher 11061344-1(1) approved by approval now awaiting further + +Date: Tue, 24 Mar 2020 14:17:16 +0000 + +Importance: Normal + +Dea + +Final voucher 11061344-1(1) has been approved by now awaiting further approval. + +Trip ID: 11061344-1 + +Voucher ID: 1 + +Voucher type: Final + +Traveler name: + +Purpose: R2ONYS 13402 - Epstein Investigation - Witness interview + +Destination: Beverly Hills, CA, United States + +Dates: 2020-02-26 - 2020-02-29 + +Current status: Pending Voucher Approval + +Voucher total expenses: 1059.52 + +Estimated trip cost: 1621.65 + +E2 Single Sign On Login (within DOJ Network Only): + +https://dojnet.doj.gSjmd/fs/e2-redirect.html + +E2 Manual Login (User ID and Password): + +https://e2.gov.cwtsatotravel.com + +Thank you for using E2Solutions. Help and support is available online by selecting the 'Online Help' link. + +Please note: Replies to this mailbox are not monitored. + +Some E2 email notifications are optional. To manage your email notifications, go to E2 Solutions to change your email settings. Click 'Profile' on the task bar and then click the 'Edit Email Notifications' link to manage the emails that you receive from us. + +Reference ID# V0010 + +This e-mail and any attachments may contain confidential and/or proprietary information. If you received this email 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. \ No newline at end of file diff --git a/marker2/ds9/EFTA00088954/EFTA00088954.metadata.json b/marker2/ds9/EFTA00088954/EFTA00088954.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..3de7df629e5feae5dca6a0b780e944ff5e5f5e9f --- /dev/null +++ b/marker2/ds9/EFTA00088954/EFTA00088954.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00088954.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1463, + "elapsed_seconds": 1.09, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 64 + ], + [ + "Line", + 33 + ], + [ + "Text", + 26 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00088954" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00088955/EFTA00088955.md b/marker2/ds9/EFTA00088955/EFTA00088955.md new file mode 100644 index 0000000000000000000000000000000000000000..e89540da23ec52dff23da3ac02e00d7cf801a4dd --- /dev/null +++ b/marker2/ds9/EFTA00088955/EFTA00088955.md @@ -0,0 +1,7 @@ +## EXHIBIT A + +DECEMBER 9 + +~~AP~~ August 1992 DECEMBER 10 + +Well, what will you do to say is something we've got for a long time. Will truly in love w/ Nea. He makes me feel something no one, else is able to accomplish. I hope we've together for a long time. Because this live like this just doesn't come around ~~the~~ like this everyday. And I really respect him for putting my half aside from love. I love him more than anything - more than I can any less ~~than~~ I might as doop trying to new. \ No newline at end of file diff --git a/marker2/ds9/EFTA00088955/EFTA00088955.metadata.json b/marker2/ds9/EFTA00088955/EFTA00088955.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..8b202e0606ceefb4681c6cbb6cdfd561e7a504cc --- /dev/null +++ b/marker2/ds9/EFTA00088955/EFTA00088955.metadata.json @@ -0,0 +1,100 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00088955.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 496, + "elapsed_seconds": 2.51, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "EXHIBIT A", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 174.42, + 223.56000000000003 + ], + [ + 442.5300598144531, + 223.56000000000003 + ], + [ + 442.5300598144531, + 274.772705078125 + ], + [ + 174.42, + 274.772705078125 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 3 + ], + [ + "Line", + 2 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 7 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00088955" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00088957/EFTA00088957.md b/marker2/ds9/EFTA00088957/EFTA00088957.md new file mode 100644 index 0000000000000000000000000000000000000000..2a9cd5b90f722bfa5a738338d9260bcac2a688d7 --- /dev/null +++ b/marker2/ds9/EFTA00088957/EFTA00088957.md @@ -0,0 +1,14 @@ +## EXHIBIT B + +APRIL 18 +1995 + +Today I learned something that would have been better for me to learn a long time ago. You can't trust anyone in this world. But there are always exceptions to the rule. For me, there is only ~~I~~ person in the world that I can trust. He is the one I confide my inner most feelings to. He is not blood related, but we have a much closer, tighter bond. We have the power of the truest, purest love, and that beats all. I've learned not even to trust your own brothers and distend. If you do, someday it will come back to haunt you. It will turn right back around, and stop you in your back. I've learned the hardway - through + +APRIL 19/8 + +Experience. I've been in an act, a shaw my whole life, and I was the punch line. To look at me, you would think I was normal-good 'ol American middle class family. But if you looked into my mind, you would see torments - abuse of a disgreent kind. You see, all I ever really wanted was someone to lave me, and accept me for who I was, as a person. I wanted someone sincere, not judging. My whole life I've been obliged around for the benefit of others. I've been put down and made fun of they target everything I believe in, love, and care about. They give no thought to human + +APRIL 18 + +emotion of love. They're algrish and purple and think ~~restraining~~ of rotting but themselves. This is what I have learned through my experiences. But as I saw beyond, there is always an exception. And this one has listened all the pain. He's made my hants glad again and leap out & such happiness and love. You don't have to say a verde of explanation and you know he understands your depress thoughts and emotions. This one has achieved me of all the latest I've known. And made me love again - to the depress part of my heart. I love him. And that is the most I can say of anyone. \ No newline at end of file diff --git a/marker2/ds9/EFTA00088957/EFTA00088957.metadata.json b/marker2/ds9/EFTA00088957/EFTA00088957.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..8b2f19af4bebcdce2c1d42fc48dfefd4217fe53d --- /dev/null +++ b/marker2/ds9/EFTA00088957/EFTA00088957.metadata.json @@ -0,0 +1,126 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00088957.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 1843, + "elapsed_seconds": 4.96, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "EXHIBIT B", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 175.64399999999998, + 223.56000000000003 + ], + [ + 444.92010498046875, + 223.56000000000003 + ], + [ + 444.92010498046875, + 275.28216552734375 + ], + [ + 175.64399999999998, + 275.28216552734375 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 3 + ], + [ + "Line", + 2 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 4 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 6 + ], + [ + "PageHeader", + 2 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00088957" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00088960/EFTA00088960.md b/marker2/ds9/EFTA00088960/EFTA00088960.md new file mode 100644 index 0000000000000000000000000000000000000000..c6efad26a39500a95bb6a6c6a9df054109eec15f --- /dev/null +++ b/marker2/ds9/EFTA00088960/EFTA00088960.md @@ -0,0 +1,31 @@ +## FEDERAL BUREAU OF INVESTIGATION + +Ihmeahhhhhilhiat 05/29/2008 + +On Ma 29 2008, Special Agents (SAs) and of the Federal Bureau of Inni.t.1.4H11 EI) met wit at her residence at , New York. + +was advised of the identity of the interviewing a ents and.. agents could state the purpose of the interview, stated she did not want to speak to the agents and wanted to speak to her attorney. then provided agents with her attorney's business card. attorney as listed on the business card is DIARMUID WHITE, White and White Law Firm), 148 E. 78th Street, New York, NY 10075, telephone number (212) 861-9850. + +Agents explained they were not there to arrest and stated she was not a target of any FBI investigation ut were there to interview . She was then provided with a copy of a Grand Jury Subpoena issued by the Southern District of Florida, United States District Court, 701 Clemantis Street, West Palm Beach, Florida 33401 to appear before the grand jury on June 3, 2008. + +stated that she would speak to her attorney and understooditlilinsequences of not showing up to the rand jury in Florida. Agents provided contact information for should she later want to contact agents regarding this matter. + +It should be noted that did call SA 111111111 later that same day and stated she wantelltillow why agents wants to talk to her so that she in turn could consult her attorney in this matter. SA areplied that this was regarding JEFFREY EPSTEIN. SA then askedIIIIIIII, "well you are familiar with JEFFREY EPSTEIN right?".. then answered "OK...", and then asked about travel arrangements to Florida for grand jury. + +was then referred to the printed material that Skdi. e with the tzub .na .:- regarding her travel and answered questions. 11111111 added that her was n town and her uncle was also supposed to vi!!!!!!!!!!!!!!!!' her but she would do i est.to make arrangements for them. She added that her husband (last name not provided) would probably be + +lavedipWat im 05/29/2008 e + +Filed 31E-X04-1 2A Debt dittabid + +This docuakat commits nether reecentaabletione Not cowhide.. of the F8L R is the poverty of the FBI and Is looted to MO thiater. it end Its cements ere both:the distributed oubkk your .pact'. + +Si -6-4-414- tO,S0bz-16, + +FD-302a (Rev. 10-6-95) + +31E-MM-108062 + +Continuation of FD-302 of [REDACTED], On 05/30/2008, Page 2 + +traveling with her. [REDACTED] provided no further information at this time. \ No newline at end of file diff --git a/marker2/ds9/EFTA00088960/EFTA00088960.metadata.json b/marker2/ds9/EFTA00088960/EFTA00088960.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..186f522d23572bf785a742848df69815aa49c5a4 --- /dev/null +++ b/marker2/ds9/EFTA00088960/EFTA00088960.metadata.json @@ -0,0 +1,112 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00088960.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2415, + "elapsed_seconds": 2.09, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "FEDERAL BUREAU OF INVESTIGATION", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 229.5, + 144.17999999999998 + ], + [ + 386.9073181152344, + 144.17999999999998 + ], + [ + 386.9073181152344, + 153.95416259765625 + ], + [ + 229.5, + 153.95416259765625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 109 + ], + [ + "Line", + 44 + ], + [ + "Text", + 12 + ], + [ + "PageHeader", + 2 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 8 + ], + [ + "PageHeader", + 2 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00088960" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00088962/EFTA00088962.md b/marker2/ds9/EFTA00088962/EFTA00088962.md new file mode 100644 index 0000000000000000000000000000000000000000..41cdd36bbbb64a04085af0e3b5c4d6592cc7b1f0 --- /dev/null +++ b/marker2/ds9/EFTA00088962/EFTA00088962.md @@ -0,0 +1,25 @@ +From: " :1" + +To:' + +Subject: accessory + +Date: Wed, 01 Apr 2020 05:33:58 +0000 + +Embedded: possible\_guidelines\_calculation.msg + +Just throwing this out there, but accessory after the fact (18 U.S.C. 3) has the following elements: + +First, that the crime of [specify crime' alleged in the Indictment was committed by 'specify offenderl; + +Second, that the defendant had knowledge of the commission of that crime and [the offender's' participation in it: + +Third, that with such knowledge, the defendant in some way assisted 'the offender' with the specific purpose or plan to hinder or prevent [the offender's' apprehension, trial or punishment. + +The punishment is: an accessory after the fact shall be imprisoned not more than one-half the maximum term of imprisonment [. . .]; or if the principal is punishable by life imprisonment or death, the accessory shall be imprisoned not more than 15 years. + +One-half the maximum term of conspiracy to commit sex trafficking being, of course, a cap of 2.5 years. The guidelines would be higher for accessory than for misprision — it's the same calculation as obstruction, it goes to 2X3.1 (though really you start at 2X1.1, because conspiracy, but you still end up in the same place), so would be 41 to 51 months (assuming a 3 point reduction for role — or with no role reduction, could be as high as 57-71). Versus closer to something like 21-27 (with no role reduction) or down to 12-18 (with role reduction) for misprision, because it caps at 19 base offense. But also versus a three year cap for misprision. + +I don't have strong feelings about this in any direction, just noticed it while looking for the misprision elements and figured worth mentioning, depending on our views of what the conduct is most appropriately encompassed by. + +Assistant U.S. Attorney Southern District of New York \ No newline at end of file diff --git a/marker2/ds9/EFTA00088962/EFTA00088962.metadata.json b/marker2/ds9/EFTA00088962/EFTA00088962.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..d2aef00bd5de708a6dacb0364db71154d69eb49f --- /dev/null +++ b/marker2/ds9/EFTA00088962/EFTA00088962.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00088962.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1832, + "elapsed_seconds": 0.66, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 52 + ], + [ + "Line", + 24 + ], + [ + "Text", + 13 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00088962" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00088963/EFTA00088963.md b/marker2/ds9/EFTA00088963/EFTA00088963.md new file mode 100644 index 0000000000000000000000000000000000000000..c89bdfb138c30eec93917d2d1a5927c0686cde55 --- /dev/null +++ b/marker2/ds9/EFTA00088963/EFTA00088963.md @@ -0,0 +1,39 @@ +From: " To: a" ; ' + +Subject: possible guidelines calculation + +Date: Fri, 06 Mar 2020 19:39:08 +0000 + +As discussed. And note that the reduction for role (I have it as -3) makes a significant difference; with it, range is 41-51 versus 57-71 without. But obviously I think was very significantly less culpable than Epstein. Please let me know if anybody thinks I have any of this wrong?? + +## A. Offense Level + +1. The November 1, 2006, edition of the Guidelines Manual applies to the offense charged in Count One of the Information. + +2. Pursuant to U.S.S.G. § 211.2(c), because the offense involved obstructing the investigation or prosecution of a criminal offense, the base offense level is determined by referencing U.S.S.G. § 2X3.1. + +3. Pursuant to U.S.S.G. § 2X3.1, the base offense level is 6 levels lower than the offense level for the underlying offense, but not more than level 30 except in circumstances not here applicable. + +a. Pursuant to U.S.S.G. § 2G1.3(a), because the underlying offense constituted sex trafficking of minors, the base offense level is 24. + +b. Pursuant to U.S.S.G. § 2G1.3(b)(4), because the offense involved the commission of a sex act or sexual contact, the base offense level is increased by 2 levels. + +c. Pursuant to U.S.S.G. §§ 2G1.3(d)(1) and 3D1.4, because the offense involved more than five minor victims, the grouping analysis includes more than five units, and the base offense level is increased by 5 levels. + +d. In accordance with the above, the applicable base offense level for the underlying offense is 31. + +4. Pursuant to U.S.S.G. § 2X3.1(a)(1), because the base offense level is 6 levels lower than the offense level for the underlying offense, the base offense level is 25. + +5. Pursuant to U.S.S.G. § 3B1.2, because the defendant was a minor participant in the criminal activity, the base offense level is reduced by 3 levels. + +6. Assuming the defendant clearly demonstrates acceptance of responsibility, to the satisfaction of the Government, through her allocution and subsequent conduct prior to the imposition of sentence, a two-level reduction will be warranted, pursuant to U.S.S.G. § 3E1.1(a). Furthermore, assuming the defendant has accepted responsibility as described in the previous sentence, the Government will move at sentencing for an additional one-level reduction, pursuant to U.S.S.G. § 3E1.1(b), because the defendant gave timely notice of her intention to enter a plea of guilty, thereby permitting the Government to avoid preparing for trial and permitting the Court to allocate its resources efficiently. + +Based upon the information now available to this Office (including representations by the defense), the defendant has zero criminal history points. + +In accordance with the above, the defendant's Criminal History Category is I. + +## C. Sentencing Range + +Based upon the calculations set forth above, the defendant's stipulated Guidelines range is 41 to 51 months' imprisonment (the "Stipulated Guidelines Range"). + +Assistant U.S. Attorney Southern District of New York \ No newline at end of file diff --git a/marker2/ds9/EFTA00088963/EFTA00088963.metadata.json b/marker2/ds9/EFTA00088963/EFTA00088963.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..ce712dac6903922ad42c94bf4e4d8545f4b2a5a2 --- /dev/null +++ b/marker2/ds9/EFTA00088963/EFTA00088963.metadata.json @@ -0,0 +1,162 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00088963.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 3040, + "elapsed_seconds": 0.84, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "A. 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I was in an intense mediation yesterday and did not even read your email until you corrected it. Also, I did speak to [REDACTED] today and she indicated that she would not want to testify at trial, because she wishes to protect her privacy. She would ,however, like me to keep her informed about any plea. I look forward to hearing from you when you are in a position to share information on that subject, if a plea will be accepted in lieu of a trial. + +**Gloria Allred** + +**Allred, Maroko & Goldberg** + +![](_page_0_Picture_137.jpeg) + +[www.amglaw.com](http://www.amglaw.com) + +[www.gloriaallred.com](http://www.gloriaallred.com) + +![](_page_0_Picture_140.jpeg) + +**Inducted into National Women's Hall of Fame - 2019** + +**From:** [REDACTED] <[REDACTED]> +**Sent:** Friday, April 3, 2020 5:09 PM +**To:** Gloria Allred <[REDACTED]> +**Cc:** [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> +**Subject:** RE: RE: Epstein investigation + +I'm sorry, Gloria, I inadvertently swapped attorneys' names below, I apologize! But the below was intended to go to you. Apologies again and thanks as always. + +**From:** [REDACTED] +**Sent:** Friday, April 03, 2020 20:03 +**To:** Gloria Allred <[REDACTED]> +**Cc:** [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> +**Subject:** RE: Epstein investigation + +We wanted to briefly let you know that the DOJ Office of Professional Responsibility, which has its own investigation of the original plea deal, may get in touch with you. We are completely separate from them, but we understand that as part of their inquiry into the circumstances of the initial investigation, they may seek to ask some very brief and limited questions about victims' experiences at that time, potentially including one or more of your clients. We're not conveying any obligation at all, we just didn't want it to be a surprise if they reached out. + +thank you, + +Assistant U.S. Attorney Southern District of New York + +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 323-653-6530. 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(FBI " + +Subject: Epstein - Financial Update + +Date: Wed, 16 Oct 2019 15:25:07 +0000 + +Given and availability, I have scheduled a meeting on 10/24 at 3:00 at 290 Broadway 9th floor Criminal conference room. + +If you are not able to attend, please apprise me. + +Thanks + +Forensic Accountant FBI New York Field Office \ No newline at end of file diff --git a/marker2/ds9/EFTA00088967/EFTA00088967.metadata.json b/marker2/ds9/EFTA00088967/EFTA00088967.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..a81585da0cf33419cf088d2798926afdb3d38a6f --- /dev/null +++ b/marker2/ds9/EFTA00088967/EFTA00088967.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00088967.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 366, + "elapsed_seconds": 0.63, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 29 + ], + [ + "Line", + 15 + ], + [ + "Text", + 13 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00088967" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00088968/EFTA00088968.md b/marker2/ds9/EFTA00088968/EFTA00088968.md new file mode 100644 index 0000000000000000000000000000000000000000..5934138eb87eb9c6c0cae815adf1dc4fd1e3b589 --- /dev/null +++ b/marker2/ds9/EFTA00088968/EFTA00088968.md @@ -0,0 +1,197 @@ +From To Cc + +Subject: Re: URGENT REQUEST FOR VTCs-GHISLAINE MAXWELL 02879-509 + +Date: Tue, 15 Dec 2020 17:33:45 +0000 + +At so long as possible - but at least 3 hours. + +Thanks. again + +S + +Law Offices o + +eW York, NS + +Mai + +Cell: + +Fax: + +••Covid-I9 Notice: The Wen Ith Street office iscurrently closed but ne continue to work warmly. + +Please use email cc fax. instead a Nagar moil. for all conespondence during this. time. + +We eonunue to work regular business bourn throughout thts \*Motion. + +Thank you for your consideration. Our best wishes for your good health and well being. + +This message and any attached documents contain information from the Law Offices of + +that may be confidential and/or privileged. + +If you are not the intended recipient, you may not read, copy. distribute, or use this information. + +If you have received this transmission in error, please notify the sender immediately by reply e-mail and then delete this message. Thank you. + +On Dec 15.2020, at 11:48 AM, :rote: + +Ls there a specific time and length you are looking for? + +12/15/2020 11A6 AM s + +an you for your assistance in arranging legal video conferencing for Ms. Mame'. + +We request daily VTCs. + +It is my understanding that there is a V7C terminal in the vicinity of Ms. Manvelrs + +isolation cell and day room area. + +Please let me know if I need to arrange these through the MDC legal conferencing portal managed by f DNY. + +Mu& appreciated. + +Best- + +New Yak, NY 10011 + +Mai + +Cell + +Fax: + +•tcwid-19 Notice: The West 19th Street office is currently closed but we continue to work remotely. + +Please use email or fax, instead of regular mail for a conesponderce during this time. + +We continte to work regular busasess hours throughout this situation. + +Thank you for your consideration. Our test wishes for your good health and well being. + +This message and any attached documents contain information from the Law Offices of + +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. + +Hi all- + +Trving tonavigate the logistics of this and will try to get back to you lomat-rawwith an answer on how to schedule. + +k/10/20204:59 PM »> + +Good afternoon- + +I write again regarding my immediate need for video teleconferencing with my client GHISUUNE MAXWELL 02879-509 (SEE EMAIL BELOW). + +I am informed that in-person legal visiting has been suspended due to the COVID outbreak at the facility. + +It is imperative that I be able to review discovery documents with my client with via video. + +Legal calls are insufficient for review of the millions of documents in this case. + +Please make these arrangements immediately + +or provide a response that I can bring to the Court's attention. + +Thank you- + +Bobbl + +law ices o + +New York. NY 10011 + +Main: Cell: Fax: + +On Dec 9,2020, at 2:24 PM, wrote: + +Good afternoon- + +I am counsel for GHISLAINE MAXWELL 02879.509 + +I have requested but received video calls with my client Ghislaine Maxwell. + +Ms. and Mr. formed the Court that Ms. Maxwell + +was provided one video ca , ich I confirmed occurred on August 18th but failed due to audio problems. + +I am informed that the VTC occurred in a room between Ms. Maxwell's isolation cell and day room. + +Yesterday, I was informed of the following- + +"Unfortunately there are no VTCs on East SHU. You may reach out t. nd for further assistance in this matter.' + +I am requesting that videoconferences be arranged for Ms. Maxwell or provide explanation for review by the Court. + +Thank + +On Dec 8, 2020, at 345 PM. NYS\_MDCemarl .ch/Y4 MOCemailitaMorga mote: + +Hello + +We can get you an hour long call on Thursday and do our best to make it recurring. Unfortunately there are no Vita on East SHU. You may reach out to + +or further assistance in this matter. + +Thank you. + +From: + +Sent: Tuesd December 8 2020 5:44:17 PM + +To: + +Subject: URGENT REQUEST-GHISLAINE MAXWEU.02879-509 + +Hi Athal. + +Rewesting assistance to arrange legal calls with my client Ghislaine Maxwell 02879-509. + +No response for segued for visit (not sure illegal visiting suspended due to COVID outbreak.) + +Ana up against a filing deadline and need to review voluminous discovery with client. + +Any chance for VTCs so I can review discovery client? + +Otherwise daily legal calls? + +Thanks for all your assistance. + +aw was of + +ew or:. IUUI I + +Main + +Cell: + +Fax: + +Thank you for your consideration. Our best wishes for your good health and well being. + +This message and any attached documents contain information from the Law Offices that may be confidential ander privileged. + +If you are not the intended recipient. you may not read, copy, distribute. or use this information. + +If you have received this IIMISMiSSiOO in error. please notil), the sender immediately by reply e-mail and then delete this message. Thank you. + +On Nov 25,2020, at 2:41 PM. wrote: + +Hi + +My client • Ghislaine Maxwell - 02879.509 • is in quarantine; all of her in•person legal visits have been cancelled. + +Any assistance you can provide arranging daily legal calls • any time of the thy • and an occasional VTC + +(which has been requested but never arranged) would be greatly appreciated. + +This case involves voluminous discovery (the latest production is 1.2 million documents) and upcoming filing deadlines. + +It is imperative that I have contact with my client. \ No newline at end of file diff --git a/marker2/ds9/EFTA00088968/EFTA00088968.metadata.json b/marker2/ds9/EFTA00088968/EFTA00088968.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..191bf963b6f249df89ef5f18376f0cd89d683cdf --- /dev/null +++ b/marker2/ds9/EFTA00088968/EFTA00088968.metadata.json @@ -0,0 +1,114 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00088968.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 5442, + "elapsed_seconds": 2.65, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 97 + ], + [ + "Text", + 56 + ], + [ + "Line", + 46 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 107 + ], + [ + "Line", + 55 + ], + [ + "Text", + 51 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 31 + ], + [ + "Line", + 15 + ], + [ + "Text", + 13 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00088968" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00088971/EFTA00088971.md b/marker2/ds9/EFTA00088971/EFTA00088971.md new file mode 100644 index 0000000000000000000000000000000000000000..f3e6a6e7e5fea20433cae98d486a57f3f6be5d0b --- /dev/null +++ b/marker2/ds9/EFTA00088971/EFTA00088971.md @@ -0,0 +1,177 @@ +# Exhibit 0 + +# GHISLAINE MAXWELL + +FINANCIAL CONDITION REPORT: 2015 - 2020 + +INDEPENDENT REPORT & COMMENTARY PREPARED BY MACALVINS LIMITED CHARTERED ACCOUNTANTS + +FOR + +COHEN & GRESSER LLP + +# GHISLAINE MAXWELL FINANCIAL CONDITION REPORT 2015 - 2020 + +# Table of Contents + +| Independent Accountants' Commentary | 3 | +|-------------------------------------|---| +| | | +| Statement of Financial Condition | 9 | +| | | +| Appendices | | + +### Independent Accountants' Commentary + +Cohen & Gresser LLP + +- 1. In accordance with our engagement of 10 August 2020, we have prepared a summary of the financial condition of Ghislaine Maxwell based on the following information + - (i) Copies of her US tax returns filed in the years 2015 to 2020' + - (ii) Documentation provided by Ghislaine Maxwell's office and her spouse including bank statements and financial correspondence relating to bank accounts, pension fund, and investments2 + - (iii) Documentation provided by the United States Attorney's Office for the Southern District of New York under disclosure in the criminal proceedings; +- 2. We have assisted in the preparation of this statement of financial condition in accordance with International Financial Reporting Standards (IFRS)4 on behalf of your client Ghislaine Maxwell. +- 3. The information supplied by Ghislaine Maxwell's office and by her spouse is incomplete due to the limited ability to access historic banking information from some banks that have terminated their relationship either with Ghislaine Maxwell and/or her spouse. However, we are satisfied from the review we have carried out that the absence of some contemporaneous documentary evidence does not invalidate or cast doubt on the conclusions we have reached nor on the overall reliability of the financial information as presented in the summary of the financial condition of Ghislaine Maxwell. +- 4. We are not able to perform a full audit of the statement of financial condition, nor have we performed any audit type procedures, due to the current circumstances relating both to the impact of the Covid-19 pandemic and the conditions of the detention of Ghislaine Maxwell. +- 5. Accordingly, our opinion is reliant on the information provided to us, which is outlined in paragraph 1(i)-1(iii) above. + +Tax returns filed for the years 2015-2020 are attached as appendices to this report. + +2Attached as appendices to this report. + +3 Relevant discovery materials reviewed pursuant to the terms of the Protective Order issued in United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) are attached as appendices to this report. + +4 See appendices to this report + +- 6. In our professional opinion, notwithstanding the issues highlighted above, the conclusions that we reach in this report are substantiated by all of the data that we have been able to review. +- 7. We have not carried out nor commissioned any independent valuation of assets and have recorded valuations at the lower of historic cost or net realisable value in accordance with IFRS. The accounting policies adopted are to value investments at cost, motor vehicles and the rigid inflatable boat have been depreciated at 20% per annum. The carrying value of jewellery and chattels is presented at lower of cost or estimated net realisable values based on the information provided by Ghislaine Maxwell's spouse. For the purposes of this Report and exchange of El : US\$1.30 has been used throughout the period. +- 8. The statement of financial condition does not include the following categories of asset and liability: + - Contingent assets including any contingent proceeds arising from inheritances; cash recoveries from litigation against third parties; future income derived from intellectual property rights; + - Taxation liabilities including a potential \$1,500,000 liability arising from the New York state audit for the year ending 31 December 2016; + - Any other contingent liabilities including potential damages or costs arising from civil litigation in the United States or other jurisdictions + +# Summary of Facts and Conclusions & Summary of Assets (E&OE) + +- 9. This Financial Condition Report summarizes the total assets of Ghislaine Maxwell and her spouse in the time period from 2015-2020. +- 10. All of Ghislaine Maxwell's assets either owned directly by her, or transferred by her to trusts, or owned by her spouse are fully recorded in this Financial Condition Report. +- 11. Ghislaine Maxwell's net worth at 1 January 2015 was approximately US\$20,200,000. +- 12. The 2015 tax return records the sale of a residentialproperty in New York Cit for \$15,075,000. The address of this property is This report tracks the application of these proceeds all of which are accounted for at all times under review. The proceeds were deposited at UBS in an account of 116 E 65th LLC, an LLC established by Ghislaine Maxwell. The net proceeds were subsequently transferred to other accounts at UBS controlled by Ghislaine Maxwell and were used, in part, to purchase other properties. +- 13. Ghislaine Maxwell married her spouse in 2016 and commenced filing joint US tax returns from the 2016 tax year until today. In 2016 Ghislaine Maxwell transferred the majority of her assets into a trust controlled by her spouse and her sister. + +14. Ghislaine Maxwell's net worth varied in the period under review.5 + +15. Ghislaine Maxwell and her spouse's net worth at 31 October 2020 is approximately US\$22,500,000. This is an estimate based on the 2019 tax filings to the end of December 2019 and review of bank statements and explanations provided by her spouse where bank statements are currently unavailable. This figure includes approximately \$7.67m of advance legal retainer fees. + +16. There has been no alienation of any assets in the period 2015-2020 other than expenditure in the ordinary course of family life and more recently since 2019 very substantial expenditure on professionals engaged in the defense of Ghislaine Maxwell from the criminal charges she faces. + +17. In light of our inability to access all of the bank statements for the entire period for the reasons already explained in paragraphs 3 and 4 above, we have not been able to review every movement of cash from every account; we can, however, deduce from starting or opening balances and the closing balances that we have reviewed in each year that no significant sum of cash has been transferred outside of the control of Ghislaine Maxwell and or her spouse. All of the principal sources and uses of cash from 2015 through 2020 are covered by this report of financial condition without exception. + +### Summary of Specific Transfers and Accounts + +18. We noted that accounts controlled either by Ghislaine Maxwell and/or her spouse, either directly or indirectly, maintained substantial cash and equity balances of approximately \$16 million during the period under review. The cash and equity balances clearly increased from the time of the disposal of the New York property. There are many examples of transfers between accounts, movements triggered by the closure of one banking relationship and the opening of new relationship (examples include the movement of cash and assets from JPM to UBS to Citizens Bank) as well movements of cash maturing on deposit and other financial investments. + +19. In its initial bail submission, the Government referenced transfers totaling more than \$20 million in the earlier period of 2007-2011 which the Government described as transfers from Jeffrey Epstein's accounts to Ghislaine Maxwell's accounts and vice versa. We noted in our review of the financial disclosure materials, that during the period 2007-2011 Ghislaine Maxwell acted as an officer of various corporate entities related to aircraft and air travel associated with Jeffrey Epstein and we noted substantial transfers involving these corporate entities. We did not note any transfers of this nature or the nature described by the government in the 2015-2020 period which forms the subject of our Financial Condition Report. + +5 Macalvins prepared a report of financial condition for Ghislaine Maxwell dated April 30th 2017 (see appendices to this report). The report recorded assets legally and beneficially owned by Ghislaine Maxwell on the balance sheet date. The specific liability recorded arose from a personal guarantee given by Ghislaine Maxwell. This matter was resolved by the year end of 2017 without diminution of assets. + +- 20. We have reviewed available accounts and filings of Terramar Project Inc, a 501C charitable corporation in the United States, and the available accounts and filings of Terramar UK, a charity registered in the United Kingdom. Both charities were established by Ghislaine Maxwell who sat on the respective boards of each. The objects of the charity are to promote for the public benefit: a) the conservation, protection and improvement of the environment, and in particular the environment of the oceans, seas, coastlines and tidal areas b) the conservation and protection of endangered marine flora and fauna c) the education of the public in the fields of marine conservation, marine ecology and related areas. +- 21. Terramar Project Inc was founded in 2012 and Terramar UK was formed in 2014. Both organizations ceased operations in 2019 and were dissolved as corporations and charities in 2019/2020. During this period of time, Ghislaine Maxwell contributed US\$560,650 to the running costs of Terramar Project and approximately \$10,000 to Terramar UK. +- 22. We have identified one donation outside of the time period of this report from Epstein Interests Foundation of US\$57,000 which was recorded as a donation to Terramar Project Inc in the financial year ending 1/21/2013.6 All funds received by Terramar Project Inc were disbursed for the charitable purposes of Terramar Project Inc. No personal, financial benefit was obtained by Ghislaine Maxwell. + +# Summary of Materials Reviewed + +- 23. The principal US bank accounts (i.e., bank accounts with US registered and licensed banks) covered by this report are accounts in the names of Ghislaine Maxwell, her spouse, trusts of which her spouse was a beneficiary and she could have been a beneficiary, and various Limited Liability Corporations owned either by Ghislaine Maxwell or her spouse or trusts of which her spouse was a beneficiary and she could have been a beneficiary held with: + +- I) JPMorgan (accounts closed in April 2014) +- 2) UBS7 +- 3) Citizens Bank (accounts closed in 2020) +- 4) USAA (accounts closed in 2020) +- 5) (account opened in 2020) + +We have not been able to review the bank statements of USAA or Citizens Bank due to the termination of the accounts in 2020 and the lack of access to the underlying documents. We have therefore had to rely on information provided by the Spouse which we can confirm is consistent with our conclusions + +6 See appendices to this report. + +At the bail hearing on July 14, 2020, the Government described UBS as a "Swiss Bank." In fact, Ghislaine Maxwell's accounts were held in the United States at the US registered, domiciled and licenced subsidiary of UBS's publicly quoted Swiss parent company. + +- 24. We have reviewed information for other USA banks and financial institutions including Chemical Bank, Citibank, Sandford Bernstein and UK banks and financial institutions including Cater Allen Bank, Credit Lyonnais, Hobart Capital and Nat West Bank but have concluded that these accounts operated outside of the relevant time period, were closed by 2015 (or in the case of Cater Allen Bank in 2017), and/or the sums involved (unless recorded in the summary analysis) are immaterial to the reliability of the overall presentation. +- 25. All of Ghislaine Maxwell's foreign bank accounts are listed each year in her US FBAR filings + +Barclays Bank + +Cater Allen (closed 2017) + +Credit Lyonnais (closed c2010) + +NatWest Bank (closed c2012) + +- 26. All of the Limited Liability Corporations associated with or controlled by either Ghislaine Maxwell, her spouse, and/or Trusts of which her spouse was a beneficiary and she could have been a beneficiary have been reviewed: + +| Name | Purpose | +|-------------------------|-----------------------------------| +| Angara Trust | Trust holding company | +| Edgarley LLC | Investment in unquoted securities | +| Ellmax LLC | General business activity | +| Granite Reality LLC | Investment in real estate | +| Max Foundation | General philanthropic activity | +| Max Hotel Services Corp | Interior design consultancy | +| Montpelier Trust | Trust Holding Company | +| Pleuston LLC | Investment in real estate | +| Pot & Kettle LLC | Investment in unquoted securities | +| Temporary Cookware LLC | Investment in unquoted securities | +| Terramar Project Inc | Philanthropy | +| Terramar UK Ltd | Philanthropy | +| Tidewood LLC | Investment in real estate | + +- 27. In our review the cash balances on accounts for most of the LLCs did not exceed \$150,000 at any time and the total balances for all LLCs (with the exception of the real estate LLCs including 116 E65th St LLC, Tidewood LLC, Granite Reality LLC) did not exceed \$200,000 in total. +- 28. This report does not cover any analysis of personal living or travel expenditures. However, Ghislaine Maxwell's personal expenditure appears well within her reported annual income in any year. + +29. We report on all of the real estate owned either by Ghislaine Maxwell in her own name, in the name of trusts or Limited Liability Corporations owned by trusts of which she was potentially a beneficiary or of which her spouse was a beneficiary, or in her spouse's name or in Limited Liability Corporations owned by her spouse. + +| Property Address | Ownership Structure | Ultimate Beneficial Owner | +|------------------|---------------------|---------------------------| +| | Ghislaine Maxwell | Ghislaine Maxwell | +| Tucked Awa | Granite Reality LLC | Spouse | +| | Spouse | Spouse | +| Tidewood | Tidewood LLC | Spouse | + +# Conclusion + +- 30. This report confirms that the bank accounts, investments and assets owned by Ghislaine Maxwell have been properly declared in her US tax filings at all times. +- 31. We have spoken to Ghislaine Maxwell's husband and he has confirmed, to the best of his knowledge, information and belief, the accuracy of the information contained in this analysis and for the reasons stated above, we believe that the contents of this Financial Condition Report accurately summarize the net worth of Ghislaine Maxwell and her spouse during the period 2015-2020 based on our review of all of the information provided. +- 32. As previously noted, the net worth of Ghislaine Maxwell and her spouse at 31 October 2020 is approximately USD\$22,500,000. + +For and on behalf of Macalvins Limited + +ASSET CLASS + +**CASH** + +### INVESTMENTS + +Major cash movements for purchase on investments + +**LLCs (at cost)** + +### LIABILITIES + +Pleuston LLC + +Short term unsecured UK loan + +REAL ESTATE + +Properties held + +W +X +Y +Z +ZZ + +Tucked Away, Bradford, NH + Tidewood, [REDACTED] + Tidewood, [REDACTED] + +**CHATTELS** + +**ADVANCE LEGAL RETAINER FEES** \ No newline at end of file diff --git a/marker2/ds9/EFTA00088971/EFTA00088971.metadata.json b/marker2/ds9/EFTA00088971/EFTA00088971.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..c10cdd3fec0afcec277ec81335060d46c119e561 --- /dev/null +++ b/marker2/ds9/EFTA00088971/EFTA00088971.metadata.json @@ -0,0 +1,827 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00088971.pdf", + "engine": { + "marker_major": "2", 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/dev/null +++ b/marker2/ds9/EFTA00088981/EFTA00088981.md @@ -0,0 +1,134 @@ +**To:** "Weinstein, Marc A." <[REDACTED]>, + +"[REDACTED]" <[REDACTED]> + +**Cc:** "[REDACTED]>, "[REDACTED]> + +**Subject:** RE: US v Epstein (Civil Forfeiture Matter) + +**Date:** Sat, 19 Oct 2019 03:53:36 +0000 + +**Attachments:** 2019-10-18, subpoena to Darren Indyke, estate executor.pdf; 2019-10-18, subpoena to Richard Kahn, estate executor.pdf + +--- + +[REDACTED] + +Thank you for speaking with us yesterday, and as discussed we're glad to have the lines of communication open. As we mentioned, we also appreciate you respectively accepting service of process for Mr. Kahn and Mr. Indyke. I have attached both here, but please let me know if either or both of you would prefer to receive process separately. (And we can discuss if there are privilege issues with respect to Mr. Indyke in particular.) + +Additionally, we understand from having spoken with certain victim counsel since our conversation yesterday that they have been told by Bennet Moskowitz that Mr. Moskowitz represents the Epstein estate (and also that discussions between Mr. Moskowitz and at least some victim counsel may have already effectively broken down). Would it be necessary or productive for us to have a call that included Mr. Moskowitz as well, or otherwise could you clarify his role—including whether victim counsel should be communicating with you both or Mr. Moskowitz in the first instance? Happy to discuss any of this in real time if that would be useful. + +Thanks again, and looking forward to being in touch. + +[REDACTED] + +--- + +**From:** Weinstein, Marc A. <[REDACTED]> + +**Sent:** Wednesday, October 16, 2019 16:29 + +**To:** [REDACTED] > + +**Cc:** [REDACTED] >; [REDACTED] > + +[REDACTED] > + +**Subject:** RE: US v Epstein (Civil Forfeiture Matter) + +Alex, + +A call within the following ranges would work for us: 11:00-12:45 or 3:30-5:30. Let us know if something within those ranges works on your end. + +Regards, +Marc + +**Marc A. Weinstein** | Partner +Co-Chair, White Collar Defense + +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. + +**From:** [REDACTED] > + +**Sent:** Wednesday, October 16, 2019 4:13 PM + +**To:** Weinstein, Marc A. [REDACTED] + +**Cc:** [REDACTED] >; [REDACTED] + +[REDACTED] > + +**Subject:** Re: US v Epstein (Civil Forfeiture Matter) + +**CAUTION:** This email was sent by someone outside of the Firm. + +Marc, + +The team has a combination of travel and other obligations this evening, but I f you could please let us know a couple times (or ranges) that work for you tomorrow, we should be able to set a time for then. + +Thanks, + +[REDACTED]. + +On Oct 16, 2019, at 13:05, Weinstein, Marc A. [REDACTED] wrote: + +[REDACTED]: + +Would you be available after 4:30 today for a call with me and Andy? + +Thanks, +Marc + +**Marc A. Weinstein |** Partner + +Co-Chair, White Collar Defense + +**Hughes Hubbard & Reed LLP** + +One Battery Park Plaza, 17th floor | New York, NY 10004-1482 + +Office [REDACTED] | Cell [REDACTED] | Fax [REDACTED] + +[REDACTED] + +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. + +**From:** [REDACTED] > + +**Sent:** Tuesday, October 15, 2019 7:09 PM + +**To:** [REDACTED] ; Weinstein, Marc A. [REDACTED] + +**Cc:** [REDACTED] >; [REDACTED] > + +**Subject:** RE: US v Epstein (Civil Forfeiture Matter) + +We had expected to hear from you following this email last month—please let us know if you would still like to be in touch. And please confirm that you can accept service of process on behalf of the estate. + +Thank you, + +From: Martin Weinberg < + +Date: Se u tember 6, 2019 at 12:02:53 CDT + +To: ' Andrew Tomback "Marc A. Weinstein" artin + +"emerg + +Subject: US v Epstein (Civil Forfeiture Matter) + +Reply-To: Martin Weinberg + +, you have asked, understandably, in the past, for information about the Epstein estate. The attorneys who will be representing the interests of the Estate in any future civil forfeiture matter are Andrew Tomack and Marc Weinstein who I am copying on this email. I know one or both will be attempting to coordinate an introductory phone call with you next week. I will have a continuing role in these matters as well. + +Best + +Marty + +Martin G. Weinberg, Esq. + +20 Park Plaza + +Suite 1000 + +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. 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Mono Building One Saint Andrew's Plaza Neu• York, Neu• York 10007 + +October 18, 2019 + +## VIA EMAIL + +Darren Indyke Executor, Estate of Jeffrey Epstein + +Re: Grand Jury Subpoena + +Please be advised that the accompanying grand jury subpoena has been issued in connection with an official criminal investigation of a suspected felony being conducted by a federal grand July. The Government hereby requests that you voluntarily refrain from disclosing the existence of the subpoena to any third party. While you are under no obligation to comply with our request, we are requesting you not to make any disclosure in order to preserve the confidentiality of the investigation and because disclosure of the existence of this investigation might interfere with and impede the investigation. + +Thank you for your cooperation in this matter. + +Very truly yours, + +GE FFREY S. BERMAN + +By: + +Assistant United States Attorney Southern District of New York + +**United States District Court** +**SOUTHERN DISTRICT OF NEW YORK** + +TO: Darren Indyke +Executor, Estate of Jeffrey Epstein + +**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: November 1, 2019 + +Appearance Time: 10 a.m. + +to testify and give evidence in regard to alleged violations of federal criminal law, including: +18 U.S.C. §§ 1591, 1594(c), 2422(b), 371 + +and not to depart the Grand Jury without leave thereof, or of the United States Attorney, and that you bring with you and produce at the above time and place the following: + +SEE ATTACHED RIDER. **Personal appearance is not required** if the requested records are (1) produced by on or before the return date to Assistant U.S. Attorney [REDACTED] at: U.S. Attorney's Office, Southern District of New York, 1 St. Andrew's Plaza, New York, NY 10007, telephone: [REDACTED], or via email at [REDACTED]; 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 +October 18, 2019 + +[REDACTED] + +GEOFFREY S. BERMAN +*United States Attorney for the* +*Southern District of New York* + +[REDACTED] + +Assistant United States Attorney +One St. Andrew's Plaza +New York, New York 10007 +Telephone: [REDACTED] + +[REDACTED] + +![](_page_1_Picture_136.jpeg) + +#### RIDER + +(Grand Jury Subpoena to Darren Indyke, dated October 18, 2019) + +#### Instructions and Definitions: + +- 1. This Subpoena calls for the production of categories of documents, records, correspondence, and other material (including electronically stored material), as specified below, in the possession, custody, or control of Darren Indyke. +- 2. This subpoena covers all responsive documents wherever they may be found, including on computers, servers, and personal electronic devices, whether in the United States or any foreign jurisdiction. +- 3. The "Will" means the Last Will and Testament of Jeffrey E. Epstein, executed on August 8, 2019. +- 4. Where possible, please produce the records requested herein in electronic form (native format where necessary to view the material in its full scope) in a manner that is OCR-searchable, and with all available electronic metadata. +- 5. This subpoena does not call for the production of any documents protected by a valid claim of privilege, although any responsive document over which privilege is being asserted must be preserved. Any documents withheld on grounds of privilege may be required to be specifically identified on a privilege log with descriptions sufficient to identify their dates, authors, recipients, and general subject matter. + +## Materials To Be Produced: + +- I. Any documents relating to "The 1953 Trust," described in the Will, executed on August 8, 2019, including but not limited to The 1953 Trust agreement itself, and any trust documents referenced or referred to within The 1953 Trust, including but not limited to any such trust agreements themselves for any such trusts referenced or referred to in The 1953 Trust (collectively and in total, the "Trust Documents"); +- 2. Any drafts or notes of the Trust Documents; and +- 3. Any communications relating to the Trust Documents. + +N.B.: Personal appearance is not required if the re uested records are (1) produced by on or before the return date to Assistant U.S. Attorney at: U.S. Attorney's Office, Southern District of New York 1 St. Andrew's Plaza New York, NY 10007, telephone: lin 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: REOUEST 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. + +#### Declaration of Custodian of Records + +Pursuant to 28 U.S.C. § 1746, I, the undersigned, hereby declare: + +My name is (name of declarant) + +I am a United States citizen and I am over eighteen years of age. I am the custodian of records of the business named below, or I am otherwise qualified as a result of my position with the business named below to make this declaration. + +I am in receipt of a Grand J Subpoena, dated October 18, 2019, and signed by Assistant United States Attorney requesting specified records of the business named below. Pursuant to Rules 902(11) and 803(6) of the Federal Rules of Evidence, I hereby certify that the records provided herewith and in response to the Subpoena: + +- (1) were made at or near the time of the occurrence of the matters set forth in the records, by, or from information transmitted by, a person with knowledge of those matters; +- (2) were kept in the course of regularly conducted business activity; and +- (3) were made by the regularly conducted business activity as a regular practice. + +I declare under penalty of perjury that the foregoing is true and correct. + +Executed on (date) + +(signature of declarant) + +(name and title of declarant) + +(name of business) + +(business address) + +## Definitions of terms used above: + +As defined in Fed. R. Evid. 803(6), "record" includes a memorandum, report, record, or data compilation, in any form, of acts, events, conditions, opinions, or diagnoses. The term, "business" as used in Fed. R. 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Mono Building One Saint Andrew's Plaza Neu• York, Neu• York 10007 + +October 18, 2019 + +### VIA EMAIL + +Richard Kahn Executor, Estate of Jeffrey Epstein + +Re: Grand Jury Subpoena + +Please be advised that the accompanying grand jury subpoena has been issued in connection with an official criminal investigation of a suspected felony being conducted by a federal grand July. The Government hereby requests that you voluntarily refrain from disclosing the existence of the subpoena to any third party. While you are under no obligation to comply with our request, we are requesting you not to make any disclosure in order to preserve the confidentiality of the investigation and because disclosure of the existence of this investigation might interfere with and impede the investigation. + +Thank you for your cooperation in this matter. + +Very truly yours, + +GE FFREY S. BERMAN + +B + +Assistant United States Attorney Southern District of New York + +**United States District Court** +**SOUTHERN DISTRICT OF NEW YORK** + +TO: Richard Kahn +Executor, Estate of Jeffrey Epstein + +**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: November 1, 2019 + +Appearance Time: 10 a.m. + +to testify and give evidence in regard to alleged violations of federal criminal law, including: +18 U.S.C. §§ 1591, 1594(c), 2422(b), 371 + +and not to depart the Grand Jury without leave thereof, or of the United States Attorney, and that you bring with you and produce at the above time and place the following: + +SEE ATTACHED RIDER. **Personal appearance is not required** if the requested records are (1) produced by on or before the return date to Assistant U.S. Attorney [REDACTED] at: U.S. Attorney's Office, Southern District of New York, 1 St. Andrew's Plaza, New York, NY 10007, telephone: [REDACTED], or via email at [REDACTED]; 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 +October 18, 2019 + +[REDACTED] + +GEOFFREY S. BERMAN +*United States Attorney for the +Southern District of New York* + +[REDACTED] + +Assistant United States Attorney +One St. Andrew's Plaza +New York, New York 10007 +Telephone: [REDACTED] + +[REDACTED] + +![](_page_1_Picture_136.jpeg) + +#### RIDER (Grand Jury Subpoena to Richard Kahn, dated October 18, 2019) + +#### Instructions and Definitions: + +- 1. This Subpoena calls for the production of categories of documents, records, correspondence, and other material (including electronically stored material), as specified below, in the possession, custody, or control of Richard Kahn. +- 2. This subpoena covers all responsive documents wherever they may be found, including on computers, servers, and personal electronic devices, whether in the United States or any foreign jurisdiction. +- 3. The "Will" means the Last Will and Testament of Jeffrey E. Epstein, executed on August 8, 2019. +- 4. Where possible, please produce the records requested herein in electronic form (native format where necessary to view the material in its full scope) in a manner that is OCR-searchable, and with all available electronic metadata. +- 5. This subpoena does not call for the production of any documents protected by a valid claim of privilege, although any responsive document over which privilege is being asserted must be preserved. Any documents withheld on grounds of privilege may be required to be specifically identified on a privilege log with descriptions sufficient to identify their dates, authors, recipients, and general subject matter. + +## Materials To Be Produced: + +- I. Any documents relating to "The 1953 Trust," described in the Will, executed on August 8, 2019, including but not limited to The 1953 Trust agreement itself, and any trust documents referenced or referred to within The 1953 Trust, including but not limited to any such trust agreements themselves for any such trusts referenced or referred to in The 1953 Trust (collectively and in total, the "Trust Documents"); +- 2. Any drafts or notes of the Trust Documents; and +- 3. Any communications relating to the Trust Documents. + +N.B.: Personal appearance is not required if the re uested records are (1) produced by on or before the return date to Assistant U.S. Attorney at: U.S. Attorney's Office, Southern District of New York 1 St. Andrew's Plaza New York, NY 10007, telephone: lin 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: REOUEST 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. + +#### Declaration of Custodian of Records + +Pursuant to 28 U.S.C. § 1746, I, the undersigned, hereby declare: + +My name is (name of declarant) + +I am a United States citizen and I am over eighteen years of age. I am the custodian of records of the business named below, or I am otherwise qualified as a result of my position with the business named below to make this declaration. + +I am in receipt of a Grand J Subpoena, dated October 18, 2019, and signed by Assistant United States Attorney requesting specified records of the business named below. Pursuant to Rules 902(11) and 803(6) of the Federal Rules of Evidence, I hereby certify that the records provided herewith and in response to the Subpoena: + +- (1) were made at or near the time of the occurrence of the matters set forth in the records, by, or from information transmitted by, a person with knowledge of those matters; +- (2) were kept in the course of regularly conducted business activity; and +- (3) were made by the regularly conducted business activity as a regular practice. + +I declare under penalty of perjury that the foregoing is true and correct. + +Executed on (date) + +(signature of declarant) + +(name and title of declarant) + +(name of business) + +(business address) + +# Definitions of terms used above: + +As defined in Fed. R. Evid. 803(6), "record" includes a memorandum, report, record, or data compilation, in any form, of acts, events, conditions, opinions, or diagnoses. The term, "business" as used in Fed. R. 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Cc + +Subject: RE: US v Epstein (Civil Forfeiture Matter) + +Date: Tue, 22 Oct 2019 16:01:54 +0000 + +Marc, + +That would be fine, thanks. We can call a conference number or one of your desk lines, whatever you prefer. + +thanks, + +From: Weinstein, Marc A. wrote: + +CAUTION: This email was sent by someone outside of the Firm. + +Marc, Andrew, + +Thank you for speaking with us yesterday, and as discussed we're glad to have the lines of communication open. As we mentioned, we also appreciate you respectively accepting service of process for Mr. Kahn and Mr. lndyke. I have attached both here, but please let me know if either or both of you would prefer to receive process separately. (And we can discuss if there are privilege issues with respect to Mr. Indyke in particular.) + +Additionally, we understand from having spoken with certain victim counsel since our conversation yesterday that they have been told by Bennet Moskowitz that Mr. Moskowitz represents the Epstein estate (and also that discussions between Mr. Moskowitz and at least some victim counsel may have already effectively broken down). Would it be necessary or productive for us to have a call that included Mr. Moskowitz as well, or otherwise could you clarify his role—including whether victim counsel should be communicating with you both or Mr. Moskowitz in the first instance? Happy to discuss any of this in real time if that would be useful. + +Thanks again, and looking forward to being in touch. + +From: Weinstein, Marc A. < + +Sent: Wednesday, October 16, 2019 16:29 + +To: + +Cc: + +Subject: RE: US v Epstein (Civil Forfeiture Matter) + +A call within the following ranges would work for us: 11:00-12:45 or 3:30-5:30. Let us know if something within those ranges works on your end. + +Regards, Marc + +Marc A. Weinstein I Partner + +Co-Chair. White Collar Defense + +1111111111 1 + +This message contains confidential information and is intended only for the indo.. L.L.3 y.i.1 c named addressee you should not disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail it you have received this e-mail by mistake and delete this e- ,.1 fr-^' vnit cvctern E tranernkcinn cuaranteed to be secure or error-free as information could be intercepted, corrupted, lost, sender therefore does not accept liability for any errors or omissions in the contents of this verification is required please request a hard-copy version. + +From: + +Sent: Wednesday, Octob + +To: + +Cc + +Subject: Re: US v Epstein (Civil Forfeiture Matter) + +CAUTION: This email was sent by someone outside of the Firm. + +Marc, + +The team has a combination of travel and other obligations this evening, but I f you could please let us know a couple times (or ranges) that work for you tomorrow, we should be able to set a time for then. + +On Oct 16, 2019, at 13:05, Weinstein, Marc A. wrote: + +Would you be available after 4:30 today for a call with me and Andy? + +Thanks, Marc + +Marc A. Weinstein I Partner + +Co-Chair, White Collar Defense + +Hughes Hubbard & Reed LLP + +This message contains confidential information arid 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 frr. n cur system. E-mail transmission cannot be guaranteed to be secure or error-free as information could be intercepted, corrupted, log, - incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in the contents of this a result of e-mail transmission. If verification is required please request a hard-copy version. + +From: Sent: Tuesday, October 15, 2019 7:09 PM T Cc: Subject: RE: US v Epstein (Civil Forfeiture Matter) Weinstein, Marc + +CAUTION: This email was sent by someone outside of the Firm. + +Andrew, Marc, + +We had expected to hear from you following this email last month—please let us know if you would still like to be in touch. And please confirm that you can accept service of process on behalf of the estate. + +Thank you, + +From: Martin Weinberg Date: Sc tember 6. 2019 at 12:02:53 CDT To: ' • , Andrew Tomback "Marc A. Weinstein" artin Weinberg Subject: v ps etn nit orfeiture Matter) Reply-To: Martin Weinberg MOMMINEM + +you have asked, understandably, in the past, for information about the Epstein estate. The attorneys who will be representing the interests of the Estate in any future civil forfeiture matter are Andrew Tomack and Marc Weinstein who I am copying on this email. I know + +one or both will be attempting to coordinate an introductory phone call with you next week. I will have a continuing role in these matters as well. + +Best + +Marty + +Martin G. Weinberg, Esq. + +20 Park Plaza + +Suite 1000 + +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. + +<2019-10-18, subpoena to Darren Indyke, estate executor.pdf> + +<2019-10-18, subpoena to Richard Kahn, estate executor.pdf> \ No newline at end of file diff --git a/marker2/ds9/EFTA00088994/EFTA00088994.metadata.json b/marker2/ds9/EFTA00088994/EFTA00088994.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..06b6b8524be6e733f229590bd60d798569836c54 --- /dev/null +++ b/marker2/ds9/EFTA00088994/EFTA00088994.metadata.json @@ -0,0 +1,144 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00088994.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 4, + "chars": 6204, + "elapsed_seconds": 1.21, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 72 + ], + [ + "Line", + 31 + ], + [ + "Text", + 16 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 73 + ], + [ + "Line", + 34 + ], + [ + "Text", + 21 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 90 + ], + [ + "Line", + 36 + ], + [ + "Text", + 15 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 3, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 28 + ], + [ + "Line", + 14 + ], + [ + "Text", + 11 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00088994" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00088998/EFTA00088998.md b/marker2/ds9/EFTA00088998/EFTA00088998.md new file mode 100644 index 0000000000000000000000000000000000000000..3b39d8ad103561b802a89655ddd534730c989681 --- /dev/null +++ b/marker2/ds9/EFTA00088998/EFTA00088998.md @@ -0,0 +1,93 @@ +From: )" + +To: + +Cc: ' + +Subject: RE: discovery + +Date: Thu, 31 Oct 2019 20:32:14 +0000 + +I have a court conference right at 10. Any chance you could do a bit earlier or a bit later in the morning? + +Thanks, + +Assistant United States Attorney Southern District of New York 1 St. Andrew's Plaza New York, NY 10007 + +From: + +Sent: Thursday, October 31, 2019 4:31 PM + +To: + +Cc: + +Subject: Re: discovery + +Can we chat at 10? + +Sent from my Verizon, Samsung Galaxy smartphone + +Original message + +From: "- + +Date: 10/31/19 4:25 PM (GMT-05:00) + +To: C + +Cc: + +Subject: FW: discovery + +" 10/31/2019 16:25 >>> + +Very sorry to bother you, but would you be available for a call tomorrow to discuss? We need to make sure Tartaglione has regular access to his discovery. + +Assistant United States Attorney Southern District of New York 1 St. Andrew's Plaza New York, NY 10007 + +From: Bruce Barket • + +Sent: Thursday, October 31, 2019 4:21 PM + +To: + +Subject: FW: discovery + +There is a problem here. This is just the latest exchange. I have been writing about this since before the 21st. You asked me to let you know if we ran into a roadblock and we have. My understanding is that Nick has not seen his discovery since the 18th, when it was taken from him. + +Bruce A. Barket, Esq. + +Barket Epstein Kearon Aldea & LoTurco, LLP + +www.barketepstein.com + +This transmittal may be a confidential attorney client communication or may otherwise be privileged or confidential. If it is not clear that you are the intended recipient, you are hereby notified that you have received this transmittal in error; any review, dissemination, distribution or copying of this transmittal is strictly prohibited. If you suspect that you have received this communication in error, please notify us immediately by telephone or email and immediately delete this message and all its attachments + +From: [mailto: + +Sent: Thursday, October 31, 2019 2:07 PM + +To: Bruce Barket + +Subject: Re: discovery + +I am out of the office today. Arrangements were made for him to view his discovery in attorney conference last weekend. The same arrangement will be made for this weekend as well. + +Sent from my Verizon, Samsung Galaxy smartphone + +Original message ------- + +From: Bruce Barket < + +>>> "Bruce Barket" 10/31/2019 13:34 >» + +There seems to be a problem. I don't think Nick has been permitted to view his discovery since it was taken from him. Can we talk + +Bruce A. Barket, Esq. + +Barket Epstein Kearon Aldea & LoTurco, LLP + +www.barketepstein.com + +This transmittal may be a confidential attorney client communication or may otherwise be privileged or confidential. If it is not clear that you are the intended recipient, you are hereby notified that you have received this transmittal in error; any review, dissemination, distribution or copying of this transmittal is strictly prohibited. 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This is very likely covered by exemption. When you have a few minutes, may we discuss? + +## Request Summary: + +This request concerns the criminal case against Jeffrey Epstein brought by the U.S. Attorney for the Southern District of New York in July of 2019. I am interested in records or communications between SDNY and a bank, referred to as "Institution-1" in a court filing from July 12. The case number is 19-cr-00490, and the filing I'm referring to is Document 11 (attached). The references to the unnamed financial institution are on pages 4 and 5 of this filing and concern the assets controlled by Mr. Epstein, who has since died. I am primarily interested in the name of this financial institution. Thank you. + +Thanks, + +![](_page_0_Picture_16.jpeg) + +UNITED STATES ATTORNEY'S OFFICE Southern District of New York \ No newline at end of file diff --git a/marker2/ds9/EFTA00089001/EFTA00089001.metadata.json b/marker2/ds9/EFTA00089001/EFTA00089001.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..ec411df1def98d64c4ed7503e5448eceb4c38926 --- /dev/null +++ b/marker2/ds9/EFTA00089001/EFTA00089001.metadata.json @@ -0,0 +1,88 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089001.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1244, + "elapsed_seconds": 0.84, + "image_assets": [ + "_page_0_Picture_16.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Request Summary:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 31.212, + 344.25 + ], + [ + 120.54647827148438, + 344.25 + ], + [ + 120.54647827148438, + 357.8340759277344 + ], + [ + 31.212, + 357.8340759277344 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 54 + ], + [ + "Line", + 25 + ], + [ + "Text", + 16 + ], + [ + "SectionHeader", + 1 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089001" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089001/_page_0_Picture_16.jpeg b/marker2/ds9/EFTA00089001/_page_0_Picture_16.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..ebdf739451119de74d916bca59e4140918444267 --- /dev/null +++ b/marker2/ds9/EFTA00089001/_page_0_Picture_16.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:5be1cf409ce87fdd5e20a6082ad191bdf31035ad89c84cb0779e7140e4300eab +size 3852 diff --git a/marker2/ds9/EFTA00089002/EFTA00089002.md b/marker2/ds9/EFTA00089002/EFTA00089002.md new file mode 100644 index 0000000000000000000000000000000000000000..1b8b6e863ff8da40d36f80385272d460e14d4a45 --- /dev/null +++ b/marker2/ds9/EFTA00089002/EFTA00089002.md @@ -0,0 +1,125 @@ +From: r + +To: + +Cc: ' H + +Subject: Re: discovery + +Date: Fri, 01 Nov 2019 11:56:10 +0000 + +Hi=, + +No problem at all. I don't think I'll be at the office in time for 8:30. Can we take the 11 am slot ? If not, you can give me a call once you 9am is done. + +Thanks, + +On Nov I, 2019, at 7:44 AM, < > wrote: + +Hi, + +My 11:00 got bumped to 9. Is 8:30 too early? Can I call you as soon as my 9:00 is over (hoping it is only 30 minutes)? + +Sorry, + +Supervisory Staff Attorney CLC New York Metropolitan Correctional Center 150 Park Row New York, New York 10007 + +>>>' yl < > 10/31/2019 4:35 PM >» + +9 is perfect, thank you so much. I'll give you a call then. + +Assistant United States Attorney Southern District of New York 1 St. Andrew's Plaza New York, NY 10007 + +To: Cc: Subject: Re: discovery > + +I can do 9 if that works. I have a teleconference at 11, a meeting at 1, and have to leave by 3 tomorrow. + +Sent from my Verizon, Samsung Galaxy smartphone + +Original message + +From: " Date: 10/31/19 4:32 PM (GMT-05:00) To: Cc: Subject: RE: discovery + +>» " )" 10/31/2019 16:32 >>> + +I have a court conference right at 10. Any chance you could do a bit earlier or a bit later in the morning? + +Thanks, + +Assistant United States Attorney Southern District of New York I St. Andrew's Plaza New York, NY 10007 + +From: + +Sent: Thursday, October 31, 2019 4:31 PM + +To: + +Cc: + +Subject: Re: discovery + +Can we chat at 10? + +Sent from my Verizon, Samsung Galaxy smartphone + +Original message + +From: " < + +r10/31/2019 16:25 >>> + +Very sorry to bother you, but would you be available for a call tomorrow to discuss? We need to make sure Tartaglione has regular access to his discovery. + +Thanks, + +Assistant United States Attorney Southern District of New York 1 St. Andrew's Plaza New York, NY 10007 + +From: Bruce Barket c => + +Sent: Thursday, October 31, 2019 4:21 PM + +To: ) 11: › + +Subject: FW: discovery + +There is a problem here. This is just the latest exchange. I have been writing about this since before the 2P. You asked me to let you know if we ran into a roadblock and we have. My understanding is that Nick has not seen his discovery since the 18th, when it was taken from him. + +Bruce A. Barket, Esq. Barket Epstein Kearon Aldea & LoTurco, LLP + +www.barketepstein.com + +This transmittal may be a confidential attorney client communication or may otherwise be privileged or confidential. If it is not clear that you are the intended recipient, you are hereby notified that you have received this transmittal in error; any review, dissemination, distribution or copying of this transmittal is strictly prohibited. If you suspect that you have received this communication in error, please notify us immediately by telephone or email and immediately delete this message and all its attachments + +From: fmailto: + +Sent: Thursday, October 31, 2019 2:07 PM + +To: Bruce Barket + +Subject: Re: discovery + +I am out of the office today. Arrangements were made for him to view his discovery in attorney conference last weekend. The same arrangement will be made for this weekend as well. + +Sent from my Verizon, Samsung Galaxy smartphone + +Original message ------- + +From: Bruce Barket < + +Date: 10/31/19 1:34 PM (GMT-05:00) + +To: + +Subject: discovery + +>>> "Bruce Barket" 10/31/2019 13:34>>> + +There seems to be a problem. I don't think Nick has been permitted to view his discovery since it was taken from him. Can we talk + +Bruce A. Barket, Esq. + +Barket Epstein Kearon Aldea & LoTurco, LLP + +www.barketepstein.com + +This transmittal may be a confidential attorney client communication or may otherwise be privileged or confidential. If it is not clear that you are the intended recipient, you are hereby notified that you have received this transmittal in error; any review, dissemination, distribution or copying of this transmittal is strictly prohibited. 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The Inbound or Outbound travel is listed in the column with "I/O" at the top. [REDACTED] + +[REDACTED] There are a few "vehicle" crossings listed, but appear to be him arriving at the USVI Pre-departure and Cyril King GAF Pre-flight which appear to be airports in the USVI. The last few pages of the report include an index for some of the airport codes/ports of entry. Unfortunately, much of the travel does appear to be to/from the US Virgin Islands and the continental United States. If during his trips he made his way to the British Virgin Islands or another outside US territory, then he would most likely have to go through US CBP, and in that case he would most likely have to report that he was a sexual offender. + +Here are the private airline tail numbers that are listed for the travel that I came across: + +- \*GA N212JE +- \*GA N120JE +- \*GA N415LM +- \*GA N331JE +- \*GA N90JE + +Please let me know if you need anything else, + +[REDACTED] + +United States Attorney's Office +Southern District of New York + +[REDACTED] + +If any of the information I provide is required for hearings/trials, let me know and I will work with U.S. Customs and Border Protection (CBP) Legal to obtain a certificate of authentication or CBP witness. Unfortunately, I am not authorized to testify as a CBP custodian of records. (LES/FOUO) LAW ENFORCEMENT SENSITIVE - FOR OFFICIAL USE ONLY + +## WARNING: + +The information contained in this email is considered confidential and sensitive in nature as well as sensitive but unclassified and/or legally privileged information. It is not to be released to the media, the general public, or to non-law enforcement personnel who do not have a "need-to-know". This information is not to be posted on the Internet, or disseminated through unsecured channels, and is intended for law enforcement personnel only. It is solely for the use of the intended recipient(s). Unauthorized interception, review, use or disclosure is prohibited and may violate applicable laws including the Electronic Communications Privacy Act. 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As discussed, if needed for court purposes please let me know and I will get a "court ready" approved copy through the CBP Office of Chief Counsel. + +This document reads in reverse chronological order, so the most recent travel is at the top of the report. The Inbound or Outbound travel is listed in the column with "I/O" at the top. For the time period that you are concerned with the subject appears to have all private aircraft travel. There are a few "vehicle" crossings listed, but appear to be him arriving at the USVI Pre-departure and Cyril King GAF Pre-flight which appear to be airports in the USVI. The last few pages of the report include an index for some of the airport codes/ports of entry. Unfortunately ,much of the travel does appear to be to/from the US Virgin Islands and the continental United States. If during his trips he made his way to the British Virgin Islands or another outside US territory, then he would most likely have to go through US CBP, and in that case he would most likely have to report that he was a sexual offender. + +Here are the private airline tail numbers that are listed for the travel that I came across: + +\*GA N212JE + +\*GA NI20JE + +\*GA N415LM + +\*GA N331JE + +\*GA N90JE + +Please let me know if you need anything else, + +Supervisory CBP Officer/TFO + +United States Attorney's Office + +Southern District of New York + +CBP Cell: - CBP Email: DOJ Cell: - DOJ Email: + +If any of the information I provide is required for hearings/trials, let me know and I will work with U.S. Customs and Border Protection (CBP) Legal to obtain a certificate of authentication or CBP witness. Unfortunately, I am not authorized to testify as a CBP custodian of records. (LES/FOUO) LAW ENFORCEMENT SENSITIVE - FOR OFFICIAL USE ONLY + +WARNING: + +The information contained in this email is considered confidential and sensitive in nature as well as sensitive but unclassified and/or legally privileged information. It is not to be released to the media, the general public, or to non-law enforcement personnel who do not have a "need-to-know". This information is not to be posted on the + +Internet, or disseminated through unsecured channels, and is intended for law enforcement personnel only. It is solely for the use of the intended recipient(s). Unauthorized interception, review, use or disclosure is prohibited and may violate applicable laws including the Electronic Communications Privacy Act. 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b/marker2/ds9/EFTA00089010/EFTA00089010.md @@ -0,0 +1,393 @@ +![](_page_0_Picture_0.jpeg) + +# U.S. Customs and Border Protection U.S. Department of Homeland Security TECS - Person Encounter List + +Generated By: Page 1 of 7 + +| Lest Name | First Name | DOB Doc | | | | | | | | | +|-----------|------------|--------------|-----------|------------------|--------|----|-----------|------|-------------------|-----------| +| | | | | DaM.Tkne Carrier | | | | | | | +| | | | | | | UO | Site ken | Type | Status Ref | Am | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 12/14/2018 | | | | | | | +| | | | | •GA | N212JE | I | A523 | APIS | PASSENGER CUSTOMS | KPB: TIST | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 12/14/2018 | | | | | | | +| | | | | *GA | N212JE | O | | APIS | PASSENGER | KPBI TIST | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 11/28/2018 | | | | | | | +| | | | | •GA | N212JE | I | Al0D | APIS | PASSENGER INS | KTEB TIST | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 11/28/2018 | | | | | | | +| | | | | *GA | N212JE | O | | APIS | PASSENGER | KTEB TIST | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 11/25/2018 | | | | | | | +| | | | | •GA | N212JE | O | | APIS | PASSENGER | TIST KBCT | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 11/24/2018 | | | | | | | +| | | | | •GA | N212JE | O | | APIS | PASSENGER | TIST KBCT | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 11/11/2018 | | | | | | | +| | | | | •GA | N212JE | I | Al0D | APIS | PASSENGER INS | KTEB LFPB | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 11/02/2018 | | | | | | | +| | | | | *GA | N212JE | O | | APIS | PASSENGER | LFPB KTEB | +| EPSTEIN | JEFFREY | | | | | | | | | | +| | | 01/20/1953 P | 547017616 | 10/30/2018 | | | | | | | +| | | | | •GA | N212JE | I | Al0D-APIS | | PASSENGER INS | KTEB TIST | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 10/28/2018 | | | | | | | +| | | | | •GA | N212JE | O | | APIS | PASSENGER | TIST KPBI | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 10/11/2018 | | | | | | | +| | | | | •GA | N212JE | O | | APIS | PASSENGER | TIST KPBI | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 10/10/2018 | | | | | | | +| | | | | •GA | N212JE | O | | APIS | PASSENGER | TIST KPBI | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 09/30/2018 | | | | | | | +| | | | | •GA | N212JE | O | | APIS | PASSENGER | LFPB KTEB | +| EPSTEIN | JEFFREY | | | | | | | | | | +| | | 01/20/1953 P | 547017616 | 09/22/2018 | | | | | | | +| | | | | •GA | N120JE | I | A10D | PIS | PASSENGER INS | KTEB TIST | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 09/22/2018 | | | | | | | +| | | | | •GA | N120JE | I | | APIS | PASSENGER | KTEB TIST | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 09/20/2018 | | | | | | | +| | | | | •GA | N120JE | O | | APIS | PASSENGER | TIST KPBI | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 09/13/2018 | | | | | | | +| | | | | *GA | N120JE | I | Al0D | APIS | PASSENGER INS | KTEB LFPB | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 09/06/2018 | | | | | | | +| | | | | *GA | N120JE | O | | APIS | PASSENGER | LFPB KTEB | +| EPSTEIN | JEFFREY | | | | | | | | | | +| | | 01/20/1953 P | 547017616 | 08/29/2018 | | | | | | | +| | | | | •GA | N120JE | I | A523 | APIS | PASSENGER CUSTOMS | KPBI TIST | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 08/25/2018 | | | | | | | +| | | | | •GA | N120JE | O | | APIS | PASSENGER | TIST KTEB | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 08/15/2018 | | | | | | | +| | | | | •GA | N120JE | I | Al0D_APIS | | PASSENGER | KTEB TIST | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 08/14/2018 | | | | | | | +| | | | | •GA | N120JE | O | | APIS | PASSENGER | TIST KPBI | + +![](_page_1_Picture_0.jpeg) + +# U.S. Customs and Border Protection U.S. Department of Homeland Security TECS - Person Encounter List + +Generated By: Page 2 of 7 + +| Lest Name | Petitions | DOB Doc | | | | | | | | | +|-----------|-----------|--------------|-----------|------------------|--------|----|-----------|------|-------------------|-----------| +| | | | | Date-Time Carder | | | | | | | +| | | | | | | V0 | Site insp | Type | Status Ref | Am | +| EPSTEIN | JEFFREY | | | | | | | | | | +| | | 01/20/1953 P | 547017616 | 08/06/2018 | | | | | | | +| | | | | *GA | N120JE | I | I-10D | APIS | PASSENGER INS | KTEB TIST | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 08/05/2018 | | | | | | | +| | | | | •GA | N120JE | O | | APIS | PASSENGER | TIST KPBI | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 07/29/2018 | | | | | | | +| | | | | •GA | N212JE | Z | AIDS | APIS | PASSENGER INS | KTEB LFPB | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 07/21/2018 | | | | | | | +| | | | | •GA | N212JE | O | | APIS | PASSENGER | LFPB KTEB | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 07/10/2018 | | | | | | | +| | | | | •GA | N212JE | Z | Al0D-APIS | | PASSENGER INS | KTEB TIST | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 07/07/2018 | | | | | | | +| | | | | •GA | N212JE | O | | APIS | PASSENGER | TIST KPBI | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 06/27/2018 | | | | | | | +| | | | | 'GA | N212JE | Z | MOD | APIS | PASSENGER INS | KTEB LFPB | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 06/20/2018 | | | | | | | +| | | | | *GA | N212JE | O | | APIS | PASSENGER | LFPB KTEB | +| EPSTEIN | JEFFREY | | | | | | | | | | +| | | 01/20/1953 P | 547017616 | 06/15/2018 | | | | | | | +| | | | | •GA | N212JE | Z | A523 | APIS | PASSENGER CUSTOMS | KPBI TIST | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 06/15/2018 | | | | | | | +| | | | | •GA | N212JE | O | | APIS | PASSENGER | TIST KPBI | +| EPSTEIN | JEFFREY | | | | | | | | | | +| | | 01/20/1953 P | 547017616 | 06/02/2018 | | | | | | | +| | | | | •GA | N212JE | Z | A47E | APIS | PASSENGER INS | KISP TIST | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 06/02/2018 | | | | | | | +| | | | | •GA | N212JE | O | | APIS | PASSENGER | TIST KPBI | +| EPSTEIN | JEFFREY | | | | | | | | | | +| | | 01/20/1953 P | 547017616 | 05/27/2018 | | | | | | | +| | | | | 'GA | N212JE | Z | A523 | APIS | PASSENGER | KPBI TIST | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 05/22/2018 | | | | | | | +| | | | | •GA | N212JE | | A47E | APIS | PASSENGER | KISP LFPB | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 05/13/2018 | | | | | | | +| | | | | 'GA | N212JE | O | | APIS | PASSENGER | LFPB KTEB | +| EPSTEIN | JEFFREY | | | | | | | | | | +| | | 01/20/1953 P | 547017616 | 04/27/2018 | | | | | | | +| | | | | •GA | N120JE | 1 | A523 | APIS | PASSENGER CUSTOMS | KPBI TIST | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 04/27/2018 | | | | | | | +| | | | | 'GA | N120JE | O | | APIS | PASSENGER | TIST KTEB | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 04/20/2018 | | | | | | | +| | | | | 'GA | N212JE | Z | Al0D | APIS | PASSENGER INS | KTEB TIST | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 04/20/2018 | | | | | | | +| | | | | •GA | N212JE | O | | APIS | PASSENGER | TIST KPBI | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 04/09/2018 | | | | | | | +| | | | | *GA | N212JE | Z | Al0D | APIS | PASSENGER INS | KTEB LFPB | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 03/31/2018 | | | | | | | +| | | | | •GA | N212JE | O | | APIS | PASSENGER | LFPB KTEB | +| EPSTEIN | JEFFREY | | | | | | | | | | +| | | 01/20/1953 P | 547017616 | 03/27/2018 | | | | | | | +| | | | | •GA | N212JE | I | A512 | APIS | | | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 03/27/2018 | | | | | | | +| | | | | •GA | N212JE | Z | | APIS | PASSENGER | KPBI TIST | + +![](_page_2_Picture_0.jpeg) + +## U.S. Customs and Border Protection U.S. Department of Homeland Security TECS - Person Encounter List + +Generated B Page 3 of 7 + +| Last Name | First Name | DOB Doc | | | | | | | | | | +|-----------|------------|--------------|-----------|------------|--------|--------|----|-----------|------|-------------------|-----------| +| | | | | Date.Tkne | Carder | | | | | | | +| | | | | | | | VO | Site Inv | Type | Status Ref | Am | +| EPSTEIN | JEFFREY | | | | | | | | | | | +| | | 01/20/1953 P | 547017616 | 03/13/2018 | | | | | | | | +| | | | | | 'GA | N120JE | : | Al0D | APIS | PASSENGER INS | KTEB LFPB | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 03/08/2018 | | | | | | | | +| | | | | | 'GA | N120JE | O | | APIS | PASSENGER | LFPB KTEB | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 03/03/2018 | | | | | | | | +| | | | | | 'GA | N120JE | : | Al0D | APIS | PASSENGER INS | KTEB TIST | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 03/03/2018 | | | | | | | | +| | | | | | 'GA | N120JE | O | | APIS | PASSENGER | TIST KPBI | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 02/21/2018 | | | | | | | | +| | | | | | 'GA | N120JE | : | Al0D | APIS | PASSENGER INS | KTEB TIST | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 02/21/2018 | | | | | | | | +| | | | | | 'GA | N120JE | O | | APIS | PASSENGER | TIST KFXE | +| EPSTEIN | JEFFREY | | | | | | | | | | | +| | | 01/20/1953 P | 547017616 | 02/07/2018 | | | | | | | | +| | | | | | 'GA | N120JE | I | A523 | APIS | PASSENGER CUSTOMS | KPBI TIST | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 02/07/2018 | | | | | | | | +| | | | | | 'GA | N120JE | 0 | | APIS | PASSENGER | TIST KPBI | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 01/27/2018 | | | | | | | | +| | | | | | 'GA | N120JE | : | Al0D | APIS | PASSENGER INS | KTEB CYYR | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 01/27/2018 | | | | | | | | +| | | | | | 'GA | N120JE | : | | APIS | PASSENGER | KTEB CYYR | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 01/21/2018 | | | | | | | | +| | | | | | 'GA | N120JE | O | | APIS | PASSENGER | LFPB KTEB | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 01/20/2018 | | | | | | | | +| | | | | | 'GA | N120JE | O | | APIS | PASSENGER | LFPB KTEB | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 01/16/2018 | | | | | | | | +| | | | | | 'GA | N120JE | : | Al0D | APIS | PASSENGER INS | KTEB TIST | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 01/16/2018 | | | | | | | | +| | | | | | 'GA | N120JE | O | | APIS | PASSENGER | TIST KPBI | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 01/07/2018 | | | | | | | | +| | | | | | 'GA | N120JE | : | Al0D_APIS | | PASSENGER INS | KTEB TIST | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 01/07/2018 | | | | | | | | +| | | | | | 'GA | N120JE | O | | APIS | PASSENGER | TIST KPBI | +| EPSTEIN | JEFFREY | | | | | | | | | | | +| | | 01/20/1953 P | 547017616 | 12/20/2017 | | | | | | | | +| | | | | | 'GA | N120JE | I | A523 | APIS | PASSENGER CUSTOMS | KPBI TIST | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 12/20/2017 | | | | | | | | +| | | | | | 'GA | N120JE | O | | APIS | PASSENGER | TIST KPBI | +| EPSTEIN | JEFFREY | 01/20/1953 P | 547017616 | 12/12/2017 | | | | | | | | +| | | | | | 'GA | N120JE | : | MOD | APIS | PASSENGER INS | KTEB LFPB | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 12/08/2017 | | | | | | | | +| | | | | | 'GA | N120JE | O | | APIS | PASSENGER | LFPB KTEB | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 12/05/2017 | | | | | | | | +| | | | | | 'GA | N120JE | O | | APIS | PASSENGER | TIST KPBI | +| EPSTEIN | JEFFREY | | | | | | | | | | | +| | | 01/20/1953 P | 547017616 | 11/26/2017 | | | | | | | | +| | | | | | 'GA | N120JE | : | Al0D | APIS | PASSENGER | KTEB TIST | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 11/26/2017 | | | | | | | | +| | | | | | 'GA | N120JE | O | | APIS | PASSENGER | TIST KPBI | + +![](_page_3_Picture_0.jpeg) + +## U.S. Customs and Border Protection U.S. Department of Homeland Security TECS - Person Encounter List + +Generated By: Page 4 of 7 + +| Last Name | First Name | DOB Dec | | | | | | | | | +|-----------|------------|--------------|-----------|------------------|--------|----|----------|---------|-------------------|-----------| +| | | | | Date.Tkne Carder | | | | | | | +| | | | | | | V0 | Site Imp | Type | Status Ref | Am | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 11/07/2017 | | | | | | | +| | | | | *GA | N120JE | I | A1OD | APIS | PASSENGER INS | KTEB TIST | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 11/07/2017 | | | | | | | +| | | | | *GA | N120JE | 0 | | APIS | PASSENGER | TIST KPBI | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 11/03/2017 | | | | | | | +| | | | | *GA | N120JE | 0 | | APIS | PASSENGER | TIST KPBI | +| EPSTEIN | JEFFREY | | | | | | | | | | +| | | 01/20/1953 P | 547017616 | 10/20/2017 | | | | | | | +| | | | | *GA | N415LM | I | A1OD | APIS | PASSENGER INS | KTEB LFPB | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 10/09/2017 | | | | | | | +| | | | | *GA | N415LM | 0 | | APIS | PASSENGER | LFPB KTEB | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 10/05/2017 | | | | | | | +| | | | | *GA | N415LM | I | A47E | APIS | PASSENGER INS | KISP TIST | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 09/13/2017 | | | | | | | +| | | | | *GA | N415LM | I | A47E | APIS | PASSENGER INS | KISP LFPB | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 09/02/2017 | | | | | | | +| | | | | *GA | N415LM | 0 | | APIS | PASSENGER | LFPB KTEB | +| EPSTEIN | JEFFREY | | | | | | | | | | +| | | 01/20/1953 P | 547017616 | 08/29/2017 | | | | | | | +| | | | | *GA | N120JE | | A514 | APIS | | | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 08/29/2017 | | | | | | | +| | | | | *GA | N120JE | = | Name No | | | | +| | | | | | | | | APIS | PASSENGER | TEB XXX | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 08/02/2017 | | | | | | | +| | | | | *GA | N212JE | = | AlOD | APIS | PASSENGER INS | KTEB TIST | +| EPSTEIN | JEFFREY | | | | | | | | | | +| | | 01/20/1953 P | 547017616 | 07/20/2017 | | | | | | | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 07/20/2017 | | | | | | | +| | | | | *GA | N212JE | I | Name No | | | | +| | | | | | | | | APIS | PASSENGER | TEB XXX | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 07/16/2017 | | | | | | | +| | | | | *GA | N212JE | 0 | Name No | | | | +| | | | | | | | | APIS | PASSENGER | XXX PHI | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 07/11/2017 | | | | | | | +| | | | | *GA | N212JE | I | A1OD | APIS | PASSENGER INS | KTEB LFPB | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 07/02/2017 | | | | | | | +| | | | | *GA | N212JE | 0 | Name No | | | | +| | | | | | | | | APIS | PASSENGER | XXX TEB | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 07/01/2017 | | | | | | | +| | | | | *GA | N212JE | 0 | Name No | | | | +| | | | | | | | | APIS | PASSENGER | XXX TEB | +| EPSTEIN | JEFFREY | | | | | | | | | | +| | | 01/20/1953 P | 547017616 | 06/25/2017 | | | | | | | +| | | | | *GA | N212JE | I | A523 | APIS | PASSENGER CUSTOMS | KPBI TIST | +| EPSTEIN | JEFFREY | | | | | | | | | | +| | | 01/20/1953 P | 547017616 | 05/29/2017 | | | | | | | +| | | | | | | B | P515 | VEHICLE | | | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 05/29/2017 | | | | | | | +| | | | | *GA | N212JE | I | | APIS | PASSENGER | KTEB TIST | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 05/20/2017 | | | | | | | +| | | | | *GA | N212JE | 0 | | APIS | PASSENGER | TIST KISP | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 05/17/2017 | | | | | | | +| | | | | *GA | N415LM | I | AI7E | APIS | PASSENGER INS | KISP LFPB | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 05/11/2017 | | | | | | | +| | | | | *GA | N415LM | 0 | | APIS | PASSENGER | LFPB KTEB | + +![](_page_4_Picture_0.jpeg) + +# U.S. Customs and Border Protection U.S. Department of Homeland Security TECS - Person Encounter List + +Generated By Page 5 of 7 + +| Last Name | First emme | DOB Doc | | | | | | | | | +|-----------|------------|--------------|-----------|------------------|--------|----|----------|---------|-------------------|------------| +| | | | | Date.Tkne Carder | | | | | | | +| | | | | | | V0 | Slte Map | Type | Status Ref | Am | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 04/30/2017 | | | | | | | +| | | | | •GA | N415LM | I | A47E | APIS | PASSENGER INS | KISP TIST | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 04/23/2017 | | | | | | | +| | | | | *GA | N415LM | I | | APIS | PASSENGER | TIST KTEB | +| EPSTEIN | JEFFREY | | | | | | | | | | +| | | 01/20/1953 P | 547017616 | 04/16/2017 | | | | | | | +| | | | | | | B | P512 | VEHICLE | CUSTOMS | | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 04/16/2017 | | | | | | | +| | | | | •GA | N415LM | I | | APIS | PASSENGER | KPBI TIST | +| EPSTEIN | JEFFREY | | | | | | | | | | +| | | 01/20/1953 P | 547017616 | 04/12/2017 | | | | | | | +| | | | | | | B | P512 | VEHICLE | | | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 04/12/2017 | | | | | | | +| | | | | •GA | N415LM | I | | APIS | PASSENGER | KISP TIST | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 04/08/2017 | | | | | | | +| | | | | •GA | N415LM | I | | APIS | PASSENGER | TIST KTEB | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 04/06/2017 | | | | | | | +| | | | | *GA | N212JE | I | A47E | APIS | PASSENGER INS | KISP GLIM% | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 03/30/2017 | | | | | | | +| | | | | *GA | N212JE | 0 | | APIS | PASSENGER | LFPB KTEB | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 03/25/2017 | | | | | | | +| | | | | *GA | N212JE | I | AlOD | APIS | PASSENGER INS | KTEB TIST | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 03/25/2017 | | | | | | | +| | | | | *GA | N212JE | I | | APIS | PASSENGER | KTEB TIST | +| EPSTEIN | JEFFREY | | | | | | | | | | +| | | 01/20/1953 P | 547017616 | 03/11/2017 | | | | | | | +| | | | | | | B | P512 | VEHICLE | CUSTOMS | | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 03/11/2017 | | | | | | | +| | | | | *GA | N212JE | I | | APIS | PASSENGER | KBAF TIST | +| EPSTEIN | JEFFREY | | | | | | | | | | +| | | 01/20/1953 P | 547017616 | 03/10/2017 | | | | | | | +| | | | | *GA | N331JE | I | A511 | APIS | PASSENGER CUSTOMS | TIST TFFJ | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 03/10/2017 | | | | | | | +| | | | | *GA | N331JE | 0 | | APIS | PASSENGER | TFFJ TIST | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 03/08/2017 | | | | | | | +| | | | | •GA | N331JE | I | A511 | APIS | PASSENGER INS | TIST TFFJ | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 03/08/2017 | | | | | | | +| | | | | •GA | N331JE | 0 | | APIS | PASSENGER | TUPW TIST | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 03/07/2017 | | | | | | | +| | | | | •GA | N331JE | 0 | | APIS | PASSENGER | TFFJ TIST | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 02/24/2017 | | | | | | | +| | | | | *GA | N212JE | I | AlOD | APIS | PASSENGER | KTEB LFPB | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 02/17/2017 | | | | | | | +| | | | | *GA | N212JE | 0 | | APIS | PASSENGER | LFPB KTEB | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 02/16/2017 | | | | | | | +| | | | | •GA | N212JE | 0 | | APIS | PASSENGER | LFPB KTEB | +| EPSTEIN | JEFFREY | | | | | | | | | | +| | | 01/20/1953 P | 547017616 | 02/09/2017 | | | | | | | +| | | | | •GA | N212JE | I | A514 | APIS | MANUAL | | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 02/09/2017 | | | | | | | +| | | | | *GA | N212JE | I | | APIS | PASSENGER | KPBI TIST | + +![](_page_5_Picture_0.jpeg) + +| Last Name | First Name | DOB Doe | | | | | | | | +|-----------|------------|--------------|-----------|-----------------|--------|-----|-------------------|-------------------|-----------| +| | | T | e | | | | | | | +| | | | | DMe-TIme Carder | | | | | | +| | | | | | | 1rO | Site Insp Typo | Status Ref | Am | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 02/06/2017 *GA | N212JE | O | APIS | PASSENGER | TIST KPBI | +| EPSTEIN | JEFFREY | 01/20/1953 P | 547017616 | 01/29/2017 | | B | P512 VEHICLE | | | +| | EDWARD | | | 12:37 | | | | | | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 01/29/2017 'GA | N212JE | | APIS | PASSENGER | KTEB TIST | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 01/27/2017 'GA | N212JE | O | APIS | PASSENGER | TIST KPBI | +| EPSTEIN | JEFFREY | 01/20/1953 P | 547017616 | 01/19/2017 | | B | P512 VEHICLE | | | +| | EDWARD | | | 06:52 | | | | | | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 01/19/2017 'GA | N90JE | I | APIS | PASSENGER | KTEB TIST | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 01/18/2017 eGA | N90JE | I | APIS | PASSENGER | KTEB TIST | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 01/13/2017 *GA | N212JE | O | APIS | PASSENGER | TIST KTEB | +| EPSTEIN | JEFFREY | 01/20/1953 P | 547017616 | 01/02/2017 | | B | P515 VEHICLE | | | +| | EDWARD | | | 12:48 | | | | | | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 01/02/2017 •GA | N212JE | I | Name No Name APIS | PASSENGER | TEB XXX | +| | | | | 00:00 | | | N | | | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 12/29/2016 •GA | N212JE | O | APIS | PASSENGER | TIST KPBI | +| EPSTEIN | JEFFREY | 01/20/1953 P | 547017616 | 12/11/2016 | | B | P512 VEHICLE | | | +| | EDWARD | | | 06:41 | | | | | | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 12/11/2016 eGA | N212JE | I | APIS | PASSENGER | KBED TIST | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 12/02/2016 eGA | N212JE | O | APIS | PASSENGER | TIST KTEB | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 11/23/2016 'GA | N212JE | I | A523 APIS | PASSENGER CUSTOMS | KPBI TIST | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 11/11/2016 •GA | N212JE | I | Al0D APIS | PASSENGER | TEB XXX | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 10/28/2016 •GA | N212JE | O | Name No Name APIS | PASSENGER | XXX TEB | +| | | | | 00:00 | | | N | | | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 10/26/2016 •GA | N212JE | I | AI0D APIS | PASSENGER INS | TEB XXX | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 10/15/2016 'GA | N212JE | I | Al0D APIS | PASSENGER INS | TEB XXX | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 10/09/2016 'GA | N212JE | O | Name No Name APIS | PASSENGER | XXX TEB | +| | | | | 00:00 | | | N | | | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 10/02/2016 •GA | N212JE | I | AI0D APIS | PASSENGER INS | TEB XXX | +| EPSTEIN | JEFFREY | 01/20/1953 P | 469911707 | 10/02/2016 •GA | N212JE | = | Name No Name APIS | PASSENGER | TEB XXX | +| | | | | 00:00 | | | N | | | + +## U.S. Customs and Border Protection U.S. Department of Homeland Security TECS - Person Encounter List + +Generated By Page 6 of 7 + +![](_page_6_Picture_0.jpeg) + +## U.S. Customs and Border Protection U.S. Department of Homeland Security TECS - Person Encounter List + +Generated By: Page 7 of 7 + +| | d Loc | +|--------|--------------------------------------------------------------| +| Cedes | 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b/marker2/ds9/EFTA00089017/EFTA00089017.md @@ -0,0 +1,81 @@ +From: + +Subject: FW: guidance + +Date: Thu, 05 Sep 2019 21:49:33 +0000 + +Importance: Normal + +This is Mike Polenberg who is the Director of Safe Horizons. Safe Horizons runs all the victim organizations around New York City and the surrounding boroughs. + +I would like to give him an answer but it is up to you. + +He has been very helpful to the office in the past. + +From: Polenberg, Michael + +Sent: Thursday, September 5, 2019 5:25 PM + +T. + +Cc: Meagher, James + +Subject: guidance + +With the passage of the Child Victims Act in NYS last January, there seems to be some (renewed) interest in considering statute of limitation reform on the federal level for survivors of childhood sexual abuse. Since I gather SOL reform at the federal level would only apply to federal crimes (and if I'm mistaken, please correct me,) and since I believe civil claims are brought in state — not federal — courts, I wonder if you can let us know what the SOL currently is for federal sex crimes against children. + +For a frame of reference, I'm pasting an op-ed that ran in the NY Daily News last week that calls for a "change in federal laws to enable victims, regardless of the state they live in, to have the opportunity to face their abuser in court..." + +Also, introducing you both to our Policy Director Jimmy Meagher (cc-d here.) Jimmy has been with Safe Horizon for many years in a variety of roles, and moved into the Policy Director position earlier this summer. + +Thank you both so much! + +Michael + +## We need a federal Child Victims Act + +In the wake of high-profile cases involving Jeffrey Epstein and Larry Nassar, child sexual abuse has become a bigger part of the national dialogue. The common thread that runs through both of cases is the multiple institutions that failed to address very visible warning signs for protecting young girls at risk. + +In the Epstein case, a lenient federal non-prosecution agreement in 2008 resulted in Epstein serving only 13 months in jail, during which he was allowed out on a daily basis for work release. Police had called for more serious changes involving sexual abuse of underage girls, but the deal resulted in those charges being wiped clean. + +In a recent congressional report focused on the Nassar case, investigators found that multiple institutions failed to take proper action to stop sexual abuse by Nassar. These included USA Gymnastics, the U.S. Olympic Committee, Michigan State University and even the FBI. They all failed to protect victims and enabled their abuse through institutional inaction. + +According to research from the Crimes Against Children Research Center an estimated one in five girls and one in 20 boys is a victim of child sexual abuse. A Centers for Disease Control study found that this and other traumatic childhood experiences can have serious implications for long-term health, leading to greater risk of suicide, substance abuse and physical ailments such as heart disease. + +When the Commission to Eliminate Child Abuse and Neglect Fatalities, on which I served, released its report in 2016, we determined that no single agency can fully address the circumstances that impact troubled families and children facing abuse. We called for a multidisciplinary approach that includes the involvement of health care and public health agencies, educators, law enforcement, judiciary and more in order to assure the safety of children. + +One of the examples we found of a multidisciplinary approach was Child Advocacy Centers, which were introduced in the 1980s. By placing various institutions of law enforcement, child protective services, mental health, + +medical health and victim advocacy under one roof, their aim is to reduce the trauma experienced by young victims in telling their story to multiple agencies. There are currently more than 1,000 Child Advocacy Centers across the U.S. serving more than 300,000 children. + +The Commission has also called for greater access to prevention and earlier intervention services and supports, meaning doing much more to identify children at risk. + +Just this past January, the state passed the Child Victims Act which greatly extends the statues of limitations for a number of sex crimes, letting victims sue those who abused them. Previously, victims had to file civil suits by their 23rd birthday. Because so many children of abuse fail to come forward initially, the Child Victims Act enables victims to file civil suits until age 55. And we are currently in the midst of a one-year window in which victims can bring lawsuits for molestation predating passage of the law. + +Three more states have proposed similar legislation. + +Finding justice is one important step for victims of sexual abuse. Ensuring our institutions are prepared to protect children is equally important. As world class gymnast Simone Biles noted in a recent interview when asked about the accountability of USA Gymnastics, "It's hard coming here for an organization having had them fail us so many times. And we had one goal and we've done everything that they've asked us for, and even when we didn't want to, and they couldn't do one damn job. You had one job. You literally had one job and you couldn't protect us." + +Its time to change our federal laws to enable victims, regardless of the state they live in, to have the opportunity to face their abuser in court and make it harder for those who target children to get away with their crimes with impunity. We owe it to our children to better ensure their safety from predators like Jeffrey Epstein and Larry Nassar. + +Covington is director of the Within Our Reach office at the Alliance for Strong Families and Communities. + +Michael Polenberg + +Vice President, Government Affairs + +Sara zon + +2 Lafayette Street, 3rd Floor + +New York, NY 10007 + +michael.polenberg@safehorizon.org + +Pronouns: He, him, his + +Twitter: @PolenbergM + +This message is intended only for the use of the Addressee and may contain information that is PRIVILEGED and CONFIDENTIAL. If you are not the intended recipient, you are hereby notified that any dissemination of this communication is strictly prohibited. If you have received this communication in error, please erase all copies of the message and its attachments and notify us immediately at 212-577-7700. Thank you. + +moving victims of violence from crisis to confidence \ No newline at end of file diff --git a/marker2/ds9/EFTA00089017/EFTA00089017.metadata.json b/marker2/ds9/EFTA00089017/EFTA00089017.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..bcf32ace5c1be87a7f36b4b851cb8deec5ab684a --- /dev/null +++ b/marker2/ds9/EFTA00089017/EFTA00089017.metadata.json @@ -0,0 +1,146 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089017.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 6383, + "elapsed_seconds": 1.42, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "We need a federal Child Victims \nAct", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 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are confident it's bunk — this guy is pretty controversial and they should consider the source — so do what you can to tamp down any hysteria. + +Sent from my iPhone + +On Oct 30, 2019, at 8:26 AM, wrote: + +Baden emphatically told FOX News this morning that his findings are more consistent with strangulation: "I've not seen in 50 years where that occurred in a suicidal hanging case," the 85-year-old medical legend told Fox News. + +We'll get a lot of inquiries about this today. + +Sent from my iPhone \ No newline at end of file diff --git a/marker2/ds9/EFTA00089020/EFTA00089020.metadata.json b/marker2/ds9/EFTA00089020/EFTA00089020.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..13c61e2357f0831cda6a12e5aed0e8bddd89c630 --- /dev/null +++ b/marker2/ds9/EFTA00089020/EFTA00089020.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089020.pdf", + "engine": { + "marker_major": "2", + "marker_version": 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/dev/null +++ b/marker2/ds9/EFTA00089021/EFTA00089021.md @@ -0,0 +1,9 @@ +From: To: Cc: (USANYS)" (USANYS)" alMIE> (USANYS)" + +Subject: PC Unit -- Short Form Update.10.31.19.docx + +Date: Fri, 01 Nov 2019 15:05:16 +0000 + +Attachments: PC\_Unitr \_Short\_Form\_Update.10.31.19.docx + +Hi here are the updates! \ No newline at end of file diff --git a/marker2/ds9/EFTA00089021/EFTA00089021.metadata.json b/marker2/ds9/EFTA00089021/EFTA00089021.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..87f60e0eb5108ef4fb10bc77a71a90bbd103c11d --- /dev/null +++ b/marker2/ds9/EFTA00089021/EFTA00089021.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089021.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + 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limited access to emails. For urgent matters, please contact the other AUSA(s) on the case. \ No newline at end of file diff --git a/marker2/ds9/EFTA00089022/EFTA00089022.metadata.json b/marker2/ds9/EFTA00089022/EFTA00089022.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..fbe564bc3ace1c956761c66c84f60d135f89e2a1 --- /dev/null +++ b/marker2/ds9/EFTA00089022/EFTA00089022.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089022.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 208, + "elapsed_seconds": 0.32, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 12 + ], + [ + "Line", + 6 + ], + [ + "Text", + 5 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089022" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089023/EFTA00089023.md b/marker2/ds9/EFTA00089023/EFTA00089023.md new file mode 100644 index 0000000000000000000000000000000000000000..847e4e3cb4e68630e200c8c7469c05fc7cde1013 --- /dev/null +++ b/marker2/ds9/EFTA00089023/EFTA00089023.md @@ -0,0 +1,27 @@ +To: + +Subject: Epstein recent flight records + +Date: Wed, 07 Aug 2019 21:58:23 +0000 + +UC Customs and Border Protection records show the following recent flight information for Epstein as it relates to St. Thomas. + +6/11/2019 flight from St Thomas to Teterboro. + +5/18/2019 flight from St Thomas to West Palm Beach. + +5/5/2019 flight from St Thomas to Teterboro. + +4/14/2019 flight from St. Thomas to West Palm Beach. + +Detective + +NYPD FBI + +Child Exploitation Human Trafficking Task Force + +Office: + +Cell: + +Fax: \ No newline at end of file diff --git a/marker2/ds9/EFTA00089023/EFTA00089023.metadata.json b/marker2/ds9/EFTA00089023/EFTA00089023.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..220970908eb43d1cf6d0f2c472f10520f4f1b950 --- /dev/null +++ b/marker2/ds9/EFTA00089023/EFTA00089023.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089023.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 502, + "elapsed_seconds": 0.69, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 33 + ], + [ + "Line", + 17 + ], + [ + "Text", + 15 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089023" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089024/EFTA00089024.md b/marker2/ds9/EFTA00089024/EFTA00089024.md new file mode 100644 index 0000000000000000000000000000000000000000..d045baec927ea79123b4e80b4d7f80fe7a15bd2b --- /dev/null +++ b/marker2/ds9/EFTA00089024/EFTA00089024.md @@ -0,0 +1,47 @@ +To: Ted Gibbs Mia + +Cc: + +Subject: RE: CONFIDENTIAL: Victim Reports Against Jeffrey Epstein, 19 Cr. 490 (RMB) + +Date: Wed, 07 Aug 2019 21:03:34 +0000 + +Inline-Images: image00 Ljpg + +Teri, + +Thanks very much for reaching out regarding scheduling. We would propose meeting at 12 p.m. on 8/26 with Ms. + +if that is convenient for her. For Ms. iven the time zone difference, could you please let us know what times would work for a video conference with her on either 8/26 or 8/27? + +Thanks, + +Assistant United States Attorney Southern District of New York One Saint Andrew's Plaza New York. NY 10007 + +From: Ted Gibbs + +Sent: Monday, August 5, 2019 6:52 PM + +To: + +Cc: Colleen Mullen + +Subject: CONFIDENTIAL: Victim Reports Against Jeffrey Epstein, 19 Cr. 490 (RMB) + +Hi Ms. + +M u for taking the time to speak with our firm on Friday, August 2, 2019, regarding our clients and who believe they were assaulted by Epstein in or around June 2004. + +We have confirmed our clients' availability for interviews with our office. Ms. is available for an inperson interview on August 26, 2019, or August 27, 2019. Ms. who is local is available for an interview via video conference referably the week of August . lease confirm whether your office is available to meet with Ms. n those dates and whether we can arrange a video conference for Ms. + +Ms. Mland Ms. Mom 2004. If possible, please confirm whether our clients are in any of the photograp s seized from Epstein's home. + +Thank you. We look forward to hearing from you soon. + +Best regards, + +Teri Gibbs + +Notice To Recipient: This e-mail is meant for only the intended recipient of the transmission. and may be a communication privileged by law. If you received this e-mail in error. any review. use, dissemination. distnbubon. or copyIng of mis e-mail is strictly prohibited. Please nobly us immediately of the error by retum and please deete this message and any and all dupbcates of mis message from your system. Thank you in advance for your cooperabon. + +IRS Circular 230 Disclosure: In order to comply with requirements imposed by the Internal Revenue Service, we inform you that any U.S. tax advice contained in this communication (including any attachments) rs not intended to be used. and cannot be used. for the purpose of @avoiding penalties under the Internal Revenue Code or (li) promoting. marketing. or recommending to another party any transacbon or matter addressed herein. \ No newline at end of file diff --git a/marker2/ds9/EFTA00089024/EFTA00089024.metadata.json b/marker2/ds9/EFTA00089024/EFTA00089024.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..608b1262c6392c27f4eda95622dbe0440aca6ee2 --- /dev/null +++ b/marker2/ds9/EFTA00089024/EFTA00089024.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089024.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2413, + "elapsed_seconds": 0.98, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 62 + ], + [ + "Line", + 31 + ], + [ + "Text", + 20 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 23 + ], + [ + "Line", + 12 + ], + [ + "Text", + 7 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089024" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089026/EFTA00089026.md b/marker2/ds9/EFTA00089026/EFTA00089026.md new file mode 100644 index 0000000000000000000000000000000000000000..5d21a0f4f599e1312055981af15a457a61d09893 --- /dev/null +++ b/marker2/ds9/EFTA00089026/EFTA00089026.md @@ -0,0 +1,103 @@ +To: ' + +Cc: ' " 'I , Colleen Mullen , Arick Fudali < + +Subject: e: CONFIDENTIAL: Victim Reports Against Jeffrey Epstein, 19 Cr. 490 (RMB) + +Date: Thu, 08 Aug 2019 19:32:23 +0000 + +Inline-Images: image00 Ljpg; image002.jpg + +Hi + +who I have cc'd, and I can coordinate Ms MI travel with For Ms. we will provide you with the video conference logistics c oser o e date of the interview. e will likely use ype, the computer application. + +Best, + +Teri + +On Thu, Aug 8, 2019 at 12:11 PM > wrote: + +Hi Teri, + +That sounds great, thanks. On scheduling, we'll plan to meet with Ms. 't 12 p.m. on 8/26 at our office, and we will plan to speak with Ms. My video conference at 5 p.m. on 8/27. + +Regarding travel logistics for Ms. our office has a witness coordinator who can make travel arrangements. Let us know if there is someone at your office she should connect with to discuss arrangements, or whether you would like her to coordinate with your client directly to arrange travel. + +As for the video conference logistics, if you could please provide us with dial in information as we get closer, that would be great. + +Thanks, + +To: ) sc > + +Cc: >; ) < + +Lisa Bloom • Arick Fudali Colleen Mullen + +Subject: Re: CONFIDENTIAL: Victim Reports Against Jeffrey Epstein, 19 Cr. 490 (RMB) + +H + +Thank you for your email. Ms. available to meet with you on 8/26 at 12 PM. Please send us details regarding her travel arran eme eeting location. Our New York attorney, Arick Fudali, will accompany Ms + +Ms. Ms available for a video conference on either 8/26 or 8/27 between the hours of 9 AM and 5 PM EST. As we intend to be on the call with Ms 'e propose to schedule the call for 5 PM EST/2 PM PST/6 AM Okinawa Time. + +Best regards, + +Teri + +On Wed, Aug 7, 2019 at 2:03 PM ) < > wrote: + +I Ted, + +Thanks very much for reaching out regarding scheduling. We would propose meeting at 12 p.m. on 8/26 with Ms. if that is convenient for her. For Ms. =given the time zone difference, could you please let us know would work for a video conference with her on either 8/26 or 8/27? + +Thanks, + +Assistant United States Attorney + +Southern District of New York + +From: Ted Gibbs + +Sent: Monday, August 5, 2019 6:52 PM + +To: ) + +Cc: + +; Lisa Bloom Arick Fudali + +Colleen Mullen + +Subject: CONN t Jeffrey Epstein, 19 Cr. 490 (RMB) + +lii Msa + +Thank you for taking the time to s peak with our firm on Friday, August 2, 2019, regarding our clients, nd ho believe they were assaulted by Epstein in or around June 2004. + +We have confirmed our clients' availability for interviews with your office. Ms available for an in-person interview on August 26, 2019, or August 27, 2019. Ms. nho is ocate is available for an interview via video conference, preferably the week of August 26th. Please confirm whether your office is available to meet with Ms n those dates and whether we can arrange a video conference for Ms. + +Additionally, as discussed in our call we have attached two PDF files for your review which contain pictures of Msad Ms. =from 2004. If possible, please confirm whether our clients are in any of the photographs seized from Epstein's home. + +Thank you. We look forward to hearing from you soon. + +Best regards, + +Teri Gibbs + +Notice To Recipient: This e- mad is meant for only the intended recipient of the transmtssion, and may be a communication privileged by law. If you received this e-mail in error, any review, use, dissemination. distnbubon. or copying of this e-mail is strictly prohibited. Please notify us immediately of the error by return e-mail and please delete this message and any and al duplicates of this message from your system. Thank you in advance for your cooperation. + +IRS Circular 230 Disclosure: In order to comply with requirements imposed by the Internal Revenue Service, we inform you that any U.S. tax advice contained in this communication (including any attachments) is not intended to be used, and cannot be used. for the purpose of (i) avoiding penalties under the Internal Revenue Code or (e) promoting. marketing. or recommending to another party any transaction or matter addressed herein, + +Notice To Recipient: This e-mail is meant for only the intended recipient of the transmission. and may be a communication privieged by law. If you received this e-mail in error, any review, use, dtssemination, distribution, or copying of this e-mail is strictly prohibited. Please notify us immediately of the error by return e-mail and please delete this message and any and all duplicates of this message from your system. Thank you in advance for your cooperation, + +IRS Circular 230 Disclosure: In order to comply with requirements imposed by the Internal Revenue Service, we inform you that any U.S. tax advice contained in this communication (including any attachments) is not intended to be used, and cannot be used. for the purpose of (i) avoiding penalties under the Internal Revenue Code or (.) promoting, marketing. or recommending to another party any transaction or matter addressed herein. + +![](_page_4_Picture_0.jpeg) + +![](_page_4_Picture_1.jpeg) + +Notice To Recipient: This e-mail is meant for only the intended recipient of the transmission. and may be a communication privileged by law. If you received this e-mail in error, any review, use, dissemination. distnbution. or copying of this e-mail is strictly prohibited. Please notify us immediately of the error by return e-mail and please delete this message and any and all dupbcates of this message from your system. Thank you in advance for your cooperation. + +IRS CtrcuLar 230 Disclosure: In order to comply with requirements imposed by the Internal Revenue Seroce, we inform you that any U.S. tax advice contained in this communication (including any attachments) is not intended to be used, and cannot be used. for the purpose of (0 avoiding penalties under the Internal Revenue Code or (ii) promoting. marketing. or recommending to another party any transaction or matter addressed herein. \ No newline at end of file diff --git a/marker2/ds9/EFTA00089026/EFTA00089026.metadata.json b/marker2/ds9/EFTA00089026/EFTA00089026.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..cdd2eb6b968b81fe0525ee9d91262172237ad3c1 --- /dev/null +++ b/marker2/ds9/EFTA00089026/EFTA00089026.metadata.json @@ -0,0 +1,185 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089026.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 5, + "chars": 5929, + "elapsed_seconds": 1.48, + "image_assets": [ + "_page_4_Picture_0.jpeg", + "_page_4_Picture_1.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 59 + ], + [ + "Line", + 28 + ], + [ + "Text", + 17 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 66 + ], + [ + "Line", + 27 + ], + [ + "Text", + 20 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 47 + ], + [ + "Line", + 23 + ], + [ + "Text", + 17 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 3, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 25 + ], + [ + "Line", + 13 + ], + [ + "Text", + 4 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 4, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 13 + ], + [ + "Line", + 7 + ], + [ + "Picture", + 2 + ], + [ + "Text", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089026" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089026/_page_4_Picture_0.jpeg b/marker2/ds9/EFTA00089026/_page_4_Picture_0.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..aea61c012ae493321b9ed3eed09304062f348ec4 --- /dev/null +++ b/marker2/ds9/EFTA00089026/_page_4_Picture_0.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:6f92becacdd22a7854dd00cdd9f52f0bf407805e943703ccd914d1d4d2f746c8 +size 1130 diff --git a/marker2/ds9/EFTA00089026/_page_4_Picture_1.jpeg b/marker2/ds9/EFTA00089026/_page_4_Picture_1.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..a40e62af2d69a8acab503e95da41577e518fa466 --- /dev/null +++ b/marker2/ds9/EFTA00089026/_page_4_Picture_1.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:e8b95d0131681927a5e03330780c22186396f9cf19b9ea1875e2eb4aaef7246f +size 9601 diff --git a/marker2/ds9/EFTA00089031/EFTA00089031.md b/marker2/ds9/EFTA00089031/EFTA00089031.md new file mode 100644 index 0000000000000000000000000000000000000000..376f5a6e02305bc28beb85d4212a77f368a169e5 --- /dev/null +++ b/marker2/ds9/EFTA00089031/EFTA00089031.md @@ -0,0 +1,181 @@ +### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +x + +UNITED STATES OF AMERICA + +JEFFREY EPSTEIN, + +Defendant. + +x + +SEALED + +INDICTMENT + +19 Cr. + +19 CRIM 490 + +COUNT ONE (Sex Trafficking Conspiracy) + +The Grand Jury charges: + +#### OVERVIEW + +1. As set forth herein, over the course of many years, JEFFREY EPSTEIN, the defendant, sexually exploited and abused dozens of minor girls at his homes in Manhattan, New York, and Palm Beach, Florida, among other locations. + +2. In particular, from at least in or about 2002, up to and including at least in or about 2005, JEFFREY EPSTEIN, the defendant, enticed and recruited, and caused to be enticed and recruited, minor girls to visit his mansion in Manhattan, New York (the "New York Residence") and his estate in Palm Beach, Florida (the "Palm Beach Residence") to engage in sex acts with him, after which he would give the victims hundreds of dollars in cash. Moreover, and in order to maintain and increase his supply of victims, EPSTEIN also paid certain of his victims to recruit additional girls to be similarly abused by EPSTEIN. In + +this way, EPSTEIN created a vast network of underage victims for him to sexually exploit in locations including New York and Palm Beach. + +3. The victims described herein were as young as 14 years old at the time they were abused by JEFFREY EPSTEIN, the defendant, and were, for various reasons, often particularly vulnerable to exploitation. EPSTEIN intentionally sought out minors and knew that many of his victims were in fact under the age of 18, including because, in some instances, minor victims expressly told him their age. + +4. In creating and maintaining this network of minor victims in multiple states to sexually abuse and exploit, JEFFREY EPSTEIN, the defendant, worked and conspired with others, including employees and associates who facilitated his conduct by, among other things, contacting victims and scheduling their sexual encounters with EPSTEIN at the New York Residence and at the Palm Beach Residence. + +# FACTUAL BACKGROUND + +5. During all time periods charged in this Indictment, JEFFREY EPSTEIN, the defendant, was a financier with multiple residences in the continental United States, including the New York Residence and the Palm Beach Residence. + +6. Beginning in at least 2002, JEFFREY EPSTEIN, the defendant, enticed and recruited, and caused to be enticed and + +recruited, dozens of minor girls to engage in sex acts with him, after which EPSTEIN paid the victims hundreds of dollars in cash, at the New York Residence and the Palm Beach Residence. + +7. In both New York and Florida, JEFFREY EPSTEIN, the defendant, perpetuated this abuse in similar ways. Victims were initially recruited to provide "massages" to EPSTEIN, which would be performed nude or partially nude, would become increasingly sexual in nature, and would typically include one or more sex acts. EPSTEIN paid his victims hundreds of dollars in cash for each encounter. Moreover, EPSTEIN actively encouraged certain of his victims to recruit additional girls to be similarly sexually abused. EPSTEIN incentivized his victims to become recruiters by paying these victim-recruiters hundreds of dollars for each girl that they brought to EPSTEIN. In so doing, EPSTEIN maintained a steady supply of new victims to exploit. + +#### The New York Residence + +8. At all times relevant to this Indictment, JEFFREY EPSTEIN, the defendant, possessed and controlled amulti-story private residence on the Upper East Side of Manhattan, New York, i.e., the New York Residence. Between at least in or about 2002 and in or about 2005, EPSTEIN abused numerous minor victims at the New York Residence by causing these victims to be recruited to engage in paid sex acts with him. + +9. When a victim arrived at the New York Residence, she typically would be escorted to a room with a massage table, where she would perform a massage on JEFFREY EPSTEIN, the defendant. The victims, who were as young as 14 years of age, were told by EPSTEIN or other individuals to partially or fully undress before beginning the "massage." During the encounter, EPSTEIN would escalate the nature and scope of physical contact with his victim to include, among other things, sex acts such as + +EPSTEIN typically would also + +10. In connection with each sexual encounter, JEFFREY EPSTEIN, the defendant, or one of his employees or associates, paid the victim in cash. Victims typically were paid hundreds of dollars in cash for each encounter. + +11. JEFFREY EPSTEIN, the defendant, knew that many of his New York victims were underage, including because certain victims told him their age. Further, once these minor victims were recruited, many were abused by EPSTEIN on multiple subsequent occasions at the New York Residence. EPSTEIN sometimes personally contacted victims to schedule appointments at the New York Residence. In other instances, EPSTEIN directed + +employees and associates, including aNew York-based employee ("Employee-1"), to communicate with victims via phone to arrange for these victims to return to the New York Residence for additional sexual encounters with EPSTEIN. + +12. Additionally, and to further facilitate his ability to abuse minor girls in New York, JEFFREY EPSTEIN, the defendant, asked and enticed certain of his victims to recruit additional girls to perform "massages" and similarly engage in sex acts with EPSTEIN. When avictim would recruit another girl for EPSTEIN, he paid both the victim-recruiter and the new victim hundreds of dollars in cash. Through these victimrecruiters, EPSTEIN gained access to and was able to abuse dozens of additional minor girls. + +13. In particular, certain recruiters brought dozens of additional minor girls to the New York Residence to give massages to and engage in sex acts with JEFFREY EPSTEIN, the defendant. EPSTEIN encouraged victims to recruit additional girls by offering to pay these victim-recruiters for every additional girl they brought to EPSTEIN. When avictimrecruiter accompanied anew minor victim to the New York Residence, both the victim-recruiter and the new minor victim were paid hundreds of dollars by EPSTEIN for each encounter. In addition, certain victim-recruiters routinely scheduled these + +encounters through Employee-1, who sometimes asked the recruiters to bring a specific minor girl for EPSTEIN. + +# The Palm Beach Residence + +14. In addition to recruiting and abusing minor girls in New York, JEFFREY EPSTEIN, the defendant, created a similar network of minor girls to victimize in Palm Beach, Florida, where EPSTEIN owned, possessed and controlled another large residence, i.e., the Palm Beach Residence. EPSTEIN frequently traveled from New York to Palm Beach by private jet, before which an employee or associate would ensure that minor victims were available for encounters upon his arrival in Florida. + +15. At the Palm Beach Residence, JEFFREY EPSTEIN, the defendant, engaged in a similar course of abusive conduct. When a victim initially arrived at the Palm Beach Residence, she would be escorted to a room, sometimes by an employee of EPSTEIN's, including, at times, two assistants ("Employee-2" and' "Employee-3") who, as described herein, were also responsible for scheduling sexual encounters with minor victims. Once inside, the victim would provide a nude or semi-nude massage for EPSTEIN, who would himself typically be naked. During these encounters, EPSTEIN would escalate the nature and scope of the physical contact to include sex acts such as + +EPSTEIN would also typically + +[REDACTED] + +[REDACTED] + +16. In connection with each sexual encounter, JEFFREY EPSTEIN, the defendant, or one of his employees or associates, paid the victim in cash. Victims typically were paid hundreds of dollars for each encounter. + +17. JEFFREY EPSTEIN, the defendant, knew that certain of his victims were underage, including because certain victims told him their age. In addition, as with New York-based victims, many Florida victims, once recruited, were abused by JEFFREY EPSTEIN, the defendant, on multiple additional occasions. + +18. JEFFREY EPSTEIN, the defendant, who during the relevant time period was frequently in New York, would arrange for Employee-2 or other employees to contact victims by phone in advance of EPSTEIN's travel to Florida to ensure appointments were scheduled for when he arrived. In particular, in certain instances, Employee-2 placed phone calls to minor victims in Florida to schedule encounters at the Palm Beach Residence. At the time of certain of those phone calls, EPSTEIN and Employee-2 were in New York, New York. Additionally, certain of the individuals victimized at the Palm Beach Residence were contacted by phone by Employee-3 to schedule these encounters. + +19. Moreover, as in New York, to ensure a steady stream of minor victims, JEFFREY EPSTEIN, the defendant, asked and enticed certain victims in Florida to recruit other girls to engage in sex acts. EPSTEIN paid hundreds of dollars to victimrecruiters for each additional girl they brought to the Palm Beach Residence. + +## STATUTORY ALLEGATIONS + +20. From at least in or about 2002, up to and including in or about 2005, in the Southern District of New York and elsewhere, JEFFREY EPSTEIN, the defendant, and others known and unknown, willfully and knowingly did combine, conspire, confederate, and agree together and with each other to commit an offense against the United States, to wit, sex trafficking of minors, in violation of Title 18, United States Code, Section. 1591(a) and (b). + +21. It was a part and object of the conspiracy that JEFFREY EPSTEIN, the defendant, and others known and unknown, would and did, in and affecting interstate and foreign commerce, recruit, entice, harbor, transport, provide, and obtain, by any means a person, and to benefit, financially and by receiving anything of value, from participation in a venture which has engaged in any such act, knowing that the person had not attained the age of 18 years and would be caused to engage in a + +commercial sex act, in violation of Title 18, United States Code, Sections 1591(a) and (b)(2). + +#### Overt Acts + +22. In furtherance of the conspiracy and to effect the illegal object thereof, the following overt acts, among others, were committed in the Southern District of New York and elsewhere: + +a. In or about 2004, JEFFREY EPSTEIN, the defendant, enticed and recruited multiple minor victims, including minor victims identified herein as Minor Victim-1, Minor Victim-2, and Minor Victim-3, to engage in sex acts with EPSTEIN at his residences in Manhattan, New York, and Palm Beach, Florida, after which he provided them with hundreds of dollars in cash for each encounter. + +b. In or about 2002, Minor Victim-1 was recruited to engage in sex acts with EPSTEIN and was repeatedly sexually abused by EPSTEIN at the New York Residence over a period of years and was paid hundreds of dollars for each encounter. EPSTEIN also encouraged and enticed Minor Victim-1 to recruit other girls •to engage in paid sex acts, which she did. EPSTEIN asked Minor Victim-1 how old she was, and Minor Victim-1 answered truthfully. + +c. In or about 2004, Employee-1, located in the Southern District of New York, and on behalf of EPSTEIN, placed + +atelephone call to Minor Victim-1 in order to schedule an appointment for Minor Victim-1 to engage in paid sex acts with EPSTEIN. + +d. In or about 2004, Minor Victim-2 was recruited to engage in sex acts with EPSTEIN and was repeatedly sexually abused by EPSTEIN at the Palm Beach Residence over a period of years and was paid hundreds of dollars after each encounter. EPSTEIN also encouraged and enticed Minor Victim-2 to recruit other girls to engage in paid sex acts, which she did. + +e. In or about 2005, Employee-2, located in the Southern District of New York, and on behalf of EPSTEIN, placed atelephone call to Minor Victim-2 in order to schedule an appointment for Minor Victim-2 to engage in paid sex acts with EPSTEIN. + +f. In or about 2005, Minor Victim-3 was recruited to engage in sex acts with EPSTEIN and was repeatedly sexually abused by EPSTEIN at the Palm Beach Residence over a period of years and was paid hundreds of dollars for each encounter. EPSTEIN also encouraged and enticed Minor Victim-3 to recruit other girls to engage in paid sex acts, which she did. EPSTEIN asked Minor Victim-3 how old she was, and Minor Victim-3 answered truthfully. + +g• In or about 2005, Employee-2, located in the Southern District of New York, and on behalf of EPSTEIN, placed atelephone call to Minor Victim-3 in Florida in order to schedule an appointment for Minor Victim-3 to engage in paid sex acts with EPSTEIN. + +h. In or about 2004, Employee-3 placed a telephone call to Minor Victim-3 in order to schedule an appointment for Minor Victim-3 to engage in paid sex acts with EPSTEIN. + +(Title 18, United States Code, Section 371.) + +### COUNT TWO (Sex Trafficking) + +The Grand Jury further charges: + +23. The allegations contained in paragraphs 1 through 19 and 22 of this Indictment are repeated and realleged as if fully set forth within. + +24. From at least in or about 2002, up to and including in or about 2005, in the Southern District of New York, JEFFREY EPSTEIN, the defendant, willfully and knowingly, in and affecting interstate and foreign commerce, did recruit, entice, harbor, transport, provide, and obtain by any means a person, knowing that the person had not attained the age of 18 years and would be caused to engage in acommercial sex act, and did aid and abet the same, to wit, EPSTEIN recruited, enticed, harbored, transported, provided, and obtained numerous + +individuals-who were less than 18 years old, including but not limited to Minor Victim-1, as described above, and who were then caused to engage in at least one commercial sex act in Manhattan, New York. + +> (Title 18, United States Code, Sections 1591(a), (b)(2), and 2.) + +#### FORFEITURE ALLEGATIONS + +25. As aresult of committing the offense alleged in Count Two of this Indictment, JEFFREY EPSTEIN, the defendant, shall forfeit to the United States, pursuant to Title 18, United States Code, Section 1594(c) (1), any property, real and personal, that was used or intended to be used to commit or to facilitate the commission of the offense alleged in Count Two, and any property, real or personal, constituting or derived from any proceeds obtained, directly or indirectly, as aresult of the offense alleged in Count Two, or any property traceable to such property, and the following specific property: + +a. The lot or parcel of land, together with its buildings, appurtenances, improvements, fixtures, attachments and easements, located at 9 East 71st Street, New York, New York, with block number 1386 and lot number 10, owned by Maple, Inc. + +Substitute Asset Provision + +26. If any of the above-described forfeitable property, as a result of any act or omission of the defendant: + +- (a) cannot be located upon the exercise of due diligence; +- (b) has been transferred or sold to, or deposited with, a third person; +- (c) has been placed beyond the jurisdiction of the Court; +- (d) has been substantially diminished in value; or +- (e) has been commingled with other property which cannot be subdivided without difficulty; + +it is the intent of the United States, pursuant to 21 U.S.C. § 853(p) and 28 U.S.C. § 2461(c), to seek forfeiture of any other property of the defendant up to the value of the above forfeitable property. + +(Title 18, United States Code, Section 1594; Title 21, United States Code, Section 853(p); and Title 28, United States Code, Section 2461.) + +![]()![]()Form No. USA-33s-274 (Ed. 9-25-58) + +--- + +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK + +--- + +UNITED STATES OF AMERICA + +v. + +JEFFREY EPSTEIN, + +Defendant. + +--- + +INDICTMENT + +(18 U.S.C. §§ 371, 1591(a), (b)(2), +and 2) + +GEOFFREY S. 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--- /dev/null +++ b/marker2/ds9/EFTA00089045/EFTA00089045.md @@ -0,0 +1,97 @@ +UNITED STATES DISTRICT COURT + +for the +Southern District of New York + +*Doc #2* + +In the Matter of the Search of +*(Briefly describe the property to be searched +or identify the person by name and address)* + +See Attachment A + +) +) +) +) +) +) + +Case No. + +**19 MAG 6573** + +**SEARCH AND SEIZURE WARRANT** + +To: Any authorized law enforcement officer + +An application by a federal law enforcement officer or an attorney for the government requests the search of the following person or property located in the Southern District of New York +*(identify the person or describe the property to be searched and give its location):* + +See Attachment A + +The person or property to be searched, described above, is believed to conceal *(identify the person or describe the property to be seized):* + +See Attachment A + +The search and seizure are related to violation(s) of *(insert statutory citations):* + +**Title 18, United States Code, Sections 371 and 1591** + +I find that the affidavit(s), or any recorded testimony, establish probable cause to search and seize the person or property. + +**YOU ARE COMMANDED** to execute this warrant on or before 7-20-19 +*(not to exceed 14 days)* + + in the daytime 6:00 a.m. to 10 p.m. at any time in the day or night as I find reasonable cause has been established. + +Unless delayed notice is authorized below, you must give a copy of the warrant and a receipt for the property taken to the person from whom, or from whose premises, the property was taken, or leave the copy and receipt at the place where the property was taken. + +The officer executing this warrant, or an officer present during the execution of the warrant, must prepare an inventory as required by law and promptly return this warrant and inventory to the Clerk of the Court. + + Upon its return, this warrant and inventory should be filed under seal by the Clerk of the Court. \_\_\_\_\_ +*USMJ Initials* + + I find that immediate notification may have an adverse result listed in 18 U.S.C. § 2705 (except for delay of trial), and authorize the officer executing this warrant to delay notice to the person who, or whose property, will be searched or seized *(check the appropriate box)* for \_\_\_\_\_ days *(not to exceed 30)*. + + until, the facts justifying, the later specific date of \_\_\_\_\_. + +Date and time issued: 7-6-19 10:14 a.m. + +*Soberstein* +Judge's signature + +Hon. Barbara Moses, U.S. Magistrate Judge +*Printed name and title* + +#### Return + +| Case No.: | Date and time warrant executed: | Copy of warrant and inventory left with: | +|-----------|---------------------------------|------------------------------------------| +|-----------|---------------------------------|------------------------------------------| + +Inventory made in the presence of : + +Inventory of the property taken and name of any person(s) seized: + +#### Certification + +I declare under penalty of perjury that this inventory is correct and was returned along with the original warrant to the Court. Date: Executing officer's signature Printed name and title + +### ATTACHMENT A + +## I. Premises to be Searched—Subject Premises + +1. The premises to be searched (the "Subject Premises") are described as a nearly 19,000 square foot multi-story single-family residence located at New York, New York, and include all locked and closed containers found therein. A photograph of the front entrance to the Subject Premises is included below: + +![](_page_2_Picture_3.jpeg) + +## II. Items to Be Seized + +1. This warrant authorizes executing agents to photograph, video record and otherwise document the full interior of the Subject Premises, including any items, furnishings, or possessions therein. + +2. In addition, this warrant authorizes the seizure of certain evidence, fruits, and instrumentalities of violations of Title 18, United States Code, Sections 1591 (sex trafficking of minors) and 371 (sex trafficking conspiracy) (the "Subject Offenses") described as follows: + +- a. Evidence concerning occupancy or ownership of the Subject Premises, including utility and telephone bills, mail envelopes, addressed correspondence, diaries, statements, identification documents, address books, telephone directories, and photographs of its occupant(s). +- b. 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USMJ Initials + + I find that immediate notification may have an adverse result listed in 18 U.S.C. § 2705 (except for delay of trial), and authorize the officer executing this warrant to delay notice to the person who, or whose property, will be searched or seized (check the appropriate box) for days (not to exceed 30). + + Until, the facts justifying, the later specific date of \_\_\_\_\_. + +Date and time issued: 7-7-19 2:03 a.m. + +[Signature] +Judge's signature + +#### Return + +| Case No.: | Date and time warrant executed: | Copy of warrant and inventory left with: | +|-----------|---------------------------------|------------------------------------------| +|-----------|---------------------------------|------------------------------------------| + +Inventory made in the presence of : Inventory of the property taken and name of any person(s) seized: + +#### Certification + +I declare under penalty of perjury that this inventory is correct and was returned along with the original warrant to the Court. Date: Executing officer's signature Printed name and tide + +## ATTACHMENT A + +## L Premises to be Searched—Subject Premises + +I . The premises to be searched the "Subject Premises") are described as a multi-story single-family residence located at New York, New York, and include all locked and closed containers found therein. A photograph of the front entrance to the Subject Premises is included below: + +![](_page_2_Picture_3.jpeg) + +## IL Items to Be Seized + +# A. Evidence, Fruits, and Instrumentalities of the Subject Offenses + +This warrant authorizes the seizure of certain evidence, fruits, and instrumentalities of violations of Title 18, United States Code, Sections 1591 (sex trafficking of minors) and 371 (sex trafficking conspiracy) (the "Subject Offenses") described as follows: + +- i. Any and all taxidermied dogs. +- ii. Any and all massage tables and massage paraphernalia. +- iii. Any and all busts or three-dimensional representations of female human torsos. +- iv. Any and all photos or representations depicting nude or partially nude women located in the Massage Room, as defined herein. +- v. Any and all sex toys and sex paraphernalia located in the Massage Room, as defined herein. + +- vi. 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USMJ Initials + + I find that immediate notification may have an adverse result listed in 18 U.S.C. § 2705 (except for delay of trial), and authorize the officer executing this warrant to delay notice to the person who, or whose property, will be searched or seized *(check the appropriate box)* for days (not to exceed 30). + + until, the facts justifying, the later specific date of \_\_\_\_\_. + +Date and time issued: 7-7-19 11:33P.M. + +*Barbara Moses* +Judge's signature + +| Return | | | +|-----------------------------------------------------------------------------------------------------------------------------------------|---------------------------------|-----------------------------------------------| +| Case No.: | Date and time warrant executed: | Copy of warrant and inventory left with: | +| Inventory made in the presence of : | | | +| Inventory of the property taken and name of any person(s) seized: | | | +| | | | +| Certification | | | +|

I declare under penalty of perjury that this inventory is correct and was returned along with the original warrant to the Court.

| | | +| Date: _____ | | _____
Executing officer's signature | +| _____ | | _____
Printed name and title | + +#### ATTACHMENT A + +# I. The Subject Devices to Be Searched + +The Subject Devices arc particularly described as compact discs stored in containers marked with FBI evidence numbers 15, 16, 17, 18, and 22, seized from the residence located at 9 East 71st Street, New York, New York, on or about July 7, 2019. + +## II. Items to Be Seized + +## A. Evidence, Fruits, and Instrumentalities of the Subject Offenses + +This warrant authorizes the seizure of certain evidence, fruits, and instrumentalities of violations of Title 18, United States Code, Sections 1591 (sex trafficking of minors), and 371 (sex trafficking conspiracy) (the "Subject Offenses") described as follows: + +- 1. Any documents or communications with or regarding victims or potential victims of the Subject Offenses; + - 2. Any photographs of victims or potential victims of the Subject Offenses; +- 3. Any nude, partially nude, or sexually suggestive photographs of individuals who appear to be teenage girls, or younger; +- 4. Motion pictures, films, videos, and other recordings of visual or written depictions of minors engaged in sexually explicit conduct, as defined in 18 U.S.C. § 2256(2); +- 5. Records or other items that evidence ownership, control, or use of, or access to devices, storage media, and related electronic equipment used to access, transmit, or store information relating to the Subject Offenses, including, but not limited to, sales receipts, warranties, bills for Internet access, handwritten notes, registry entries, configuration files, saved usemames and passwords, user profiles, e-mail contacts, and photographs; +- 6. Any child erotica, defined as suggestive visual depictions of nude minors that do not constitute child pornography as defined by 18 U.S.C. § 2256(8). + +# B. Review of ESI + +Law enforcement personnel (including, in addition to law enforcement officers and agents, and depending on the nature of the ESI and the status of the investigation and related proceedings, attorneys for the government, attorney support staff, agency personnel assisting the government in this investigation, and outside technical experts under government control) will create a forensic image of the Subject Devices (if practicable) and review the ESI contained therein for information responsive to the warrant. + +In conducting this review, law enforcement personnel may use various techniques to determine which files or other ESI contain evidence or fruits of the Subject Offenses. Such techniques may include, for example: + +- surveying directories or folders and the individual files they contain (analogous to looking at the outside of a file cabinet for the markings it contains and opening a drawer believed to contain pertinent files); +- conducting a file-by-file review by "opening" or reading the first few "pages" of such files in order to determine their precise contents (analogous to performing a cursory examination of each document in a file cabinet to determine its relevance); +- "scanning" storage areas to discover and possibly recover recently deleted data or deliberately hidden files; and +- performing electronic keyword searches through all electronic storage areas to determine the existence and location of data potentially related to the subject matter of the investigation6; and +- reviewing metadata, system information, configuration files, registry data, and any other information reflecting how, when, and by whom the computer was used. + +Law enforcement personnel will make reasonable efforts to search only for files, documents, or other electronically stored information within the categories identified in Section LLA of this Attachment. However, law enforcement personnel are authorized to conduct a complete review of all the ESI from seized devices or storage media if necessary to evaluate its contents and to locate all data responsive to the warrant. + +6 Keyword searches alone are typically inadequate to detect all relevant data. For one thing, keyword searches work only for text data, yet many types of files, such as images and videos, do not store data as searchable text. 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Introduction + +#### A. Affiant + +I. I have been a Special Agent with the Federal Bureau of Investigation ("FBI") since 2017. As such, I am a "federal law enforcement office?' 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 have been employed by the FBI for approximately two years, and I am currently assigned to investigate violations of criminal law relating to the sexual exploitation of children. 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 sex trafficking cases, and have participated in the execution of search warrants for physical premises. + +2. I make this Affidavit in support of an application pursuant to Rule 41 of the Federal Rules of Criminal Procedure for a warrant to search the premises specified below (the "Subject Premises") for the purpose of seizing the items and information described in Attachment A. This affidavit is based upon my personal knowledge; my review of documents and other evidence; and my conversations with other law enforcement personnel. Because this affidavit is being submitted + +for the limited purpose of establishing probable cause, it does not include all the facts that I have learned during the course of my 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. + +## B. The Subject Premises + +3. The Subject Premises are particularly described as a private island in the U.S. Virgin Islands, known as Little Saint James, any buildings or other structures contained thereon, and any closed containers/items contained therein. Little Saint James is an approximately 75 acre island located approximately four miles off the southeast coast of St. Thomas Island. The Subject Premises is depicted in the following photograph: + +![](_page_1_Picture_3.jpeg) + +Based on my conversations with a law enforcement agent who has reviewed publicly available satellite information, images, and drone videos, I am aware that the Subject Premises contains multiple structures, including but not limited to: + +- a. On the northeast end of the Subject Premises, there is a single story structure next to a pool. +- b. On the southwest end of the Subject Premises, there is a single-story, four-wall structure. The walls are painted with blue and white stripes. The structure has large double doors as its main entrance and large windows on the three remaining walls. +- c. On the north east end of the Subject Premises, there are multiple structures. The main structure is a single story residence (the "Main Residence") with a stone exterior, a blue roof, and a white detailed exterior that includes white columns. +- d. A separate structure ("Residence One") with a blue roof and stone exterior is at the back of the Main Residence, located at the end of the northeast tip of the island and surrounded by coastline on two of its sides. +- e. A second larger structure ("Residence Two) is set between the Main Residence and the coastline. +- f. Four smaller single story structures (the "Four Cabanas") are next to the Main Residence and a large pool. All four smaller structures have blue roofs. +- g. A third large structure ("Residence Three") set off from the four smaller structures and next to the coast line is painted white and has a blue roof. Residence Three appears to have two levels throughout and also appears to be at a lower elevation than the Main Residence, Residence Two, and the Four Cabanas. +- h. Behind Residence Three and along the coastline is a small roofed structure at the end of a wooden dock (the "Dock House"). + +i. There are two single story sheds ("Shed One" and "Shed Two") that are located just southwest of the Main Residence. Shed One and Shed Two appear to have a metal-like exterior that is a green-blue color. + +j. Next to Shed One and Shed Two is a four wall structure that appears to have several sally port type doors ("Maintenance One"). A second structure ("Maintenance Two") is next to Maintenance One and has a white exterior with four sets of white double doors and three single white doors. + +k. Near the center of the island is a single story structure ("Residence Four") that has a stone exterior and blue roof. The front of "Residence Four" has three dark double doors. + +I. Next to the helicopter landing pad are two small blue roof structures ("Helipad Buildings"). + +m. On the west side of the Subject Premises on the coast is an approximately two-level structure ("Residence Five") with a blue roof. + +4. As detailed further herein, at least through his death on August 10, 2019, the Subject Premises was believed to be owned, possessed, and controlled by JEFFREY EPSTEIN. + +# C. The Target Subject and the Subject Offenses + +5. For the reasons detailed below, I believe that there is probable cause to believe that the Subject Premises contain evidence, fruits, and instrumentalities of violations of Title 18, United States Code, Sections 1591 (sex trafficking of minors), and 371 (sex trafficking conspiracy) (the "Subject Offenses") . The Target Subjects of this investigation are known and unknown coconspirators of JEFFREY EPSTEIN, including but not limited to + +### II. Probable Cause and the Initial Search Warrants + +### A. Probable Cause Regarding the Target Subject's Commission of the Subject Offenses + +6. On or about July 2, 2019, a grand jury in the Southern District of New York returned an Indictment charging JEFFREY EPSTEIN with violations of Title 18, United States Code, Section 1591 (sex trafficking of minors); and Title 18, United States Code, Section 371 (sex trafficking conspiracy). A copy of the Indictment is attached hereto as Exhibit A and is incorporated by reference. EPSTEIN was arrested pursuant to the Indictment on or about July 6, 2019, and had been detained pending trial at the Metropolitan Correctional Center ("MCC") in New York, New York. + +7. On or about August 10, 2019, the Bureau of Prisons confirmed that JEFFREY EPSTEIN had been found unresponsive in his cell at the MCC that morning, and was pronounced dead shortly thereafter. + +8. Notwithstanding EPSTEIN's death, the sex trafficking investigation that led to his indictment remains ongoing. In particular, Count One of the Indictment alleged that EPSTEIN conspired with others to traffic minors, and further identified three individuals who worked for EPSTEIN (identified in Exhibit A as "Employee-1", "Employee-2," and "Employee-3") and facilitated EPSTEIN's abuse of minor girls by, among other things, arranging victims' encounters with EPSTEIN and paying victims after these encounters. The individual identified in Exhibit A as "Employee-2" is a target subject of this investigation + +9. As set forth in Exhibit A, from at least in or about 2002, up to and including at least in or about 2005, JEFFREY EPSTEIN sexually abused multiple minor girls in Manhattan, New York; West Palm Beach, Florida; and elsewhere. During that time and continuing to the present, + +EPSTEIN possessed and controlled a residence, which is described in Exhibit A as "the New York Residence." + +10. As further set forth in paragraphs 8 through 10 of Exhibit A, from at least in or about 2002, up to and including at least in or about 2005, EPSTEIN sexually abused numerous minor victims at the New York Residence. In particular, and as alleged in the Indictment, when a victim arrived at the New York Residence, she would be escorted to a room inside the New York Residence with a massage table, where she would perform a massage on EPSTEIN. The victims, who were as young as 14 years of age, were told by EPSTEIN or other individuals to partially or fully undress before beginning the "massage." During the encounter, EPSTEIN would escalate the nature and scope of physical contact with his victim to include, among other things, sex acts EPSTEIN typically would also + +Following each encounter, EPSTEIN or one of his employees or associates paid the victim in cash. + +I I. As set forth in paragraphs 12 through 13 of Exhibit A, to further facilitate his ability to abuse minor girls in New York, JEFFREY EPSTEIN asked and enticed certain of his victims to recruit additional minor girls to perform "massages" and similarly engage in sex acts with EPSTEIN. When a victim would recruit another minor girl for EPSTEIN, he paid both the victimrecruiter and the new victim hundreds of dollars in cash. EPSTEIN knew that his victims were underage, including because certain victims told him their age. + +12. One of the victims identified in paragraph 22 of Exhibit A is Victim-1. As part of the FBI's investigation of EPSTEIN, I have participated in interviews with Victim-1, along with + +other law enforcement officers.' Based on my participation in those interviews and my conversations with other law enforcement officers, I know that Victim-1 has provided the following information, in substance and in part: + +a. Between approximately 2002 and 2005, EPSTEIN sexually abused Victim-I on multiple occasions in the New York Residence. This sexual abuse all occurred when Victim-I was under the age of 18. + +b. During that same period, Victim-1 observed multiple floors of the New York Residence and numerous individual rooms within the New York Residence. Victim-1 has provided detailed descriptions of certain aspects of the interior of the Subject Premises, including Victim-I's memory of specific details regarding the layout, furnishings, decorations, and floor pattern of various areas within the Subject Premises. Among other details, Victim-1 recalled that EPSTEIN typically abused her in a room she described as a "massage room," (the "Massage Room"), which contained a massage table, and was decorated with artwork depicting naked women, hung on walls that appeared to be adorned with fabric. In describing the sexual abuse that occurred in the Massage Room, Victim-1 has stated that EPSTEIN would often during these abusive encounters. + +In meetings with the Governmen + +Victim- 1 is currently pursuing a civil damages claim against EPSTEIN for his sexual abuse of her. Information provided by Victim-1 has proven reliable and has been corroborated by independent evidence, including documents and records obtained during the investigation and the accounts of other victims whom Victim-1 has never met. + +### The July 6 2019 Search Warrant of the Subject Premises + +13. On or about July 6, 2019, the Honorable Barbara Moses, United States Magistrate Judge, signed a search warrant authorizing a search of the New York Residence. The search warrant is attached as Exhibit B and incorporated by reference herein. + +14. At approximately 6 p.m. on or about July 6, 2019, law enforcement officers (the "Search Team") commenced executing the search warrant at the New York Residence. JEFFREY EPSTEIN had been arrested on the charges contained in the Indictment shortly before the execution of the search warrant. Based on the Search Team's observations during an initial search of the New York Residence, at approximately 7 p.m., the Search Team stopped the search and froze the scene in order to seek a new search warrant. On or about July 7, 2019, the Honorable Barbara Moses, United States Magistrate Judge, signed a search warrant authorizing a search of the New York Residence (the "Second Warrant"). The Second Warrant is attached as Exhibit C, and incorporated by reference herein. At approximately 2:30 a.m., the Search Team resumed the search, and commenced searching pursuant to the Second Warrant. Later on July 7, 2019, the Honorable Barbara Moses, United States Magistrate Judge, signed a third search warrant to search and seize certain electronic media stored on discs seized during the execution of the Second Warrant (the "Compact Disc Search Warrant"). The search warrant is attached as Exhibit D, and incorporated by reference herein. + +15. During the execution of the warrants described above on the New York Residence, the Search Team located evidence of the Subject Offenses. In particular, the Search Team located the following, among other items: + +c. Inside the Subject Premises, I observed a room that, based on my participation in interviews of Victim-1, appears to be consistent with Victim-1 's descriptions of the Massage + +Room. The room contained a table covered with a sheet, and appeared to be a massage table. The room also contained several vibrating sex toys. The walls appeared to be covered in a type of feltlike tapestry fabric. I further observed two paintings and three photographs hanging on the walls of the Massage Room. The paintings and photographs depict nude females. One of the photographs appears to depict a nude girl. Thus, it appears that the Massage Room was in substantially the same condition as Victim-1 observed the room more than 18 years ago. + +d. Inside a safe in a closet on the third floor, the Search team discovered and seized, among other items, several binders containing sleeves of compact discs, most of which are labeled with handwriting. In total, the binders contain dozens of compact discs. Some discs contain the word "Zorro" or "LSJ." Based on my conversations with law enforcement agents who have participated in this investigation, I believe the name "Zorro" refers to Zorro Ranch, EPSTEIN's property in New Mexico, and the name LSJ refers to Little Saint James, i.e., the Subject Premises. The majority of the discs contain titles that include female names. Some of the discs in the binders seized by the Search Team have titles that appear to refer to trips or vacations. + +e. In the drawer of a dresser in a room on the Fifth floor of the New York Residence, the Search team discovered and seized, among other items, a shoebox (the "Shoebox") containing numerous compact discs. The majority of the discs are labeled, in handwriting, with female names. One disc is marked "Thai Massage." Another disc is marked "Blonde Girl Photo Shoot." Yet another disc is marked "Misc. Girls Nude/Dinner--Scientists." The discs in the Shoebox were seized by the Search Team. In another drawer of that same dresser, the Search Team discovered loose polaroid photographs depicting young, nude females who, based on the training and experience of law enforcement officers who observed them, appear to be teenagers. + +f. In a closet on the Fifth Floor of the Epstein Residence, the Search Team discovered, among other items, a box marked "women/old photos." The box contained, among other items, approximately seven compact discs, which are labeled with hand-written titles. One disc is marked "nudes 00-24." Another is labeled "Photographer-- `03" The remaining discs contain titles that include female names. All of the foregoing discs were seized by the Search Team. + +g. In that same closet, the Search Team discovered numerous black binders containing what appear to be print outs of digital photographs (with file names underneath) and compact discs. The binders appeared to contain, among other photographs, photographs of nude or partially nude young girls, some of which are in sexually suggestive poses. Based on the training and experience of law enforcement officers who observed them, some of the young girls appear to be teenagers, some of whom appear to be under the age of 18. + +16. Based on my conversations with law enforcement agents who have conducted an initial review (the "Reviewing Agents") of the compact discs seized at the New York Residence as described in paragraphs 15(b)-(e) above (the "Seized Discs"), I have learned that the discs contain approximately thousands of nude or partially nude photographs of girls or young women, many of which are in sexually suggestive poses. Based on my conversations with the Reviewing Agents, who have particular training and experience relating to child erotica and visual depictions of children in child exploitation cases, I have learned that the Reviewing Agents believe that many of the nude or partially nude images they have reviewed appear to depict girls under the age of 18. Certain of these images appear to have been taken at a tropical location, and/or were labeled "LSJ" either in the image file name, or on the compact disc that contained the image. Based on the foregoing, I believe that a portion of the foregoing photographs appear to have been taken at the Subject Premises. In addition, I have learned that some of the file names are marked "." which + +are the initials of . As set forth below, I have interviewed an individual who has reported that photographed her at the Subject Premises. Accordingly, I believe that a portion of these photos may have been taken by + +17. On or about November 28, 2018, the Miami Herald began publishing a series of articles relating to the defendant, his sexual misconduct with minors, and a previous investigation into his conduct in Florida from in or about 2005 through 2008. The article included information about 's role in EPSTEIN's sexual abuse of minors. Based on my participation in this investigation, I have learned that bank records obtained by the Government appear to show that just days later, on or about December 3, 2018, the defendant wired \$250,000 from a trust account to This course of action, and in particular its timing, suggests that EPSTEIN was attempting to influence who might provide information against him in light of the recently re-emerging allegations. + +# B. Probable Cause Regarding the Subject Premises + +18. Based on my review of property records, I believe that JEFFREY EPSTEIN has been the owner of the Subject Premises since at least the time of the Subject Offenses. In particular, it appears that an entity named "L.S.J., LLC" held title to the Subject Premises from in or about 1998. In or about 2011, L.S.J., LLC transferred title to the Subject Premises to an entity named "Nautilus, Inc.," for \$10. On the transfer paperwork, EPSTEIN signed as the "sole member" of L.S.J., LLC and as the "president and sole beneficial owner" of Nautilus, Inc. + +19. In addition, I believe that up until recently, the Subject Premises was JEFFREY EPSTEIN's principal residence. In particular, I have reviewed sex offender registration data, and have learned that, on or about June 17, 2019, EPSTEIN listed the Subject Premises as his primary residence. At the time of EPSTEIN's arrest on or about July 6, 2019, I and other law enforcement officers conducted an inventory search of EPSTEIN's personal effects, and observed that EPSTEIN was carrying a driver's license that listed the Subject Premises as EPSTEIN's home address. + +20. As discussed herein, I believe that evidence of the Subject Offenses will be found at the Subject Premises. In particular, based on my conversations with law enforcement agents who have conducted an initial review of the Seized Discs, I have learned the following: + +a. Many of the photographs appear to be labeled with file names that include "LSJ," which I believe stands for Little St. James. + +b. As discussed above, photographs seized from the New York Residence appear to depict nude or partially nude young girls, and a portion of those photos appear to have been taken at the Subject Premises, based on the fact that (i) some of the photos appear to have been taken in a tropical location, and (ii) some of the file names of the photographs and/or the labels on the discs containing the files of nude or partially nude young girls in a tropical location are marked "LSJ," i.e., the Subject Premises. + +c. Among the photographs seized from the New York Residence, the Reviewing Agents identified partially-nude photographs of a young girl, labeled with the name of a particular individual ("Individual-1"). The photographs appear to depict Individual-1 on a beach in what appears to be a tropical location. + +21. In or about July 2019, I participated in an interview of Individual-1, with her counsel present. Based on my personal observations, I believe that the photographs described in Paragraph 17(c) depict Individual-1. During the course of the interview, Individual-1 stated that she met EPSTEIN in 2003 when she was approximately 17, and that she travelled to EPSTEIN's properties in New Mexico, Florida, and the U.S. Virgin Islands, i.e., the Subject Premises, before she turned 18. EPSTEIN paid for the trips, and would give Individual-1 money and gifts while she traveled with him. + +22. During these trips, EPSTEIN sexually abused and assaulted her on approximately four different occasions, all of which occurred before she turned 18. Individual-1 reported that EPSTEIN raped her during two of these incidents. Indivdual-1 recalled that one or more of these instances of sexual abuse occurred on the Subject Premises. Individual-1 further reported that, when she was approximately 17, asked to photograph her, and did in fact photograph Individual-1 at the Subject Premises. + +23. In or about August 2019, I and another law enforcement officer interviewed an individual ("Individual-2") who regularly performed work for JEFFREY EPSTEIN as a contractor at the Subject Premises from approximately 1999 to 2005 or 2006. Individual-2 reported that, on several occasions, Individual-2 observed photographs of what appeared to be nude or partially nude young girls in several locations throughout the main residence of the Subject Premises. Individual-2 recalled a photograph depicting 4nd two of girls, all of three whom were topless; Individual-2 estimated that the two girls in the photograph appeared to be approximately 15 or 16 years old. Individual-2 knew to be EPSTEIN's assistant at that time. + +24. Based on my review of flight logs from a private jet owned by JEFFREY EPSTEIN, I have learned that traveled to the U.S. Virgin Islands at least approximately once a month between October 2001 and November of 2005. These records do not include any travel may have taken on commercial airlines. + +25. For all of these reasons, I am aware that has spent significant time at the Subject Premises and that evidence of her involvement, and potentially the involvement of other co-conspirators, may be located at the Subject Premises. In particular, flight logs from EPSTEIN's private jet reflect that the individual identified in the Indictment as "Employee-3" traveled to the U.S. Virgin Islands on approximately nine separate occasions. These records do not include any travel Employee-3 may have taken on commercial airlines. As set forth in the Indictment, Employee-3 scheduled victims' encounters with EPSTEIN. + +26. Based on my training, experience, and participation in this investigation, I believe that there is probable cause that evidence of the Subject Offenses, such as photographs of EPSTEIN's victims and co-conspirators, will be found at the Subject Premises. In particular, information provided by Individual-1, with whom EPSTEIN engaged in sex acts at the Subject Premises while Individual-1 was a minor, confirms that EPSTEIN engaged in conduct relevant to the Subject Offenses at the Subject Premises. In addition, photographs on the Seized Discs recovered during the search of the New York Residence depict other young and partially nude girls photographed at the Subject Premises, which suggests that EPSTEIN brought those girls to the Subject Premises and that, consistent with the accounts provided by Individual-1, Victim-1 and other victims identified in the Indictment, EPSTEIN likely sexually abused them at the Subject Premises as well. Evidence of co-conspirators' presence at the Subject Premises at times when victims were abused, including photographs, may also be found at the Subject Premises. Indeed, as noted above, Individual-2 has observed a photograph of partially-nude young girls at the Subject Premises. + +27. Moreover, while the sexual abuse described above occurred principally between approximately 2002 and 2005, as evidence recovered from the New York Residence including the Seized Discs makes clear, EPSTEIN continued to maintain substantial evidence of the Subject Offenses up until the time he was arrested in 2019. Indeed, as described above, in addition to the Seized Discs, Epstein continued to maintain a "massage room" complete with a massage table and various sex toys that remained similar in makeup and appearance to descriptions of the same room provided by Victim-1 based on Victim-l's encounters with EPSTEIN in 2004. + +28. In addition, I believe that evidence of the Subject Offenses, including but not limited to photographs/evidence created at the Subject Premises, may be located not only at the New York Residence but also at the Subject Premises because (i) the Subject Premises was the location of multiple photo shoots of young girls; (ii) the Subject Premises appears to have been, for the last several years and up until the time of his arrest, EPSTEIN's primary residence; and (iii) given its location, the Subject Premises is JEFFREY EPSTEIN's most private residence. Therefore, given that EPSTEIN has maintained evidence of the Subject Offenses, he is likely to have maintained some of that evidence in or on the Subject Premises. Moreover, given that there is JEFFREY EPSTEIN ...kart. probable cause to believe that and others, conspired to commit the Subject Offenses, evidence of EPSTEIN's involvement in trafficking minors would also be relevant to the investigation of, and any future charges against, other members of the conspiracy, such as + +29. According to international flight records that I have reviewed, a private jet owned and utilized by Epstein has traveled to or from the U.S. Virgin Islands at least on or about April 14, 2019; May 5, 2019; May 18, 2019; and June I1, 2019. Accordingly, there is probable cause to believe that EPSTEIN recently has been present at the Subject Premises. + +30. Based on my training and experience in investigating individuals who engage in sex trafficking of minors, and who sexually exploit minors, such individuals often maintain photographs of their victims, and/or other erotic images of minors, at their residences. Individuals who engage in such offenses often hoard such images in the privacy of their residences. In particular, data related to their illegal activity is often stored on their computers. + +31. In my training and experience, individuals who store nude and/or sexually suggestive photographs of minors on compact discs or other external storage devices typically access those images from computers and other electronic devices in order to view those images, and individuals who store such materials on compact discs typically store similar files on other computing devices and storage devices. + +32. Based on my training and experience, I also know that, where computers are used in furtherance of criminal activity, evidence of the criminal activity can often be found months or even years after it occurred. This is typically true because: + +- Electronic files can be stored on a hard drive for years at little or no cost and users thus have little incentive to delete data that may be useful to consult in the future. +- Even when a user does choose to delete data, the data can often be recovered months or years later with the appropriate forensic tools. When a file is "deleted" on a home computer, the data contained in the file does not actually disappear, but instead remains on the hard drive, in "slack space," until it is overwritten by new data that cannot be stored elsewhere on the computer. Similarly, files that have been viewed on the Internet are generally downloaded into a temporary Internet directory or "cache," which is only overwritten as the "cache" fills up and is replaced with more recently viewed Internet pages. Thus, the ability to retrieve from a hard drive or other electronic storage media depends less on when the file was created or viewed than on a particular user's operating system, storage capacity, and computer habits. +- In the event that a user changes computers, the user will typically transfer files from the old computer to the new computer, so as not to lose data. In addition, users often keep backups of their data on electronic storage media such as thumb drives, flash memory cards, CD-ROMs, or portable hard drives. + +# C. Return of ESI + +33. If the Government determines that the electronic devices are no longer necessary to retrieve and preserve the data, and the devices themselves are not subject to seizure pursuant to Federal Rule of Criminal Procedure 41(c), the Government will return these items, upon request. Computer data that is encrypted or unreadable will not be returned unless law enforcement personnel have determined that the data is not (i) an instrumentality of the offense, (ii) a fruit of the criminal activity, (iii) contraband, (iv) otherwise unlawfully possessed, or (v) evidence of the Subject Offenses. + +#### III. Conclusion and Ancillary Provisions + +34. Based on the foregoing, I respectfully submit there is probable cause to believe that evidence of the Subject Offenses, and in particular the items described in Attachment A, will be located within the Subject Premises and therefore request the court to issue a warrant to seize the items and information specified in Attachment A to this affidavit and to the Search and Seizure Warrant. + +> Special Agent Federal Bureau of Investigation + +Sworn to before me on August 2019 + +THE HONORABLE RUTH MILLER UNITED STATES MAGISTRATE JUDGE + +# EXHIBIT A + +# EXHIBIT B + +# EXHIBIT C + +# EXHIBIT D + +#### ATTACHMENT A + +#### I. Premises to be Searched—Subject Premises + +The Subject Premises are particularly described as a private island in the U.S. Virgin Islands, known as Little Saint James, any buildings or other structures contained thereon, and any closed containers/items contained therein. Little Saint James is an approximately 75 acre island located approximately four miles off the southeast coast of St. Thomas Island. The Subject Premises is depicted in the following photograph: + +![](_page_21_Picture_3.jpeg) + +The Subject Premises contains multiple structures, including but not limited to: + +- a. On the northeast end of the Subject Premises, there is a single story structure next to a pool. +- b. On the southwest end of the Subject Premises, there is a single-story, four-wall structure. The walls are painted with blue and white stripes. The structure has large double doors as its main entrance and large windows on the three remaining walls. +- c. On the north east end of the Subject Premises, there are multiple structures. The main structure is a single story residence (the "Main Residence") with a stone exterior, a blue roof, and a white detailed exterior that includes white columns. +- d. A separate structure ("Residence One") with a blue roof and stone exterior is at the back of the Main Residence, located at the end of the northeast tip of the island and surrounded by coastline on two of its sides. + +e. A second larger structure ("Residence Two) is set between the Main Residence and the coastline. + +f. Four smaller single story structures (the "Four Cabanas") are next to the Main Residence and a large pool. All four smaller structures have blue roofs. + +g. A third large structure ("Residence Three") set off from the four smaller structures and next to the coast line is painted white and has a blue roof. Residence Three appears to have two levels throughout and also appears to be at a lower elevation than the Main Residence, Residence Two, and the Four Cabanas. + +h. Behind Residence Three and along the coastline is a small roofed structure at the end of a wooden dock (the "Dock House"). + +i. There are two single story sheds ("Shed One" and "Shed Two") that are located just southwest of the Main Residence. Shed One and Shed Two appear to have a metal-like exterior that is a green-blue color. + +j. Next to Shed One and Shed Two is a four wall structure that appears to have several sally port type doors ("Maintenance One"). A second structure ("Maintenance Two") is next to Maintenance One and has a white exterior with four sets of white double doors and three single white doors. + +k. Near the center of the island is a single story structure ("Residence Four") that has a stone exterior and blue roof. The front of Residence Four has three dark double doors. + +I. Next to the helicopter landing pad are two small structures with blue roofs ("Helipad Buildings"). + +m. On the west side of the Subject Premises on the coast is an approximately two-level structure with a blue roof ("Residence Five"). + +## II. Items to Be Seized + +## A. Evidence, Fruits, and Instrumentalities of the Subject Offenses + +This warrant authorizes the seizure of certain evidence, fruits, and instrumentalities of violations of Title 18, United States Code, Sections 1591 (sex trafficking of minors), and 371 (sex trafficking conspiracy) (the "Subject Offenses") described as follows: + +1. Any documents or communications with or regarding victims or potential victims of the Subject Offenses or between EPSTEIN and co-conspirators to the Subject Offenses; + +2. Any photographs of victims or potential victims of the Subject Offenses, or coconspirators to the Subject Offenses. + +3. Any nude, partially nude, or sexually suggestive photographs of individuals who appear to be teenage girls, or younger. + +4. Any documents evidencing the presence of co-conspirators at the Subject Premises. + +5. Records or other items that evidence ownership, control, or use of, or access to devices, storage media, and related electronic equipment used to access, transmit, or store information relating to the Subject Offenses, including, but not limited to, sales receipts, warranties, bills for Internet access, handwritten notes, registry entries, configuration files, saved usernames and passwords, user profiles, e-mail contacts, and photographs. + +6. Any child erotica, defined as suggestive visual depictions of nude minors that do not constitute child pornography as defined by 18 U.S.C. § 2256(8). + +7. Any computer devices and storage media believed to be owned or used by JEFFREY EPSTEIN including, but not limited to, desktop and laptop computers, disk drives, modems, thumb drives, personal digital assistants, smart phones, digital cameras, scanners, routers, modems, and network equipment used to connect to the Internet. In lieu of seizing any such computer devices or storage media, this warrant also authorizes, in the alternative, the copying of such devices or media for later review. + +8. Any items or records needed to access the data stored on any seized or copied computer devices or storage media, including but not limited to any physical keys, encryption devices, or records of login credentials, passwords, private encryption keys, or similar information. + +9. Any items or records that may facilitate a forensic examination of the computer devices or storage media, including any hardware or software manuals or other information concerning the configuration of the seized or copied computer devices or storage media. + +10. Any evidence concerning the identities or locations of those persons with access to, control over, or ownership of the seized or copied computer devices or storage media. + +11. 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Thereon, and Any Locked or Closed Containers/Items Contained Therein + +DISTRICT OF THE VIRGIN ISLANDS) ss.: + +TO BE FILED UNDER SEAL + +Agent Affidavit in Support of Application for Search and Seizure Warrant + +being duly sworn, deposes and says: + +#### I. Introduction + +#### A. Affiant + +1. I have been a Special Agent with the Federal Bureau of Investigation ("FBI") since 2017. As such, I am a "federal law enforcement office?' 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 have been employed by the FBI for approximately two years, and I am currently assigned to investigate violations of criminal law relating to the sexual exploitation of children. 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 sex trafficking cases, and have participated in the execution of search warrants for physical premises. + +2. I make this Affidavit in support of an application pursuant to Rule 41 of the Federal Rules of Criminal Procedure for a warrant to search the premises specified below (the "Subject Premises") for the purpose of seizing the items and information described in Attachment A. This affidavit is based upon my personal knowledge; my review of documents and other evidence; and my conversations with other law enforcement personnel. Because this affidavit is being submitted + +for the limited purpose of establishing probable cause, it does not include all the facts that I have learned during the course of my 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. + +### B. The Subject Premises + +3. The Subject Premises are particularly described as a private island in the U.S. Virgin Islands, known as Little Saint James, any buildings or other structures contained thereon, and any closed containers/items contained therein. Little Saint James is an approximately 75 acre island located approximately four miles off the southeast coast of St. Thomas Island. The Subject Premises is depicted in the following photograph: + +![](_page_1_Picture_3.jpeg) + +Based on my conversations with a law enforcement agent who has reviewed publicly available satellite information, images, and drone videos, I am aware that the Subject Premises contains multiple structures, including but not limited to: + +- a. On the northeast end of the Subject Premises, there is a single story structure next to a pool. +- b. On the southwest end of the Subject Premises, there is a single-story, four-wall structure. The walls are painted with blue and white stripes. The structure has large double doors as its main entrance and large windows on the three remaining walls. +- c. On the north east end of the Subject Premises, there are multiple structures. The main structure is a single story residence (the "Main Residence") with a stone exterior, a blue roof, and a white detailed exterior that includes white columns. +- d. A separate structure ("Residence One") with a blue roof and stone exterior is at the back of the Main Residence, located at the end of the northeast tip of the island and surrounded by coastline on two of its sides. +- e. A second larger structure ("Residence Two) is set between the Main Residence and the coastline. +- f. Four smaller single story structures (the "Four Cabanas") are next to the Main Residence and a large pool. All four smaller structures have blue roofs. +- g. A third large structure ("Residence Three") set off from the four smaller structures and next to the coast line is painted white and has a blue roof. Residence Three appears to have two levels throughout and also appears to be at a lower elevation than the Main Residence, Residence Two, and the Four Cabanas. +- h. Behind Residence Three and along the coastline is a small roofed structure at the end of a wooden dock (the "Dock House"). + +i. There are two single story sheds ("Shed One" and "Shed Two") that are located just southwest of the Main Residence. Shed One and Shed Two appear to have a metal-like exterior that is a green-blue color. + +j. Next to Shed One and Shed Two is a four wall structure that appears to have several sally port type doors ("Maintenance One"). A second structure ("Maintenance Two") is next to Maintenance One and has a white exterior with four sets of white double doors and three single white doors. + +k. Near the center of the island is a single story structure ("Residence Four") that has a stone exterior and blue roof. The front of "Residence Four" has three dark double doors. + +I. Next to the helicopter landing pad are two small blue roof structures ("Helipad Buildings"). + +m. On the west side of the Subject Premises on the coast is an approximately two-level structure ("Residence Five") with a blue roof. + +4. As detailed further herein, at least through his death on August 10, 2019, the Subject Premises was believed to be owned, possessed, and controlled by JEFFREY EPSTEIN. + +## C. The Target Subject and the Subject Offenses + +5. For the reasons detailed below, I believe that there is probable cause to believe that the Subject Premises contain evidence, fruits, and instrumentalities of violations of Title 18, United States Code, Sections 1591 (sex trafficking of minors), and 371 (sex trafficking conspiracy) (the "Subject Offenses") . The Target Subjects of this investigation arc known and unknown coconspirators of JEFFREY EPSTEIN, including but not limited to + +#### II. Probable Cause and the Initial Search Warrants + +#### A. Probable Cause Regarding the Target Subject's Commission of the Subject Offenses + +6. On or about July 2, 2019, a grand jury in the Southern District of New York returned an Indictment charging JEFFREY EPSTEIN with violations of Title 18, United States Code, Section 1591 (sex trafficking of minors); and Title 18, United States Code, Section 371 (sex trafficking conspiracy). A copy of the Indictment is attached hereto as Exhibit A and is incorporated by reference. EPSTEIN was arrested pursuant to the Indictment on or about July 6, 2019, and had been detained pending trial at the Metropolitan Correctional Center ("MCC") in New York, New York. + +7. On or about August 10, 2019, the Bureau of Prisons confirmed that JEFFREY EPSTEIN had been found unresponsive in his cell at the MCC that morning, and was pronounced dead shortly thereafter. + +8. Notwithstanding EPSTEIN's death, the sex trafficking investigation that led to his indictment remains ongoing. In particular, Count One of the Indictment alleged that EPSTEIN conspired with others to traffic minors, and further identified three individuals who worked for EPSTEIN (identified in Exhibit A as "Employee-1", "Employee-2," and "Employee-3") and facilitated EPSTEIN's abuse of minor girls by, among other things, arranging victims' encounters with EPSTEIN and paying victims after these encounters. The individual identified in Exhibit A as "Employee-2" is a target subject of this investigation. + +9. As set forth in Exhibit A, from at least in or about 2002, up to and including at least in or about 2005, JEFFREY EPSTEIN sexually abused multiple minor girls in Manhattan, New York; West Palm Beach, Florida; and elsewhere. During that time and continuing to the present, + +EPSTEIN possessed and controlled a residence, which is described in Exhibit A as "the New York Residence." + +10. As further set forth in paragraphs 8 through 10 of Exhibit A, from at least in or about 2002, up to and including at least in or about 2005, EPSTEIN sexually abused numerous minor victims at the New York Residence. In particular, and as alleged in the Indictment, when a victim arrived at the New York Residence, she would be escorted to a room inside the New York Residence with a massage table, where she would perform a massage on EPSTEIN. The victims, who were as young as 14 years of age, were told by EPSTEIN or other individuals to partially or fully undress before beginning the "massage." During the encounter, EPSTEIN would escalate the nature and scope of physical contact with his victim to include, among other things, sex acts such as EPSTEIN typically would also + +Following each encounter, EPSTEIN or one of his employees or associates paid the victim in cash. + +I I. As set forth in paragraphs 12 through 13 of Exhibit A, to further facilitate his ability to abuse minor girls in New York, JEFFREY EPSTEIN asked and enticed certain of his victims to recruit additional minor girls to perform "massages" and similarly engage in sex acts with EPSTEIN. When a victim would recruit another minor girl for EPSTEIN, he paid both the victimrecruiter and the new victim hundreds of dollars in cash. EPSTEIN knew that his victims were underage, including because certain victims told him their age. + +12. One of the victims identified in paragraph 22 of Exhibit A is Victim-1. As part of the FBI's investigation of EPSTEIN, I have participated in interviews with Victim-1, along with + +other law enforcement officers.' Based on my participation in those interviews and my conversations with other law enforcement officers, I know that Victim-1 has provided the following information, in substance and in part: + +a. Between approximately 2002 and 2005, EPSTEIN sexually abused Victim-I on multiple occasions in the New York Residence. This sexual abuse all occurred when Victim-I was under the age of 18. + +b. During that same period, Victim-1 observed multiple floors of the New York Residence and numerous individual rooms within the New York Residence. Victim-1 has provided detailed descriptions of certain aspects of the interior of the Subject Premises, including Victim-I's memory of specific details regarding the layout, furnishings, decorations, and floor pattern of various areas within the Subject Premises. Among other details, Victim-1 recalled that EPSTEIN typically abused her in a room she described as a "massage room," (the "Massage Room"), which contained a massage table, and was decorated with artwork depicting naked women, hung on walls that appeared to be adorned with fabric. In describing the sexual abuse that occurred in the Massage Room, Victim-1 has stated that EPSTEIN would often during these abusive encounters. + +Victim- 1 is currently pursuing a civil damages claim against EPSTEIN for his sexual abuse of her. Information provided by Victim-1 has proven reliable and has been corroborated by independent evidence, including documents and records obtained during the investigation and the accounts of other victims whom Victim-1 has never met. + +s with the Government + +#### The July 6 2019 Search Warrant of the Subject Premises + +13. On or about July 6, 2019, the Honorable Barbara Moses, United States Magistrate Judge, signed a search warrant authorizing a search of the New York Residence. The search warrant is attached as Exhibit B and incorporated by reference herein. + +14. At approximately 6 p.m. on or about July 6, 2019, law enforcement officers (the "Search Team") commenced executing the search warrant at the New York Residence. JEFFREY EPSTEIN had been arrested on the charges contained in the Indictment shortly before the execution of the search warrant. Based on the Search Team's observations during an initial search of the New York Residence, at approximately 7 p.m., the Search Team stopped the search and froze the scene in order to seek a new search warrant. On or about July 7, 2019, the Honorable Barbara Moses, United States Magistrate Judge, signed a search warrant authorizing a search of the New York Residence (the "Second Warrant"). The Second Warrant is attached as Exhibit C, and incorporated by reference herein. At approximately 2:30 a.m., the Search Team resumed the search, and commenced searching pursuant to the Second Warrant. Later on July 7, 2019, the Honorable Barbara Moses, United States Magistrate Judge, signed a third search warrant to search and seize certain electronic media stored on discs seized during the execution of the Second Warrant (the "Compact Disc Search Warrant"). The search warrant is attached as Exhibit D, and incorporated by reference herein. + +15. During the execution of the warrants described above on the New York Residence, the Search Team located evidence of the Subject Offenses. In particular, the Search Team located the following, among other items: + +c. Inside the Subject Premises, I observed a room that, based on my participation in interviews of Victim-1, appears to be consistent with Victim-1 's descriptions of the Massage + +Room. The room contained a table covered with a sheet, and appeared to be a massage table. The room also contained several vibrating sex toys. The walls appeared to be covered in a type of feltlike tapestry fabric. I further observed two paintings and three photographs hanging on the walls of the Massage Room. The paintings and photographs depict nude females. One of the photographs appears to depict a nude girl. Thus, it appears that the Massage Room was in substantially the same condition as Victim-1 observed the room more than 18 years ago. + +d. Inside a safe in a closet on the third floor, the Search team discovered and seized, among other items, several binders containing sleeves of compact discs, most of which are labeled with handwriting. In total, the binders contain dozens of compact discs. Some discs contain the word "Zorro" or "LSJ." Based on my conversations with law enforcement agents who have participated in this investigation, I believe the name "Zorro" refers to Zorro Ranch, EPSTEIN's property in New Mexico, and the name LSJ refers to Little Saint James, i.e., the Subject Premises. The majority of the discs contain titles that include female names. Some of the discs in the binders seized by the Search Team have titles that appear to refer to trips or vacations. + +e. In the drawer of a dresser in a room on the Fifth floor of the New York Residence, the Search team discovered and seized, among other items, a shoebox (the "Shoebox") containing numerous compact discs. The majority of the discs are labeled, in handwriting, with female names. One disc is marked "Thai Massage." Another disc is marked "Blonde Girl Photo Shoot." Yet another disc is marked "Misc. Girls Nude/Dinner--Scientists." The discs in the Shoebox were seized by the Search Team. In another drawer of that same dresser, the Search Team discovered loose polaroid photographs depicting young, nude females who, based on the training and experience of law enforcement officers who observed them, appear to be teenagers. + +f. In a closet on the Fifth Floor of the Epstein Residence, the Search Team discovered, among other items, a box marked "women/old photos." The box contained, among other items, approximately seven compact discs, which are labeled with hand-written titles. One disc is marked "nudes 00-24." Another is labeled "Photographer-- `03" The remaining discs contain titles that include female names. All of the foregoing discs were seized by the Search Team. + +g. In that same closet, the Search Team discovered numerous black binders containing what appear to be print outs of digital photographs (with file names underneath) and compact discs. The binders appeared to contain, among other photographs, photographs of nude or partially nude young girls, some of which are in sexually suggestive poses. Based on the training and experience of law enforcement officers who observed them, some of the young girls appear to be teenagers, some of whom appear to be under the age of 18. + +16. Based on my conversations with law enforcement agents who have conducted an initial review (the "Reviewing Agents") of the compact discs seized at the New York Residence as described in paragraphs 15(b)-(e) above (the "Seized Discs"), I have learned that the discs contain approximately thousands of nude or partially nude photographs of girls or young women, many of which are in sexually suggestive poses. Based on my conversations with the Reviewing Agents, who have particular training and experience relating to child erotica and visual depictions of children in child exploitation cases, I have learned that the Reviewing Agents believe that many of the nude or partially nude images they have reviewed appear to depict girls under the age of 18. Certain of these images appear to have been taken at a tropical location, and/or were labeled "LSJ" either in the image file name, or on the compact disc that contained the image. Based on the foregoing, I believe that a portion of the foregoing photographs appear to have been taken at the Subject Premises. In addition, I have learned that some of the file names are marked "." which + +are the initials of . As set forth below, I have interviewed an individual who has reported tha photographed her at the Subject Premises. Accordingly, I believe that a portion of these photos may have been taken by + +17. On or about November 28, 2018, the Miami Herald began publishing a series of articles relating to the defendant, his sexual misconduct with minors, and a previous investigation into his conduct in Florida from in or about 2005 through 2008. The article included information about 's role in EPSTEIN's sexual abuse of minors. Based on my participation in this investigation, I have learned that bank records obtained by the Government appear to show that just days later, on or about December 3, 2018, the defendant wired \$250,000 from a trust account to This course of action, and in particular its timing, suggests that EPSTEIN was attempting to influence who might provide information against him in light of the recently re-emerging allegations. + +### B. Probable Cause Regarding the Subject Premises + +18. Based on my review of property records, I believe that JEFFREY EPSTEIN has been the owner of the Subject Premises since at least the time of the Subject Offenses. In particular, it appears that an entity named "L.S.J., LLC" held title to the Subject Premises from in or about 1998. In or about 2011, L.S.J., LLC transferred title to the Subject Premises to an entity named "Nautilus, Inc.," for \$10. On the transfer paperwork, EPSTEIN signed as the "sole member" of L.S.J., LLC and as the "president and sole beneficial owner" of Nautilus, Inc. + +19. In addition, I believe that up until recently, the Subject Premises was JEFFREY EPSTEIN's principal residence. In particular, I have reviewed sex offender registration data, and have learned that, on or about June 17, 2019, EPSTEIN listed the Subject Premises as his primary residence. At the time of EPSTEIN's arrest on or about July 6, 2019, I and other law enforcement officers conducted an inventory search of EPSTEIN's personal effects, and observed that EPSTEIN was carrying a driver's license that listed the Subject Premises as EPSTEIN's home address. + +20. As discussed herein, I believe that evidence of the Subject Offenses will be found at the Subject Premises. In particular, based on my conversations with law enforcement agents who have conducted an initial review of the Seized Discs, I have learned the following: + +a. Many of the photographs appear to be labeled with file names that include "LSJ," which I believe stands for Little St. James. + +b. As discussed above, photographs seized from the New York Residence appear to depict nude or partially nude young girls, and a portion of those photos appear to have been taken at the Subject Premises, based on the fact that (i) some of the photos appear to have been taken in a tropical location, and (ii) some of the file names of the photographs and/or the labels on the discs containing the files of nude or partially nude young girls in a tropical location are marked "LSJ," i.e., the Subject Premises. + +c. Among the photographs seized from the New York Residence, the Reviewing Agents identified partially-nude photographs of a young girl, labeled with the name of a particular individual ("Individual-1"). The photographs appear to depict Individual-1 on a beach in what appears to be a tropical location. + +21. In or about July 2019, I participated in an interview of Individual-1, with her counsel present. Based on my personal observations, I believe that the photographs described in Paragraph 17(c) depict Individual-1. During the course of the interview, Individual-1 stated that she met EPSTEIN in 2003 when she was approximately 17, and that she travelled to EPSTEIN's properties in New Mexico, Florida, and the U.S. Virgin Islands, i.e., the Subject Premises, before she turned 18. EPSTEIN paid for the trips, and would give Individual-1 money and gifts while she traveled with him. + +22. During these trips, EPSTEIN sexually abused and assaulted her on approximately four different occasions, all of which occurred before she turned 18. Individual-1 reported that EPSTEIN raped her during two of these incidents. Indivdual-1 recalled that one or more of these instances of sexual abuse occurred on the Subject Premises. Individual-1 further reported that, when she was approximately 17, photograph Individual-1 at the Subject Premises. asked to photograph her, and did in fact + +23. In or about August 2019, I and another law enforcement officer interviewed an individual ("Individual-23') who regularly performed work for JEFFREY EPSTEIN as a contractor at the Subject Premises from approximately 1999 to 2005 or 2006. Individual-2 reported that, on several occasions, Individual-2 observed photographs of what appeared to be nude or partially nude young girls in several locations throughout the main residence of the Subject Premises. Individual-2 recalled a photograph depicting and two of girls, all of three whom were topless; Individual-2 estimated that the two girls in the photograph appeared to be approximately 15 or 16 years old. Individual-2 knew to be EPSTEIN's assistant at that time. + +24. Based on my review of flight logs from a private jet owned by JEFFREY EPSTEIN, I have learned that traveled to the U.S. Virgin Islands at least approximately once a month between October 2001 and November of 2005. These records do not include any travel may have taken on commercial airlines. + +25. For all of these reasons, I am aware that has spent significant time at the Subject Premises and that evidence of her involvement, and potentially the involvement of other co-conspirators, may be located at the Subject Premises. In particular, flight logs from EPSTEIN's private jet reflect that the individual identified in the Indictment as "Employee-3" traveled to the U.S. Virgin Islands on approximately nine separate occasions. These records do not include any travel Employee-3 may have taken on commercial airlines. As set forth in the Indictment, Employee-3 scheduled victims' encounters with EPSTEIN. + +26. Based on my training, experience, and participation in this investigation, I believe that there is probable cause that evidence of the Subject Offenses, such as photographs of EPSTEIN's victims and co-conspirators, will be found at the Subject Premises. In particular, information provided by Individual-1, with whom EPSTEIN engaged in sex acts at the Subject Premises while Individual-1 was a minor, confirms that EPSTEIN engaged in conduct relevant to the Subject Offenses at the Subject Premises. In addition, photographs on the Seized Discs recovered during the search of the New York Residence depict other young and partially nude girls photographed at the Subject Premises, which suggests that EPSTEIN brought those girls to the Subject Premises and that, consistent with the accounts provided by Individual-1, Victim-1 and other victims identified in the Indictment, EPSTEIN likely sexually abused them at the Subject Premises as well. Evidence of co-conspirators' presence at the Subject Premises at times when victims were abused, including photographs, may also be found at the Subject Premises. Indeed, as noted above, Individual-2 has observed a photograph of partially-nude young girls at the Subject Premises. + +27. Moreover, while the sexual abuse described above occurred principally between approximately 2002 and 2005, as evidence recovered from the New York Residence including the Seized Discs makes clear, EPSTEIN continued to maintain substantial evidence of the Subject Offenses up until the time he was arrested in 2019. Indeed, as described above, in addition to the Seized Discs, Epstein continued to maintain a "massage room" complete with a massage table and various sex toys that remained similar in makeup and appearance to descriptions of the same room provided by Victim-1 based on Victim-I's encounters with EPSTEIN in 2004. + +28. In addition, I believe that evidence of the Subject Offenses, including but not limited to photographs/evidence created at the Subject Premises, may be located not only at the New York Residence but also at the Subject Premises because (i) the Subject Premises was the location of multiple photo shoots of young girls; (ii) the Subject Premises appears to have been, for the last several years and up until the time of his arrest, EPSTEIN's primary residence; and (iii) given its location, the Subject Premises is JEFFREY EPSTEIN's most private residence. Therefore, given that EPSTEIN has maintained evidence of the Subject Offenses, he is likely to have maintained some of that evidence in or on the Subject Premises. Moreover, given that there is probable cause to believe that JEFFREY EPSTEIN and others, including conspired to commit the Subject Offenses, evidence of EPSTEIN's involvement in trafficking minors would also be relevant to the investigation of, and any future charges against, other members of the conspiracy, such as + +29. According to international flight records that I have reviewed, a private jet owned and utilized by Epstein has traveled to or from the U.S. Virgin Islands at least on or about April 14, 2019; May 5, 2019; May 18, 2019; and June I1, 2019. Accordingly, there is probable cause to believe that EPSTEIN recently has been present at the Subject Premises. + +30. Based on my training and experience in investigating individuals who engage in sex trafficking of minors, and who sexually exploit minors, such individuals often maintain photographs of their victims, and/or other erotic images of minors, at their residences. Individuals who engage in such offenses often hoard such images in the privacy of their residences. In particular, data related to their illegal activity is often stored on their computers. + +31. In my training and experience, individuals who store nude and/or sexually suggestive photographs of minors on compact discs or other external storage devices typically access those images from computers and other electronic devices in order to view those images, and individuals who store such materials on compact discs typically store similar files on other computing devices and storage devices. + +32. Based on my training and experience, I also know that, where computers are used in furtherance of criminal activity, evidence of the criminal activity can often be found months or even years after it occurred. This is typically true because: + +- Electronic files can be stored on a hard drive for years at little or no cost and users thus have little incentive to delete data that may be useful to consult in the future. +- Even when a user does choose to delete data, the data can often be recovered months or years later with the appropriate forensic tools. When a file is "deleted" on a home computer, the data contained in the file does not actually disappear, but instead remains on the hard drive, in "slack space," until it is overwritten by new data that cannot be stored elsewhere on the computer. Similarly, files that have been viewed on the Internet are generally downloaded into a temporary Internet directory or "cache," which is only overwritten as the "cache" fills up and is replaced with more recently viewed Internet pages. Thus, the ability to retrieve from a hard drive or other electronic storage media depends less on when the file was created or viewed than on a particular user's operating system, storage capacity, and computer habits. +- In the event that a user changes computers, the user will typically transfer files from the old computer to the new computer, so as not to lose data. In addition, users often keep backups of their data on electronic storage media such as thumb drives, flash memory cards, CD-ROMs, or portable hard drives. + +## C. Return of ESI + +33. If the Government determines that the electronic devices are no longer necessary to retrieve and preserve the data, and the devices themselves are not subject to seizure pursuant to Federal Rule of Criminal Procedure 41(c), the Government will return these items, upon request. Computer data that is encrypted or unreadable will not be returned unless law enforcement personnel have determined that the data is not (i) an instrumentality of the offense, (ii) a fruit of the criminal activity, (iii) contraband, (iv) otherwise unlawfully possessed, or (v) evidence of the Subject Offenses. + +#### III. Conclusion and Ancillary Provisions + +34. Based on the foregoing, I respectfully submit there is probable cause to believe that evidence of the Subject Offenses, and in particular the items described in Attachment A, will be located within the Subject Premises and therefore request the court to issue a warrant to seize the items and information specified in Attachment A to this affidavit and to the Search and Seizure Warrant. + +> Special Agent Federal Bureau of Investigation + +Sworn to before me on August 2019 + +THE HONORABLE RUTH MILLER UNITED STATES MAGISTRATE JUDGE + +# EXHIBIT A + +# EXHIBIT B + +# EXHIBIT C + +# EXHIBIT D + +#### ATTACHMENT A + +#### I. Premises to be Searched—Subject Premises + +The Subject Premises are particularly described as a private island in the U.S. Virgin Islands, known as Little Saint James, any buildings or other structures contained thereon, and any closed containers/items contained therein. Little Saint James is an approximately 75 acre island located approximately four miles off the southeast coast of St. Thomas Island. The Subject Premises is depicted in the following photograph: + +![](_page_21_Picture_3.jpeg) + +The Subject Premises contains multiple structures, including but not limited to: + +- a. On the northeast end of the Subject Premises, there is a single story structure next to a pool. +- b. On the southwest end of the Subject Premises, there is a single-story, four-wall structure. The walls are painted with blue and white stripes. The structure has large double doors as its main entrance and large windows on the three remaining walls. +- c. On the north east end of the Subject Premises, there are multiple structures. The main structure is a single story residence (the "Main Residence") with a stone exterior, a blue roof, and a white detailed exterior that includes white columns. +- d. A separate structure ("Residence One") with a blue roof and stone exterior is at the back of the Main Residence, located at the end of the northeast tip of the island and surrounded by coastline on two of its sides. + +e. A second larger structure ("Residence Two) is set between the Main Residence and the coastline. + +f. Four smaller single story structures (the "Four Cabanas") are next to the Main Residence and a large pool. All four smaller structures have blue roofs. + +g. A third large structure ("Residence Three") set off from the four smaller structures and next to the coast line is painted white and has a blue roof. Residence Three appears to have two levels throughout and also appears to be at a lower elevation than the Main Residence, Residence Two, and the Four Cabanas. + +h. Behind Residence Three and along the coastline is a small roofed structure at the end of a wooden dock (the "Dock House"). + +i. There are two single story sheds ("Shed One" and "Shed Two") that are located just southwest of the Main Residence. Shed One and Shed Two appear to have a metal-like exterior that is a green-blue color. + +j. Next to Shed One and Shed Two is a four wall structure that appears to have several sally port type doors ("Maintenance One"). A second structure ("Maintenance Two") is next to Maintenance One and has a white exterior with four sets of white double doors and three single white doors. + +k. Near the center of the island is a single story structure ("Residence Four") that has a stone exterior and blue roof. The front of Residence Four has three dark double doors. + +I. Next to the helicopter landing pad are two small structures with blue roofs ("Helipad Buildings"). + +m. On the west side of the Subject Premises on the coast is an approximately two-level structure with a blue roof ("Residence Five"). + +### II. Items to Be Seized + +### A. Evidence, Fruits, and Instrumentalities of the Subject Offenses + +This warrant authorizes the seizure of certain evidence, fruits, and instrumentalities of violations of Title 18, United States Code, Sections 1591 (sex trafficking of minors), and 371 (sex trafficking conspiracy) (the "Subject Offenses") described as follows: + +1. Any documents or communications with or regarding victims or potential victims of the Subject Offenses or between EPSTEIN and co-conspirators to the Subject Offenses; + +2. Any photographs of victims or potential victims of the Subject Offenses, or coconspirators to the Subject Offenses. + +3. Any nude, partially nude, or sexually suggestive photographs of individuals who appear to be teenage girls, or younger. + +4. Any documents evidencing the presence of co-conspirators at the Subject Premises. + +5. Records or other items that evidence ownership, control, or use of, or access to devices, storage media, and related electronic equipment used to access, transmit, or store information relating to the Subject Offenses, including, but not limited to, sales receipts, warranties, bills for Internet access, handwritten notes, registry entries, configuration files, saved usernames and passwords, user profiles, e-mail contacts, and photographs. + +6. Any child erotica, defined as suggestive visual depictions of nude minors that do not constitute child pornography as defined by 18 U.S.C. § 2256(8). + +7. Any computer devices and storage media believed to be owned or used by JEFFREY EPSTEIN including, but not limited to, desktop and laptop computers, disk drives, modems, thumb drives, personal digital assistants, smart phones, digital cameras, scanners, routers, modems, and network equipment used to connect to the Internet. In lieu of seizing any such computer devices or storage media, this warrant also authorizes, in the alternative, the copying of such devices or media for later review. + +8. Any items or records needed to access the data stored on any seized or copied computer devices or storage media, including but not limited to any physical keys, encryption devices, or records of login credentials, passwords, private encryption keys, or similar information. + +9. Any items or records that may facilitate a forensic examination of the computer devices or storage media, including any hardware or software manuals or other information concerning the configuration of the seized or copied computer devices or storage media. + +10. Any evidence concerning the identities or locations of those persons with access to, control over, or ownership of the seized or copied computer devices or storage media. + +11. 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The findings of autopsy are consistent with strangulation/hanging themselves. At this moment there is NO REASON to suspect or suggest Epstein did not hang himself. However, the OCME is not finalizing the findings or the death certificate until a toxicology is done and interviews of the first guards on scene who discovered Epstein are completed and available for review by Dr . Epstein had a broken hiatal bone and injuries to the left should, both of which I am told are consistent with hanging. The bone is just above the Adam's apples and breaks to the pressure and the injury to the shoulder I am told is consistent when the body starts to convulse. This information was provided by NYPD Det of the OCME liaison unit. \ No newline at end of file diff --git a/marker2/ds9/EFTA00089104/EFTA00089104.metadata.json b/marker2/ds9/EFTA00089104/EFTA00089104.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..0b9918d4042986971362909221ead2666084e9fc --- /dev/null +++ b/marker2/ds9/EFTA00089104/EFTA00089104.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089104.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 855, + "elapsed_seconds": 0.44, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 32 + ], + [ + "Line", + 15 + ], + [ + "Text", + 7 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089104" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089105/EFTA00089105.md b/marker2/ds9/EFTA00089105/EFTA00089105.md new file mode 100644 index 0000000000000000000000000000000000000000..3bbe9c353c7648194a3d9c607a9d46e05c33963f --- /dev/null +++ b/marker2/ds9/EFTA00089105/EFTA00089105.md @@ -0,0 +1,47 @@ +'lb: + +Subject: Fwd: Staff Assignments + +Date: Sun, 11 Aug 2019 21:15:33 +0000 + +Sent from mobile device, please excuse typos. + +Special Agent + +Office of the Inspector General + +1 Battery Park Plaza, 29th floor + +New York NY 10004 + +Begin forwarded message: + +From: + +Date: August 11, 2019 at 4:51:26 PM EDT + +To: + +Subject: Staff Assignments + +Below are the staff assignments on 8-10-2019. + +-North Housing Unit Evening Shift 4-12 PM + +str i9cial Housing Unit#3 Officer PM Shift 2-10 PM + +Not on Shift + +Day Off + +11-North Housing Unit Day Shift 8-4 PM + +Day Off + +Tova Noel Special Housing Unit#1 Officer Morning Shift 12:00 AM-8:00 AM + +Michael Thomas Special Housing Unit#2 Officer Morning Shift 12:00 AM-8:00 AM + +-Institution Duty Officer + +I am working on the job duties. \ No newline at end of file diff --git a/marker2/ds9/EFTA00089105/EFTA00089105.metadata.json b/marker2/ds9/EFTA00089105/EFTA00089105.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..0e888a8db69ecfce83b9b936ffe55d5ea3adfc5c --- /dev/null +++ b/marker2/ds9/EFTA00089105/EFTA00089105.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089105.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 756, + "elapsed_seconds": 1.22, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 55 + ], + [ + "Text", + 29 + ], + [ + "Line", + 26 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089105" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089106/EFTA00089106.md b/marker2/ds9/EFTA00089106/EFTA00089106.md new file mode 100644 index 0000000000000000000000000000000000000000..12484b21f06a7df23794b1bcce20a1583887f433 --- /dev/null +++ b/marker2/ds9/EFTA00089106/EFTA00089106.md @@ -0,0 +1,33 @@ +To: + +Cc: + +Subject: 18 U.S.C. 1519 Elements + +Date: Mon, 12 Aug 2019 01:56:58 +0000 + +-- + +Regarding your question on the 1519, here's our research and an overview of the charge: + +Under 18 U.S.C. § 1519, in pertinent part, "[w]hoever knowingly . . . falsifies, or makes a false entry in . . . any record [or] document . .. with the intent to impede, obstruct, or influence the ... proper administration of any matter within the jurisdiction of any department or agency of the United States ... or in relation to or contemplation of any such matter" commits a twenty-year felony. Congress enacted § 1519 as part of the Sarbanes-Oxley Act following the prosecution of the accounting firm Arthur Andersen for its destruction of Enron-related documents. The statute "was intended to prohibit, in particular, corporate document-shredding to hide evidence of financial wrongdoing." Yates v. United States, 135 S. Ct. 1074, 1081 (2015). Nonetheless, the legislative history of the statute reflects the fact that Congress "meant [the act] to apply broadly" and cover a wide range of "obstructive conduct." S. Rep. 107-146, 14-15 (2002). In Yates, which concerned whether a fish was a "tangible object" as used in the statute, the Supreme Court rejected "reading § 1519 expansively to create a coverall spoliation of evidence statute" and instead held that "a 'tangible object' within § 1519's compass is one used to record or preserve information." W. at 188-89. Ultimately, the restrictive reading of "tangible object" in Yates does not affect the application of the statute here because the proposed charge concerns the fabrication of a record or document, not a tangible object. + +Thus, to prove a defendant violated § 1519, as is relevant here, the government must establish that (1) the defendant knowingly falsified a record or document; (2) the defendant acted with intent to impede, obstruct, or influence the administration of a matter, or in contemplation of a matter; and (3) the matter was within the jurisdiction of a department or agency of the United States. + +## 1. Falsification of Documents and Entries + +Section 1519 criminalizes the knowing falsification of a document, or false entries on a form. While the statute contained multiple verbs (e.g., "conceals: "creates a false entry," etc.), the "falsifies" charge is appropriate when a false document is created, and the "false entry" charge is "usually reserved for entries made on pre-existing forms." United States v. Schmeltz, 667 F.3d 685, 688 (6th Cir. 2011). Convictions for falsifying records or entries are upheld when the records or entries contain misrepresentations or omissions. See United States v. Gray, 692 F.3d 514, 517-21 (6th Cir.2012) (assuming without discussion that § 1519 covers omissions); United States v. Norman, 87 F. Supp. 3d 737, 743 (E.D. Pa. 2015) (collecting cases). Misrepresentations that are sufficient to support a § 1519 conviction include factual misrepresentations about the occurrence of an event. See United States v. Yielding, 657 F.3d 688, 715-16 (8th Cir. 2011) (backdating a document); United States v. Taohim, 529 F. App'x 969 (11th Cir. 2013) (omission of plastic discharge from ship's garbage record book). As is relevant here, 1519 has been applied to false BOP reports. See, e.g., United States v. Gray, 642 F.3d 371, 374 (2d Cir. 2011) (private prison guard charged for writing a false report regarding an assault); United States v. Morris, 404 F. App'x 916 (5th Cir. 2010) (submitting a false use of force report before there was a pending investigation); United States v. Hamilton, No. 15-CR-0240-TCB-LTW, 2016 WL 11432647, at \*3 (N.D. Ga. Mar. 15, 2016), report and recommendation adopted, 2016 WL 1696136 (N.D. Ga. Apr. 28, 2016) (false jail incident report). + +## 2. Knowledge Requirement + +Violations of § 1519 require that the defendant "knowingly ... falsifies, or makes a false entry in ... any record [or] document ... with the intent to impede, obstruct, or influence the ... proper administration of any matter .. or in relation to or contemplation of any such matter." A defendant must "knowingly" falsify documents or make false entries "with the intent to impede, obstruct, or influence." Section 1519 "requires only proof that the accused knowingly committed one of several acts, including falsification of a document or falsification of a record, and did so 'with the intent to impede, obstruct, or influence the investigation or proper administration' of a federal matter." Yielding, 657 F.3d at 711. Provided a defendant commits an act knowingly — here, that he or she knowingly made an entry in a record that was not true — then the question is whether the defendant did so with the intent to obstruct or influence the investigation or administration of a matter. + +It is settled that knowledge of a pending federal investigation is not an element of the crime. See United States v. Gray, 642 F.3d 371, 378-79 (2d Cir. 2011) ("By the plain terms of § 1519, knowledge of a pending federal investigation or proceeding is not an element of the obstruction crime."); United States v. Cassette, 593 F. App'x 28, 31 (2d Cir. 2014) (same). Additionally, there is no requirement that an investigation be pending or imminent. See Gray, 642 F.3d at 377 ("in enacting § 1519, Congress rejected any requirement that the government prove a link between a defendant's conduct and an imminent or pending official proceeding"); Yielding, 657 F.3d at 711 ("The statute ... does not allow a defendant to escape liability for shredding documents with intent to obstruct a foreseeable investigation of a matter ... just because the investigation has not yet commenced."). There is also no requirement that there be a nexus or link between the defendant's conduct and an official proceeding. Gray, 642 F.3d at 377. Rather, in general, courts have found that defendants acted "in contemplation of" or "in relation to" a federal matter when a reasonable fact-finder could infer that the defendants' behavior was in anticipation of an investigation. Such evidence includes notice of a possible investigation, previous knowledge that the matter could be the subject of an investigation, or communications with other parties to design an appearance of legitimacy. See Gray, 642 F.3d at 378 (affirming a § 1519 conviction for corrections officers who did not report the abuse of an inmate by other officers, finding there was sufficient evidence that their actions were in "contemplation" of a matter since the defendant had been trained to report any improper use of force and omitted the beating in an official report); see also United States v. Kernel!, 667 F.3d 746, 755 (6th Cir. 2012). Similarly, if a defendant believe that a false record "would be reviewed" or inspected some time in the future, that is sufficient for the false entry to satisfy the "in contemplation" prong. Taohim, 529 F. App'x 969 (11th Cir. 2013). + +## 3. Jurisdictional Element + +A matter is "within the jurisdiction of any department or agency of the United States" if the department or agency has power to exercise authority in a particular situation. United States v. Ionia Mgmt. S.A., 526 F.Supp.2d 319, 329 (D. Conn. 2007), aff'd, 555 F.3d 303 (2d Cir. 2009). Here, there's no question that the matter is within the purview of the BOP and the DOJ. + +Let us know if you have any questions. + +Assistant United States Attorney United States Attorney's Office Southern District of New York One St. Andrew's Plaza New York, New York 10007 \ No newline at end of file diff --git a/marker2/ds9/EFTA00089106/EFTA00089106.metadata.json b/marker2/ds9/EFTA00089106/EFTA00089106.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..d674f9fbf69dd05ba46a95d7b41bd92fba42ff88 --- /dev/null +++ b/marker2/ds9/EFTA00089106/EFTA00089106.metadata.json @@ -0,0 +1,162 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089106.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 7512, + "elapsed_seconds": 0.83, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "1. 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The Special housing unit Shu#1 Officer announced by via radio medical emergency on 9 South upon arrival, officer=stated to me that inmate Epstein had hung himself. As I entered cell Z06-220 on L-tier, I witnessed inmate Epstein on the floor of his cell unresponsive with Shu#2 officerMerforming life- saving CPR on him. I immediately relieved him and begin administering CPR continuously until relieved by clinical nurse who continued to perform CPR. I then notified the control center to call 911 emergency services at 6:35 a.m.; CPR was being continuously administered as inmate Epstein was escorted to the 2nd FL. Health Service Area, while in the medical area I witnessed nurse continuously performing CPR on inmate Epstein until relieved by EMT staff at 6:43 am. Inmate Epstein #76318-054 was escorted from the medical area to the Rear-gate area where he was transferred into EMS ambulance 04D at 7:10 am with #1 Escort office and followed in the Bo chase vehicle by #2 Escort officer= to downtown Beekman Hospital. During the emergency situation s/o stated to me "we did not complete the 3am nor 5am rouinds." Officer vas appearing very distrau en ask what happened he stated "we messed up, followed by" I messed up" she's not to blame we didn't do any rounds. . \ No newline at end of file diff --git a/marker2/ds9/EFTA00089108/EFTA00089108.metadata.json b/marker2/ds9/EFTA00089108/EFTA00089108.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..b31f5ff65f7d1b6a0ad2c99cd8c708991ca39d09 --- /dev/null +++ b/marker2/ds9/EFTA00089108/EFTA00089108.metadata.json @@ -0,0 +1,111 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089108.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1531, + "elapsed_seconds": 0.56, + "image_assets": [ + "_page_0_Picture_0.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "U.S. Department of Justice", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 319.553, + 34.83 + ], + [ + 482.5714416503906, + 34.83 + ], + [ + 482.5714416503906, + 51.3714599609375 + ], + [ + 319.553, + 51.3714599609375 + ] + ] + }, + { + "title": "Memorandum", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 319.553, + 97.19999999999999 + ], + [ + 423.41827392578125, + 97.19999999999999 + ], + [ + 423.41827392578125, + 116.78033447265625 + ], + [ + 319.553, + 116.78033447265625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 49 + ], + [ + "Line", + 23 + ], + [ + "Text", + 7 + ], + [ + "SectionHeader", + 2 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089108" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089108/_page_0_Picture_0.jpeg b/marker2/ds9/EFTA00089108/_page_0_Picture_0.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..1fae0a7305541247711d4681942ec968ac6e25c8 --- /dev/null +++ b/marker2/ds9/EFTA00089108/_page_0_Picture_0.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:1a8c615c49000e4106d9eca288f20d71df5330ae6a70df25ab87c2878ef66475 +size 8161 diff --git a/marker2/ds9/EFTA00089109/EFTA00089109.md b/marker2/ds9/EFTA00089109/EFTA00089109.md new file mode 100644 index 0000000000000000000000000000000000000000..8b35c968f1ea73167e01013736270e391c4a5580 --- /dev/null +++ b/marker2/ds9/EFTA00089109/EFTA00089109.md @@ -0,0 +1,166 @@ +**Metropolitan Correctional Center** +**Official Count Slip** + +| Unit: HESR
Count: 4 | Date: 8/10/19
Time: 10:01 AM | +|--------------------------------------|-----------------------------------------------| +|--------------------------------------|-----------------------------------------------| + +Metropolitan Correctional Center +Official Count Slip + +Unit: BA Date: 8/10/19 +Count: 26 Time: 7:00 AM + +Metropolitan Correctional Center +Official Count Slip + +| Unit: A | Date 8/10/79 | +|------------------|----------------------| +| Count: 10 | Time: 1201 AM | + +![Stamp for Metropolitan Correctional Center Official Count Slip with Unit FN, Date 28-10-19, Count 81, and Time 120/m.]()**Metropolitan Correctional Center +Official Count Slip** + +Unit: ~~85~~ Date: 8/10/19 +Count: 78 Time: 12 01 AM + +[REDACTED] + +Print Name: Thomas + +Signature [Signature] + +|

Metropolitan Correctional Center
Official Count Slip

| | +|--------------------------------------------------------------------------------|-----------------| +| Unit: | GN | +| Count: | #2 | +| Date: | 8/10/19 | +| Time: | 12:30 AM | + +![Metropolitan Correctional Center Official Count Slip with handwritten date and count information.]()Metropolitan Correctional Center +Official Count Slip + +Unit: GS Date: 05/14/99 +Count: 88 Time: 8:00 + +| Metropolitan Correctional Center | | +|----------------------------------|-----------------------| +| Official Count Slip | | +| Unit: IN | Date 8/10/2019 | +| Count: 86 | Time: 1201Am | +| [REDACTED] | | +| _____ | | +| _____ | | +| _____ | | + +| Metropolitan Correctional Center | | +|----------------------------------|---------------------| +| Official Count Slip | | +| Unit: IN | Date 8/10/19 | +| Count: 89 | Time: 1201Am | +| [REDACTED] | | +| _____ | | +| _____ | | +| _____ | | + +| Metropolitan Correctional Center | | +|----------------------------------|-----------------------| +| Official Count Slip | | +| Unit: IN | Date 8/10/2019 | +| Count: 86 | Time: 1201Am | +| [REDACTED] | | +| _____ | | +| _____ | | +| _____ | | +| _____ | | + +Metropolitan Correctional Center +Official Count Slip + +| Unit: | ZA | Date: | 8/10/19 | +|--------|---------------|-------|-----------------| +| Count: | 73 | Time: | 12:00 AM | + +![Metropolitan Correctional Center New York, New York Official Count Slip with unit 'B' and date '8-18-19'.]() + +| COUNT AREA | CENSUS | A | F | F | F | F | H | M | R | S | TR | V | OC | VERIFY | COUNT | COUNT AREA | +|------------|--------|---|---|---|---|---|---|---|---|---|----|----|----|--------|-------|------------| +| | | T | N | N | N | S | O | S | & | A | N | I | UO | | | | +| | | T | J | Y | Y | S | S | D | N | W | S | TU | | | | | +| | | Y | E | S | P | | | I | D | I | N | T | | | | | +| | | | | | | | | V | T | T | | | | | | | + +| B-A | 26 | . | . | . | . | . | . | . | . | . | . | . | . | X | 26 | B-A | +|-------|-----|---|---|---|---|---|---|---|---|---|---|---|---|---|-----|-----| +| C-A | 10 | . | . | . | . | . | . | . | . | . | . | . | . | X | 10 | C-A | +| E-N | 83 | . | . | . | . | . | 2 | . | . | . | . | . | 2 | X | 81 | E-N | +| E-S | 79 | . | . | . | . | . | 1 | . | . | . | . | . | 1 | X | 78 | E-S | +| G-N | 78 | . | . | . | . | . | . | . | . | . | . | . | . | X | 78 | G-N | +| G-S | 88 | . | . | . | . | . | . | . | . | . | . | . | . | X | 88 | G-S | +| H-A | 4 | . | . | . | . | . | . | . | . | . | . | . | . | X | 4 | H-A | +| I-N | 86 | . | . | . | . | . | . | . | . | . | . | . | . | X | 86 | I-N | +| K-N | 89 | . | . | . | . | . | . | . | . | . | . | . | . | X | 89 | K-N | +| K-S | 137 | . | . | . | . | . | 1 | . | . | . | . | . | 1 | X | 136 | K-S | +| R-A | 1 | . | . | . | . | . | . | . | . | . | . | . | . | X | 1 | R-A | +| Z-A | 72 | . | . | . | . | . | . | . | . | . | . | . | . | X | 72 | Z-A | +| Z-B | 5 | . | . | . | . | . | . | . | . | . | . | . | . | X | 5 | Z-B | +| TOTAL | 758 | . | . | . | . | . | 4 | . | . | . | . | . | 4 | X | 754 | | + +COUNT VERIFY ----- X + OFFICIAL PREPARING COUNT: [REDACTED] + OFFICIAL TAKING COUNT: [REDACTED] + COUNT CLEARED TIME: 12:40 + +Good Verbal 31200 + +## METROPOLITAN CORRECTIONAL CENTER NEW YORK, NY + +DATE: OR- le.).-/Y + +FROM: + +APPROVED: + +| REG # | NAME | UNIT | REG # | NAME | UNIT | +|------------|------------|------|-------|------|------| +| [REDACTED] | [REDACTED] | ES | 13. | | | +| | | EN | 14. | | | +| | | EN | 15. | | | +| | | KS | 16. | | | +| 5. | | | 17. | | | +| 6. | | | 18. | | | +| 7. | | | 19. | | | +| 8. | | | 20. | | | +| 9. | | | 21. | | | +| 10. | | | 22. | | | +| 11. | | | 23. | | | +| 12. | | | 24. | | | + +## OFFICIAL OUT COUNT + +COUNT TIME: 2 O/ + +LOCATION: + +## OUT-COUNT BY UNIT + +B-A C-A E-N E-S G-N G-S I-N K-N K-S R-A Z-A Z-B + +Total Out-Counted: + +This form must be submitted to the Counts and Assignments Officer FORTY-FIVE MINUTES PRIORto th affected count Prepare this form in ink. Group the inmates according to their respective housing units. This form is to be Ted only as an Out-Count No other form will be accepted in lieu of the Out-Count Form. + +CATEGORY: OCT GROUP CODE: +ASSIGNMENT: HOSP FACILITY: NYM +OPER CATG ASSIGNMENT OPER CATG ASSIGNMENT OPER CATG ASSIGNMENT + +| NUM | ASSIGNMENT | REG NO | NAME | OCT DATE | QTR | WRK | +|------|------------|--------|------------|------------|----------|-----------------------| +| 0001 | HOSP | | [REDACTED] | 08-09-2019 | E05-535L | SUICIDE OR
UNASSG | +| 0002 | | | [REDACTED] | 08-09-2019 | E07-555L | ORD CCS
SUICIDE OR | +| 0003 | | | [REDACTED] | 08-09-2019 | E03-519L | SUICIDE OR
UNASSG | +| 0004 | | | [REDACTED] | 08-09-2019 | K12-064L | SUICIDE OR
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0000000000000000000000000000000000000000..4227ad9435359686e4ea36ce841a9f950a261bd5 --- /dev/null +++ b/marker2/ds9/EFTA00089117/EFTA00089117.md @@ -0,0 +1,378 @@ +## Bureau of Prisons Psychology Services + +# Clinical Intervention - Clinical Contact + +\*\*SENSITIVE BUT UNCLASSIFIED\*\* + +Inmate Name: EPSTEIN, JEFFREY EDWARD Reg #: 76318-064 + +Date of Birth: 01/20/1953 Sex: M Facility' NYM Unft Team: 5 + +Date: 07/27/2019 07:14 Provider. PsyD + +#### Focus of Session + +He was seen by writer while he was on Psych Observation. + +#### Subjective/Objective Presentation + +The "Eating/Shower Chart' indicated yesterday he ate dinner, drank liquids, and took a shower when offered. The Psych Observation Log noted he brushed his teeth, went to a Legal visit, talked about business and investing to an Inmate Companion, ate, and slept. + +When interviewed, he stated he still cannot remember what happened in SHU that caused the marks on his neck. He stated that for the 5 days before that he had only slept about 30 minutes each night because of noise in SHU. He stated he is arudous about going back to SHU because he stated he is going back to a place where he had gotten marks on his neck and he does not know why it happened. + +He said he has an appetite and is eating. He said he is waking up every 1 1/2 hours. He stated he feels dehydrated because he is not drinking enough water because he stated he feels he is not given enough bathroom breali s while with his Attorney. Medical was e-mailed with his complaint of feeling dehydrated. He said his Lawyers and friends are all emotionally supportive. + +Current Mental Status: He exhibited a neutral mood with a full range of affect. His speech was logical and coherent, with no loosening of associations or tangential, circumstantial or irrelevant speech. Auditory and visual hallucinations were denied, and delusions were not elicited. He did not engage in any bizarre or inappropriate behavior. He denied current suicidal or self harm ideation. He stated "I'm a coward? He added he does not like pain and even does not like when he has to give blood. He agreed to Immediately tell staff and Inmate Companions if he starts to have suicidal or self harm thoughts. He was future oriented. He does not appear to be an Immediate danger to self. He denied thoughts of hurting others and he agreed to tell staff and Inmate Companions if he has these thoughts. + +#### intenrentionfs1 + +Supportive and educative interventions were provided. Turning Points handouts on stress management, sleep, and building a routine in SHU were placed on his cell door to be given to him when his food slot is opened. He stated he wants it noted in his chart that he is being given a pamphlet on sleep, but that is not going to help because of the noise in SHU that prevents him from sleeping. + +#### EMS + +He will remain on Psych Observation in an abundance of caution and pending housing arrangements to be made on Monday. While on Psych Observation, he will be seen daily by Psychology. + +Completed by PsyD on 07/28/2019 09:19 + +# Bureau of Prisons "SENSITIVE BUT UNCLASSIFIED\*\* Psychology Services + +# Clinical Intervention - Clinical Contact + +Inmate Name: EPSTEIN, JEFFREY EDWARD Reg #: + +Date of Birth: 01/20/1953 Sex: NYM Unit Team + +Date: 07/28/2019 08:33 Provider: I PsyD + +76318-054 + +5 + +#### focus of Session + +He was seen by writer while he was on Psych Observation. + +#### Subjective/Objective Presentation + +The "Eating/Shower Chart" noted that yesterday he ate breakfast. He is not in the Psych Observation cell r about 12 hours per day because of being In Attorney Conference with his Attorneys, so the "Eating/Shower Chart" may not reflect all of his meals. He stated he was served one meal in Attorney Conference yesterday. He stated he drinks a lot water at night. The Psych Observation log noted he talked about life in general population and he slept. + +Earlier he had complained that his right arm was numb and hanging. Nurse from Medical had seen him for this. + +When this writer was interviewing him, he said his right arm still feels somewhat numb and he said he cannot make a fist with that hand. He also said he has numbness on his neck. This writer notified Nurse + +He stated last night when he flushed the toilet it kept flushing for 45 minutes. He stated he found it so aversive and upsetting that he said he sat in the corner and held his ears. He said because of this he was agitated for hOurs and was not able to sleep. The Li will be moving him to a different cell and he was Informed of this. He stated the feeling he got with the noise of the toilet was similar to when he was in SHU. He said he may have something on the Autism spectrum. He said in the movie "Rain Man," the person with Autism had an aversion to noise. He stated hp is also really good with numbers. + +Current Mental Status: He exhibited a mildly anxious mood with a full range of affect. His speech was logical and coherent, with no loosening of associations or tangential, circumstantial or irrelevant speech. Auditory and visual hallucinations were denied, and delusions were not elicited. He did not engage in any bizarre or inappropriate behavior. He denied current suicidal or self harm ideation and he agreed to immediately tell staff and Inmate Compapions if he starts to have suicidal or self harm thoughts. He was future oriented. He does not appear to be an immediate danger to self. He denied thoughts of hurting others and he agreed to tell staff and Inmate Companions if he has Mete thoughts. + +### Interventlnnft + +Supportive and educative interventions were again provided. He had not been given the Turning Point handouts yesterday that were on his cell door, so they were handed to him by staff today. + +#### Progress/Plan + +He will remain on Psych Observation in an abundance of caution and pending housing arrangements to b¢ made on Monday. Mile on Psych Observation, he will be seen daily by Psychology. + +Completed by PsyD on 07/28/2019 09:24 + +## Bureau of Prisons "SENSITIVE BUT UNCLASSIFIED\*\* Psychology Services + +## Clinical Intervention - Clinical Contact + +Inmate Name: EPSTEIN, JEFFREY EDWARD Reg #: 76318-054 + +Date of Birth: 01120/1953 Sex: aCity: NYM Unit Team 5 + +Date: 07/29/2019 10:01 Provider: PhD/Chief + +#### focus of Session + +Inmate Epstein was seen while on psychological observation today in the hospital area. + +#### Subjective/Objective Presentation + +Same presentation today, but he said he thinks his memory for the incident (injury to his neck) may be impaired because of his sleep apnea. He Is supposed to get his CPAP machine today. He is aware he will be returbing to SHU, but said he is feeling unwell due to his inability to sleep and numbness in his arm. He requested to have one good night of sleep with his CPAP and will return to SHU with a cellmate tomorrow. He then asked if he could remain down here where it is "safe" for the entire week. I told him he can stay down one more night to receive his CPAP anda good night's sleep, but that he would be returned to SHU tomorrow. It was explained that there is no mental health issues precluding him from returning to Still tomorrow and that we could not house him in the SW/Hospital area because he felt safe or more comfortable for him. It was explained to him that he would be placed in a safe situation in the SHU. + +According to his log book and eating/shower chart, he has been eating and drinking when not in his legal visits. He has also been writing and attending his legal visits. + +#### Intervention's) + +Inmate EPSTEIN was provided with brief supportive interventions and psychoeducation regarding additio I coping strategies. Inmate EPSTEIN was somewhat receptive to these interventions, but appears more concerned about getting his various needs in the prison (phone calls, recreation, housing placement concerns, etc.) + +#### Progress/Plan + +He will remain on psychological observation today and will transition to the SHU tomorrow. He will be seen by psychology daily to assess his mental status and psychological functioning. + +Completed byeD/Chief Psychologist on 07/29/2019 10:26 + +# Bureau of Prisons "SENSITIVE BUT UNCLASSIFIED" Psychology Services + +# Clinical Intervention - Clinical Contact + +Inmate Name: EPSTEIN, JEFFREY EDWARD Reg 1: + +Date of Birth: 01/20/1953 Sex: NYM Unit Teem + +Date: 07/30/2019 12:01 Provider: I syD + +78318-054 + +5 + +#### bus of + +He was seen by writer while he was on Psych Observation. + +#### Subjective/Objective Presentation + +He stated he hasn't slept well at MCC-NY because he hasn't had his cpap machine. He stated it Is here and he will be able to start using it tonight. He discussed how he does not think he will able to sleep in SHU and how he does not like SHU because of the noise. He discussed issues on not getting some medication with Medical today. + +The "Eating/Shower Chart" indicated yesterday he ate breakfast and dinner, drank liquids, and took a shower when offered and so far today it noted he ate breakfast and drank liquids. The Psych Observation Log noted he1slept. drank water, went to legal, and talked to an Inmate Companion about investments. + +Current Mental Status: He exhibited a neutral mood with a full range of affect. His speech was logical and herent, with no loosening of associations or tangential, circumstantial or irrelevant speech. Auditory and visual hallucin bons were denied, and delusions were not elicited. He did not engage in any bizarre or inappropriate behavior. There was no indication of disturbed thought process or content. Intellectual ability appeared to be above average. Personal hygiene was adequate. He denied current suicidal or self harm ideation and he agreed to immediately tell staff if he starts to have suicidal or self harm thoughts. He was future oriented. He does not appear to be an immediate dang to self. He denied thoughts of hurting others and he agreed to tell staff if he has these thoughts. + +#### Interventionist + +Supportive and educative interventions were provided. When asked about the Turning Point handouts for coping In SHU, he stated he already knows these strategies before he read the handouts and had tried them when was in SHU the last time. He stated with the noise in SHU, he said the strategies will not work. He was encouraged to try them. + +### progress/Plan + +The Chief Psychologist was consulted. Psych Observation will be discontinued. Mr. Epstein was educat about both routine and emergency procedures for contacting Psychology staff. He will be seen in follow up by Psych gy tomorrow to monitor his mental status and to provide further intervention if needed and he was informed he will be seen by Psychology tomorrow. In the meantime, he was encouraged to self-refer to Psychology if needs to which he agreed and seems capable of doing. If he remains in SHU, he will be seen by Psychology in SHU Round and in SHU Reviews. The SHU Lt. was informed that Mr. Epstein needs to be housed with an appropriate cellmate. + +Completed by -PsyO on 07/30/2019 13:54 + +# Bureau of Prisons Psychology Services + +# Institution Disciplinary Process Report + +"SENSITIVE BUT UNCLASSIFIED— + +Inmate Name: EPSTEIN, JEFFREY EDWARD Reg ft. 78318-054 + +Date of Birth: 01/20/1953 Sex: M F cility: NYM Unit Teem 5 + +Date: 07/30/2019 12:01 Provider. PsyD + +## Reason for Referral and Identifying Information + +Inmate Epstein was referred by Unit Manager Proto for an evaluation of competency to proceed with the d process for actions resulting in an incident report. On 7/23/19, Inmate Epstein was charged with code 228 Self-Mutilation). These infractions were assigned incident report number 3282555. .PrInalY atthoing or + +## Background Information + +According to a Suicide Risk Assessment dated 7/09/19 by Dr. "Inmate Epstein denied any history of mental health treatment, either on an inpatient or outpatient basis. Inmate Epstein denied any treatment in the past or present with psychotropic medication. He also denied any acute mental health symptoms at this time." + +According to a Suicide Risk Assessment dated 7/09/19 by Dr Inmate Epstein denied any past or present suicidal ideation, intention or plan. He denied ever engaging in any suicide attempts or self-injurious behavior in the past." + +According to this writer's Suicide Risk Assessment dated 7/23/19, "It is unclear at this time if he had placedthe string around his neck or if someone else did." + +## Clinical Interview and Mental Status Exam + +Inmate Epstein still does not remember how he obtained the marks around his neck. + +Current Mental Status: He exhibited a neutral mood with a full range of affect. His speech was logical and coherent, with no loosening of associations or tangential, circumstantial or irrelevant speech. Auditory and visual hallucinations were denied, and delusions were not elicited. He did not engage in any bizarre or inappropriate behavior. There was no indication of disturbed thought process or content. Intellectual ability appeared to be above average. P I hygiene was adequate. He denied current suicidal or self harm ideation and he agreed to immediately tell staff if h starts to have suicidal or self harm thoughts. He was future oriented. He does not appear to be an immediate dang to self. He denied thoughts of hurting others and he agreed to tell staff if he has these thoughts. + +## Clinical Impression + +According to his last Diagnostic and Care Level Formulation Note dated 7/09/19 by Dr= "No Dlagnotifti, No Dx - Current " + +## Findings + +The determination of whether an inmate is competent to proceed with the disciplinary process is based on a clinical assessment of the inmate's (1) ability to understand the nature of the proceedings, and (2) their ability to asSist in their own defense. Depending on the outcome of the assessment, one of three findings can be made: (1) the inmate is COMPETENT to proceed with the disciplinary process; (2) the inmate is NOT PRESENTLY COMPETENT but could be restored to competence with treatment; or (3) the inmate Is NOT COMPETENT and Is unlikely to become competent. + +#### Recommendations Regarding Samcilana + +In the case of inmate Epstein, after a review of available psychological and psychiatric records as well as information pertaining to the offense conduct, it Is determined that this inmate is: + +- (X) COMPETENT to proceed with the disciplinary process. ( ) NOT PRESENTLY COMPETENT, but could become competent with treatment; it is recommended that an updated competency assessment in 30 days. ( ) NOT COMPETENT and not likely to become competent. inmate for + +Inmate Name: EPSTEIN, JEFFREY EDWARD Reg #: 76318-054 + +Date of Birth: 01/20/1953 Sex: M F cility: NYM Unit Team: 5 + +Date: 07/30/2019 12:01 Provider. PsyD + +Completed by PsyD on 07/30/2019 12:33 + +# Bureau of Prisons Psychology Services General Administrative Note + +"SENSITIVE BUT NCLASSIFIED" + +Inmate Name: EPSTEIN, JEFFREY EDWARD Reg #: 76318-054 + +Date of Birth: 01/20/1953 Sex: M F= cility: NYM Unit Team: 5 + +Date: 07/30/2019 12:01 Provider. PsyD + +## Comments + +Psych Observation Discontinuation Note: + +Please see "Clinical Contact" dated today. + +Completed by PsyD on 07/30/2019 12:33 + +# Bureau of Prisons "SENSITIVE BUT UNCLASSIFIED" Psychology Services + +# Clinical Intervention - Clinical Contact + +Inmate Name: EPSTEIN, JEFFREY EDWARD Date of Birth: 01/20/1953 Sex. M Facility: NYM Date: 07/31/2019 10:35 Provider: -PsyO/DAPC Reg #. 76318-054 Unit Team- 5 + +#### Focus of Session + +Mr. EPSTEIN was seen today by this writer for a follow up appointment after he was removed from Psychological Observation yesterday. + +### Subjective/Objective Presentation + +Mr. EPSTEIN presented in a pleasant mood and reported he is generally doing well. He stated, "I could be tter," but acknowledged he is doing as well as can be expected given his circumstances. He reported he is going to Court today for a status hearing. He stated he generally slept well last night and is readjusting to being placed back in SHU. He reported getting along well with his cell mate. He was Informed of appropriate procedures for contacting Psychology staff while he is in SHU, if needed. + +Current Mental Status: Mr. EPSTEIN was alert and oriented. He was polite, calm, and cooperative in demeanor. He exhibited a neutral affect with appropriate range. Eye contact and hygiene were appropriate. He spoke witlli normal rate, tone, and volume. His thoughts were organized and coherent, with no loosening of associations or tangenyal, circumstantial, a irrelevant content. There was no evidence of perceptual disturbance, delusional ideation,,or a formal thought disorder. He did not engage in any bizarre or inappropriate behavior. He noted having normal sleeping and eating habits. Mr. EPSTEIN explicitly denied recent and current suicidal ideation, planning, and intent. He was futureoriented and expressed a commitment to life and safety, agreeing to contact staff immediately should he experience suicidal ideation or psychological distress. He also denied thoughts of harming others. + +## interventionist + +Supportive interventions and cognitive behavioral therapeutic techniques were utilized. Mr. EPSTEIN was receptive to all interventions. + +## Progress/Plan + +Mr. EPSTEIN was educated about both routine and emergency procedures for contacting psychology. There appears to be no need for follow-up at this time and he expressed willingness to self refer to psychology staff if needed. He will continue to be seen during routine SHU rounds and SHU reviews while he is housed in SHU. He was encouraged to reach out for PRN services should he experience any psychological distress. I + +Completed beD/DAPC on 07/31/2019 10:56 + +# Bureau of Prisons "SENSITIVE BUT UNCLASSIFIED\*\* Psychology Services Suicide Risk Assessment + +Inmate Name: EPSTEIN, JEFFREY EDWARD Reg X: 76318-054 I Date of Birth: 01/20/1953 Sex: M Facilit NYM Unit Team: 5 Date: 08/01/2019 13:29 Provider: PsyD + +Type of Housing: SHU- Administrative Segregation Cell Accommodation: Double-Cell + +#### FINDINGS + +This assessment and the resulting recommendations are based on the following sources of information: Clinical Interview, Medical Record, Psychology Data System, Sentry + +## Reason for Referral. + +R & D staff reported to this writer this morning at about 8:30 AM on 8/01/19 that yesterday when Mr. Epstein was brought back from court the US Marshals asked him to sign a form that noted Mr. Epstein has "suicidal tendencies." Mr. Epstein was seen for a Suicide Risk Assessment at about 1:00 PM on 8/01/19 in Attorney Conference. + +This note is being entered at about 4:20 PM on 8/01/19. + +### Mental Health History + +According to a Suicide Risk Assessment dated 7/09/19 by Dr. Inmate Epstein denied any history pf mental health treatment, either on an inpatient or outpatient basis. Inmate Epstein denied any treatment in the pest or present with psychotropic medication. He also denied any acute mental health symptoms at this time? + +### Self-Harm History + +According to a Suicide Risk Assessment dated 7/09/19 by Dr. 'Inmate Epstein denied any past or esent suicidal ideation, intention or plan. He denied ever engaging in any suicide attempts or self-injurious beh or in the past." + +According to this writer's Suicide Risk Assessment dated 7/23/19, "It is unclear at this time if he had pla around his neck or if someone else did." + +## Current erjahlem + +R & D staff reported to this writer this morning at about 8:30 AM on 8/01/19 that yesterday when Mr. Epstein was brought back from court the US Marshals asked him to sign a form that noted Mr. Epstein has "suicidal tendencies" This is likely due to the incident on 7/23/19, but as a precaution another Suicide Risk Assessment was conducted. + +Mr. Epstein seemed surprised that there was a form noting suicidal tendencies. He denied stating he wa8 suicidal. + +He said he saw the DHO today and he said his Incident report for the marks on his neck was expunged. He stated even though he has his cpap machine now, he said his cellmate talks at night and he stated this keeps him upi This writer offered to talk to the SHU Lt. to have him housed with a different cellmate, but he stated he wants to give it 3 to 4 days to see if he wants a different cellmate. He complained about the noise in SHU. + +#### Current Mental Status, + +Level of Consciousness: Alert and Oriented + +Psychomotor Activity: Normal + +General Appearance: Normal + +Behavior: Cooperative + +Mood: Appropriate to Content + +Thought Process: Goal Directed + +Thought Content: Normal + +Inmate Name: EPSTEIN, JEFFREY EDWARD Reg #: 76318-054 + +Date of Birth: 01/20/1953 Sex: M Facility NYM Unit Team: 5 + +Date: 08/01/201913:29 Provider I PsyD + +coherent, with no loosening of associations or tangential, circumstantial or irrelevant speech. Auditory and visual hallucinations were denied, and delusions were not elicited. He did not engage in any bizarre or inappropriat behavior. He denied current suicidal or self harm ideation and he agreed to immediately tell staff if he starts to have suici I or self harm 4 thoughts. He was future oriented. He does not appear to be an immediate danger to self. He denied though of hurting others and he agreed to tell staff if he has these thoughts. + +#### RISK AND PROTECTIVE FACTORS ASSESSED. + +This writer screened the inmate for a variety of empirically validated factors commonly associated with risk for self-harm and suicide. + +The following STATIC risk factors were assessed to be present and increase the Inmate's risk for engaging in suicide related behaviors: High Profile Crime. Lack of family connections, Sex offender status + +The following DYNAMIC risk factors were assessed to be present and increase the inmate's risk for engaging n suicide related behaviors: Current physical pain, Sleep problems + +The following PROTECTIVE factors were assessed to be present and may decrease the inmate's risk of sul e:Able to identify reasons to live, Denial of suicidal ideation/intention/plans, Future orientation, Religious beliefs against suicide, Supportive family relationships, View of death as negative, Willingness to engage in treatment + +Risk Factors: He was found by staff in his cell in SHU on 7/23/19 with a string loosely tied around his neck, which Mr. Epstein stated he did not remember anything about. It is still unclear at this time if Mr. Epstein had placed the string around his own neck or if someone else did. He has a high profile sex offense case. He stated his lower back hurts and he stated Medical is aware of this. He stated he has difficulty sleeping even with his cpap machine because he stated his cellmate talks at night. + +Protective Factors: He denied current suicidal or self harm thoughts and agreed to tell staff if he starts to have these thoughts. He had denied a history of self harm and suicide attempts. He had denied a family history of suicidal and self farm attempts. He had denied having any chronic medical conditions. He denied feeling hopeless. He had denied a history of childhood abuse. He denied fearing for his safety at this time. He denied feeling like a burden to anyone. He stated he lives for and lans to finish this case and to go back to his normal life. He said his friends and Lawyers are emotionally supportive. He said is Jewish and he said in his religion suicide Is against the religion. + +Overall, his current protective factors override his risk factors for suicidality. He is currently psychologically stable. He denied feeling hopeless. He is reporting positive future plans and reasons to live for. He said he has social supports the community and his Lawyers visit him often. He denied any current suicidal or self harm ideation, intention or plan. Suicl Watch is not indicated at this time. + +### DIAGNOSIS. + +No Diagnosis. No Dx - Current + +## CONCLUSIONS + +The Overall Acute Suicide Risk for this Inmate is: Low + +Overall Chronic Suicide Risk for this Inmate is: Absent + +#### RECOMMENDATIONS + +- 1. Suicide Watch is not indicated at this time. +- 2. Supportive and educative interventions were provided. +- 3. He was educated about both routine and emergency procedures for contacting Psychology staff. +- 4. He will be seen in follow up by Psychology next week to monitor his mental status and to provide further Intervention if needed. +- 5. In the meantime, he was encouraged to self-refer to Psychology if needed to which he agreed and seems capable of doing. +- 6. If he remains in SHU, he will be seen by Psychology in SHU Rounds and in SHU Reviews. + +Suicide Watch: A suicide watch Is not warranted at this time + +Inmate Name: EPSTEIN. JEFFREY EDWARD + +Date of Birth: 01/20/1953 Sex: M F II : NYM + +Date: 08/01/201913:29 Provider. PsyD + +Reg #: 76318-054 + +Unit Team: 5 + +Completed by PsyD on 08/01/2019 16:21 + +## Bureau of Prisons "SENSITIVE BUT UNCLASSIFIED" Psychology Services + +## Clinical Intervention - Clinical Contact + +Inmate Name: EPSTEIN, JEFFREY EDWARD + +Date of Birth: 01/20/1953 Sex: M Facility: NYM + +Date: 08/08/2019 10:02 Provider hD/Chief + +Reg # 76318-054 + +Unit Team 5 + +#### focus of Session + +Inmate Epstein was seen today for a follow-up session in SHU. + +#### Subjective/Objective Presentation + +Inmate Epstein stated he is feeling okay and has been eating his meals. He reported his sleep as "fair a would like to go the general population. He denied any mental health symptoms at this time and denied any feelings of depression and/or anxiety. Inmate Epstein denied any suicidal ideation, intention, or plan. He currently has a cellmate and appears to interact with him. Inmate Epstein continues to spend his days and evening with his attomey's in the attorney conference room. He told this writer he received his PAC number to make phone calls. Inmate Epstein indicated he has only had a couple of phone calls over the speaker phone and wondered if that counted" as his monthly phone contact. He also reported he his missing some books he was reading in the suicide watch area prior to returning to the SHU. + +Other than complaints about the prison and concerns regarding his housing, he had no mental health concerns today. He did not appear to be in any distress and the SHU Staff have not reported any unusual behaviors on his part. + +#### InterventIonfsi + +Inmate EPSTEIN was provided with brief supportive interventions and psychoeducation regarding additional coping strategies. Inmate EPSTEIN was receptive to these interventions. + +#### Progress/Plan + +Inmate EPSTEIN was educated about both routine and emergency procedures for contacting Psychology staff. He was reminded of the self-help books and audiotapes available through the Psychology department. There appears to be no need for follow up at this time. 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PsyD/PhD + +Reg #: 76318-054 + +Unit Team: A8O + +## Limits of Confidentiality + +Limits of confidentiality were reviewed with inmate EPSTEIN. He expressed an understanding of the limits of confidentiality and consented to be interviewed accordingly. + +## Data Source(s) + +The following data sources were reviewed in conjunction with this Initial Intake Evaluation: Self-Report, SENTRY, Staff Observation. + +Inmate Epstein is a 66-year-old, Black male who was seen by Psychology Services due to newly arriving at MCC-NY. He denied a history of mental health treatment on his Psychology Services Intake Questionnaire. + +## Mental Health History and Current Symptoms + +No history of mental health issues was noted. + +No history of prior mental health treatment was noted. + +No current mental health symptoms were noted. + +No suicidal ideation, attempts. or self-harm were noted. + +## Substance Abuse + +No history of substance abuse was noted. + +No history of substance abuse treatment was noted. + +## Sex Offenses + +No sexual offense convictions were noted. + +No history of sexual predation in a correctional setting was noted. + +# Relevant Psychosocial History + +Noteworthy psychosocial issues: Other. + +Inmate Epstein is currently incarcerated for a Sex Trafficking. He stated he was previously incarcerated three months for prostitution. Inmate Epstein stated he is single and does not have any children. He revealed he was hiving in New York. He stated he completed high school. He stated he was employed in banking work prior to his incarcer+on. + +### Adjustment to Incarceration + +Adjustment to incarceration concerns were identified: Other. + +## SEXUAL ABUSE HISTORY + +Inmate Epstein denied being the victim of physical or sexual abuse. He is currently charged with sex trafficking and has previously been charged with prostitution. He was informed of the programs offered by MCC-NY as well as the Bureau of Prisons. Additionally, he was informed of this institutions self-help program. Inmate Epstein reported he was not currently interested in any treatment programs. + +## MENTAL STATUS: + +Inmate Epstein appeared calm, controlled, without signs of psychomotor agitation or retardation. He was fully cooperative, maintained good eye-contact, and related in an interpersonally appropriate manner with Interviewer. Speech and thought processes were organized, coherent, logical, and goal-directed. + +Based on informal assessment during this interview, this Inmate's cognitive functioning appeared within normal limits, as reflected by adequate long and short-term memory, good attention, and appropriate concentration during interview, as well as adequate receptive and expressive language skills. Inmate denied any current sleep disturbances and described his appetite as adequate. + +This inmate denied recent or present morbid thoughts, passive or active suicidal ideation, intent or plan and contracted for safety. This inmate's verbalizations were optimistic, future oriented, and without indications of helpless or hopeless thinking. Inmate Brown denied any familial history of suicide behaviors or attempts. + +This inmate was provided with supportive psychotherapy, and psycho-education to strengthen coping skills and facilitate adjustment to incarceration. + +#### Findings + +Inmate Name: EPSTEIN, JEFFREY EDWARD + +Date of Birth: 01120/1953 Sex: M fi tila YM + +Date. 07/08/2019 09:24 Provider: . PsyD/PhD + +Inmate EPSTEIN denied any history of mental health symptoms or treatment. He denied any current mental health symptoms. He does not meet criteria for any current psychological diagnosis. He meets criteria for Mental Health Care Code 1. + +CARE1-MH is indicative of an inmate who shows no significant level of functional impairment associated with a mental illness and demonstrates no need for regular mental health intervention. + +### Recommendations + +The following psychological services are recommended: Other. + +Inmate EPSTEIN was educated about both routine and emergency procedures for contacting Psychology staff. He does not appear to be in distress at this time. He agreed to contact psychology if he feels he needs psychology services in the future. He meets criteria for CC1 and does not require scheduled follow up at this time. + +Completed by PsyD/PhD on 07/08/2019 09:30 + +Reg \*1: 78318-054 + +Unit Team: MO + +# Bureau of Prisons Psychology Services Risk of Sexual Abusiveness + +"SENSITIVE BUT UNCLASSIFIED\*\* + +Inmate Name: EPSTEIN, JEFFREY EDWARD Reg #: + +Date of Birth: 01/20/1953 Sex- M Facility: NYM Unit Team + +Date: 07/08/2019 09:35 Provider. . PsyD/PhD + +76318-054 + +MO + +# Comments + +#### Risk of Sexual Abusiveness + +Dunng the intake screening process, for Inmate Epstein, based on the documentation available at the time of the screening, and Inmate Epstein's self-report, he was identified as being at risk for sexual abusiveness due to previous perpetration of sexual abuse in the community or In an institutional setting, as evidenced by the following objective criteria: + +( ) Having a history of prior institutional violence or sexual abuse perpetration (X ) Having a history of prior sexual abuse perpetration in the community (X ) Having prior convictions of violent offenses + +As required by P5324.11, Sexually Abusive Behavior Prevention and Intervention, Inmate Epstein was se by Psychology on todays date to assess his risk factors for sexual abusiveness. At the onset of this clinical the inmate was informed about the BOP requirements regarding PREA. Inmate Epstein indicated he understands the institution's policy against engaging in sexual behavior. His risk factors for sexual abusiveness were asse ed and include: + +( ) History of prior sexual victimization in prison ( X ) History of prior prison sexual predation ( ) History of head Injury with loss of consciousness ( ) History of childhood psychological, physical, sexual abuse ( )1Mtnessed family violence ( ) Antisocial Personality Disorder traits of irritability/aggressiveness and recklessness ( ) Hypersexuality (defined by eight or more orgasms a week prior to prison) ( ) Hypermasculinity ( ) Other: + +Based on this clinical assessment, the inmate is considered to be at + +(X ) Low Risk of Abusiveness at this facility (Note: Even though this inmate is judged to be at low risk of sexual abusiveness, an unforeseen change in risk factors may significantly alter his risk level.). Programming recommendations included sex offender treatment. Inmate Epstein declined programming recommendations.The inmate understands the procedure for contacting Psychology for routine or emergent services. + +( ) Moderate Risk of Abusiveness. The Unit Team and Correctional Staff have been notified regarding Psychology staff's recommendation that he not be housed in a cell with any inmates identified as at Increased risk for sexual victimization. Psychology also recommends a greater level of supervision regarding his work and education assignments. Programming recommendations include XXXXX. Inmate =inmateLastName is agreeable to! declined programming recommendations. + +( ) High Risk of Abusiveness. It is recommended this inmate be housed in the Special Housing Unit in accordance with P5324.11 to "keep separate those inmates at high risk of being sexually victimized from those at high risk of being sexually abusive until Correctional Services and Correctional Programs staff can assess his appropriateness for general population at this facility. This inmate should not be housed with any inmates judged to be at an increased risk for sexual victimization. Programming recommendations include XXXXX Inmate =inmateLastName is agreeable to/ declined programming recommendations. + +Inmate Name: EPSTEIN, JEFFREY EDWARD Nag #: 76318-054 + +Date of Birth: 01/20/1953 Sex: NYM Unit Tan MO + +Date: 07/08/201909:35 Provider: . PsyD/PhO + +Completed by PsyD/PhD on 07/08/2019 09:41 + +# Bureau of Prisons Psychology Services General Administrative Note + +"SENSITIVE BUT UNCLASSIFIED" + +Inmate Name: EPSTEIN, JEFFREY EDWARD + +Date of Birth: 01/20/1953 Sex: NYM + +Date: 07/08/2019 10:41 Provider: 'hD/Chief + +Reg it. 76318-054 + +Unit Team.' A&O + +#### Comments + +This writer consulted with Drn Central Office, regarding inmate Epstein. Inmate Epstein has various risk factors for suicidality including a high profile case with media attention, sex offense charges, pre-trial status and a court proceeding today which could potentially be giving him bad news regarding his legal situation. As such, whim inmate Epstein returns from court, R&D staff as well as Lieutenants have been informed to immediately notify the psychology department. If he returns after duty hours, the aforementioned staff were instructed to notify the on-call psichologIst and to place inmate Epstein on a watch status until psychology can conduct a thorough suicide risk assessment + +Completed aPhD/Chief Psychologist on 07/08/2019 10:49 \ No newline at end of file diff --git a/marker2/ds9/EFTA00089129/EFTA00089129.metadata.json b/marker2/ds9/EFTA00089129/EFTA00089129.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..6433ae90d3245893452e0dd4ec5a1ece5fcb847e --- /dev/null +++ b/marker2/ds9/EFTA00089129/EFTA00089129.metadata.json @@ -0,0 +1,582 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089129.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 5, + "chars": 9037, + 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0000000000000000000000000000000000000000..595d26948595ec1013c648b775d995ac2a5d0e08 --- /dev/null +++ b/marker2/ds9/EFTA00089134/EFTA00089134.md @@ -0,0 +1,23 @@ +To: + +Cc: + +Subject: US v Epstein + +Date: Mon, 12 Aug 2019 12:54:55 +0000 + +MI first if the emails regarding Mr. Epstein's death and our preservation/production requests on behalf of his family should be sent to another prosecutor ad the name of but not the full name) please advise. We would ask you to confirm the request sent to you yesterday has been forwarded. We also request that DNA be lifted from the ligatures and/or bed stripping found in Mr Epstein's MCC cell on August 10, 2019. + +Separately, since the attorney client privilege survives death, we are still requesting a taint review in the event any review at all of his emails from the seizures at Teterboro on Aug 6 or from his NYC residence are to be undertaken. If you provide me with the name of the taint attorney when selected, I will provide a list of attorneys. + +Lastly, is it the Government's intention to move to dismiss the Indictment against Mr. Epstein and if so will that occur today? + +Thanks, Marty + +Martin G. Weinberg, Esq. + +Boston, MA 02116 + +O:Ice Ma C + +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. \ No newline at end of file diff --git a/marker2/ds9/EFTA00089134/EFTA00089134.metadata.json b/marker2/ds9/EFTA00089134/EFTA00089134.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..6844f0804b781c1bd87eeea05d503cfba615c952 --- /dev/null +++ b/marker2/ds9/EFTA00089134/EFTA00089134.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089134.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1350, + "elapsed_seconds": 0.69, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 47 + ], + [ + "Line", + 24 + ], + [ + "Text", + 14 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089134" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089135/EFTA00089135.md b/marker2/ds9/EFTA00089135/EFTA00089135.md new file mode 100644 index 0000000000000000000000000000000000000000..35e71495e756eaf55e8ec955c86263950dec7b1c --- /dev/null +++ b/marker2/ds9/EFTA00089135/EFTA00089135.md @@ -0,0 +1,55 @@ +**To:** + +**Cc:** + +**Subject:** RE: + +**Date:** Tue, 13 Aug 2019 18:56:23 +0000 + +--- + +Thank you, we greatly appreciate it. + +**From:** + +**Sent:** Tuesday, August 13, 2019 2:55 PM + +**To:** + +**Cc:** + +**Subject:** RE: + +Thanks, + +[REDACTED] + +[REDACTED] + +Southern District of New York + +[REDACTED] + +**From:** + +**Sent:** Tuesday, August 13, 2019 2:41 PM + +**To:** + +**Subject:** Fwd: + +Begin forwarded message: + +**From:** + +**Date:** August 13, 2019 at 2:23:10 PM EDT + +**To:** + +**Cc:** + +**Subject:** + +Hi + +Assistant United States Attorney Southern District of New York \ No newline at end of file diff --git a/marker2/ds9/EFTA00089135/EFTA00089135.metadata.json b/marker2/ds9/EFTA00089135/EFTA00089135.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..2e145893f7782a121f9f5665e09157b3a5b240fc --- /dev/null +++ b/marker2/ds9/EFTA00089135/EFTA00089135.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089135.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 552, + "elapsed_seconds": 4.59, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 59 + ], + [ + "Span", + 51 + ], + [ + "Line", + 26 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 7 + ], + [ + "Text", + 5 + ], + [ + "Line", + 4 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089135" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089137/EFTA00089137.md b/marker2/ds9/EFTA00089137/EFTA00089137.md new file mode 100644 index 0000000000000000000000000000000000000000..3c1cdf62972f9081b532f4e9e256820ef2fcedd9 --- /dev/null +++ b/marker2/ds9/EFTA00089137/EFTA00089137.md @@ -0,0 +1,156 @@ +**From:** "[REDACTED]" <[REDACTED]> +**To:** "[REDACTED]" <[REDACTED]>, "[REDACTED]" +<[REDACTED]> +**Subject:** RE: SDNY Grand Jury Subpoena Dated July 5, 2019 issued to [REDACTED] +**Date:** Tue, 13 Aug 2019 20:54:58 +0000 + +--- + +Those times work for me, thanks. + +-----Original Message----- + +**From:** [REDACTED] <[REDACTED]> +**Sent:** Tuesday, August 13, 2019 4:50 PM +**To:** [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> +**Subject:** FW: SDNY Grand Jury Subpoena Dated July 5, 2019 issued to [REDACTED] [REDACTED] + +I'm pretty full tomorrow with trial prep -- meetings with witnesses 10-12, 1-1:30, and 3-5. I could do 2:00 tomorrow, or after 5:00; or I also could do anytime on Thursday. + +-----Original Message----- + +**From:** Bloom, Suzanne Jaffe <[REDACTED]> +**Sent:** Tuesday, August 13, 2019 16:24 +**To:** [REDACTED] <[REDACTED]> +**Cc:** Hudgens, Johanna Rae <[REDACTED]>; [REDACTED] <[REDACTED]>; +[REDACTED] <[REDACTED]> +**Subject:** Re: SDNY Grand Jury Subpoena Dated July 5, 2019 issued to [REDACTED] [REDACTED] + +Are you available for a call tomorrow at 12:45? If so, we will send a dial in. Many thanks. + +Suzanne Jaffe Bloom + +Partner + +Winston & Strawn LLP + +200 Park Avenue +New York, NY 10166-4193 + +[REDACTED] +[REDACTED] + +Bio<> | +VCard<> | Email<[mailto:\[REDACTED\]](mailto:[REDACTED])> | +winston.com<> + +On Jul 30, 2019, at 1:54 PM, [REDACTED] +<[REDACTED] wrote: + +We should all be around, but for convenience you can have security let me know when you arrive. Looking forward to speaking with you both at 9:30 tomorrow. + +thanks, + +Original Message + +From: Hudgens, Johanna Rae cta> + +Sent: Tuesda Jul 30 2019 13:22 + +To: + +Bloom Suzanne Jaffe • mailto: + +Cc: I mailto: mailto: + +Subject: RE: SDNY Grand Jury Subpoena Dated July 5, 2019 issued to + +I am writing to confirm our meeting with you tomorrow at 9:30 a.m. Whom should we ask for when we arrive? + +Thank you, + +Johanna + +Johanna Rae Hudgens + +Associate Attorney + +Winston & Strawn LLP + +Pronouns: she, her, hers + +Please consider the environment before printing this e-mail. + +Original Message + +From: --mailto: + +Sent: Wednesday, July 24, 2019 2:32 PM + +To: Bloom, Suzanne Jaffe mailto: + +Cc: Hudgens, Johanna Rae --mailto: + +Subject: RE: SDNY Grand Jury Subpoena Dated July 5, 2019 issued to + +Suzanne, + +Following up on the below and our brief conversation this afternoon, you're absolutely correct that I had said we'd send transcripts of the court proceedings thus far; they are attached. + +You also had asked about additional information about written or otherwise recorded messages from (or in connection with, or referencing) victims. While we're not currently in a position to provide additional detail about those particular records (in terms of identifying information on those records themselves), we can give you related information that is more specific and I think may be more helpful. Separate from the messages, we have contemporaneous telephone records, including records from a cell phone that was registered to your client, in her name -- those cell phone records reflect numerous phone contacts with multiple girls who were underage at the time of the calls. + +Ori inal Messa e + +From: + +Sent: Tuesday, July 23, 2019 14:55 + +To: Bloom, Suzanne Jaffe mailto + +Cc: Hudgens, Johanna Rae mailto: + +mailto: + +Subject: RE: SDNY Grand Jury Subpoena Dated July 5, 2019 issued to + +Suzanne, + +Following up on our conversations last week and yesterday, and in response to your email, we are available to meet with you and Johanna next week. Given our continued discussions, and the possibility of a voluntary interview with Ms. we can confirm the understanding that we are able to hold in abeyance the grand jury appearance date of July 24, 2019, until further notice. + +As we covered on the phone yesterday, you should feel free to reach out to any of us on the team if you have any questions as you meet with your client, and thank you in advance for copying all of our team on email communications, as we also discussed. I think I also said that we would send you the docket numbers of the primary civil cases, which are 15 Civ. 7433 (RWS) (SDNY), 17 Civ. 616 (JGK) (SDNY), and 08 Civ. 80736 (SDFL) (the CVRA litigation). I believe there are also a number of docketed civil cases involving Mr. Epstein in federal court in Florida, and there may also be additional state cases. + +Separately, I don't recall if I said we would send this, but in case it is useful for your consideration, attached is an example of our standard proffer agreement. + +In terms of scheduling, next week we are available at 2:30 on Monday; anytime on Tuesday except for 12:30 to 1:30; and at either 9:30 a.m. or 5:00 p.m. on Wednesday, due to a court conference and other meetings during the day. + +Please let us know if we're forgetting anything or if any additional information would be useful, and we look forward to being in touch soon. + +Original Message + +From: Bloom, Suzanne Jaffe al cmailto:a> + +Sent: Monda Jul 22, 2019 12:32 + +To: mailto: + +Cc: Hudgens, Johanna Rae • mailto: + +Subject: SDNY Grand Jury Subpoena Dated July 5, 2019 issued to + +Hi . Thank you again for your time on the phone last week. I'm following up on our conversation. First, I'm writing to confirm that we have now been formally retained in connection with the above-referenced matter. Second, we are available to meet with you on July 29 at 2 pm. Please let us know whether that date and time works for you. Finally, I want to confirm our understanding that the July 24, 2019 appearance date listed in the above-referenced grand jury subpoena has been adjourned and no appearance is required on that date. + +Best, Suzanne + +Suzanne Jaffe Bloom + +Partner + +Winston & Strawn LLP + +200 Park Avenue New York, NY 10166-4193 + +Bio + +VCard I Email + +The contents of this message may be privileged and confidential. If this message has been received in error, please delete it without reading it. Your receipt of this message is not intended to waive any applicable privilege. Please do not disseminate this message without the permission of the author. 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Thanks. + +**From:** Bloom, Suzanne Jaffe <[REDACTED]> + +**Sent:** Tuesday, August 13, 2019 20:23 + +**To:** [REDACTED] <[REDACTED]> + +**Cc:** Hudgens, Johanna Rae <[REDACTED]>; [REDACTED] + +<[REDACTED]>; [REDACTED] + +<[REDACTED]> + +**Subject:** RE: SDNY Grand Jury Subpoena Dated July 5, 2019 issued to [REDACTED] + +I think that for purposes of tomorrow, 20 minutes should be fine. Thanks. + +Suzanne Jaffe Bloom + +Partner + +Winston & Strawn LLP + +[REDACTED] + +[REDACTED] + +[REDACTED] + +Bio<> | + +VCard<> | Email<[mailto:\[REDACTED\]](mailto:[REDACTED])> | + +winston.com<> + + + +**From:** [REDACTED] + +<[REDACTED]> + +**Sent:** Tuesday, August 13, 2019 8:21 PM + +Suzanne, + +We have obligations at 3:00, so if you think our conversation is likely to take 20 minutes or less, we can do 2:30, otherwise to give ourselves sufficient time we would prefer to do anytime 5:00 or later tomorrow or anytime at all on Thursday. + +thanks, + +[REDACTED]. + +From: Bloom, Suzanne Jaffe <[REDACTED]> + +Sent: Tuesday, August 13, 2019 20:16 + +To: [REDACTED] <[REDACTED]> + +Cc: Hudgens, Johanna Rae <[REDACTED]>; [REDACTED] + +[REDACTED] <[REDACTED]>; [REDACTED] + +<[REDACTED]> + +Subject: RE: SDNY Grand Jury Subpoena Dated July 5, 2019 issued to [REDACTED] + +Can we do 2:30? + +Suzanne Jaffe Bloom + +Partner + +Winston & Strawn LLP + +[REDACTED] + +[REDACTED] + +[REDACTED] + +Bio<> | + +VCard<> | Email | + +winston.com<> + + + +From: [REDACTED] + +<[REDACTED]> + +Sent: Tuesday, August 13, 2019 6:22 PM + +To: Bloom, Suzanne Jaffe <[REDACTED]> + +Cc: Hudgens, Johanna Rae <[REDACTED]>; [REDACTED] + +[REDACTED] <[REDACTED]>; [REDACTED] + +<[REDACTED]> + +Subject: RE: [REDACTED] + +Suzanne, + +Unfortunately we're a little over-scheduled tomorrow – we could do 2:00 tomorrow, or after 5:00. Alternatively, we could do any time on Thursday. What would you prefer? + +Sent: Tuesday, August 13, 2019 17:34 + +To: [REDACTED] <[REDACTED]> + +Cc: Hudgens, Johanna Rae <[REDACTED]>; [REDACTED] + +[REDACTED] <[REDACTED]>; [REDACTED] + +<[REDACTED]> + +Subject: RE: [REDACTED] + +Actually – I mistyped. How is 12:15? + +Suzanne Jaffe Bloom + +Partner + +Winston & Strawn LLP + +[REDACTED] + +[REDACTED] + +[REDACTED] + +Bio<> | + +VCard<> | Email<[mailto:\[REDACTED\]](mailto:[REDACTED])> | winston.com<> + + + +From: Bloom, Suzanne Jaffe <[REDACTED]> + +Sent: Tuesday, August 13, 2019 4:24 PM + +To: [REDACTED] + +<[REDACTED]> + +Cc: Hudgens, Johanna Rae <[REDACTED]>; [REDACTED] + +[REDACTED] <[REDACTED]>; [REDACTED] + +<[REDACTED]> + +Subject: Re: SDNY Grand Jury Subpoena Dated July 5, 2019 issued to [REDACTED] + +Are you available for a call tomorrow at 12:45? If so, we will send a dial in. Many thanks. + +Suzanne Jaffe Bloom + +Partner + +Winston & Strawn LLP + +[REDACTED] + +[REDACTED] + +[REDACTED] + +VCard<> | Email<[mailto:\[REDACTED\]](mailto:[REDACTED])> | winston.com<> + +On Jul 30, 2019, at 1:54 PM, [REDACTED] +<[REDACTED]> wrote: +Johanna, + +We should all be around, but for convenience you can have security let me know when you arrive. Looking forward to speaking with you both at 9:30 tomorrow. + +thanks, +[REDACTED]. + +-----Original Message----- + +From: Hudgens, Johanna Rae <[REDACTED]> +Sent: Tuesday, July 30, 2019 13:22 +To: [REDACTED] <[REDACTED]>; +Bloom, Suzanne Jaffe <[REDACTED]> +Cc: [REDACTED] <[REDACTED]>; [REDACTED] +<[REDACTED]> +Subject: RE: SDNY Grand Jury Subpoena Dated July 5, 2019 issued to [REDACTED] + +[REDACTED], [REDACTED], [REDACTED], + +I am writing to confirm our meeting with you tomorrow at 9:30 a.m. Whom should we ask for when we arrive? + +Thank you, +Johanna + +Johanna Rae Hudgens +Associate Attorney +Winston & Strawn LLP +[REDACTED] + +Pronouns: she, her, hers +Please consider the environment before printing this e-mail. + +-----Original Message----- + +From: [REDACTED] <[REDACTED]> +<[REDACTED]> +Sent: Wednesday, July 24, 2019 2:32 PM +To: Bloom, Suzanne Jaffe <[REDACTED]> +Cc: Hudgens, Johanna Rae <[REDACTED]>; [REDACTED] +[REDACTED] <[REDACTED]>; [REDACTED] +<[REDACTED]> +Subject: RE: SDNY Grand Jury Subpoena Dated July 5, 2019 issued to [REDACTED] + +Suzanne, + +Following up on the below and our brief conversation this afternoon, you're absolutely correct that I had said we'd send transcripts of the court proceedings thus far; they are attached. + +You also had asked about additional information about written or otherwise recorded messages from (or in connection with, or referencing) victims. While we're not currently in a position to provide additional detail + +about those particular records (in terms of identifying information on those records themselves), we can give you related information that is more specific and I think may be more helpful. Separate from the messages, we have contemporaneous telephone records, including records from a cell phone that was registered to your client, in her name -- those cell phone records reflect numerous phone contacts with multiple girls who were underage at the time of the calls. + +thank you, + +[REDACTED] + +-----Original Message----- + +From: [REDACTED] + +Sent: Tuesday, July 23, 2019 14:55 + +To: Bloom, Suzanne Jaffe <[REDACTED]> + +Cc: Hudgens, Johanna Rae <[REDACTED]>; [REDACTED] +[REDACTED] <[REDACTED]>; [REDACTED] + +<[REDACTED]> + +Subject: RE: SDNY Grand Jury Subpoena Dated July 5, 2019 issued to [REDACTED] + +Suzanne, + +Following up on our conversations last week and yesterday, and in response to your email, we are available to meet with you and Johanna next week. Given our continued discussions, and the possibility of a voluntary interview with Ms. [REDACTED], we can confirm the understanding that we are able to hold in abeyance the grand jury appearance date of July 24, 2019, until further notice. + +As we covered on the phone yesterday, you should feel free to reach out to any of us on the team if you have any questions as you meet with your client, and thank you in advance for copying all of our team on email communications, as we also discussed. I think I also said that we would send you the docket numbers of the primary civil cases, which are 15 Civ. 7433 (RWS) (SDNY), 17 Civ. 616 (JGK) (SDNY), and 08 Civ. 80736 (SDFL) (the CVRA litigation). I believe there are also a number of docketed civil cases involving Mr. Epstein in federal court in Florida, and there may also be additional state cases. + +Separately, I don't recall if I said we would send this, but in case it is useful for your consideration, attached is an example of our standard proffer agreement. + +In terms of scheduling, next week we are available at 2:30 on Monday; anytime on Tuesday except for 12:30 to 1:30; and at either 9:30 a.m. or 5:00 p.m. on Wednesday, due to a court conference and other meetings during the day. + +Please let us know if we're forgetting anything or if any additional information would be useful, and we look forward to being in touch soon. + +[REDACTED] + +-----Original Message----- + +From: Bloom, Suzanne Jaffe <[REDACTED]> + +Sent: Monday, July 22, 2019 12:32 + +To: [REDACTED] <[REDACTED]> + +Cc: Hudgens, Johanna Rae <[REDACTED]> + +writing to confirm that we have now been formally retained in connection with the above-referenced matter. Second, we are available to meet with you on July 29 at 2 pm. Please let us know whether that date and time works for you. Finally, I want to confirm our understanding that the July 24, 2019 appearance date listed in the above-referenced grand July subpoena has been adjourned and no appearance is required on that date. + +We look forward to hearing back from you regarding the above. Many thanks. + +Best, Suzanne + +Suzanne Jaffe Bloom + +Partner + +Winston & Strawn LLP + +200 Park Avenun-apple-data-detectors://0/1> New York, NY 10166-4193 + +Bio VCard I Emailchttp://www.winston.com/> + +The contents of this message may be privileged and confidential. If this message has been received in error, please delete it without reading it. Your receipt of this message is not intended to waive any applicable privilege. Please do not disseminate this message without the permission of the author. Any tax advice contained in this email was not intended to be used, and cannot be used, by you (or any other taxpayer) to avoid penalties under applicable tax laws and regulations. + +Suzanne Jaffe Bloom + +Partner + +Winston & Strawn LLP + +200 Park Avenue New York, NY 10166-4193 + +Bio VCard I Email + +WINSTON &STRAWN UP \ No newline at end of file diff --git a/marker2/ds9/EFTA00089141/EFTA00089141.metadata.json b/marker2/ds9/EFTA00089141/EFTA00089141.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..b56d8aa36736ea7b1efdd3a0cf255a08fdd5773b --- /dev/null +++ b/marker2/ds9/EFTA00089141/EFTA00089141.metadata.json @@ -0,0 +1,234 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089141.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 7, + "chars": 10479, + "elapsed_seconds": 13.55, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 72 + ], + [ + "Span", + 64 + ], + [ + "Line", + 29 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 69 + ], + [ + "Span", + 63 + ], + [ + "Line", + 31 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 66 + ], + [ + "Span", + 57 + ], + [ + "Line", + 29 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 3, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 71 + ], + [ + "Text", + 48 + ], + [ + "Line", + 34 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 4, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 79 + ], + [ + "Text", + 48 + ], + [ + "Line", + 39 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 5, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 57 + ], + [ + "Line", + 29 + ], + [ + "Text", + 14 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 6, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 7 + ], + [ + "Line", + 4 + ], + [ + "Text", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089141" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089148/EFTA00089148.md b/marker2/ds9/EFTA00089148/EFTA00089148.md new file mode 100644 index 0000000000000000000000000000000000000000..6079aab745bdbc53bd5d1418efb912f1b32e741b --- /dev/null +++ b/marker2/ds9/EFTA00089148/EFTA00089148.md @@ -0,0 +1,19 @@ +To: + +Subject: If you would like to pass the information to the victims that asked or if you want me to pass it along. + +Date: Mon, 12 Aug 2019 21:15:03 +0000 + +From: + +Sent: on ay, ugus , : + +To: USANYS > + +Cc: + +Subject: RE + +am looping in my colleagues (VP, Mental Health Treatment) and (Clinical Director — Counseling Center.) Our Counseling Center has available slots, so perhaps you guys can all connect and see if that would be the right fit for the victims in the Epstein case. Thanks! + +Victim Witness Coordinator United States Attorney's Office Southern District of New York 1 St. Andrews Plaza New York New York 10007 Tel \ No newline at end of file diff --git a/marker2/ds9/EFTA00089148/EFTA00089148.metadata.json b/marker2/ds9/EFTA00089148/EFTA00089148.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..8a4d50d6757e2b0d3b4f347f5a7f69a8db1780dc --- /dev/null +++ b/marker2/ds9/EFTA00089148/EFTA00089148.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089148.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 623, + "elapsed_seconds": 0.73, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 43 + ], + [ + "Line", + 20 + ], + [ + "Text", + 14 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089148" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089149/EFTA00089149.md b/marker2/ds9/EFTA00089149/EFTA00089149.md new file mode 100644 index 0000000000000000000000000000000000000000..63cb84b3c76cd1fa78d00aadce84a8cd05961b98 --- /dev/null +++ b/marker2/ds9/EFTA00089149/EFTA00089149.md @@ -0,0 +1,91 @@ +**From:** "[REDACTED]" <[REDACTED]> +**To:** [REDACTED] <[REDACTED]>, [REDACTED] +**Subject:** FW: MCC Visit Thursday +**Date:** Wed, 14 Aug 2019 16:49:18 +0000 + +--- + +Resending, I got an error last time. + +--- + +**From:** [REDACTED] +**Sent:** Wednesday, August 14, 2019 12:41 PM +**To:** [REDACTED] <[REDACTED]>; [REDACTED] +**Cc:** [REDACTED] <[REDACTED]> +**Subject:** RE: MCC Visit Thursday + +Ed O'Callahan – Principal Deputy Attorney General + +[REDACTED] + +Geoffrey Berman – US Attorney + +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] + +--- + +**From:** [REDACTED] <[REDACTED]> +**Sent:** Wednesday, August 14, 2019 12:26 PM +**To:** [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> +**Cc:** [REDACTED] <[REDACTED]> +**Subject:** RE: MCC Visit Thursday + +Hi [REDACTED], + +Not a problem. I will add them to the list. Do you have everyone's titles? + +I will advise the Warden of the request that he accompany us on the tour. + +Thank you, + +[REDACTED] + +[REDACTED] +Supervisory Staff Attorney +CLC New York +Metropolitan Correctional Center +150 Park Row +New York, New York 10007 +[REDACTED] + +Two additional people from DO1 will join the visit: + +Ed O'Callahan + +In addition, Geoff has asked that the new acting warden join the tour. Let me know if you have any questions, thanks. + +From: Sent: Tuesday, August 13, 2019 4:03 PM To: Cc: Subject: RE: MCC Visit Thursday + +If it is not too much of an imposition, we ask that all visitors come to our front lobby for screening before admission. Thanks! + +Yes, thank you. Where should we go? > 8/13/2019 3:58 PM >> > + +From: Sent: Tuesday, August 13, 2019 3:38 PM To: Cc: Subject: Re: MCC Visit Thursday C + +Hi + +It should not be a problem. Does 10 am work for Mr. Berman and the rest of his staff? + +Thank you, + +Supervisory Staff Attorney CLC New York Metropolitan Correctional Center 150 Park Row New York, New York 10007 + +> 8/13/2019 2:05 PM >> > + +The list of visitors from our office is below: + +Geoffrey Berman + +As discussed, we would like to see the e d floor pscyh observation and suicide watch area; the 9th floor SHU, and Epstein's cell, which we understand to still be cordoned off. As discussed, we would appreciate if only MCC legal would escort us, and we will not speak to any of the guards present given the ongoing investigations. Please give me a call with any questions, and let us know what time and where we should go, and if it would be easier for us to enter via the 3rd floor bridge. + +Thanks, + +Assistant United States Attorney Southern District of New York Tel: \ No newline at end of file diff --git a/marker2/ds9/EFTA00089149/EFTA00089149.metadata.json b/marker2/ds9/EFTA00089149/EFTA00089149.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..1727c9d8bd49e4582b6a4b9fcd1689fbfaf2b815 --- /dev/null +++ b/marker2/ds9/EFTA00089149/EFTA00089149.metadata.json @@ -0,0 +1,114 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089149.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 2580, + "elapsed_seconds": 4.87, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 55 + ], + [ + "Line", + 27 + ], + [ + "Text", + 26 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 69 + ], + [ + "Line", + 31 + ], + [ + "Text", + 16 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 27 + ], + [ + "Line", + 10 + ], + [ + "Text", + 3 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089149" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089152/EFTA00089152.md b/marker2/ds9/EFTA00089152/EFTA00089152.md new file mode 100644 index 0000000000000000000000000000000000000000..21ebd2f0ba59421c9b3655aa69505472d116adbe --- /dev/null +++ b/marker2/ds9/EFTA00089152/EFTA00089152.md @@ -0,0 +1,56 @@ +**From:** [REDACTED] > +**To:** [REDACTED] > +**Cc:** [REDACTED] >, [REDACTED] >, [REDACTED] >, [REDACTED] [REDACTED] +[REDACTED] [REDACTED] + +**Subject:** Re: Certified Title Search and Certified Appraisal - Little St James Island + +**Date:** Wed, 14 Aug 2019 17:29:25 +0000 + +I really appreciate your reply. I know you folks are swamped and I will try not to be a pest. + +I will proceed in anticipation of going forward with real property forfeiture (where appropriate) , until advised to stop. + +Thanks! + +[REDACTED] +Squad C-40 (FAST) +Senior Financial Investigator (SFI) +([REDACTED]) +[REDACTED] + +--- + +**From:** [REDACTED] > +**Sent:** Wednesday, August 14, 2019 11:33:40 AM +**To:** [REDACTED] > +**Cc:** [REDACTED] >; [REDACTED] >; [REDACTED] >; [REDACTED] > +**Subject:** RE: Certified Title Search and Certified Appraisal - Little St James Island + +Hi [REDACTED], + +Thanks for checking in. As I'm sure you can imagine, there's a lot going on in the case and we're still sorting out next steps. We are not sure yet how we will decide to address the question of forfeiture, and that's an ongoing and complicated conversation we're having with our supervisors, including the chiefs of the forfeiture unit. We'll definitely let you know once we have a better sense of how we'd like proceed. It may be a little while before we know, so thanks in advance for understanding. + +Thanks, + +[REDACTED] + +--- + +**From:** [REDACTED] > +**Sent:** Wednesday, August 14, 2019 8:49 AM +**To:** [REDACTED] > +**Cc:** [REDACTED] > [REDACTED] +**Subject:** Certified Title Search and Certified Appraisal - Little St James Island + +Good morning, [REDACTED]. + +For the purposes of forfeiture, I am hoping that we get an indication (from [REDACTED]) as to whether SDNY is inclined to pursue Little St James Island. + +L.S.J. LLC was the previous owner. Epstein is/was the sole beneficial owner of both entities. + +Before we go ahead and order the certified title report and certified appraisal, it would be advisable to determine if the island will be forfeited in a civil action. + +Thanks. + +S uad C-40 FAST) Senior Financial Investigator (SFI) \ No newline at end of file diff --git a/marker2/ds9/EFTA00089152/EFTA00089152.metadata.json b/marker2/ds9/EFTA00089152/EFTA00089152.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..d3b4c3cd782915bf50eba56e9d436b70a4eec634 --- /dev/null +++ b/marker2/ds9/EFTA00089152/EFTA00089152.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089152.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2129, + "elapsed_seconds": 123.22, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 71 + ], + [ + "Text", + 41 + ], + [ + "Line", + 33 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 13 + ], + [ + "Line", + 7 + ], + [ + "Text", + 6 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089152" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089154/EFTA00089154.md b/marker2/ds9/EFTA00089154/EFTA00089154.md new file mode 100644 index 0000000000000000000000000000000000000000..3d4ddf4e201f6fcf9972c8d059b039abd60600a4 --- /dev/null +++ b/marker2/ds9/EFTA00089154/EFTA00089154.md @@ -0,0 +1,235 @@ +### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +x + +UNITED STATES OF AMERICA + +20 Cr. 330 (AJN) + +GHISLAINE MAXWELL, + +Defendant. + +x + +### THE GOVERNMENT'S MEMORANDUM IN OPPOSITION TO THE DEFENDANT'S RENEWED MOTION FOR RELEASE + +AUDREY STRAUSS Acting United States Attorney Southern District of New York Attorney for the United States of America + +![](_page_0_Picture_9.jpeg) + +Assistant United States Attorneys - Of Counsel - + +### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +x + +UNITED STATES OF AMERICA + +20 Cr. 330 (AJN) + +GHISLAINE MAXWELL, + +Defendant. + +x + +### THE GOVERNMENT'S MEMORANDUM IN OPPOSITION TO THE DEFENDANT'S RENEWED MOTION FOR RELEASE + +The Government respectfully submits this memorandum in opposition to the defendant's renewed motion for release on bail, dated December 8, 2020 (the "Renewed Bail Motion"). Five months ago, after thorough briefing and a nearly two-hour hearing, this Court concluded that the defendant posed a serious flight risk and that no condition or combination of conditions could ensure her appearance in court. The defense now asks this Court to reverse that finding by essentially repackaging its prior arguments and presenting a more specific bail package. However, at the July 14, 2020 bail hearing in this case, this Court rejected the defendant's request to keep the record open to allow the defendant to do precisely what she has done here—namely, present more detailed information about her finances and a more concrete package—determining that further information about her financial picture would be irrelevant because no combination of conditions could ensure this defendant's appearance. The Court's conclusion was plainly correct, and the Renewed Bail Motion does nothing to undermine it. The offense conduct outlined in the Indictment remains incredibly serious, the evidence against the defendant remains strong, and the defendant continues to have extensive financial resources and foreign ties, as well as the demonstrated ability to live in hiding for the long term. In short, the defendant poses an extreme + +flight risk, no condition or combination of conditions can reasonably ensure her appearance in this District, and the Court should not alter its prior finding to that effect. + +## BACKGROUND + +As detailed in the Indictment, the defendant is charged with facilitating the sexual abuse of multiple minor victims by Jeffrey Epstein between approximately 1994 and 1997. The defendant played a critical role in the scheme by helping to identify, entice, and groom minor girls to engage in sex acts with Epstein. The defendant's presence as an adult woman normalized Epstein's abusive behavior, and she even took part in at least some acts of sexual abuse. Together, the defendant and Epstein conspired to entice and cause minor victims to travel to Epstein's residences in different states, which the defendant knew and intended would result in their grooming for and subjection to sexual abuse. Then, in an effort to cover up her crimes, the defendant lied under oath during a civil deposition, including when asked about her interactions with minor girls. + +Based on that conduct, the Indictment charges the defendant in six counts. Count One charges the defendant with conspiring with Epstein and others to entice minors to travel to engage in illegal sex acts, in violation of 18 U.S.C. § 371. Count Two charges the defendant with enticing a minor to travel to engage in illegal sex acts, in violation of 18 U.S.C. §§ 2422 and 2. Count Three charges the defendant with conspiring with Epstein and others to transport minors to participate in illegal sex acts, in violation of 18 U.S.C. § 371. Count Four charges the defendant with transporting minors to participate in illegal sex acts, in violation of 18 U.S.C. §§ 2423 and 2. Counts Five and Six charge the defendant with perjury, in violation of 18 U.S.C. § 1623. + +On July 2, 2020, the Federal Bureau of Investigation ("FBI") arrested the defendant. Following extensive briefing, on July 14, 2020, the Court held a lengthy bail hearing. In its written and oral submissions, the defense urged the Court to release the defendant on bail. + +Among other things, the defense emphasized the defendant's family ties and residence in the United States (Dkt. 18 at 2, 3, 12), offered to hire a private security company to monitor the defendant (Id. at 20), noted that the defendant remained in the country and was in touch with the Government through counsel following Epstein's arrest (Dkt. 18 at 12-13; Tr. 49, 52-55), argued that the defendant went into hiding to avoid a media frenzy (Dkt. 18 at 14-16; Tr. 55-56), and argued that detention would hamper the ability to prepare a defense (Tr. 42, 67-69). Responding to the Government's concerns about the lack of transparency about the defendant's finances and six proposed co-signers, the defense specifically asked the Court to keep the proceedings open if the Court believed additional information or a more fulsome bond would be useful to the bail determination. (Tr. 52 ("And if the court determines that the conditions that we have proffered are insufficient or need further verification, as long as we can have some assurance of safety and confidentiality, we would recommend that the court keep the proceeding open, and we should be able to get whatever the court needs to satisfy it."); Tr. 59 ("Even if the court were to assume for purposes of today's proceeding that she has the means that the government claims she does, it does not affect the analysis. That is to be addressed in conditions, to be addressed if the court requires it, through verifications and further proceedings before the court."); Tr. 66 ("If the court desires to leave the proceeding open for a week and allow us to come back, if the court has concerns about the number of suretors, for example, verification information, information about financial issues, we think that, now that we have some ability to breathe a little bit, that we should be able to pull this together for the court's consideration."); Tr. 70 ("And if the court needs more information from us, we would respectfully request that the court leave the proceeding open for a week so that we can try to satisfy the court because we want to.")). + +The Court declined the defense's request and instead concluded that the defendant posed a serious flight risk and that no combination of conditions could ensure her appearance. First, the Court found that "the nature and circumstances of the offense here weigh in favor of detention," given the statutory presumption of detention triggered by charges involving minor victims and the potential penalties those charges carry. (Tr. 82). Second, the Court determined that "[t]he government's evidence at this early juncture of the case appears strong" based on the "multiple victims who provided detailed accounts of Ms. Maxwell's involvement in serious crimes," as well as corroboration in the form of "significant contemporaneous documentary evidence." (Id.). Third, the Court found that the defendant's history and characteristics demonstrate that the defendant poses a risk of flight. (Tr. 83). + +In addressing that third factor, the Court emphasized the defendant's "substantial international ties," which "could facilitate living abroad," including "multiple foreign citizenships," "familial and personal connections abroad," and "at least one foreign property of significant value." (Tr. 83). The Court also noted that the defendant "is a citizen of France, a nation that does not appear to extradite its citizens." (Id.). The Court further found that the defendant "possesses extraordinary financial resources" and that "the representations made to Pretrial Services regarding the defendant's finances likely do not provide a complete and candid picture of the resources available." (Tr. 83-84). + +Although the Court recognized that the defendant "does have some family and personal connections to the United States," the Court highlighted "the absence of any dependents, significant family ties or employment in the United States" in support of the conclusion that "flight would not pose an insurmountable burden for her." (Tr. 84). The Court recognized the defense arguments that the defendant did not leave the United States after Epstein's arrest and was in contact with the Government through counsel, but emphasized that the defendant may have expected that she would not be prosecuted. (Tr. 84-85). The Court also noted that the defendant "did not provide the government with her whereabouts," and that the "[c]ircumstances of her arrest . . . may cast some doubt on the claim that she was not hiding from the government, a claim that she makes throughout the papers and here today, but even if true, the reality that Ms. Maxwell may face such serious charges herself may not have set in until she was actually indicted." (Tr. 85). Based on all of those factors, the Court found that the Government had carried its burden of demonstrating that the defendant "poses a substantial actual risk of flight." (Tr. 86). + +The Court then concluded that "even the most restrictive conditions of release would be insufficient" to ensure the defendant's appearance. (Id.). Acknowledging that the defense's initial bail package represented only a fraction of the defendant's assets, the Court found that "even a substantially larger package would be insufficient." (Id.). Although the defendant "apparently failed to submit a full accounting or even close to full accounting of her financial situation," the Court implicitly rejected the defense's offer to provide additional information by determining that "[elven if the picture of her financial resources were not opaque, as it is, detention would still be appropriate." (Tr. 86-87 (emphasis added)). That conclusion was informed not only by the defendant's "significant financial resources," but also her "demonstrated sophistication in hiding those resources and herself." (Tr. 87). "Even assuming that Ms. Maxwell only wanted to hide from the press and the public," the Court emphasized that the defendant's "recent conduct underscores her extraordinary capacity to evade detection, even in the face of what the defense has acknowledged to be extreme and unusual efforts to locate her." (Id.). Given that sophistication, the Court concluded that electronic monitoring and home security guards "would be insufficient" because the defendant could remove the monitor and evade security guards. (Tr. 87-88). Finally, + +the Court rejected the defense's arguments about the risks of COVID-19 and the difficulty of preparing a defense with an incarcerated client. In so doing, the Court noted that the defendant has no underlying conditions that place her at heightened risk of complications from COVID-19 and emphasized that the defendant had many months to prepare for trial. (Tr. 89-90). + +Viewing all of these factors together, the Court ordered the defendant detained pending trial. (Tr. 91). + +### APPLICABLE LAW + +Under the Bail Reform Act, 18 U.S.C. §§ 3141 et seq., federal courts are empowered to order a defendant detained pending trial upon a determination that the defendant poses a risk of flight. 18 U.S.C. § 3142(e). When seeking detention on this ground, "[t]he Government bears the burden of proving by a preponderance of the evidence both that the defendant `presents an actual risk of flight' and that 'no condition or combination of conditions could be imposed on the defendant that would reasonably assure his presence in court." United States v. Boustani, 932 F.3d 79, 81 (2d Cir. 2019) (quoting United States v. Sabhani, 493 F.3d 63, 75 (2d Cir. 2007)). The Bail Reform Act lists three factors to be considered in the detention analysis when the Government seeks detention based on flight risk: (1) the nature and circumstances of the crimes charged; (2) the weight of the evidence against the person; and (3) the history and characteristics of the defendant, including the person's "character . . [and] financial resources." See 18 U.S.C. § 3I42(g). If a judicial officer concludes that "no condition or combination of conditions will reasonably assure the appearance of the person as required . .. such judicial officer shall order the detention of the person before trial." 18 U.S.C. § 3142(e)(1). + +Additionally, where, as here, a defendant is charged with committing an offense involving a minor victim under 18 U.S.C. §§ 2422 or 2423, it shall be presumed, subject to rebuttal, that no condition or combination of conditions will reasonably assure the appearance of the defendant as required and the safety of the community. 18 U.S.C. § 3142(e)(3)(E). In such a case, "the defendant `bears a limited burden of production—not a burden of persuasion—to rebut that presumption by coming forward with evidence that he does not pose . . . a risk of flight.' United States v. English, 629 F.3d 311, 319 (2d Cir. 2011) (quoting United States v. Mercedes, 254 F.3d 433, 436 (2d Cir. 2001)). The act of producing such evidence, however, "does not eliminate the presumption favoring detention." Id. Rather, the presumption "remains a factor to be considered among those weighed by the district court," while the Government retains the ultimate burden of demonstrating that the defendant presents a risk of flight. Mercedes, 254 F.3d at 436. + +When the Court has already issued a detention order, the Bail Reform Act provides that the detention hearing "may be reopened . . . if the judicial officer finds that information exists that was not known to the movant at the time of the hearing and that has a material bearing on the issue of whether there are conditions of release that will reasonably assure the appearance" of the defendant. 18 U.S.C. § 3142(0. Accordingly, "[a] court may properly reject an attempt to reopen a detention hearing where the new information presented is immaterial to the issue of flight risk." United States v. Petrov, 15 Cr. 66 (LTS), 2015 WL 11022886, at \*2 (S.D.N.Y. Mar. 26, 2015). Although courts in this Circuit have recognized that "a release order may be reconsidered even where the evidence proffered on reconsideration was known to the movant at the time of the original hearing," United States v. Rowe, 02 Cr. 756 (LMM), 2003 WL 21196846, at \*1 (S.D.N.Y. May 21, 2003), generally the moving party must establish that its arguments "warrant reconsideration" by, for example, demonstrating "that the court overlooked information or + +incorrectly applied the law," or that failure to reconsider "would constitute manifest injustice." Petrov, 2015 WL 1102286 at \*3. + +## DISCUSSION + +Having already raised numerous arguments in its briefing and oral argument at the initial bail hearing in this case, the defense now asks this Court to reverse itself based on virtually the same arguments it already rejected. The Renewed Bail Application largely reiterates the same claims regarding the defendant's ties to the United States and her behavior after Epstein's arrest that the Court already found unpersuasive. To the extent the Renewed Bail Application presents new information, it consists primarily of financial data that was certainly known to the defendant at the time of her initial bail application and that the Court already assumed could be made available (and thus rejected as immaterial) when ordering detention. Ultimately, nothing in the Renewed Bail Application alters the analysis that led this Court to conclude that the defendant "poses a substantial actual risk of flight," and that no combination of conditions could assure her appearance. (Tr. 86). All three of the relevant Bail Reform Act factors still weigh heavily in favor of detention, and the defense claims to the contrary do not warrant a revisiting of this Court's wellreasoned and thorough prior decision. + +## A. The Nature and Circumstances of the Offense + +The first Bail Reform Act factor indisputably weighs in favor of detention in this case. The egregious conduct charged in the Indictment gives rise to a statutory presumption of detention, and the Renewed Bail Motion makes no effort to challenge this Court's prior conclusion that the nature and circumstances of the offense support detention. The charges in the Indictment describe horrendous conduct involving the sexual abuse of multiple minor victims. If convicted, the defendant faces up to 35 years of incarceration, and may very well spend the remainder of her natural life in prison. The seriousness of the offenses make such a steep penalty a real possibility upon conviction, thereby giving the defendant an overwhelming incentive to flee if given the chance. + +In light of that strong incentive to flee, all three of the victims listed in the Indictment have asked the Government to convey to the Court that they continue to seek the defendant's detention. Additionally, pursuant to the Crime Victims' Rights Act, one of the victims has provided a written statement urging the Court to deny bail, which is attached as Exhibit A hereto. That unanimous view of the victims reflects three related reasons that this factor weighs so heavily in favor of detention. First, the victims sincerely fear that if the defendant is released, she will be able to evade justice. Second, the pain that the victims still feel to this day as a result of the defendant's conduct supports the conclusion that this offense is especially serious and may result in a lengthy sentence. Third, as discussed further below, the victims' attention to this case and willingness to convey their views reflects their commitment to take the stand and testify at the defendant's trial, demonstrating the strength of the Government's case. + +In short, this factor offers no reason to reverse the prior detention order. + +## B. The Strength of the Evidence + +Further incentivizing the defendant to flee, the Government's evidence remains strong. As the Court recognized when analyzing this factor at the July 14, 2020 hearing, the central evidence in the Government's case will come from the detailed testimony of three different victims, who will each independently describe how the defendant groomed and enticed them to engage in sexual activity with Jeffrey Epstein. (Tr. 82). The Indictment itself contains a description of the accounts these victims have provided law enforcement, which corroborate each other in meaningful part. Further, and as set forth below, those victims' accounts are corroborated by other evidence, including contemporary documents and other witnesses. + +In challenging this factor, the defense essentially restates its prior arguments on this score. At the original hearing, the defense argued that the Government's case was weak because it rested heavily on witness testimony regarding events from 25 years ago. (See Dkt. 18 at 19; Tr. 64-65). Having received and reviewed the discovery, the defense now contends the Government's corroborating evidence—some of which the Motion itself identifies-is insufficient and reiterates defense complaints that the discovery does not include other types of evidence.' (See Mot. at 30- 33). + +None of the defense arguments on this score changes the calculus for this factor. Three different victims are prepared to provide detailed testimony describing the defendant's role in Epstein's criminal scheme to sexually abuse them as minors. As demonstrated by the information outlined in the Indictment, these accounts corroborate each other by independently describing the same techniques used by the defendant and Epstein to groom and entice minor girls to engage in sex acts. Each victim will describe how the defendant befriended her, asked detailed questions about her life, and then normalized sexual activity around Epstein. Each victim will describe the use of massage as a technique to transition into sexual activity. Each victim will describe how the presence of an adult woman manipulated her into entering an abusive situation. In other words, this is a case that involves multiple witnesses describing the same course of conduct, substantially corroborating each other. + +At the initial bail hearing, the defendant also raised a series of legal challenges she intended to make on the face of the Indictment, all of which she contended weighed in favor of granting bail. After receiving discovery, the defense now appears to have abandoned those arguments, at least insofar as they pertain to the issue of bail. + +In addition to corroborating each other, these victims' accounts are further corroborated by other witnesses and by documentary evidence, which has been produced in discovery. That evidence will make it virtually indisputable that these victims in fact met and interacted with both the defendant and Jeffrey Epstein at the times and locations they describe. Travel records, for example, confirm that both the defendant and Epstein traveled to particular locations where victims describe interacting with them. These include records demonstrating that the defendant traveled with Epstein and one of the minor victims on Epstein's private jet when the victim was a minor, consistent with the victim's anticipated testimony. Contemporaneous journal entries corroborate details of another victim's account, including the details of when, where, and how that victim came to meet Epstein.2 Other records confirm that Epstein paid high school tuition for one of the victims and that Epstein knew and communicated with another victim. Beyond this documentary evidence, additional witnesses will confirm that both the defendant and Epstein knew and interacted with certain minor victims when those victims were minors. In other words, the Government's evidence strongly corroborates the victims' testimony that they met and interacted with the defendant and Epstein at particular times and in particular places. + +In the instant motion, the defendant complains that the documentary evidence relevant to the three victims identified in the Indictment and produced to date is not sufficiently voluminous + +2 In its Renewed Bail Motion, the defense complains that the Government has produced only seven pages from this diary in discovery. To be clear, the Government produced all pages in its possession. Those pages are the only pages that relate to the charges in the Indictment, which pages describe that victim's first trip to meet Epstein. Because this victim stopped writing in her journal about a month after that first meeting with Epstein, there are no entries regarding the subsequent trip she took months later to visit Epstein, during which she met the defendant. This victim provided the Government with copies of her journal entries relating to Epstein and informed the Government that the remaining entries are personal in nature and have nothing to do with Epstein or the defendant. The defense has cited no authority suggesting that the Government is under any obligation to obtain and produce personal diary entries in the possession of a victim, especially when those entries have no bearing on the charges. + +and that certain of the corroborating documentary evidence does not specifically name Maxwell. Leaving aside the fact that volume is not a reliable proxy for quality, by its very nature, abusive sexual contact is not the type of crime that leaves extensive documentary evidence. But, as described above, there are indeed travel records confirming the defendant herself traveled to locations described by certain of the victims at or around the relevant times. To the extent other corroborative documents refer only to Epstein, they still support these victims' testimony, which will detail their interactions with both the defendant and her co-conspirator, Epstein. In other words, documentary evidence does exist, and as the Court has already found, the combination of multiple victims describing the same scheme, together with documents and other witnesses confirming that those victims did indeed interact with the defendant and Epstein at the times and places they say they did, makes this a strong case. (Tr. 82). + +Taken together, this evidence confirms that the Government's case remains as strong as it was at the time of the defendant's arrest. Accordingly, this factor continues to weigh heavily in favor of detention. + +# C. The Characteristics of the Defendant + +The defendant's history and characteristics include significant foreign ties, millions of dollars in cash that she largely transferred to her spouse in the last five years, among other assets, and a demonstrated willingness and sophisticated ability to live in hiding. The bulk of the arguments in the Renewed Bail Motion focus on this factor in a manner that largely rehashes claims that this Court already considered at the July 14, 2020 hearing. Any new information provided was either known by the defense at the time of the initial hearing, assumed to be the case when the Court analyzed this factor at the initial hearing, or, in the case of the defense report regarding + +French law, is simply incorrect. Accordingly, the defendant's foreign ties, wealth, and skill at avoiding detection continue to weigh in favor of detention. + +First, there can be no serious dispute that the defendant has foreign ties. She is a citizen of three countries and holds three passports. As was already noted at the original hearing and is again evidenced in the Renewed Bail Application, the defendant has close relatives and friends who live abroad, as well as a multi-million dollar foreign property and at least one foreign bank account. (Tr. 83). In an attempt to minimize the defendant's foreign ties, the defense emphasizes the defendant's relatives and friends in the United States, history of residence in the United States, and United States citizenship. But the Court was already aware of those factors when making its original detention decision. (See Tr. 84; Dkt. 18 at 2, 12). The letters and documentation included in the Renewed Bail Motion simply prove points that were not in dispute. What that documentation does not do, however, is suggest that the defendant has the kind of ties to this country that come with any employment in the United States or any dependents living here. Indeed, as noted in the Pretrial Services Report, the defendant stated in July that she has no children and has no current employment. (Pretrial Services Report at 3). + +The Renewed Bail Motion fails to establish sufficiently strong ties to the United States that would prevent her from fleeing. Although the defendant now claims her marriage would keep her in the United States, her motion does not address the plainly inconsistent statements she made to Pretrial Services at the time of her arrest, when, as documented in the Pretrial Services Report, the defendant said she was "in the process of divorcing her husband." (Id.). On this point, it bears noting that the defendant's motion asks that she be permitted to live with her sister if granted bail, not her spouse. Moreover, the fact that the defendant's spouse has only now come forward to support the defendant should be afforded little weight given that he refused to come forward at the + +time of her arrest. While a friend's desire to avoid publicity may be understandable, a spouse's desire to distance himself in that manner—particularly when coupled with the defendant's inconsistent statements about the state of their relationship—undermine her assertion that her marriage is a tie that would keep her in the United States. Adding to this confusion, bank records reflect that when the defendant and her spouse established a trust account in or about 2018, they filled out forms in which they were required to provide personal information, including marital status. On those forms, which the Government has attached hereto as Exhibit B, both the defendant and her spouse listed their marital status as "single." (See Ex. B at 6, 7). It is unclear why the defendant lied to the bank about her marital status, but that lack of candor on a bank form mirrors her lack of candor with Pretrial Services in this case, discussed further below. + +As for the defendant's asserted relationships with her stepchildren and other relatives in the United States, the defendant did not appear to have an issue living alone without these relatives while she was in hiding in New Hampshire, which undercuts any suggestion that these ties would keep her in the United States. In any event, the defendant could easily receive visits from her family members while living abroad, and, as noted, the defendant has multiple family members and friends who live abroad. + +In addition to those foreign connections and ample means to flee discussed further below, the defendant will have the ability, once gone, to frustrate any potential extradition. Attempting to downplay that concern, the defense relies on two legal opinions to claim that the defendant can irrevocably waive her extradition rights with respect to both the United Kingdom and France. (Mot. at 25; Def. Ex. U; Def. Ex. V). But the defendant's offer to sign a so-called "irrevocable waiver of her extradition rights" is ultimately meaningless: it provides no additional reassurance whatsoever and, with respect to France, is based on an erroneous assessment of France's position on the extradition of its nationals. (Mot. at 25). + +As an initial matter, the Government would need to seek the arrest of the defendant before such a waiver would even come into play. Even assuming the defendant could be located and apprehended—which is quite an assumption given the defendant's access to substantial wealth and demonstrated ability to live in hiding—numerous courts have recognized that purported waivers of extradition are unenforceable and effectively meaningless. See, e.g., United States v. Epstein, 425 F. Supp. 3d 306, 325 (S.D.N.Y. 2019) ("The Defense proposal to give advance consent to extradition and waiver of extradition rights is, in the Court's view, an empty gesture. And, it comes into [play] only after [the defendant] has fled the Court's jurisdiction."); United States v. Morrison, No. 16-MR-118, 2016 WL 7421924, at \*4 (W.D.N.Y. Dec. 23, 2016); United States v. Kazeem, No. 15 Cr. 172, 2015 WL 4645357, at \*3 (D. Or. Aug. 3, 2015); United States v. Young, Nos. 12 Cr. 502, 12 Cr. 645, 2013 WL 12131300, at \*7 (D. Utah Aug. 27, 2013); United States v. Cohen, No. C 10-00547, 2010 WL 5387757, at \*9 n.11 (N.D. Cal. Dec. 20, 2010); United States v. Bohn, 330 F. Supp. 2d 960, 961 (W.D. Tenn. 2004); United States v. Stroh, No. 396 Cr. 139, 2000 WL 1832956, at \*5 (D. Conn. Nov. 3, 2000); United States v. Botero, 604 F. Supp. 1028, 1035 (S.D. Fla. 1985).3 For very good reason: Any defendant who signs such a purported waiver and then + +3 The defense argues that several courts "have addressed concerns about a defendant's ties to a foreign state that enforces extradition waiver by requiring the defendant to execute such a waiver as a condition of release." (Mot. at 26). In the cases cited by the defendant, the courts approved the release of the defendants based on the particular facts, but did not address at all the question of whether a waiver of extradition is enforceable. See United States v. Khashoggi, 717 F. Supp. 1048, 1050-52 (S.D.N.Y. 1989) (noting, among other things, that the Government's case was "novel," and presented an "untried theory of liability" and that the defendant not only waived his right to appeal extradition in Switzerland but that he traveled immediately to the United States for arraignment, and that his country's government committed to ensuring his appearance at trial); United States v. Salvagno, 314 F. Supp. 2d 115, 119 (N.D.N.Y. 2004) (denying Government motion to remand after trial where court found defendant not likely to flee); United States v. Chen, 820 F. Supp. 1205, 1209, 1212 (N.D. Cal. 1992) (reconsidering pretrial release where case had + +flees will assuredly contest the validity and/or voluntariness of the waiver, and will get to do so in the jurisdiction of her choosing (Le., the one to which she chose to flee). The Department of Justice's Office of International Affairs ("OIA") is unaware of any country anywhere in the world that would consider an anticipatory extradition waiver binding. Indeed, the defendant's own experts' conclusion—that "because of these waivers and other factors, it is highly unlikely that she would be able to resist extradition successfully," (Mot. at 27)—leaves open the possibility that she could avoid extradition. + +Such an outcome is virtually a certainty as to France, a country of which the defendant is a citizen and which does not extradite its citizens to the United States. To confirm this fact, after receiving the Renewed Bail Motion, the Government, through OIA, contacted the French Ministry of Justice ("MOJ") to clarify whether there is any circumstance under which France would extradite a French citizen to the United States. In response, the MOJ provided the Government with a letter setting forth the relevant law and conclusively stating that France does not extradite its citizens to the United States. That letter in its original French, as well as an English translation of the letter, are attached hereto as Exhibit C. In that letter, the MOJ makes clear that France does not extradite its nationals outside the European Union (regardless of the existence of dual citizenship), including to the United States, and has never derogated from that principle outside the European Union. See Ex. C; see also United States v. Cilins, No. 13 Cr. 315 (WHP), 2013 WL + +&quot;taken a number of surprising turns," including the "suppression of video evidence, the indeterminate stay of proceedings, the overall uncertainty of the government's evidence"); United States v. Karni, 298 F. Supp. 2d 129, 133 (D.D.C. 2004); United States v. Cirillo, No. 99-1514, 1999 WL 1456536, at \*2 (3d Cir. July 13, 1999); see also United States v. Georgiou, No. 08-1220- M, 2008 WL 4306750, at \*3 (E.D. Pa. Sept. 22, 2008) (distinguishing Cirillo on the facts and noting that "defense counsel concedes that a waiver of extradition may not be enforceable in Canada, a fact the court in Cirillo did not mention in its opinion"). + +3802012, at \*2 (S.D.N.Y. July 19, 2013) ("Because France refuses to extradite its citizens, Cilins can avoid prosecution on this Indictment if he can reach French soil."). + +In other words, even assuming the Government could locate the defendant, if she flees to France, her citizenship in that country will completely bar her extradition. Any purported waiver of extradition executed in the United States would not be enforceable against the defendant in France because French law embodies an inflexible principle that its citizens will not be extradited to other countries outside of the European Union, including the United States. As set forth in Exhibit C, according to the MOJ, the French Code of Criminal Procedure "absolutely prohibits the extradition of a person who had French nationality at the time of the commission of the acts for which extradition is requested." (Ex. C at 3). That the defendant is a citizen of multiple countries is of no moment. (See id.). In applying the Bilateral Extradition Treaty between the United States and France and the "general principle of non-extradition of nationals under French law, France systematically refuses to grant the extradition of French nationals to the American judicial authorities." (Id. at 4). Thus, contrary to the suggestion of the defense submission, any anticipatory waiver of extradition would not be effective under French law, and would not be recognizable by French courts in any extradition process, or otherwise enforceable. + +The defendant's expert writes that "[i]n the recent past," he is "not aware that the French authorities would have had to address the situation in which the United States sought extradition of a French citizen who was also a United States citizen. Thus, there is no precedent to draw from in that regard." (Def. Ex. V. at 2). That is not so. France has previously rejected such a request. For example, in 2006, Hans Peterson, an American citizen and French national, turned himself in to French authorities in Guadeloupe and confessed to committing a murder in the United States. Despite turning himself in to French authorities, Peterson remained beyond the reach of U.S. law + +enforcement despite the repeated requests of O1A and U.S. officials. See Durbin, Schakowsky, Emanuel Urge French Justice Minister To Ensure Justice Is Done During Hans Peterson Retrial (Nov. 16, 2012), https://www.durbin.senate.govinewsroorn/press-releases/durbin-schakowskyemanuel-urge-french-justice-minister-to-ensure-justice-is-done-during-hans-peterson-retrial; see also Senators' letter to French government (Mar. 14, 2008), https://www.nbcnews.corn/id/wbna23601583 (citing a letter from the MOJ to the Department of Justice on August 22, 2007 which provides that the "Ministry of Justice considers the Americanborn, U.S. citizen Peterson to also be a French national and that the extradition request has been denied"). Indeed, the Government is unaware of any instance in which France has ever extradited a French citizen to the United States. (See Ex. C at 4 ("[T]he principle of non-extradition of nationals is a principle of extradition law from which France has never deviated outside the framework of the European Union.")). Simply put, the Court was correct when it determined at the initial bail hearing that France does not appear to extradite its own citizens. (Tr. 83). + +The defendant's supposed waiver of her extradition rights with respect to the United Kingdom should similarly be afforded no weight. Although an anticipatory waiver of extradition may be admissible in extradition proceedings in the United Kingdom, such a waiver is by no means binding, authoritative, or enforceable. See United States v. Stanton, No. 91 Cr. 889 (CHS), 1992 WL 27130, at \*2 & n.1 (S.D.N.Y. Feb. 4, 1992) (denying modification of defendant's bail where defendant indicated willingness to waive extradition proceeding by providing extradition waivers, as British authorities advised that extradition waivers were possible only in cases where the fugitive actually appeared before a British magistrate after the filing of an extradition request, and concluding that such a waiver was not an "enforceable undertaking"). Under the United Kingdom's Extradition Act of 2003, consent to extradition is permitted, "if (and only if) [a person] has the assistance of counsel or a solicitor to represent him in the proceedings before the appropriate judge." Extradition Act 2003, § 127(9), https://www.legislation.gov.uk/ukpga/ 2003/41. As such, a judge in the United Kingdom must independently evaluate any waiver of extradition in real time, thereby necessarily rendering any anticipatory waiver executed before the defendant is found in the United Kingdom meaningless. Id. at §127. In other words, consent given to authorities in the United States would not be binding in the United Kingdom, and the defendant could easily decide not to consent to extradition once found abroad. + +Further, a judge in the United Kingdom must make an independent decision on extradition based on the circumstances at the time the defendant is before the court, including the passage of time, forum, and considerations of the individual's mental or physical condition. See, e.g., id. at §§ 82, 83A, & 91. Even if a final order of extradition has been entered by a court, the Secretary of State still has the discretion to deny extradition. See id. at § 93. The Government understands from OIA that extradition from the United Kingdom is frequently extensively litigated, uncertain, and subject to multiple levels of appeal. Moreover, even where the process is ultimately successful, it is lengthy and time-consuming. + +Ultimately, although the defendant purports to be willing to waive her right to challenge being extradited to the United States, she simply cannot do so under the laws of France and the United Kingdom, and she would be free to fight extradition once in those countries. And, of course, the defendant could choose to flee to another jurisdiction altogether, including one with which the United States does not have an extradition treaty. The defendant's written waivers of extradition from France and the United Kingdom certainly provide no guarantee that the defendant will not flee to a third country from which, even if she can be located, extradition may be impossible. Courts have recognized that lack of an effective means of extradition can increase a + +defendant's flight risk, and have cited such facts as a relevant consideration in detaining defendants pending trial. See, e.g., United States v. Namer, 238 F.3d 425, 2000 WL 1872012, at •2 (6th Cir. Dec. 12, 2000); Chins, 2013 WL 3802012 at \*2; United States v. Abdullahu, 488 F. Supp. 2d 433, 443 (D.N.J. 2007) ("The inability to extradite defendant should he flee weighs in favor of detention."). Beyond being impossible to guarantee, extradition is typically a lengthy, complicated, and expensive process, which would provide no measure of justice to the victims who would be forced to wait years for the defendant's return. The strong possibility that the defendant could successfully resist extradition only heightens the defendant's incentive to flee. + +Second, the defendant's behavior in the year leading up to her arrest demonstrates her sophistication in hiding and her ability to avoid detection. The Court noted as much in denying bail, and the Renewed Bail Application also does nothing to change that conclusion. (Tr. 87). Indeed, the defendant's time in isolation in the year leading up to her arrest makes clear that, even to the extent she has loved ones and property in this country, she has proven her willingness to cut herself off entirely from them and her ability to live in hiding. She did so by purchasing a home using a trust in another name and introducing herself to the real estate under an alias, placing her assets into accounts held under other names, registering cellphones and at least one credit card under other names, and living in near total isolation away from her loved ones. + +The Renewed Bail Application again tries to cast those steps as efforts to avoid the media frenzy that followed Epstein's death. (Tr. 44, 56-57). However, as the Court already recognized, regardless of the defendant's reasons for taking these steps, that course of conduct clearly establishes her expertise at remaining hidden and her willingness to cut herself off from her family and friends in order to avoid detection. (Tr. 87). Rare is the case when a defendant has already demonstrated an aptitude for assuming other identities and concealing her assets, including when + +purchasing property, registering cellphones, and managing finances. Here, the defendant has indisputably taken all of those steps. She was able to do so because of both her finances and her willingness to take extreme measures and to experience social isolation away from her loved ones. And she was so good at assuming another identity that she was able to avoid notice by locals and the media even when a bounty was offered for her location and when numerous media outlets were searching for her. + +The charts, graphs, and affidavits proffered by the defense do not undercut the defendant's skill at evading detection, and do nothing more than restate the justification for those actions that the defense already made at the prior hearing. (See Dkt. 18 at 14-16). That said, there is still reason to believe that the defendant was hiding not just from the press, but also from law enforcement. It is undisputed that defense counsel, even while in contact with the Government, never disclosed the defendant's location or offered her surrender if she were to be charged. (Tr. 53-54). The Court already inquired about defense counsel's interactions with the Government in the year leading up to the defendant's arrest, and the Renewed Bail Application offers nothing new on that score. (Id.). Defense counsel contacted the Government when the FBI attempted to serve the defendant with a subpoena, but were unable to locate her, on July 7, 2019. Prior to her arrest, the Government and defense counsel communicated on multiple occasions between July and October of 2019, and communicated briefly on two additional occasions, most recently in March of 2020. At no point did defense counsel disclose the defendant's location, offer to surrender the defendant, or offer to bring the defendant in to be interviewed. + +Moreover it is undisputed that when the FBI located the defendant, she ignored their directives and ran away from the arresting agents. Although the defense has submitted an affidavit from the defendant's private security team, nothing in that affidavit should alter the Court's determination that detention is appropriate here. The defense already informed the Court at the July 14, 2020 bail hearing that the defendant's security protocol was to move to an inner room if her security was breached. (Tr. 55). Even still, the new affidavit makes clear that the agents who entered the defendant's property were wearing clothing that clearly identified them as FBI agents. (Def. Ex. S ¶ 12). Moreover, the FBI announced themselves as federal agents to the defendant when they first approached her. Thus, even if the defendant was following her private security's protocol when she fled, she did so knowing that she was disobeying the directives of FBI agents, not members of the media or general public. Those actions raise the very real concern, particularly in light of the terms of her proposed package, that the defendant would prioritize the directives of her private security guards over the directives of federal law enforcement. Further, the act of wrapping a cellphone in tin foil has no conceivable relevance to concerns about the press. The defense argues that the defendant only took those measures because that particular phone number had been released to the public, but that just suggests the defendant believed that was the only number of which law enforcement was aware. In other words, there is still reason to believe, as the Court previously found, that in the year leading up to her arrest, the defendant sought to evade not only the press, but also law enforcement. (Tr. 87). + +Third, the defendant has access to significant wealth. At the initial bail hearing, the Government expressed doubt that the defendant's assets were limited to the approximately \$3.8 million she reported to Pretrial Services, and noted that it appeared the defendant was less than candid with Pretrial Services regarding the assets in her control. (Tr. 28-30, 72-73). The finances outlined in the defense submission confirm the Government's suspicion that the defendant has access to far more than \$3.8 million, confirm that the defendant was less than candid with Pretrial Services (and, by extension, the Court) during her interview, and confirm that the defendant is a + +person of substantial means with vast resources.4 The defendant's apparent willingness to deceive this Court already weighed in favor of detention, and confirmation of that deception only reemphasizes that this defendant cannot be trusted to comply with bail conditions. + +Now, the defense has submitted a financial report that reflects the defendant has approximately \$22 million in assets-far more than the figure she initially reported to Pretrial Services. (Def. Ex. 0). Accepting the financial report at face value, it is clear that the defense's proposed bail package would leave the defendant with substantial resources to flee the country. Not only would she have millions of dollars in unrestrained assets at her disposal,5 but she would also have a \$2 million townhouse in London, which she could live in or sell to support herself. In other words, even with the proposed bond—which is only partially secured—the defendant would still have millions of dollars at her disposal. She could absolutely afford to leave her friends and family to lose whatever they may pledge to support her bond, and then repay them much of their losses. In fact, the defendant could transfer money to her proposed co-signers immediately following her release,6 given the large sums of money that would be left unrestrained by her proposed bail package. + +4 As noted above, the Court effectively assumed the defendant had considerably more assets than those disclosed to Pretrial Services in rejecting defense counsel's repeated offer to provide a more fulsome picture of the defendant's finances and concluding that even assuming the defense could provide a clearer description of the defendant's assets, detention was still warranted. (See Tr. 87). + +5 In particular, according to the report, the defendant would have more than \$4 million in unrestrained funds in accounts, in addition to hundreds of thousands of dollars of jewelry and other items. Moreover, the Government presumes the defendant has not yet spent all \$7 million of the retainer paid to her attorneys, which would still belong to the defendant if she fled. + +6 The Government notes that two of the defendant's proposed co-signers are citizens and residents of the United Kingdom, against whom the Government could not realistically recover a bond amount. These co-signers have not offered to secure this bond with any cash or property, and as a result, such a bond would effectively be worthless if the defendant were to flee. + +Moreover, the schedule provided by the defense is notably silent regarding any future revenue streams to which the defendant may have access. The financial report only addresses the defendant's assets without detailing her income at all. The defendant has similarly provided the Court with no information about what resources her spouse might have access to on a prospective basis, in addition to their substantial assets. The financial report submitted by the defense is also careful to note that it does not account for any possible income from inheritances. (Def. Ex. O at 5). This is significant, given that the Government has produced to the defendant in discovery a copy of Jeffrey Epstein's will, which includes a \$10 million cash grant to the defendant. + +The financial report further shows that the defendant apparently spent the last five years moving the majority of her assets out of her name by funneling them through trusts to her spouse. That pattern suggests the defendant has used the process of transferring assets as a means to hide her true wealth. As the Renewed Bail Application points out, the defendant currently has approximately \$3.4 million worth of assets held in her own name, which is close to the amount of wealth she told Pretrial Services she possessed in July 2020. Importantly, though, that number omits the millions of dollars of assets that she has transferred from her name through trust accounts to her spouse, including funds that were used to purchase the New Hampshire property where the defendant was residing when she was arrested.' This confirms that the Government was right to be concerned that the defendant had refused to identify her spouse or his assets to Pretrial Services. That practice further demonstrates the defendant's sophistication in hiding her assets and maintaining assets that are under her control in other names. + +On this score, it bears noting that that defendant told Pretrial Services that the property was owned by a corporation, and that she was "just able to stay there." (Pretrial Services Report at 2). The defendant's lack of candor does not inspire confidence that she can be trusted to comply with bail conditions. + +In this vein, the financial report suggests that the defendant originally brought more than \$20 million to her marriage, but that her husband brought only \$200,000.8 (See Def. Ex. O at 10). Setting aside whether the defendant's spouse has additional assets beyond those included in the financial report, the vast majority of the assets contained in the report itself apparently originated with the defendant. (See Def. Ex. O at 10). Based on the report, it seems clear that the defendant slowly funneled the majority of her wealth to trusts and into her husband's name over the last five years. As a result, if the Court were to grant the defendant's proposed bail package and the defendant were to flee, her spouse would primarily lose the money that the defendant gave him rather than his own independent assets. In other words, were the defendant to flee, she would largely be sacrificing her own money and assets, thereby limiting the moral suasion of her spouse co-signing the bond. In sum, the defendant's submission does not change the Government's position at the original bail hearing that the defendant has considerable financial resources, and could live a comfortable life as a fugitive. + +The combination of all these factors, including the defendant's foreign ties, demonstrated ability to live in hiding, and financial resources, confirm that the defendant's characteristics continue to weigh in favor of detention. Given the multiplicity of factors supporting detention, + +8 The Government has not been able to verify this financial information—in part because the defense has declined to provide the Government with the spouse's current banking information but according to public news articles, both prior to and during his marriage to the defendant, he was the CEO of a company that was valued at \$100 million in 2016. (See, e.g., https://www.businessinsider.com/who-is-scott-borgerson-ceo-ghislaine-maxwell-jeffrey-epsteincargometrics-2019-8; https://www. freightwaves.cominews/tech- frontrunner-cargometrics-opensup-on-game-plan; https://gcaptain.cornicargometrics-founder-and-ceo-scott-borgerson-resigns/). It thus seems unlikely that he in fact possessed only \$200,000 when he married the defendant. The Court need not resolve this question, however, because regardless of whether the defendant's husband may have additional undisclosed assets, as discussed herein, the key takeaway from the financial report is that the vast majority of the spouse's reported assets, upon which the proposed bond is based, originated with the defendant, meaning he would not be losing his own money if the defendant fled. + +this is not one of the rare cases in which a private security company could conceivably be considered as a bail condition. See United States v. Boustani, 932 F.3d 79, 82 (2d Cir. 2019). The Second Circuit has squarely held that "the Bail Reform Act does not permit a two-tiered bail system in which defendants of lesser means are detained pending trial while wealthy defendants are released to self-funded private jails," and that "a defendant may be released on such a condition only where, but for his wealth, he would not have been detained." Id. Here, detention is warranted not only because of the defendant's financial means, but also her foreign ties, her skill at and willingness to live in hiding, the nature of the offense resulting in a presumption of detention, and the strength of the evidence, among other factors. The defense suggestion that the defendant's private security guards should post cash in support of a bond does not change this calculus. There is no reason to believe that the defendant would be at all troubled by a security company in which she has no personal stake losing \$1 million, especially if that sacrifice meant she could escape conviction and sentencing. Accordingly, release to the equivalent of a "privately funded jail" is not warranted here. Id. at 83. + +Belatedly, as the Court previously recognized (Tr. 87-88), a GPS monitoring bracelet offers little value for a defendant who poses such a significant flight risk because it is does nothing to prevent the defendant's flight once it has been removed. At best, home confinement and electronic monitoring would reduce a defendant's head start after cutting the bracelet. See United States v. Banki, 10 Cr. 008 (JFK), Dkt. 7 (S.D.N.Y. Jan. 21, 2010) (denying bail to a naturalized citizen who was native to Iran, who was single and childless and who faced a statutory maximum of 20 years' imprisonment, and noting that electronic monitoring is "hardly foolproof."), aff'd, 369 F. App'x 152 (2d Cir. 2010); United States v. Zarger, No. 00 Cr. 773 (JG), 2000 WL 1134364, at \*1 (E.D.N.Y. Aug. 4, 2000) (rejecting defendant's application for bail in part because home detention + +with electronic monitoring "at best . . . limits a fleeing defendant's head start"); United States v. Benatar, No. 02 Cr. 099 (JG), 2002 WL 31410262, at \*3 (E.D.N.Y. Oct. 10, 2002) (same). Simply put, no bail conditions, including those proposed in the Renewed Bail Motion, would be sufficient to ensure that this defendant appears in court. + +In urging a different conclusion, the defense again cites the same cases discussed in its initial briefing and at the July 14, 2020 hearing to argue that the proposed bail conditions are consistent with or exceed those approved by courts in this Circuit for "high-profile defendants with financial means and foreign citizenship." (Mot. at 34; see Dkt. 18 at 16, 21; Tr. 48-51). The Court should reject the defense's efforts to raise the same precedent that the Court already took into consideration when denying bail. "A motion for reconsideration may not be used ... as a vehicle for relitigating issues already decided by the Court." Jackson v. Goord, 664 F. Supp. 2d 307, 313 (S.D.N.Y. 2009) (internal quotation marks omitted). The Court already considered and rejected the defendant's efforts to liken her case to other "serious and high-profile prosecutions where the courts, over the government's objection, granted bail to defendants with significant financial resources." (Tr. 88). Noting "crucial factual differences," the Court described those cases, including United States v. Esposito, 309 F. Supp. 3d 24 (S.D.N.Y. 2018), United States v. Dreier, 596 F. Supp. 2d 831 (S.D.N.Y. 2009), and United States v. Madoff, 586 F. Supp. 2d 240 (S.D.N.Y. 2009), as "not on point and not persuasive," and distinguished the defendant for a number of reasons, including the defendant's "significant foreign connections." (Tr. 88; see id. (distinguishing Esposito where the risk of flight appeared to "have been based on the resources available to defendant, not foreign connections or experience and a record of hiding from being found"); id. (distinguishing Madoff where "the defendant had already been released on a bail + +package agreed to by the parties for a considerable period of time before the government sought detention")). + +The Court already engaged in a fact-specific analysis in ordering the defendant detained. Among the reasons provided, the Court found that the "the defendant not only has significant financial resources, but has demonstrated sophistication in hiding those resources and herself." (Tr. 87). Following the analysis the Court has already conducted, several of the cases cited by the defendant are readily distinguishable. See, e.g., United States v. Khashoggi, 717 F. Supp. 1048, 1050-52 (S.D.N.Y. 1989) (in ordering defendant released pending trial, noting, among other things, that the defendant not only waived his right to appeal extradition in Switzerland, but that he traveled immediately to the United States for arraignment, and that his country's Government committed to ensuring his appearance at trial); United States v. Bodmer, No. 03 Cr. 947 (SAS), 2004 WL 169790, at \*1, \*3 (S.D.N.Y. June 28, 2004) (setting conditions of bail where defendant arrested abroad had already consented to extradition to the United States and finding that the Government—whose argument was "based, in large part, on speculation" as to the defendant's financial resources—had "failed to meet its burden"). And there is support in the case law for detaining individuals in comparable situations to the defendant. See, e.g., United States v. Boustani, 356 F. Supp. 3d 246, 252-55 (E.D.N.Y.), aff'd, No. 19-344, 2019 WL 2070656 (2d Cir. Mar. 7, 2019) (ordering defendant detained pending trial and finding that defendant posed a risk of flight based on several factors, including seriousness of the charged offenses, lengthy possible sentence, strength of Government's evidence, access to substantial financial resources, frequent international travel, "minimal" ties to the United States, and "extensive ties to foreign countries without extradition"); United States v. Patrick Ho, 17 Cr. 779 (KBF), Dkt. 49 (S.D.N.Y. Feb. 4, 2018) (ordering defendant detained based on defendant's risk of flight and citing the strength of + +the Government's evidence, lack of meaningful community ties, and "potential ties in foreign jurisdictions"); United States v. Epstein, 155 F. Supp. 2d 323, 324-326 (E.D. Pa. 2001) (finding that defendant's dual citizenship in Germany and Brazil, lucrative employment and property interests, and lack of an extradition treaty with Brazil weighed in favor of detention despite the fact that defendant and his wife owned "substantial" property and other significant assets in the United States). Further, unlike those cases and the cases cited by the defendant, the crimes charged here involving minor victims trigger a statutory presumption in favor of detention, weighing further in favor of detention. See Mercedes, 254 F.3d at 436. + +"Each bail package in each case is considered and evaluated on its individual merits by the Court." Epstein, 425 F. Supp. 3d at 326. Unlike the cases cited by the defense, the Government seeks detention not solely on the basis that the defendant is of financial means and has foreign citizenship. Rather, detention is warranted because the defendant is a citizen of multiple foreign countries, including one that does not extradite its nationals, with "substantial international ties," "familial and personal connections abroad," and "substantial financial resources," (Tr. 83-84), with a demonstrated sophistication in hiding herself and her assets, who, for the myriad reasons discussed herein and identified at the original hearing—including the seriousness of the offense, the strength of the Government's evidence, and the potential length of sentence—presents a substantial flight risk. (Tr. 82-91). The defendant continues to pose an extreme risk of flight, and the defense has not offered any new information sufficient to justify reversal of the Court's prior finding that no combination of conditions could ensure her appearance. + +### D. Conditions of Confinement + +Finally, the Renewed Bail Application reiterates the same argument about the potential harms of detention on the defendant that this Court rejected at the initial bail hearing. (Tr. 42, 68- 69). As was the case in July, these complaints do not warrant the defendant's release. + +The defendant continues to have more time than any other inmate at the MDC to review her discovery and as much, if not more, time to communicate with her attorneys. Specifically, the defendant currently has thirteen hours per day, seven days per week to review electronic discovery. Also during that time, the defendant has access to email with defense counsel, calls with defense counsel, and when visiting is available depending on pandemic-related conditions, the defendant has access to legal visits. Due to the recently implemented lockdown at the MDC, visitation is not currently available, but MDC legal counsel is arranging for the defendant to receive a VTC call with legal counsel three hours per day every weekday, starting this Friday. Defense counsel will also be able to schedule legal calls on weekends as needed. Given those facts, the defense argument essentially suggests that no defendant could prepare for trial while housed at the MDC a patently incorrect claim. + +The defendant is able to review her discovery using hard drives provided by the Government, discs that defense counsel can send containing any copies of discovery material defense counsel chooses within the confines of the protective order, or hard copy documents provided by defense counsel. The Government has taken multiple steps to address technical difficulties the defendant has encountered when reviewing her hard drives. These steps included modifying and reproducing productions in new formats, asking MDC IT staff to assist the defendant in viewing her hard drives on the MDC computer, and then purchasing and providing a + +laptop for the defendant's exclusive use.9 Even when the defendant was temporarily unable to review some files from some hard drives, she was always able to review other portions of her discovery. + +As to the defense's most recent complaints, the malfunctioning of the sixth production that the defense complains of resulted from the defendant herself dropping the hard drive onto the ground, and that drive has been replaced. When the defense informed the Government that the drive containing the seventh production may be malfunctioning, the Government offered to have IT staff review the drive. In response, the defense indicated the drive was in fact still viewable and declined to have IT staff review it. Accordingly, it is the Government's understanding that the defendant currently has a full, readable set of discovery at the MDC. At the defense's request, the Government is preparing yet another copy containing all productions to date on a single drive so that the defendant will have a backup copy of discovery materials at the MDC.1° Throughout the defendant's pretrial detention, the Government has been responsive to the defense's concerns regarding access to discovery and counsel. The Government will continue to work with MDC + +9 The Government understands from MDC legal counsel that the defendant has access to the laptop thirteen hours per day during weekdays and has access to the MDC desktop computer thirteen hours per day seven days per week. The use of the laptop is limited to weekdays because the MDC restricts the number of employees who carry the key to the secure location where the laptop is kept, and the employees with that key do not work regularly on weekends. The MDC previously accommodated an exception to this rule while the defendant was in quarantine and arranged for her to use the laptop in her isolation cell on weekends because otherwise she would not have had access to a computer during weekends while in quarantine. Now that she is out of quarantine, the defendant will have access to the MDC desktop computer on weekends. + +1° On this score, the Government notes the tension between the defense claim that the discovery produced to date contains little of value or relevant to the charges set forth in the Indictment, and the simultaneous claim that the defendant has been prejudiced by technical difficulties that have temporarily delayed her ability to review portions of those productions, productions which, according to the defense, counsel have already been able to conclude are essentially unimportant. + +legal counsel to ensure that the defendant is able to review her discovery and to communicate with defense counsel over the seven months still remaining before trial. + +As to the defense complaints regarding the defendant's conditions of confinement, the defense notably does not suggest that the defendant should be housed in general population. Indeed, the defense appears to agree that the best way to ensure the defendant's safety while detained is to be away from general population. Unlike other inmates in protective custody, however, the defendant is released from her isolation cell for thirteen hours per day, has her own shower, has exclusive use of two different computers, has her own phone to use, and has her own television. Those conditions set her far apart from general population inmates, not to mention other inmates in protective custody. Additionally, psychology and medical staff check on the defendant daily, MDC legal staff are highly attuned to any complaints the defendant has raised, and following initial complaints about the defendant's diet early in her incarceration, the MDC has ensured that the defendant receives three full meals per day and has access to commissary from which she can supplement her diet. + +The MDC has taken numerous steps to strike the balance between the security of the institution and providing the defendant with adequate time and resources to prepare her defense. In that vein, many of the searches the defendant complains of-such as searches after every visit, searches of her cell, pat downs when she is moved, and directing her to open her mouth for visual inspection (while the searching staff member is wearing a mask)—are the same searches to which every other inmate is subjected for the security of the institution. MDC legal counsel has assured the Government that MDC staff does not record or listen to the substance of the defendant's calls and visits with legal counsel. To the extent MDC staff conducts additional searches or monitoring of the defendant, MDC legal counsel has indicated that those steps are necessary to maintain the security of the institution and the defendant. + +With respect to the defense concerns regarding COVID-19, the Government recognizes, as it did in its initial bail briefing, that the virus presents a challenge at any jail facility. At least for this defendant, the MDC's precautionary measures appear to have worked. When the defendant was potentially exposed to the virus, she was placed in quarantine, remained asymptomatic, tested negative, and then was released from quarantine. As the Court found at the initial bail hearing, the defendant has no underlying health conditions that would place her at greater risk of complications from COVID-19. (Tr. 89). For that same reason, the Court should again reject the suggestion that the pandemic warrants the defendant's release. + +# CONCLUSION + +As this Court previously found, the defendant "poses a substantial actual risk of flight." (Tr. 86). Nothing in the defense submission justifies altering the Court's prior conclusion that there are no conditions of bail that would assure the defendant's presence in court proceedings in this case. 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I'd like to propose 3:00. + +**From:** Martin Weinberg <[REDACTED]> +**Sent:** Tuesday, August 13, 2019 13:56 +**To:** 'Miller, Michael' <[REDACTED]>; 'Weingarten, Reid' <[REDACTED]>; [REDACTED] +<[REDACTED]> +**Cc:** [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] +(USANYS) <[REDACTED]> +**Subject:** Re: US v Epstein + +[REDACTED], finally, yes, Mike Miller and I would like to schedule a call with you. Lets us know your availability after 230 today. Thanks + +Martin G. Weinberg, Esq. + +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] + +=====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. + +On Tuesday, August 13, 2019, 12:36:55 PM EDT, [REDACTED] <[REDACTED]> +wrote: + +Marty, + +In connection with your below communication, I am copying [REDACTED], [REDACTED] of our Civil Division, whom I expect will be in touch with you directly regarding your requests. + +Regarding the review of materials seized subject to search warrants, as you mentioned in your separate email of yesterday, August 12, I expect that we will be in touch with you in the coming weeks regarding the provision of information for our privilege screening process. + +Regarding your question about the Government's intentions with respect to the Indictment, that is in progress but is ordinarily a process that can take some time. Please advise if you believe there is an emergency in connection with the timing of that process. + +Finally, can you please provide contact information for counsel for Mr. Epstein's estate (or anticipated estate, if that is not yet formally established)? If that is you, I will follow up separately regarding relevant issues, or otherwise can go directly to the right person or firm. + +I realize I have been delayed in responding to your voicemails of yesterday and today, but we were working to be able to get you appropriate answers to your queries, including the correct contacts. Please let me know if you would still like to schedule a phone call to discuss any of the above. + +thank you, + +[REDACTED] + +--- + +**From:** Martin G. Weinberg <[REDACTED]> +**Sent:** Sunday, August 11, 2019 15:55 +**To:** [REDACTED] <[REDACTED]>; 'Miller, Michael' <[REDACTED]>; 'Weingarten, Reid' <[REDACTED]> +**Cc:** [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]>; 'Martin G. Weinberg' <[REDACTED]> +**Subject:** RE: US v Epstein + +[REDACTED], Mr. Epstein's family has asked me to send to you and [REDACTED] at the MCC a request for the preservation of any and all documents, records, reports, videos, pictures, physical evidence, electronic communication data, tape recordings, logs, notes, papers, emails and any and all other forms of information that would be in the possession of the MCC, its Warden, their legal counsel, the USMS, the FBI, the Inspector General, the USAO for the SDNY or any other federal or relevant state or city agency that relate to Jeffrey Epstein's imprisonment/detention since July 6, 2019 and that relate particularly but not exclusively to the July 23, 2019 occurrence which was investigated as an attempted suicide by the MCC and the events relating to his death on August 10, 2019. The request encompasses but is not limited to any videos of the 9th floor area in the proximity of his cell during the evening of August 9 through the time Mr. Epstein was taken out of his cell for the last time on August 10, 2019, or videos of the cell itself during that time period, records of the identities of (i.e. MCC employees or independent contractors or anyone else) who were on duty from midnight through 8 AM on August 10, 2019 or otherwise had access to the 9th floor unit where Mr. Epstein was incarcerated during this time period, records of any observations of Mr. Epstein on August 9-10, 2019, any and all photographs of Mr. Epstein or his cell taken on August 10, 2019, any and all electronic or tape recordings or records of any internal communications within the MCC or any external communications by MCC staff on August 9 and August 10, 2019, records of any mental health interviews or assessments of Mr. Epstein at anytime during his detention, records of any decision to put him on or take Mr Epstein off suicide watch, photos of his cell taken on or before August 9 or on or after August 10, 2019, memoranda of interviews with any prisoners who were in Mr. Epstein's SHU unit on the 9th floor on or about July 23 or on August 9-10, 2019 relating to Mr. Epstein, the same request for interview memoranda of any MCC employee or independent contractor or any other person in the MCC midnight-8 AM August 10, 2019, any and all medical and EMS and hospital records from July 23 and/or August 10, 2019, and the future pathology and + +toxicology and medical examiner's reports. Additionally, we would request the preservation of any note or notes found in Mr. Epstein's cell on August 10, 2019, any ligature or other physical evidence related to his cause of death, any bedding, any medication or vitamins, any log showing who entered or were present in the MCC for the 12 hour period before 6:30 AM on August 10, 2019, as well as a list of inmates who were in Mr. Epstein's unit during the evening of August 9 and the morning of August 10, 2019. We would in addition to the preservation request ask for the production of all of the above. We would receive and retain in subject any information received in response to this request subject to the terms and conditions of our Protective Order. In short, the family requests a preservation and production of any and all records and documents relevant to his detention, treatment, and death. I will send an identical request to Mr (as well as to Mark Epstein's personal counsel + +Thank you for your consideration of these requests and your ongoing assistance + +Martin Weinberg + +Martin G. Weinberg, Esq. + +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. + +From: Laia I Sent: Saturday, August 10 2019 7:31 PM To: Miller, Michael ; Marlin G. Weinberg <->; Weingarten, Reid Cc: Subject: RE: US v Epstein + +Mike, Marty, Reid, + +I just wanted to let you know that I don't expect we'll have any further updates today, and so wanted to send you a brief note to let you know that since we hadn't otherwise been in touch since earlier this afternoon. I imagine we will continue to be in contact in the coming days; meanwhile, I appreciate you being in touch today, and I hope the investigations of these events will be thorough and swift. + +respectfully, + +From: + +Sent: Saturday, August 10 2019 14:14 + +To: Miller. Michael ; Martin G. Weinberg < ; Weingarten, Reid + +Cc: ) + +Subject: RE: US v Epstein + +Following up on the below, wanted to make sure the attached letter from the Warden immediately got to Mike as well (in addition to Marty and Reid having been copied and emailed). As the letter indicates, there are now investigations ongoing, including as initiated by the Attorney General himself. Separately, we have not received additional information on topics such as the apparent cause of death, the status of observation of Mr. Epstein at the time, etc., but we will continue to be in touch immediately if that changes. + +thank you, + +From: + +Sent: Saturday, August 10 2019 11:57 + +To: Miller. Michael ; Martin G. Weinberg <->; Weingarten, Reid + +Cc: ) >; + +Subject: Re: US v Epstein + +Mike, Marty, Reid, + +Following up on my conversations with Mike and Marty this morning, and my discussion with Mike moments ago, attached is a press release just sent to us (and I believe also issued publicly) some minutes ago. It represents all the information we have from BOP so far, but of course if we are successful in our continuing efforts to get additional information we will pass it along immediately. + +Separately, we can tell you that the reports that an FBI investigation into the death has been initiated are accurate, and I fully expect that investigation to be extremely rigorous. + +As always please don't hesitate to reach out to us directly at any time if that would be useful. + +thank you, \ No newline at end of file diff --git a/marker2/ds9/EFTA00089188/EFTA00089188.metadata.json b/marker2/ds9/EFTA00089188/EFTA00089188.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..53f55469e1ebe1dc2a160a223120aad5f9c61ca9 --- /dev/null +++ b/marker2/ds9/EFTA00089188/EFTA00089188.metadata.json @@ -0,0 +1,136 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089188.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 4, + "chars": 8767, + "elapsed_seconds": 12.05, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 63 + ], + [ + "Text", + 28 + ], + [ + "Line", + 28 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 13 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 57 + ], + [ + "Line", + 29 + ], + [ + "Text", + 10 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 3, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 57 + ], + [ + "Line", + 29 + ], + [ + "Text", + 19 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089188" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089192/EFTA00089192.md b/marker2/ds9/EFTA00089192/EFTA00089192.md new file mode 100644 index 0000000000000000000000000000000000000000..94f915d7c898094a4e3ab085f20223bac0568205 --- /dev/null +++ b/marker2/ds9/EFTA00089192/EFTA00089192.md @@ -0,0 +1,27 @@ +To: + +Cc: + +Subject: Subpoenas Re Ghislaine Maxwell + +Date: Fri, 16 Aug 2019 19:46:38 +0000 + +Attachments: Maxwell Chase\_Bank\_Ridendocx; Maxwell\_Experian\_Rider.docx; Maxwell MoneyGram\_Riderdocx; Maxwell\_UBS\_Financial\_Services\_Rider.docx; Maxwell Western \_ Union \_ Ridenclocx + +Please prepare and return to me subpoenas for Chase, UBS Financial Services, MoneyGram, Western Union and Experian regarding Ghislaine Maxwell. I have attached the riders for the subpoenas. I will serve the subpoenas. + +Additionally, please utilize the following text in the subpoenas: + +If you have any questions, lease contact Forensic Accountant it at or Special Agent + +Please forward the results in an electronic format to Special Agen' Investigation, New York, NY 10278, telephone Federal Bureau of + +If you have any questions or comments, please contact me. + +Thanks + +Forensic Accountant FBI New York Field Office + +NYC, NY 10278 + +Office: \ No newline at end of file diff --git a/marker2/ds9/EFTA00089192/EFTA00089192.metadata.json b/marker2/ds9/EFTA00089192/EFTA00089192.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..77146bf06113b952eb47abab7f03073ea9d9d7c1 --- /dev/null +++ b/marker2/ds9/EFTA00089192/EFTA00089192.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089192.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 922, + "elapsed_seconds": 0.83, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 49 + ], + [ + "Line", + 24 + ], + [ + "Text", + 17 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089192" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089193/EFTA00089193.md b/marker2/ds9/EFTA00089193/EFTA00089193.md new file mode 100644 index 0000000000000000000000000000000000000000..f4403aecbae036ee020251b299d8bf58f437983a --- /dev/null +++ b/marker2/ds9/EFTA00089193/EFTA00089193.md @@ -0,0 +1,46 @@ +JP Morgan Chase Bank N.A. And All Affiliates National Subpoena Processing 7610 West Washing Street Indianapolis, Indiana 46231-1335 Fax Number: + +Delivered via: FAX + +Rider + +## ALL OPEN AND CLOSED ACCOUNTS + +Please provide all images of documents in Adobe PDF files on CDs. Additionally, please provide Data Transaction Files in Excel of all account statements. + +Please provide from inception to present any and all records pertaining to the following accounts(s)/organization(s)/individuals(s) whether held jointly or severally or as trustee or fiduciary as well as custodian, executor or guardian: + +A. Please use the following identifiers: + +| NAME | GHISLAINE MAXWELL | +|---------|--------------------------------------------------| +| DOB | [REDACTED] | +| SSN | [REDACTED] | +| ADDRESS | [REDACTED] BOSTON, MA
[REDACTED] NEW YORK, NY | +| PHONE | [REDACTED] | +| EMAIL | [REDACTED] | +| ACCT# | [REDACTED] | + +B. Records to be produced should include but are not limited to the items listed below: + +- 1. Documents (checks, debit memos, cash in tickets, wires in, wires out, etc.) reflecting additions and/or subtractions to the account and how the account balances are being satisfied on a monthly basis; + +- 2. Signature cards; +- 3. Proof of identification (including but not limited to copies of identification used to open the account); +- 4. Location of withdrawals +- 5. Opening account(s) documents with attachments, including any and all applications, internal documents generated to open account(s), and identification information or other documentation provided by Customer; +- 6. "Know your customer" documentation; +- 7. Wire transfer records (incoming and outgoing, and any and all applications and instructions); +- 8. "Quick Pay" transaction detail including counterparty information; +- 9. Safe deposit records, including applications, signature cards, and sign-in records; +- 10. Trust accounts; +- 11. Monthly statements; +- 12. Credit card statements; +- 13. Bank, travelers, or cashier checks drawn on account or purchased with an account check; +- 14. Prepaid debit cards, certified checks, cashiers' checks, money orders, and traveler's checks; +- 15. Loan, lease, and/or mortgage application files (whether granted or denied) including credit reports, applications, and payments made on loans; +- 16. Any and all corporate resolutions, certifications of incorporation, business certificates and/or partnership agreements; +- 17. Online banking information- All information regarding the electronic use of banking systems to include the following: username, registration IP address, online account creation date, online account status and IP logs/history, MAC addresses and online session times and duration; and +- 18. Any and all correspondence, electronic or otherwise, including memoranda, emails and text messages, that reference or concern items (1) through (17), above, and/or any financial interests involving the individuals and/or entities identified in Section A. + +If you have any questions or comments, please contact S Forensic Accountant, at \ No newline at end of file diff --git a/marker2/ds9/EFTA00089193/EFTA00089193.metadata.json b/marker2/ds9/EFTA00089193/EFTA00089193.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..f8d1ea419588690f66c38c1a8044b8cd64f5c3ad --- /dev/null +++ b/marker2/ds9/EFTA00089193/EFTA00089193.metadata.json @@ -0,0 +1,132 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089193.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 3295, + "elapsed_seconds": 1.21, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "ALL OPEN AND CLOSED ACCOUNTS", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 225.99000000000004 + ], + [ + 230.80508422851562, + 225.99000000000004 + ], + [ + 230.80508422851562, + 239.21759033203125 + ], + [ + 68.544, + 239.21759033203125 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 53 + ], + [ + "Line", + 27 + ], + [ + "Text", + 7 + ], + [ + "SectionHeader", + 1 + ], + [ + "Table", + 1 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ], + [ + "ListItem", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 55 + ], + [ + "Line", + 28 + ], + [ + "ListItem", + 17 + ], + [ + "ListGroup", + 1 + ], + [ + "Text", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089193" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089195/EFTA00089195.md b/marker2/ds9/EFTA00089195/EFTA00089195.md new file mode 100644 index 0000000000000000000000000000000000000000..c77e1044e3565227601b0dc1018bcc843f80b1c2 --- /dev/null +++ b/marker2/ds9/EFTA00089195/EFTA00089195.md @@ -0,0 +1,16 @@ +Experian Information Solutions, Inc. 701 Experian Parkway Allen, Tx 75013 Attn: Subpoena Compliance Dept. + +Please provide any and all credit reports, fraud alerts, and related documents pertaining to the following individuals listed, including all known accounts and lines of credit, addresses and personal identifying information, and all credit inquiries regarding the individuals and the addresses provide at the time of said inquiry regardless of whether accounts were open. + +Please utilize the identifiers below: + +| NAME | GHISLAINE MAXWELL | +|---------|--------------------------------------------------| +| DOB | [REDACTED] | +| SSN | [REDACTED] | +| ADDRESS | [REDACTED] BOSTON, MA
[REDACTED] NEW YORK, NY | +| PHONE | [REDACTED] | + +If you have any questions, please contact Forensic Accountant a Mier Special Agent at Please forward the results in an electronic format to Special Agen Federal Bureau of Investigation New York, NY 10278, telephone + +The Government hereby requests that you voluntarily refrain from disclosing the existence of the subpoena to any third party. While you are under no obligation to comply with our request, we are requesting you not to make any disclosure in order to preserve the confidentiality of the investigation and because disclosure of the existence of this investigation might interfere with and impede the investigation. If you intend to disclose the existence of this subpoena to a third party, please let a Special Agent know before making any such disclosure. \ No newline at end of file diff --git a/marker2/ds9/EFTA00089195/EFTA00089195.metadata.json b/marker2/ds9/EFTA00089195/EFTA00089195.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..b4408866160d405597323fda3e403d7264c7c155 --- /dev/null +++ b/marker2/ds9/EFTA00089195/EFTA00089195.metadata.json @@ -0,0 +1,58 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089195.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1667, + "elapsed_seconds": 0.88, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 49 + ], + [ + "Line", + 25 + ], + [ + "Text", + 5 + ], + [ + "Table", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089195" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089196/EFTA00089196.md b/marker2/ds9/EFTA00089196/EFTA00089196.md new file mode 100644 index 0000000000000000000000000000000000000000..31cad2f015527fb686e46827e82416af79609162 --- /dev/null +++ b/marker2/ds9/EFTA00089196/EFTA00089196.md @@ -0,0 +1,19 @@ +MoneyGram International, Inc. Attn: Global Subpoena Processing 1550 Utica Avenue South MS: MBC-5508 Minneapolis, MN 55416 + +Delivered via: Email — + +The following are the items that are required to be provided by the attached Subpoena: + +For the period of inception thru today, any and all available information regarding money transfers, the purchase of money orders, including but not limited to, senders name and address, location of purchase including name and address of selling agent, form of payment used to purchase money orders, amount of money orders purchased, date and time of purchase, the payee's name and address, the amount and currency distributed. + +Please utilize the following identifiers: + +| NAME | GHISLAINE MAXWELL | +|---------|--------------------------------------| +| DOB | [REDACTED] | +| SSN | [REDACTED] | +| ADDRESS | [REDACTED] BOSTON, MA | +| PHONE | [REDACTED] NEW YORK, NY | +| EMAIL | [REDACTED] | + +If you have any questions or comments, please contact , Forensic Accountant, at Mr at \ No newline at end of file diff --git a/marker2/ds9/EFTA00089196/EFTA00089196.metadata.json b/marker2/ds9/EFTA00089196/EFTA00089196.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..7f2d4ff72b28752feb19b913f1969b8ddf0df7b5 --- /dev/null +++ b/marker2/ds9/EFTA00089196/EFTA00089196.metadata.json @@ -0,0 +1,58 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089196.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1150, + "elapsed_seconds": 5.68, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 49 + ], + [ + "Line", + 23 + ], + [ + "Text", + 6 + ], + [ + "Table", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089196" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089197/EFTA00089197.md b/marker2/ds9/EFTA00089197/EFTA00089197.md new file mode 100644 index 0000000000000000000000000000000000000000..4c65df43ff4c15c7310bfd13a876251eb160fd0e --- /dev/null +++ b/marker2/ds9/EFTA00089197/EFTA00089197.md @@ -0,0 +1,55 @@ +UBS Financial Services, Inc. + +1000 Harbor Blvd + +8th Floor + +Weehawken, NJ 07086 + +Attention: SLG (Subpoenas, Levies and Garnishments) + +Delivered via: FedEX + +## Rider + +## ALL OPEN AND CLOSED ACCOUNTS + +Please provide all images of documents in Adobe PDF files on CDs. Additionally, please provide Data Transaction Files in Excel of all account statements. + +Please provide from inception to present any and all records pertaining to the following accounts(s)/organization(s)/individuals(s) whether held jointly or severally or as trustee or fiduciary as well as custodian, executor or guardian: + +A. Please use the following identifiers: + +| NAME | GHISLAINE MAXWELL

TERRAMAR PROJECT INC.

ELLMAX LLC

MAX FOUNDATION

MAX HOTEL SERVICES CORP | +|---------|-----------------------------------------------------------------------------------------------------------------------| +| DOB | [REDACTED] | +| SSN | [REDACTED] | +| ADDRESS | [REDACTED] BOSTON, MA

[REDACTED] NEW YORK, NY | +| PHONE | [REDACTED]
[REDACTED]
[REDACTED] | +| EMAIL | [REDACTED] | +| DLN | | +| ACCT# | [REDACTED] (UBS – TERRAMAR) | + +UBS - ELLMAX) UBS - MAXWELL) (UBS - MAX FOUNDATION) UBS - MAX HOTEL) + +## B. Records to be produced should include but are not limited to the items listed below: + +- 1. Documents (checks, debit memos, cash in tickets, wires in, wires out, etc.) reflecting additions and/or subtractions to the account and how the account balances are being satisfied on a monthly basis; +- 2. Signature cards; +- 3. Proof of identification (including but not limited to copies of identification used to open the account); +- 4. Location of withdrawals +- 5. Opening account(s) documents with attachments, including any and all applications, internal documents generated to open account(s), and identification information or other documentation provided by Customer; +- 6. "Know your customer" documentation; +- 7. Wire transfer records (incoming and outgoing, and any and all applications and instructions); +- 8. Safe deposit records, including applications, signature cards, and sign-in records; +- 9. Trust accounts; +- 10. Monthly statements; +- 11. Credit card statements; +- 12. Bank, travelers, or cashier checks drawn on account or purchased with an account check; +- 13. Prepaid debit cards, certified checks, cashiers' checks, money orders, and traveler's checks; +- 14. Loan, lease, and/or mortgage application files (whether granted or denied) including credit reports, applications, and payments made on loans; +- 15. Any and all corporate resolutions, certifications of incorporation, business certificates and/or partnership agreements; +- 16. Online banking information- All information regarding the electronic use of banking systems to include the following: username, registration IP address, online account creation date, online account status and IP logs/history, MAC addresses and online session times and duration; and +- 17. Any and all correspondence, electronic or otherwise, including memoranda, emails and text messages, that reference or concern items (1) through (16), above, and/or any financial interests involving the individuals and/or entities identified in Section A. + +If you have any questions or comments, please contact Forensic Accountant, at \ No newline at end of file diff --git a/marker2/ds9/EFTA00089197/EFTA00089197.metadata.json b/marker2/ds9/EFTA00089197/EFTA00089197.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..78b6c3c60436764558b6c024210652c7e29eab15 --- /dev/null +++ b/marker2/ds9/EFTA00089197/EFTA00089197.metadata.json @@ -0,0 +1,174 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089197.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 3969, + "elapsed_seconds": 1.78, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Rider", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 290.7, + 210.60000000000002 + ], + [ + 321.0067443847656, + 210.60000000000002 + ], + [ + 321.0067443847656, + 223.46759033203125 + ], + [ + 290.7, + 223.46759033203125 + ] + ] + }, + { + "title": "ALL OPEN AND CLOSED ACCOUNTS", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 241.38 + ], + [ + 230.80508422851562, + 241.38 + ], + [ + 230.80508422851562, + 254.34 + ], + [ + 68.544, + 254.34 + ] + ] + }, + { + "title": "B. 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Belford Ave, M21A2 + +Englewood, CO 80112 + +Phone Number: + +Delivered via: Email — + +The following are the items that are required to be provided by the attached Subpoena: + +For the period of inception thru today, any and all available information regarding money transfers, the purchase of money orders, including but not limited to, senders name and address, location of purchase including name and address of selling agent, form of payment used to purchase money orders, amount of money orders purchased, date and time of purchase, the payee's name and address, the amount and currency distributed. + +Please utilize the following identifiers: + +| NAME | GHISLAINE MAXWELL | +|---------|------------------------| +| DOB | | +| SSN | | +| ADDRESS | [REDACTED], BOSTON, MA | +| | [REDACTED] NY | +| PHONE | [REDACTED] | +| | [REDACTED] | +| EMAIL | [REDACTED] | + +If you have any questions or comments, please contact or atil li Forensic Accountant, at \ No newline at end of file diff --git a/marker2/ds9/EFTA00089199/EFTA00089199.metadata.json b/marker2/ds9/EFTA00089199/EFTA00089199.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..043aeaa40a4ddad798450c50703ad1cc2eeee630 --- /dev/null +++ b/marker2/ds9/EFTA00089199/EFTA00089199.metadata.json @@ -0,0 +1,58 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089199.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1139, + "elapsed_seconds": 1.17, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 51 + ], + [ + "Line", + 24 + ], + [ + "Text", + 10 + ], + [ + "Table", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089199" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089200/EFTA00089200.md b/marker2/ds9/EFTA00089200/EFTA00089200.md new file mode 100644 index 0000000000000000000000000000000000000000..417b8c9308b9491b4d03e33b269a73c37baf6bbe --- /dev/null +++ b/marker2/ds9/EFTA00089200/EFTA00089200.md @@ -0,0 +1,19 @@ +To: "Robert C. Josefsbe + +Cc: + +Subject: Epstein victims + +Date: Mon, 19 Aug 2019 18:04:20 +0000 + +Bob, + +We've discussed victim resources before, but I wanted to follow up as a reminder to say that if any of your clients would like counseling or other victim services, please let them know that they are encouraged to contact the case agent on this case, who can put them in touch with victim services at FBI. The agent is Special Agent , and her phone number is . We recognize that this is a complicated and stressful time for victims, so we wanted to remind you that resources are available. + +Our team is always available if issues come up, so please feel free to give us a call. + +Thanks, + +Assistant United States Attorney Southern District of New York + +New York, NY 10007 \ No newline at end of file diff --git a/marker2/ds9/EFTA00089200/EFTA00089200.metadata.json b/marker2/ds9/EFTA00089200/EFTA00089200.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..fa7f1aa1db3eb4f34e545341e0c26b7f8128048f --- /dev/null +++ b/marker2/ds9/EFTA00089200/EFTA00089200.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089200.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 770, + "elapsed_seconds": 0.75, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 36 + ], + [ + "Line", + 17 + ], + [ + "Text", + 16 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089200" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089201/EFTA00089201.md b/marker2/ds9/EFTA00089201/EFTA00089201.md new file mode 100644 index 0000000000000000000000000000000000000000..692fd92da2df19c3b696a86ed058daf4071559d2 --- /dev/null +++ b/marker2/ds9/EFTA00089201/EFTA00089201.md @@ -0,0 +1,145 @@ +To: Teri Gibbs + +Cc: ' " , ' + +, Colleen Mullen + +Subject: RE: CONFIDENTIAL: Victim Reports Against Jeffrey Epstein, 19 Cr. 490 (RMB) + +Date: Mon, 19 Aug 2019 17:02:18 +0000 + +Inline-Images: image00 ljpg; image002.jpg + +Teri, + +For our meeting with Ms. :m August 26th, would it be possible to switch the time to 10:30 a.m. that morning? I believe Ms. vill be traveling down the day before, so hopefully that timing would work, be let us know if that's an issue and we can sort it out. + +Thanks, + +From: Teri Gibbs + +Sent: Thursday, August 8, 2019 8:15 PM + +To: sc= > + +Cc: + +Colleen Mullen + +Subject: Re: CONFIDENTIAL: Victim Reports Against Jeffrey Epstein, 19 Cr. 490 (RMB) + +Great. Thank you. I will contact in a separate email. + +Best, + +Teri + +On Thu, Aug 8, 2019 at 12:50 PM > wrote: + +Great, sounds good, and thank you. I've copied here, so that you can coordinate with her directly regarding travel arrangements for Ms. -If, after iscussing travel, it makes more sense to meet at a different time on 8/26, please let us know, that's not a problem. + +From: Ted Gibbs + +Sent: Thursday, August 8, 2019 3:32 PM + +To: + +Cc: •S; • + +Colleen Mullen < Arick Fudali + +Subject: Re: CONFIDENTIAL: Victim Reports Against Jeffrey Epstein, 19 Cr. 490 (RMB) + +Hi + +Great. Collen Mullen, who I have cc'd, and I can coordinate Ms. travel with For Ms. will provide you with the video conference logistics c oser to the date of the interview. We will + +Best, + +Teri + +On Thu, Aug 8, 2019 at 12:11 PM wrote: + +Hi Ted, + +That sounds great, thanks. On scheduling, we'll plan to meet with Ms. n 12 p.m. on 8/26 at our office, and we will plan to speak with Ms by video conference at 5 p.m. on 8/27. + +Regarding travel logistics for Ms. our office has a witness coordinator who can make travel arrangements. Let us know if there is someone at your office she should connect with to discuss arrangements, or whether you would like her to coordinate with your client directly to arrange travel. + +As for the video conference logistics, if you could please provide us with dial in information as we get closer, that would be great. + +Thanks, + +From: Ted Gibbs + +Sent: Thursday, August , + +To: + +Cc: + +; Lisa Bloom ; Arick Fudali < + +Colleen Mullen + +Subject: Re: CONFIDENTIAL: Victim Reports Against Jeffrey Epstein, 19 Cr. 490 (RMB) + +Thank you for your email. available to meet with you on 8/26 at 12 PM. Please send us details regarding her travel arrangements and the meeting location. Our New York attorney, Arick Fudali, will accompany Ms. + +Ms. Mks available for a video conference on either 8/26 or 8/27 between the hours of 9 AM and 5 PM EST. As we intend to be on the call with Ms. we propose to schedule the call for 5 PM EST/2 PM PST/6 AM Okinawa Time. + +Best regards, + +Teri + +On Wed, Aug 7, 2019 at 2:03 PM ) < > wrote: + +Teri, + +Thanks very much for reaching out regarding scheduling. We would propose meeting at 12 p.m. on 8/26 with Ms. f that is convenient for her. For Ms. Nil given the time zone difference, could you please let us know what times would work for a video conference wi er on either 8/26 or 8/27? + +Assistant United States Attorney Southern District of New York New York. NY 10007 + +From: Ted Gibbs + +Sent: Monday, August 5, 2019 6:52 PM + +To: + +Cc: + +>; Lisa Bloom ; .• • + +Great. Thank you. I will contact in a separate email. + +Best, + +Teri + +On Thu, Aug 8, 2019 at 12:50 PM > wrote: + +Great, sounds good, and thank you. I've copied sere, so that you can coordinate with her directly regarding travel arrangements for Ms. . If, after discussing travel, it makes more sense to meet at a different time on 8/26, please let us know, that's not a problem. + +From: Ted Gibb + +Sent: Thursday, August 8, 2019 3:32 PM + +To: + +Cc: Colleen Mullen < Arick Fudali + +Subject: Re: CONFIDENTIAL: Victim Reports Against Jeffrey Epstein, 19 Cr. 490 (RMB) + +Hi .= + +Great. Cohen Mullen, who I have cc'd, and I can coordinate Ms avel with For Ms. iwe will provide you with the video conference logistics closer to the date of the interview. We will likely use Skype, the computer application. + +Best, + +Teri + +On Thu, Aug 8, 2019 at 12:11 PM ) < > wrote: + +Hi Teri, + +That sounds great, thanks. On scheduling, we'll plan to meet with Ms.fl 12 p.m. on 8/26 at our office, and we will plan to speak with Ms. video conference at 5 p.m. on 8/27. + +Regarding travel logistics for Ms. ur office has a witness coordinator avho can make travel arrangements. Let us know i ere is someone at your office she should connect with to discuss arrangements, or whether you would like her to coordinate with your client directly to arrange travel. + +As for the video conference logistics, if you could please provide us with dial in information as we get closer, that would be great. + +Thanks, + +From: Teri Gibbs > + +Sent: Thursday, August 8, 2019 1:45 PM + +To: + +Cc: 'c ›; + +>; Lisa Bloom
  • ; + +Thank ou for takin the time to s eak with our firm on Friday, August 2, 2019, regarding our clients, who believe they were assaulted by Epstein in or around June 2004. + +We have confirmed our clients' availability for interviews with your office. Ms. is available for an in-person interview on August 26, 2019, or August 27, 2019. Ms. who is located in Japan, is available for an interview via video conference, preferably the week of August 26th. Please confirm whether your office is avail i meet with Ms. n those dates and whether we can arrange a video conference for Ms. + +Additionally, as discussed in our call, we have attached two PDF files for your review which contain pictures of Ms nd Ms. Mom 2004. If possible, please confirm whether our clients are in any of the photograp s seized from Epstein's home. + +Thank you. We look forward to hearing from you soon. + +Best regards, + +Teri Gibbs + +Notice To Recipient: This e-mail is meant for only the intended reopient of the transmission, and may be a communication pnwleged by law. If you received this e-mail in error. any review, use. dissemination. distribution. or copying of this e-mail's strictly prohibited. Please notify us immediately of the error by return email and ptease delete this message and any and all duplicates of this message from your system. Thank you in advance for your cooperation. + +IRS Circular 230 Disclosure: In cider to comply with requirements imposed by the Internal Revenue Service. we inform you that any U.S. tax adwce contained in this commumcabon (including any attachments) is not intended to be used, and cannot be used. for the purpose of 0) avoiding penalties under the Internal Revenue Code or (s) promoting. marketing. or recommending to another party any transaction or matter addressed herein. + +Notice To Recipient: This e-mail is meant for only the intended recipient of the transmission, and may be a communication privileged by law. If you received this email in error, any review, use. dissemination. drstribution, or copying of this e-mail is strictly prohibited. Please notify us imme:bately of the error by return e-mail and please delete this message and any and all duplicates of this message from your system. Thank you in advance for your cooperation. + +IRS Crcular 230 Disclosure: In order to comply wilh requirements imposed by the Internal Revenue Service. we inform you that any U.S. tax advice contained in this communication (including any attachments) is not intended to be used. and cannot be used. for the purpose of 0) avoiding penalties under the Internal Revenue Code or (s)promobng. marketeng. or recommending to another party any transaction or matter addressed herein. + +Notice To Recipient: This e-mail is meant for only the intended recipient of the transmission, and may be a communication privileged by law. If you received this e-mail in error, any review. use. dissemination. distribution. or copying of this e-mail is stncdy prohibited. Please notify us rnmediately of the error by return e-mail and please delete this message and any and all duplicates of this message from your system. Thank you in advance for your cooperation. + +IRS Circular 230 Disclosure: In ceder to comply with requirements mposed by the Internal Revenue Service. we inform you that any U.S. tax advice contained in this communication (including any attachments) is not intended to be used. and cannot be used. for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting. markebng, or recommending to another party any transaction or matter addressed herein. + +Notice To Recipient: This e-mail is meant for only the intended recipient of the transmission, and may be a communication pnvileged by law. If you received this e-mail in error. any review. use. disseminabon. distribution. or copying of this e-mail is strictly prohibited. Please notify us immediately of the error by return e- mad and please delete this message and any and all duplicates of this message from your system. Thank you in advance for your cooperation. + +IRS Circular 230 Disclosure: In order to comply wth requirements imposed by the Internal Revenue Service, we inform you that any U.S. tax advice contained in this communication (including any attachments) is not intended to be used, and cannot be used, for the purpose of 0) avoiding penalties under the Internal Revenue Code or (s) promoting. marketing. or recommending to another party any transaction or matter addressed herein. + +Notice To Recipient: This e-mail is meant for orty the intended recipient of the transmission. and may be a communication privileged by law. If you received this e-mail in error, any review, use, dtssemination, distribution, or copying of this e-mail is strictly prohibited. Please notify us immediately of the error by return e-mail and please delete this message and any and all dupbcates of this message from your system. Thank you in advance for your cooperation, + +IRS Circular 230 Disclosure: In order to comply with requirements imposed by the Interns Revenue Service. we inform you that any U.S. tax advice contained in this communication (including any attachments) is not intended to be used, and cannot be used, for the purpose of (\*avoiding penalties under the Internal Revenue Code or (s) promoting. marketing. or recommending to another party any transaction or matter addressed herein. \ No newline at end of file diff --git a/marker2/ds9/EFTA00089206/EFTA00089206.metadata.json b/marker2/ds9/EFTA00089206/EFTA00089206.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..1d43a70b1b5b539c02ce911bc1967145eece2e10 --- /dev/null +++ b/marker2/ds9/EFTA00089206/EFTA00089206.metadata.json @@ -0,0 +1,204 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089206.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 6, + "chars": 9429, + "elapsed_seconds": 1.75, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 68 + ], + [ + "Line", + 33 + ], + [ + "Text", + 26 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 84 + ], + [ + "Line", + 38 + ], + [ + "Text", + 22 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 79 + ], + [ + "Line", + 35 + ], + [ + "Text", + 25 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 3, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 45 + ], + [ + "Line", + 22 + ], + [ + "Text", + 11 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 4, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 24 + ], + [ + "Line", + 13 + ], + [ + "Text", + 4 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 5, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 25 + ], + [ + "Line", + 13 + ], + [ + "Text", + 4 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089206" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089212/EFTA00089212.md b/marker2/ds9/EFTA00089212/EFTA00089212.md new file mode 100644 index 0000000000000000000000000000000000000000..1a0a6727bff8b4eb4ef654cee54a1c1d3507e781 --- /dev/null +++ b/marker2/ds9/EFTA00089212/EFTA00089212.md @@ -0,0 +1,34 @@ +**From:** "[REDACTED]" <[REDACTED]> + +**To:** [REDACTED] <[REDACTED]> + +**Subject:** RE: Reference question + +**Date:** Mon, 19 Aug 2019 21:07:23 +0000 + +--- + +Excellent, thank you! + +**From:** [REDACTED] <[REDACTED]> + +**Sent:** Monday, August 19, 2019 5:02 PM + +**To:** [REDACTED] <[REDACTED]> + +**Subject:** Re: Reference question + +[REDACTED] + +- • Attended witness interviews, proffers and interviews in preparation for a grand jury hearing. (You) +- • Performed legal research for Epstein matter. (You) + +[REDACTED] + +Thank you! + +[REDACTED] + +[REDACTED] + +![](_page_1_Picture_0.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00089212/EFTA00089212.metadata.json b/marker2/ds9/EFTA00089212/EFTA00089212.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..b44a7911cc351aa55598443e91ee883b84978aae --- /dev/null +++ b/marker2/ds9/EFTA00089212/EFTA00089212.metadata.json @@ -0,0 +1,90 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089212.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 573, + "elapsed_seconds": 3.43, + "image_assets": [ + "_page_1_Picture_0.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 28 + ], + [ + "Span", + 25 + ], + [ + "Line", + 13 + ], + [ + "ListGroup", + 2 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ], + [ + "Line", + 1 + ], + [ + "Span", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089212" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089212/_page_1_Picture_0.jpeg b/marker2/ds9/EFTA00089212/_page_1_Picture_0.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..9f24aa6296ebd0e565c52c0187cb6c275c69f61c --- /dev/null +++ b/marker2/ds9/EFTA00089212/_page_1_Picture_0.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:9b340cc2b309fd77b2f9046d1f92fdd4c236aaf6c03649062bf522595996eabf +size 3399 diff --git a/marker2/ds9/EFTA00089214/EFTA00089214.md b/marker2/ds9/EFTA00089214/EFTA00089214.md new file mode 100644 index 0000000000000000000000000000000000000000..c4a5e998402bdb84289661f7fc475f80c49ae6e1 --- /dev/null +++ b/marker2/ds9/EFTA00089214/EFTA00089214.md @@ -0,0 +1,17 @@ +To: Gloria Allred + +Cc: ' . > I , + +Subject: 8/27 Conference + +Date: Thu, 22 Aug 2019 17:56:32 +0000 + +Gloria, + +Judge Berman has scheduled a conference regarding the dismissal of the indictment in light of Epstein's death for Tuesday, August 27th at 10:30am in Courtroom 17B of the 500 Pearl Street courthouse. The order scheduling the conference indicated that Judge Berman will allow victims to be heard—either directly or through their counsel—during the proceeding. If any of your clients would like to attend the conference but cannot afford the travel costs, can provide assistance in arranging travel. They are certainly not required to attend, but we wanted to let you know that the option is available. + +Feel free to give me a call if you have any questions or would like to discuss. + +Best, + +Assistant United States Attorney Southern District of New York 1 St. Andrew's Plaza New York, NY 10007 \ No newline at end of file diff --git a/marker2/ds9/EFTA00089214/EFTA00089214.metadata.json b/marker2/ds9/EFTA00089214/EFTA00089214.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..54b67c59816229a4993e3c35a0df9cfee17436ef --- /dev/null +++ b/marker2/ds9/EFTA00089214/EFTA00089214.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089214.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 899, + "elapsed_seconds": 0.71, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 46 + ], + [ + "Line", + 21 + ], + [ + "Text", + 14 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089214" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089215/EFTA00089215.md b/marker2/ds9/EFTA00089215/EFTA00089215.md new file mode 100644 index 0000000000000000000000000000000000000000..af949760358bc4216188db1770c3c649f9476b1d --- /dev/null +++ b/marker2/ds9/EFTA00089215/EFTA00089215.md @@ -0,0 +1,19 @@ +To: + +Cc: + +Subject: Victim contact list + +Date: Tue, 20 Aug 2019 18:31:56 +0000 + +Attachments: 2019.08.20 JE\_Victim\_List.xlsx + +Hi + +Following up on our meeting yesterday, attached is the updated spreadsheet of all identified victims and noting which ones have been contacted. Would you please review this with the FBI victim specialists to note any additional contact with victims since Epstein's death? And if there are still any victims in this spreadsheet who have not been contacted since Epstein's death, would you please attempt to contact them and make a note of those attempts in the spreadsheet? + +Give me a call if you have any questions, and thanks so much for your help with this. + +Assistant United States Attorney ew York + +New York, NY 10007 \ No newline at end of file diff --git a/marker2/ds9/EFTA00089215/EFTA00089215.metadata.json b/marker2/ds9/EFTA00089215/EFTA00089215.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..6c35fe24c9bdb15a4b0d41083a96aa4194276d45 --- /dev/null +++ b/marker2/ds9/EFTA00089215/EFTA00089215.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089215.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 751, + "elapsed_seconds": 0.73, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 31 + ], + [ + "Line", + 16 + ], + [ + "Text", + 14 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089215" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089216/EFTA00089216.md b/marker2/ds9/EFTA00089216/EFTA00089216.md new file mode 100644 index 0000000000000000000000000000000000000000..6a852705f12cb9bcdadcd7994c8bb87507f299a6 --- /dev/null +++ b/marker2/ds9/EFTA00089216/EFTA00089216.md @@ -0,0 +1,33 @@ +To:' + +Cc: c'r + +Subject: Re: Epstein-Related Touhy Requests + +Date: Tue, 20 Aug 2019 18:53:49 +0000 + +Sounds good. Thanks, M. + +Sent from my iPhone + +On Aug 20, 2019, at 2:23 PM, > wrote: + +Thanks very much for reaching out —we're just waiting on final approval here on how to make the handoff, and then we'll send you the materials immediately. Hopefully later today. + +thanks, + +From: + +Sent: Tuesday, August 20, 2019 14:22 + +To: + +Subject: Epstein-Related Touhy Requests + +All, + +I'll be handling Epstein-related Touhy requests on the civil side. Could you please pass along the letters from Steptoe they sent today? Thanksl + +J. Kochevar Assistant United States Attorney Southern District of New York + +New York. New York 10007 \ No newline at end of file diff --git a/marker2/ds9/EFTA00089216/EFTA00089216.metadata.json b/marker2/ds9/EFTA00089216/EFTA00089216.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..5a4a752c1e6362908db55156bde3b4f60be48c81 --- /dev/null +++ b/marker2/ds9/EFTA00089216/EFTA00089216.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089216.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 716, + "elapsed_seconds": 0.98, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 46 + ], + [ + "Line", + 23 + ], + [ + "Text", + 22 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089216" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089217/EFTA00089217.md b/marker2/ds9/EFTA00089217/EFTA00089217.md new file mode 100644 index 0000000000000000000000000000000000000000..fdcae2f5b289c38c7e9471324615283ac6c05d64 --- /dev/null +++ b/marker2/ds9/EFTA00089217/EFTA00089217.md @@ -0,0 +1,113 @@ +From: ' )" To: ' + +Subject: RE: 2019.8.15 - SDNY Production Index.xlsx + +Date: Wed, 21 Aug 2019 20:52:14 +0000 + +Monday afternoon, Tuesday afternoon, and all day Thursday are good for me that week, thanks. + +From: Sent: Wednesday, August 21, 2019 10:41 AM To: ›; Subject: FW: 2019.8.15 - SDNY Production Index.xlsx + +I could do anytime on M/T/Th of that week — y'all? + +From: Moyne, Parvin Sent: Wednesday, August 21, 2019 09:25 To: Cc: Moyer, Thomas Subject: RE: 2019.8.15 - SONY Production Index.xlsx + +I'm so sorry for the inconvenience but those dates are not good on our end. + +The following week is relatively clear. Might September 9th work? Or other dates that week? + +Best, Parvin + +From: Sent: Tuesday, August 20, 2019 11:58 PM To: Moyne, Parvin Cc: Moyer, Thomas < Subject: RE: 2019.8.15 - SONY Production Index.xlsx + +Parvin, + +That makes good sense, thanks. Because of the scheduling issues I mentioned, we'd like to set it for a time in early September, if we can — is there a time during the afternoon of September 5 or the morning of September 6 that would work for you? We should be able to do either of those dates and times. Or if not, we can propose possible times the following week. + +thank you, + +Sent: Tuesday, August 20, 2019 14:03 + +To: > < >; + +Cc: Moyer, Thomas + +Subject: RE: 2019.8.15 - SONY Production Index.xlsx + +- + +Initially, we propose that the lawyers (myself, my colleagues at Akin Gump, and someone from ELegal) deliver a presentation that provides an overview of Epstein's relationship with the bank, the different accounts affiliated with Epstein and the types of transactions found in the accounts. We would also highlight various transactions that we have noted in our internal investigation. Our aim is that the attorney proffer would help you in sifting through the records we have provided so you can more readily identify whatever information you are most interested in. Following the proffer, if there are particular accounts or transactions of interest, we can identify the person within.who can best answer questions on those areas and that person would then meet with you. + +In terms of timing, I estimate 2-3 hours for the attorney proffer. (I think closer to 2 hours but I hate to underestimate.) + +Best, + +Parvin + +From: + +Sent: Monday, August 19, 2019 8:14 PM + +To: Moyne, Parvin + +Cc: Moyer, Thomas + +Subject: RE: 2019.8.15 - SONY Production Index.xlsx + +Parvin, + +Could you please let us know what format we should expect in terms of the proffer? That will help us with figuring out scheduling. I.e., do you expect to make an attorney proffer in the first instance, or should be expect to be meeting with personnel, etc? And approximately how long should we be planning to block out? + +thanks, + +From: Moyne, Parvin + +Sent: Monday, August 19, 2019 12:04 + +To: > <->; + +Cc: Moyer, Thomas + +Subject: RE: 2019.8.15 - SONY Production Index.xlsx + +Hi MI — + +The proffer may be helpful in guiding you through the production. That said, we can be available whenever makes most sense on your ends. + +We have time this week (Thursday or Friday afternoon) and next week (Monday — Wednesday), and we have time in September. If you give us a few options in terms of dates/times, we will sort out schedules on our ends. + +Best Parvin + +From: Sent: Saturday, August 17, 2019 1:59 PM To: Moyne, Parvin Cc: Moyer, Thomas Subject: RE: 2019.8.15 - SDNY Production Index.xlsx + +\*\*EXTERNAL Email\*\* + +Parvin, + +We received the index, thank you. In terms of a proffer, what generally did you have in mind regarding timing? I think we'd like to have some time with the subpoena returns to get familiarized, and our team has a combination of travel and trials in the next couple weeks, but we could do early September if that works on your end. Thoughts? + +thanks, + +From: Moyne, Parvin Sent: Thursday, August 15, 2019 09:48 To: c E> Cc: Moyer, Thomas Subject: 2019.8.15 - SDNY Production Index.xlsx > >; + +& + +Please find attached an index to our productions to date. This is a work in progress — we will update it as we gather and produce additional documents. + +Would you like to touch base later today about scheduling a proffer? We are free after 4 p.m. + +Best, Parvin + +Parvin Daphne Moyne + +AKIN GUMP STRAUSS HAUER Si FELD ALP + +One Bryant New York, NY 10036-6745 I USA I Direct: +1 Fax: +1 I akingump.com I Bio I Internal: MI + +The information contained in this e-mail message is intended only for the personal and confidential use of the recipient(s) named above. If you have received this communication in error, please notify us immediately by e-mail, and delete the original message. + +The information contained in this e-mail message is intended only for the personal and confidential use of the recipient(s) named above. If you have received this communication in error, please notify us immediately by e-mail, and delete the original message. + +The information contained in this e-mail message is intended only for the personal and confidential use of the recipient(s) named above. If you have received this communication in error, please notify us immediately by e-mail, and delete the original message. + +The information contained in this e-mail message is intended only for the personal and confidential use of the recipient(s) named above. If you have received this communication in error, please notify us immediately by e-mail, and delete the original message. \ No newline at end of file diff --git a/marker2/ds9/EFTA00089217/EFTA00089217.metadata.json b/marker2/ds9/EFTA00089217/EFTA00089217.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..9c8058448a088ebc31feceae5266903a3b208a37 --- /dev/null +++ b/marker2/ds9/EFTA00089217/EFTA00089217.metadata.json @@ -0,0 +1,136 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089217.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 4, + "chars": 5362, + "elapsed_seconds": 4.95, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 65 + ], + [ + "Line", + 31 + ], + [ + "Text", + 15 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 76 + ], + [ + "Line", + 37 + ], + [ + "Text", + 29 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 74 + ], + [ + "Line", + 35 + ], + [ + "Text", + 16 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 3, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 8 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089217" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089221/EFTA00089221.md b/marker2/ds9/EFTA00089221/EFTA00089221.md new file mode 100644 index 0000000000000000000000000000000000000000..a25fed368addf8c8dc5a681c10fab865a0245f11 --- /dev/null +++ b/marker2/ds9/EFTA00089221/EFTA00089221.md @@ -0,0 +1,113 @@ +From: ' To:' Cc: ' )" + +Subject: Re: 2019.8.15 - SDNY Production Index.xlsx + +Date: Wed, 21 Aug 2019 03:56:39 +0000 + +I'm free in the afternoon on the 5th and the morning on the 6th. + +On Aug 20, 2019, at 8:34 PM, )< > wrote: + +Sounds good. Either of you have any conflicts on the 5th or 6th? (I'm totally free both days.) + +From: Sent: Tuesday, August 20, 2019 14:20 To: ) Subject: RE: 2019.8.15 - SDNY Production Index.xlsx •c > + +I tend to agree. + +From: sc > Sent: Tuesday, August 20, 2019 2:15 PM To: .; Subject: FW: 2019.8.15 - SDNY Production Index.xlsx + +Up to you guys, but given that there's no rush on moving on financial leads, it seems most efficient to just do this together on 9/5, when everyone is back from Florida. But I don't have strong views. + +From: Moyne, Parvin •c= > Sent: Tuesday, August 20, 2019 2:03 PM To: Cc: Moyer, Thomas Subject: RE: 2019.8.15 - SDNY Production Index.xlsx c\*M 1 >; + +Initially, we propose that the lawyers (myself, my colleagues at Akin Gump, and someone fromMILegal) deliver a presentation that provides an overview of Epstein's relationship with the bank, the different accounts affiliated with Epstein and the types of transactions found in the accounts. We would also highlight various transactions that we have noted in our internal investigation. Our aim is that the attorney proffer would help you in sifting through the records we have provided so you can more readily identify whatever information you are most interested in. Following the proffer, if there are particular accounts or transactions of interest, we can identify the person within who can best answer questions on those areas and that person would then meet with you. + +In terms of timing, I estimate 2-3 hours for the attorney proffer. (I think closer to 2 hours but I hate to underestimate.) + +From: ) •< > + +Sent: Monday, August 19, 2019 8:14 PM + +To: Moyne, Parvin ) + +Cc: Moyer, Thomas + +Subject: RE: 2019.8.15 - SONY Production Index.xlsx + +Parvin, + +Could you please let us know what format we should expect in terms of the proffer? That will help us with figuring out scheduling. I.e., do you expect to make an attorney proffer in the first instance, or should be expect to be meeting with personnel, etc? And approximately how long should we be planning to block out? + +thanks, + +From: Moyne, Parvin + +Sent: Monday, August 19, 2019 12:04 + +To: ) < + +Cc: Moyer, Thomas + +Subject: RE: 2019.8.15 - SDNY Production Index.xlsx + +Hi MI — + +The proffer may be helpful in guiding you through the production. That said, we can be available whenever makes most sense on your ends. + +We have time this week (Thursday or Friday afternoon) and next week (Monday — Wednesday), and we have time in September. If you give us a few options in terms of dates/times, we will sort out schedules on our ends. + +Best + +Parvin + +From: ) c > + +Sent: Saturday, August 17, 2019 1:59 PM + +To: Moyne, Parvin ) + +Cc: Moyer, Thomas + +Subject: RE: 2019.8.15 - SDNY Production Index.xlsx + +\*\*EXTERNAL Email" + +Parvin, + +We received the index, thank you. In terms of a proffer, what generally did you have in mind regarding timing? I think we'd like to have some time with the subpoena returns to get familiarized, and our team has a combination of travel and + +thanks, + +From: Moyne, Parvin + +Sent: Thursday, August 15, 2019 09:48 + +To: >; + +< > + +Cc: Moyer, Thomas + +Subject: 2019.8.15 - SDNY Production Index.xlsx + +& + +Please find attached an index to our productions to date. This is a work in progress — we will update it as we gather and produce additional documents. + +Would you like to touch base later today about scheduling a proffer? We are free after 4 p.m. + +Best, + +Parvin + +Parvin Daphne Moyne + +AKIN GUMP STRAUSS HAUER & FELD LLP + +One Bryant Park New York NY 10036-6745 USA I Direct: +1 Fax: +1 I I alingiap.com I Bio Internal: + +The information contained in this e-mail message is intended only for the personal and confidential use of the recipient(s) named above. If you have received this communication in error, please notify us immediately by email, and delete the original message. + +The information contained in this e-mail message is intended only for the personal and confidential use of the recipient(s) named above. If you have received this communication in error, please notify us immediately by email, and delete the original message. + +The information contained in this e-mail message is intended only for the personal and confidential use of the recipient(s) named above. 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Could you please pass along the letters from Steptoe they sent today? Thanks! + +[REDACTED] + +Assistant United States Attorney +Southern District of New York + +[REDACTED] + +New York, New York 10007 + +[REDACTED] \ No newline at end of file diff --git a/marker2/ds9/EFTA00089224/EFTA00089224.metadata.json b/marker2/ds9/EFTA00089224/EFTA00089224.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..3399a38478e9f71444bd890464167c726088c92c --- /dev/null +++ b/marker2/ds9/EFTA00089224/EFTA00089224.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089224.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 417, + "elapsed_seconds": 2.66, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 25 + ], + [ + "Span", + 21 + ], + [ + "Line", + 11 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089224" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089225/EFTA00089225.md b/marker2/ds9/EFTA00089225/EFTA00089225.md new file mode 100644 index 0000000000000000000000000000000000000000..3d0da1434cf3de87f09ca3d316a4520863c278d9 --- /dev/null +++ b/marker2/ds9/EFTA00089225/EFTA00089225.md @@ -0,0 +1,25 @@ +From: To: Cc: + +Subject: RE: update for Epstein victim website + +Date: Wed, 21 Aug 2019 15:10:38 -4)000 + +Perfect, thanks again. + +From: Sent: e nes ay, August , 910:47 To: Cc: Subject: RE: RE: update for Epstein victim website + +Here you go. The server may take a few moments to update, but here's the link: + +https://www.justice.goviusao-sdnyiprogramshictim-witness-services/united-states-v-jeffrey-epstein-19-cr-490-rmb + +From: Sent: Wednesda Au ust 21 2019 10:40 AM To Cc: Subject: RE: update for Epstein victim website + +Could we please add the following to the Victim & Witnesses Services page for Epstein: + +August 21, 2019 update: + +On August 21, 2019, a hearing was ordered by the Court in the case of United States v. Jeffrey Epstein, 19 Cr. 490 (RMB). The hearing is in connection with the nolle prosequi order proposed to the Court on August 19, 2019, by the United States Attorney, following the death of defendant Jeffrey Epstein. At the hearing, counsel for the victims and the victims will be heard, if they wish to be. The hearing is scheduled for Tuesday, August 27, 2019, at 10:30 a.m. before the Honorable Richard M. Berman, United States District Judge for the Southern District of New York, Daniel Patrick Moynihan United States Courthouse, 500 Pearl Street, New York, New York, in Courtroom 17B. + +thanks, + +Assistant U.S. Attorney Southern District of New York \ No newline at end of file diff --git a/marker2/ds9/EFTA00089225/EFTA00089225.metadata.json b/marker2/ds9/EFTA00089225/EFTA00089225.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..f2932ee4d96ac3ed5be42b2d5cef10e11460af57 --- /dev/null +++ b/marker2/ds9/EFTA00089225/EFTA00089225.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089225.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1372, + "elapsed_seconds": 0.67, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 59 + ], + [ + "Line", + 30 + ], + [ + "Text", + 13 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089225" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089226/EFTA00089226.md b/marker2/ds9/EFTA00089226/EFTA00089226.md new file mode 100644 index 0000000000000000000000000000000000000000..42d34ca5fce6a6fc8a5bb7a3a9ccdf183ed82198 --- /dev/null +++ b/marker2/ds9/EFTA00089226/EFTA00089226.md @@ -0,0 +1,143 @@ +From: ' To: "I < + +Subject: FW: 2019.8.15 - SDNY Production Index.xlsx + +Date: Wed, 21 Aug 2019 14:41:15 +0000 + +I could do anytime on M/T/Th of that week — y'all? + +From: Moyne, Parvin + +Sent: Wednesday, August 21, 2019 09:25 + +To: + +Cc: Moyer, Thomas + +Subject: RE: 2019.8.15 - SDNY Production Index.xlsx + +I'm so sorry for the inconvenience but those dates are not good on our end. + +The following week is relatively clear. Might September 9th work? Or other dates that week? + +Best, Parvin + +From: + +Sent: Tuesday, August 20, 2019 11:58 PM + +To: Moyne, Parvin + +Cc: Moyer, Thomas ) + +Subject: RE: 2019.8.15 - SDNY Production Index.xlsx + +Parvin, + +That makes good sense, thanks. Because of the scheduling issues I mentioned, we'd like to set it for a time in early September, if we can — is there a time during the afternoon of September 5 or the morning of September 6 that would work for you? We should be able to do either of those dates and times. Or if not, we can propose possible times the following week. + +thank you, + +From: Moyne, Parvin + +Sent: Tuesday, August 20, 2019 14:03 + +To: -)< <->: + +Cc: Moyer, Thomas c + +Subject: RE: 2019.8.15 - SDNY Production Index.xlsx + +Initially, we propose that the lawyers (myself, my colleagues at Akin Gump, and someone from Legal) deliver a presentation that provides an overview of Epstein's relationship with the bank, the different accounts affiliated with Epstein and the types of transactions found in the accounts. We would also highlight various transactions that we have noted in our internal investigation. Our aim is that the attorney proffer would help you in sifting through the records we have provided so you can more readily identify whatever information you are most interested in. Following the proffer, if there are particular accounts or transactions of interest, we can identify the person within.who can best answer questions on those areas and that person would then meet with you. + +In terms of timing, I estimate 2-3 hours for the attorney proffer. (I think closer to 2 hours but I hate to underestimate.) + +Best, Parvin + +From: ) + +Sent: Monday, August 19, 2019 8:14 PM + +To: Moyne, Parvin < + +Cc: Moyer, Thomas + +Subject: RE: 2019.8.15 - SDNY Production Index.xlsx + +Parvin, + +Could you please let us know what format we should expect in terms of the proffer? That will help us with figuring out scheduling. I.e., do you expect to make an attorney proffer in the first instance, or should be expect to be meeting with personnel, etc? And approximately how long should we be planning to block out? + +thanks, + +From: Moyne, Parvin < + +Sent: Monday, August 19, 2019 12:04 + +To: < >; <->; + +Cc: Moyer, Thomas < > + +Subject: RE: 2019.8.15 - SDNY Production Index.xlsx + +Hi + +The proffer may be helpful in guiding you through the production. That said, we can be available whenever makes most sense on your ends. + +We have time this week (Thursday or Friday afternoon) and next week (Monday — Wednesday), and we have time in September. If you give us a few options in terms of dates/times, we will sort out schedules on our ends. + +Best + +Parvin + +Sent: Saturday, August 17, 2019 1:59 PM + +To: Moyne, Parvin + +Cc: Moyer, Thomas ez > + +Subject: RE: 2019.8.15 - SDNY Production Index.xlsx + +## \*\*EXTERNAL Email\*\* + +Parvin, + +We received the index, thank you. In terms of a proffer, what generally did you have in mind regarding timing? I think we'd like to have some time with the subpoena returns to get familiarized, and our team has a combination of travel and trials in the next couple weeks, but we could do early September if that works on your end. Thoughts? + +thanks, + +From: Moyne, Parvin c M> + +Sent: Thursday, August 15, 2019 09:48 + +To: I .c ).; >; + +Cc: Moyer, Thomas + +Subject: 2019.8.15 - SDNY Production Index.xlsx + +& + +Please find attached an index to our productions to date. This is a work in progress - we will update it as we gather and produce additional documents. + +Would you like to touch base later today about scheduling a proffer? We are free after 4 p.m. + +Best, + +Parvin + +Parvin Daphne Moyne + +AKIN GUMP STRAUSS HAUER & FELD Ltr, + +One Bryant Park New York, NY 10036-6745 I USA I Direct: +1 Internal:M + +Fax: +1 I Bio + +The information contained in this e-mail message is intended only for the personal and confidential use of the recipient(s) named above. If you have received this communication in error, please notify us immediately by email, and delete the original message. + +The information contained in this e-mail message is intended only for the personal and confidential use of the recipient(s) named above. If you have received this communication in error, please notify us immediately by email, and delete the original message. + +The information contained in this e-mail message is intended only for the personal and confidential use of the recipient(s) named above. If you have received this communication in error, please notify us immediately by e-mail, and delete the original message. + +The information contained in this e-mail message is intended only for the personal and confidential use of the recipient(s) named above. 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The order scheduling the conference indicated that Judge Berman will allow victims to be heard—either directly or through their counsel during the proceeding. If any of your clients would like to attend the conference but cannot afford the travel costs, our office's victim witness coordinator ( ) can provide assistance in arranging travel. They are certainly not required to attend, but we wanted to let you know that the option is available. + +Feel free to give me a call if you have any questions or would like to discuss. + +Thanks, + +From: > + +Sent: Monday, August 19, 2019 7:02 PM + +To: + +Cc: >;I + +Subject: Re: Epstein victims + +- Thank you for your informative email/invitation. We will attempt to contact each of our clients re your offer. Thank you for this offer of counseling, and for your dedication to the entire bizarre situation. + +Esq. + +Sent from my iPhone + +On Aug 19, 2019, at 1:18 PM, wrote: + +We've discussed victim resources before, but I wanted to follow up as a reminder to say that if any of your clients would like counseling or other victim services, please let them know that they are encouraged to contact the case agent on this case, who can put them in touch with victim services at FBI. The agent is Special Agent , and her phone number is . We recognize that this is a complicated and stressful time for victims, so we wanted to remind you that resources are available. + +Our team is always available if issues come up, so please feel free to give us a call. + +Thanks, + +New York, NY 10007 \ No newline at end of file diff --git a/marker2/ds9/EFTA00089230/EFTA00089230.metadata.json b/marker2/ds9/EFTA00089230/EFTA00089230.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..584ac475850a45a16c74efa1f053b73b2bcf7bf1 --- /dev/null +++ b/marker2/ds9/EFTA00089230/EFTA00089230.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089230.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 1787, + "elapsed_seconds": 1.05, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 67 + ], + [ + "Line", + 33 + ], + [ + "Text", + 22 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 7 + ], + [ + "Line", + 4 + ], + [ + "Text", + 3 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089230" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089232/EFTA00089232.md b/marker2/ds9/EFTA00089232/EFTA00089232.md new file mode 100644 index 0000000000000000000000000000000000000000..b5c1028781abea20a30e4a42319fc04c03472867 --- /dev/null +++ b/marker2/ds9/EFTA00089232/EFTA00089232.md @@ -0,0 +1,94 @@ +**To:** "[REDACTED]" > + +**Subject:** RE: 8/27 Conference + +**Date:** Thu, 22 Aug 2019 18:22:00 +0000 + +**Images:** image001.png; image003.jpg; image004.jpg; image005.png + +--- + +Thanks. + +**Gloria Allred** + +**Allred, Maroko & Goldberg** + +[REDACTED] +[REDACTED] +[REDACTED] + +[www.amglaw.com](http://www.amglaw.com) + +[www.gloriaallred.com](http://www.gloriaallred.com) + +![](_page_0_Picture_137.jpeg) + +--- + +**From:** [REDACTED] > + +**Sent:** Thursday, August 22, 2019 11:08 AM + +**To:** Gloria Allred <[REDACTED]> + +**Cc:** [REDACTED] >; [REDACTED] > + +**Subject:** RE: 8/27 Conference + +This includes any and all victims who wish to attend but cannot afford the travel costs, regardless of whether they have met with us. + +Best, + +[REDACTED] + +[REDACTED] + +Assistant United States Attorney +Southern District of New York +1 St. Andrew's Plaza +New York, NY 10007 + +Sent: Thursday, August 22, 2019 1:59 PM + +To: + +Cc: + +Subject: RE: 8/27 Conference + +Thanks very much. I will ask them. Would this include victims who have not yet spoken to you or just those who have spoken to you? + +Gloria Allred + +Allred, Maroko & Goldber + +www.amglaw.corn + +www.gloriaallred.corn + +![](_page_1_Picture_10.jpeg) + +From: + +Sent: Thursday, August 22, 2019 10:57 AM + +To: Gloria Allred < + +Cc: + +Subject: 8/27 Conference + +Gloria, + +Judge Berman has scheduled a conference regarding the dismissal of the indictment in light of Epstein's death for Tuesday, August 27th at 10:30am in Courtroom 178 of the 500 Pearl Street courthouse. The order scheduling the conference indicated that Judge Berman will allow victims to be heard—either directly or through their counsel—during the proceeding. If any of your clients would like to attend the conference but cannot afford the travel costs, can provide assistance in arranging travel. They are certainly not required to attend, but we wanted to let you know that the option is available. + +Feel free to give me a call if you have any questions or would like to discuss. + +Best, + +Assistant United States Attorney Southern District of New York I St. Andrew's 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. 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I understand that your office will be coordinating the responses to those subpoenas and any others relating to this investigation. As promised, copied are my colleagues and IM=, and we are all reachable at these email addresses or at the following numbers: + +I understand that your collection of materials as to both individuals is in progress, and that you expect to be able to follow up with us on volume and anticipated schedule next week; feel free to call any of us any time, or if you're in touch via email, please include the full team. And as you progress in your response, please let us know if any additional information from our Office would be useful. + +thank you, + +From: D'Alessandro, Steven L Sent: Wednesday, August 21, 2019 11:28 To: Cc: Buentello, Jennifer L ica; Swarts, David E Subject: RE: JPMorgan + +Good speaking with you earlier. I'm copying Jenn and David. + +Jenn is handling the requests from you and so please feel free to reach out to her with any questions. + +Best, + +--Steve \ No newline at end of file diff --git a/marker2/ds9/EFTA00089235/EFTA00089235.metadata.json b/marker2/ds9/EFTA00089235/EFTA00089235.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..bc60abbee49051b8cb6a035cbc3a2e6d1913eb21 --- /dev/null +++ b/marker2/ds9/EFTA00089235/EFTA00089235.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089235.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1311, + "elapsed_seconds": 0.75, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 53 + ], + [ + "Line", + 25 + ], + [ + "Text", + 14 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089235" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089236/EFTA00089236.md b/marker2/ds9/EFTA00089236/EFTA00089236.md new file mode 100644 index 0000000000000000000000000000000000000000..74db0177ddeeca71f96fd2c040aa9004fa8312d5 --- /dev/null +++ b/marker2/ds9/EFTA00089236/EFTA00089236.md @@ -0,0 +1,19 @@ +UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ---- UNITED STATES OF AMERICA. + +JEFFREY EPSTEIN, Defendant. X USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC #: DATE FILED: 7 PI + +Government. MICR + +19 Cr 490 + +The Court will conduct a brief heating on Tuesday, August 27, 2019 at 10:30 a.m. in connection with the node prusequi order proposed to the Court on August 19, 2019 by the United States Attorney. + +The Court believes that where, as here, a defendant has died before anyjudgment has been entered against him, the public may still have au informational interest in the process by which the prosecutor seeks dismissal of an indictment. + +At the hearing, Counsel for the Government and for the deceased Defendant, Jeffrey Epstein, will be heard. Counsel for the victims and the victims will also be heard, if they wish to be. + +The hearing will be held in Courtroom 17B. + +Dated: New York, New York August 21, 2019 + +> RICHARD ete•ti M. BERMAN, --3 U.S.D.J. \ No newline at end of file diff --git a/marker2/ds9/EFTA00089236/EFTA00089236.metadata.json b/marker2/ds9/EFTA00089236/EFTA00089236.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..b2c8662d71e3437637668e9087bc40cda1e7d42d --- /dev/null +++ b/marker2/ds9/EFTA00089236/EFTA00089236.metadata.json @@ -0,0 +1,58 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089236.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 963, + "elapsed_seconds": 0.61, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 67 + ], + [ + "Line", + 33 + ], + [ + "Text", + 11 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089236" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089237/EFTA00089237.md b/marker2/ds9/EFTA00089237/EFTA00089237.md new file mode 100644 index 0000000000000000000000000000000000000000..8eca4c1f0aa5da162575255d1113d9220cf16c68 --- /dev/null +++ b/marker2/ds9/EFTA00089237/EFTA00089237.md @@ -0,0 +1,27 @@ +From: "I To: "I Cc: 'J (USANYS) [Contractor]" Ir > r + +Subject: RE: 863 tomorrow + +Date: Mon, 26 Aug 2019 17:41:01 +0000 + +Got it, thank you! + +From: < Sent: Monday, August 26, 2019 1:40 PM To: (USANYS) [Contractor] Cc: Subject: RE: 863 tomorrow + +Hey, yeah, all the rooms booked tomorrow under any of the three of our names are for the Epstein matter, thanks. + +From: (USANYS) [Contractor] < Sent: Monday, August 26, 2019 11:53 To: Subject: RE: 863 tomorrow cM > > + +Sorry for the double email while you're on trial. + +This is for Epstein victims — is that what you had already booked 863 for? If so, we're all good. If not, Geoff would like the space available for them tomorrow. + +Thanks again, + +From: (USANYS) [Contractor] Sent: Monday, August 26, 2019 11:51 AM To: Cc: ) [Contractor] Subject: 863 tomorrow + +— hope trial/jury selection is going well. + +M, I see you're book in 863 tomorrow afternoon from 1 to the end of the day. Are you still planning on using the room? Unfortunately Geoff has asked me to book 863 for the entire day tomorrow, to accommodate a large group of visitors. Would that be alright? It appears there are some other rooms open for your time. + +Sorry for the late notice. \ No newline at end of file diff --git a/marker2/ds9/EFTA00089237/EFTA00089237.metadata.json b/marker2/ds9/EFTA00089237/EFTA00089237.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..c1e3aae6825c058e1edaa1b4ab9f0e57b6965a10 --- /dev/null +++ b/marker2/ds9/EFTA00089237/EFTA00089237.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089237.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1190, + "elapsed_seconds": 0.78, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 74 + ], + [ + "Line", + 36 + ], + [ + "Text", + 15 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089237" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089238/EFTA00089238.md b/marker2/ds9/EFTA00089238/EFTA00089238.md new file mode 100644 index 0000000000000000000000000000000000000000..9c4e2f7088814269c5adb27ec95c7b849dc61dc1 --- /dev/null +++ b/marker2/ds9/EFTA00089238/EFTA00089238.md @@ -0,0 +1,29 @@ +To: ' ) + +"Swergold, Jason USANYS + +"Adam Johnson + +"'Stephanie Scannell"' + +Cc: Aida Leisenring > + +Subject: Tartaglkione and MCC + +Date: Mon, 26 Aug 2019 19:06:17 +0000 + +In a follow up to the Government's letter to the Court on Friday I am hoping there is a time this week to discuss the conditions under which Mr. Tartaglione would agree to withdraw his request to be moved from MCC. + +Bruce A. Barket, Esq. + +Barket Epstein Kearon Aldea & LoTurco, LLP + +666 Old Country Road , Ste. 700 + +Garden City, NY 11530 + +Ill [Fl + +www.barketepstein.com + +This transmittal may be a confidential attorney client communication or may otherwise be privileged or confidential. If it is not clear that you are the intended recipient, you are hereby notified that you have received this transmittal in error; any review, dissemination, distribution or copying of this transmittal is strictly prohibited. If you suspect that you have received this communication in error, please notify us immediately by telephone or email and immediately delete this message and all its attachments \ No newline at end of file diff --git a/marker2/ds9/EFTA00089238/EFTA00089238.metadata.json b/marker2/ds9/EFTA00089238/EFTA00089238.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..3ee32b04229e0eb225fd5bd62f6d3775ee5364e5 --- /dev/null +++ b/marker2/ds9/EFTA00089238/EFTA00089238.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089238.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1056, + "elapsed_seconds": 0.77, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 43 + ], + [ + "Line", + 22 + ], + [ + "Text", + 16 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089238" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089239/EFTA00089239.md b/marker2/ds9/EFTA00089239/EFTA00089239.md new file mode 100644 index 0000000000000000000000000000000000000000..429c4bd1bf12949ffc5ea53f31d79a5bec8793c7 --- /dev/null +++ b/marker2/ds9/EFTA00089239/EFTA00089239.md @@ -0,0 +1,30 @@ +To: + +Cc: + +Subject: United States v. Jeffrey Epstein, 19 Cr. 490 (RMB) + +Date: Mon, 26 Aug 2019 17:57:57 +0000 + +Dear Judge Berman, + +We received a request from the Court for the contact information for victim attorneys. Not all victims are represented by counsel, but the attorneys we are aware of are: + +- Brad Edwards ( +- Stan Pottinger +- Gloria Allred ■ +- **Sigrid McCawley** +- **Alex Conlon** +- **Bob Josefsberg** +- **Kimberly Lerner** +- **Teri Gibbs** + +**Although the Government has made best efforts to notify victims of tomorrow's proceeding, the Government does not know which victims plan to attend tomorrow's conference, and it is possible that victims the Government is not aware of may attend.** + +**We have not copied defense counsel here, in order to respect the privacy of the victims.** + +**Respectfully,** + +**Assistant United States Attorney Southern District of New York** + +**New York, NY 10007** \ No newline at end of file diff --git a/marker2/ds9/EFTA00089239/EFTA00089239.metadata.json b/marker2/ds9/EFTA00089239/EFTA00089239.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..2a3a6a39b2122ff69a3536256b01864c9d7bd463 --- /dev/null +++ b/marker2/ds9/EFTA00089239/EFTA00089239.metadata.json @@ -0,0 +1,62 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089239.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 912, + "elapsed_seconds": 0.82, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 51 + ], + [ + "Line", + 25 + ], + [ + "Text", + 16 + ], + [ + "ListItem", + 8 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089239" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089240/EFTA00089240.md b/marker2/ds9/EFTA00089240/EFTA00089240.md new file mode 100644 index 0000000000000000000000000000000000000000..e3f879e59fe1cfcf1911cea35d5e5863bedb121d --- /dev/null +++ b/marker2/ds9/EFTA00089240/EFTA00089240.md @@ -0,0 +1,23 @@ +From: (USANYS)" alMl.' + +To: (USANYS)" ' IMIE> + +Subject: Touhy letters from last week + +Date: The, 27 Aug 2019 19:43:11 +0000 + +Attachments: 8.20.19\_Epstein\_Letter to\_SDNY-c2.pdf; 8.20.19\_Epstein\_Letter to\_MCC-c2.pdf; 8.20.19\_Epstein\_Letter to\_FBI-c2.pdf + +H + +As discussed, here are the three Touhy letters Steptoe sent last week. Let me know if I should follow up with the FBI at all on this—the FBI letter is addressed to Kelly Maguire. + +Thanks, + +Assistant United States Attorney Southern District of New York + +New York, New York 10007 + +Telephone + +Facsimile \ No newline at end of file diff --git a/marker2/ds9/EFTA00089240/EFTA00089240.metadata.json b/marker2/ds9/EFTA00089240/EFTA00089240.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..c50468317d76eec3bbdd6f895566726a41e18d9d --- /dev/null +++ b/marker2/ds9/EFTA00089240/EFTA00089240.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089240.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 564, + "elapsed_seconds": 0.66, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 33 + ], + [ + "Line", + 16 + ], + [ + "Text", + 14 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089240" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089241/EFTA00089241.md b/marker2/ds9/EFTA00089241/EFTA00089241.md new file mode 100644 index 0000000000000000000000000000000000000000..aff7ab9cc25285bcb5cc391441e2dea5ce593d31 --- /dev/null +++ b/marker2/ds9/EFTA00089241/EFTA00089241.md @@ -0,0 +1,77 @@ +From: " aNIMIE> + +To: "ME, (USANYS)" + +Subject: RE: Epstein investigation + +Date: Wed, 28 Aug 2019 18:33:14 +0000 + +Thank you! + +Orli coal + +From: (USANYS) <:=MIMIIM> + +Sent: Wednesda Au ust 28 2019 9:50 AM + +To: aNIMIIM> + +Subject: RE: Epstein investigation + +Okay, great! I'll start on making the travel arrangements shortly. + +U.S. Attorney's Office (SDNY) + +Le al Assistant Public Corruption + +Ori inal Messa e + +From: + +Sent: Wednesda , August 28, 2019 9:11 AM + +To: USANYS + +Cc: + +Subject: FW: Epstein investigation + +Hi + +Below is approval for the trip, including conference room. Thank you so much for your help! + +Ori i + +From: M, (USANYS) `M=IMMI> + +Sent: Wednesda , August 28, 2019 8:47 AM + +To: + +Cc: + +(USANYS) (USANYS) + +Subject: RE: Epstein investigation + +Approved + +Ori inal Messa e + +From: + +Sent: Wednesda , August 28, 2019 8:46 AM + +To: USANYS + +c MIE> Subject: Epstein investigation + +a + +Thank you so much for helping to make yesterday possible, the victims were very grateful, and it was very helpful to our ongoing investigation to meet with them. + +In connection with the ongoing investigation of Epstein's co-conspirators, we would like to request permission to travel to Palm Beach next week for a proffer with MIIIME We would plan to fly in on Tuesday and fly out on Wednesday. We would also like to request permission to book a conference room at the hotel for the meeting, as we've done before. I think we will only need the conference room for one day, but if victims will meet with us while we are down there we might need to book a second day. + +Thanks, + +Sent from my iPhone \ No newline at end of file diff --git a/marker2/ds9/EFTA00089241/EFTA00089241.metadata.json b/marker2/ds9/EFTA00089241/EFTA00089241.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..d972a3a80de2e3fd3f9c7da18ee3265f31c595cb --- /dev/null +++ b/marker2/ds9/EFTA00089241/EFTA00089241.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089241.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 1570, + "elapsed_seconds": 1.7, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 76 + ], + [ + "Text", + 39 + ], + [ + "Line", + 37 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 27 + ], + [ + "Line", + 13 + ], + [ + "Text", + 6 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089241" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089244/EFTA00089244.md b/marker2/ds9/EFTA00089244/EFTA00089244.md new file mode 100644 index 0000000000000000000000000000000000000000..27fc4281016ac306e81ff4a3d33a76a76b0efe7c --- /dev/null +++ b/marker2/ds9/EFTA00089244/EFTA00089244.md @@ -0,0 +1,69 @@ +To: ' (USANYS)" c + +Subject: FW: RE: United States v. Jeffrey Epstein + +Date: Thu, 29 Aug 2019 16:42:09 +0000 + +FYI—today BOP fwded me what they sent to Epstein's counsel several weeks ago in response to their request for preservation and production. Basically, BOP acknowledged the preservation request and advised counsel of FOIA. + +From: + +Sent: Thursday, August 29, 2019 9:47 AM + +To: (USANYS) + +Cc + +Subject: Fwd: RE: United States v. Jeffrey Epstein + +Hi + +I understand you are our point of contact for all document requests related to the Epstein matter. Below please find a response I sent counsel when they initially requested preservation and production. Please let me know if you need anything else. + +Thank you, + +Supervisory Staff Attorney CLC New York Metropolitan Correctional Center 150 Park Row New York, New York 10007 + +»> 8/12/2019 9:45 AM >> > Good morning Mr. Weinberg, + +I have notified the appropriate parties at MCC New York as to the below request for preservation and advised that they preserve any responsive documentation in their possession. Please be advise that policy requires any request for production to be routed as a Freedom of Information Act request. For more information, please visit our website at mvw.bop.gov. + +Thank you, + +Supervisory Staff Attorney CLC New York Metropolitan Correctional Center 150 Park Row New York New York 10007 + +>> > "Martin G. Weinberg'. <-> 8/11/2019 3:56 PM >>> + +Mr. Epstein's family has asked me to send to you and at the MCC a request for the preservation of any and all documents, records, reports, videos, pictures, physical evidence, electronic communication data, tape recordings, logs, notes, papers, emails and any and all other forms of information that would be in the possession of the MCC, its Warden, their legal counsel, the USMS, the FBI, the Inspector General, the USAO for the SDNY or any other federal or relevant state or city agency that relate to Jeffrey Epstein's imprisonment/detention since July 6, 2019 and that relate particularly but not exclusively to the July 23, 2019 occurrence which was investigated as an attempted suicide by the MCC and the events relating to his death on August 10, 2019. The request encompasses but is not limited to any videos of the 9th floor area in the proximity of his cell during the evening of August 9 through the time Mr. Epstein was taken out of his cell for the last time on August 10, 2019, or videos of the cell itself during that time period, records of the identities of (i.e. MCC employees or independent contractors or anyone else) who were on duty from midnight through 8 AM on August 10, 2019 or otherwise had access to the 9th floor unit where Mr. Epstein was incarcerated during this time period, records of any observations of Mr. Epstein on August 9-10, 2019, any and all photographs of Mr. Epstein or his cell taken on August 10, 2019, any and all electronic or tape recordings or records of any internal communications within the MCC or any external communciations by MCC staff on August 9 and August 10, 2019, records of any mental health interviews or assessements of Mr. Epstein at anytime during his detention, records of any decision to put him on or take Mr Epstein off suicide watch, photos of his cell taken on or before August 9 or on or after August 10, 2019, memoranda of interviews with any prisoners who were in Mr. Epstein's SHU unit on the 9th floor on or about July 23 or on August 9-10, 2019 relating to Mr. Epstein, the same request for interview memoranda of any MCC employee or independent contractor or any other person in the MCC midnight-8 AM August 10, 2019, any and all medical and EMS and hospital records from July 23 and/or August 10, 2019, and the future pathology and toxicology and medical examiner's reports. Additionally, we would request the preservation of any note or notes found in Mr. Epstein's cell on August 10, 2019, any ligature or other physical evidence related to his cause of death, any bedding, any medication or vitamins, any log showing who entered or were present in the MCC for the 12 hour period before 6:30 AM on August 10, 2019, as well as a list of inmates who were in Mr. Epstein's unit during the evening of August 9 and the morning of August 10, 2019. We would in addition to the preservation request ask for the production of all of the above. We would receive and retain in subject any information received in response to this request subject to the terms and conditions of our Protective Order. In short, the family requests a preservation and production of any and all records and documents relevant to his detention, treatment, and death. I will send an identical request to. (as well as to Mark Epstein's personal counsel + +Thank you for your consideration of these requests and your ongoing assistance + +Martin Weinberg + +Martin G. Weinberg, Esq. + += MI Boston, MA 02116 + +- Office - Cell + +Martin G. Weinberg, Esq. + +Boston, MA 02116 + +- Office - Cell + +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. + +Sent: Saturday, August 10, 20191:57 PM + +To: + +Subject: United States v. Jeffrey Epstein + +Good afternoon, + +Enclosed please find official notification from Warden regarding Mr. Epstein's passing. As the investigation is ongoing, we have no further details at this time. We will continue to keep you updated as more information is available. + +Thank you, + +Supervisory Staff Attorney CLC New York Metropolitan Correctional Center 150 Park Row New York, New York 10007 \ No newline at end of file diff --git a/marker2/ds9/EFTA00089244/EFTA00089244.metadata.json b/marker2/ds9/EFTA00089244/EFTA00089244.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..4695ad82b31b409f996df5c8ed1f6db329db2d3e --- /dev/null +++ b/marker2/ds9/EFTA00089244/EFTA00089244.metadata.json @@ -0,0 +1,114 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089244.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 5726, + "elapsed_seconds": 1.02, + "image_assets": [], + "marker_metadata": { + 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+![](_page_0_Picture_148.jpeg) + +DRAFT + +**U.S. Department of Justice** +Southern District of New York +One St. Andrews Plaza +New York, NY 10007 +Phone: (212) 637-1028 +Fax: (212) 637-0421 + +July 08, 2020 + +Gloria Allred +Allred, Maroko & Goldberg +6300 Wilshire Blvd. Suite 1500 +Los Angeles, CA 90048 + +Re: United States v. Defendant(s) Ghislaine Maxwell +Case Number 2020R00719 and Court Docket Number 20-CR-00330 + +Dear Gloria Allred: + +The enclosed information is provided by the United States Department of Justice Victim Notification System (VNS). As a victim witness professional, my role is to assist you with information and services during the prosecution of this case. You have been designated to receive notifications on behalf of the following victim(s) (or potential victims) identified by law enforcement during the investigation of the case: [REDACTED] +[REDACTED] + +Charges have been filed against defendant(s) Ghislaine Maxwell. The lead prosecutor for this case is [REDACTED]. The main charge is categorized as Project Safe Childhood. Assistant United States [REDACTED] and Assistant United States Attorney [REDACTED] + +Victims of all crimes under federal investigation are entitled to services under the Victims' Rights and Restitution Act (VRRA), including notification of court events. For further details, please refer to Title 34 United States Code section 20141 or the VRRA link posted at . + +Now that charges have been filed in federal court, victims of the charges filed are, in addition, entitled to the following rights, according to the Crime Victims' Rights Act, Title 18 United States Code section 3771: (1) The right to be reasonably protected from the accused; (2) The right to reasonable, accurate, and timely notice of any public court proceeding, or any parole proceeding, involving the crime or of any release or escape of the accused; (3) The right not to be excluded from any such public court proceeding, unless the court, after receiving clear and convincing evidence, determines that testimony by the victim would be materially altered if the victim heard other testimony at that proceeding; (4) The right to be reasonably heard at any public proceeding in the district court involving release, plea, sentencing, or any parole proceeding; (5) The reasonable right to confer with the attorney for the Government in the case; (6) The right to full and timely restitution as provided in law; (7) The right to proceedings free from unreasonable delay; (8) The right to be treated with fairness and with respect for the victim's dignity and privacy; (9) The right to be informed in a timely manner of any plea bargain or deferred prosecution agreement; and (10) The right to be informed of the rights under this section and the services described in section 503(c) of the Victims' Rights and Restitution Act of 1990 (34 U.S.C. 20141(c)) and provided contact information for the Office of the Victims' Rights Ombudsman of the Department of Justice. + +Please understand that these rights apply only to victims of the counts charged in federal court, and thus you may not be able to exercise all of these rights if the crime of which you are a victim was not charged. In any event, we will continue to provide you with notifications and services unless you tell us not to. We will make our best efforts to ensure you are provided the rights and services to which you are entitled. You may contact the Victim/Witness Coordinator at the office listed above if you have questions about the progress of your + +case, your rights or the services to which you are entitled, or how you can assert them during the proceedings. If you believe that a Justice Department employee has not provided you with these rights, you may file a complaint with the Justice Department's Victims' Rights Ombudsman. For more information, go to http://www.justice.gov/usao/resources/crime-victims-rights-ombudsman. If you have questions about filing a complaint against an employee, you may contact the Ombudsman by email at usaeo.VictimOmbudsman@usdoj.gov. Questions concerning this case should be directed to office listed above. + +It is important to keep in mind that the defendant(s) are presumed innocent until proven guilty and that presumption requires both the Court and our office to take certain steps to ensure that justice is served. While our office cannot act as your attorney or provide you with legal advice, you can seek the advice of an attorney with respect to the rights above or other related legal matters. + +Additionally, please be aware that most criminal cases are resolved by a plea agreement between the United States Attorney's Office and the defendant. You should also know that it is not unusual for a defendant to seek to negotiate a plea agreement shortly before a trial is scheduled to begin. Plea agreements can be made at any time and as late as the morning of trial, leaving little or no opportunity to provide notice to you of the date and time of the plea hearing. If the court schedules a plea hearing in this case, we will use our best efforts to notify you of available information as soon as practicable. If you want to inform the prosecutor of your views regarding potential plea agreements, or any other aspect of the case, please contact the prosecutor assigned to this case or me. + +An arraignment is scheduled before Judge Alison Nathan on July 14, 2020, 01:00 PM at Clerk's Office, 500 Pearl Street, New York, NY 10007 for the case which involves defendant(s) Ghislaine Maxwell. The main purpose of this hearing is for the defendant to enter a plea to the charges filed in this case. Your attendance is not required. The government expects the defendant to enter a plea of not guilty at this hearing. If the plea is guilty, you will be notified. + +Because of the Court's schedule, hearing dates could change on very short notice. If you plan on attending, you may want to call the VNS Call Center or check the website to confirm the date and time. Please note, there is a 24-hour delay in information transfer to the website. + +Please note that certain documents (i.e. indictment, judgment, etc.) may become available periodically on the Internet at WWW.Notify.USDOJ.GOV under the field "downloads/links." You will need to log in using your VIN number and password to access any existing documents. + +Through the Victim Notification System (VNS) we will continue to provide you with updated scheduling and event information as the case proceeds through the criminal justice system. You may obtain current information about this case on the VNS website at https://www.notify.usdoj.gov or from the VNS Call Center at 1.866-DOJ-4YOU (1-866.365.4968) (TDD/TTY: 1.866.228.4619) (International: 1.502-213-2767). In addition, you may use the Call Center or Internet to update your contact information and/or change your decision about participation in the notification program. + +You will use your Victim Identification Number (VIN) and Personal Identification Number (PIN) M' anytime you contact the Call Center and the first time you log into VNS on the website. You are associated with multiple cases. You will need only this victim ID/PIN code to access all case information. If you are receiving notifications with multiple victim ID/PIN codes please contact the VNS Call Center. In addition, the first time you access the VNS website, you will be prompted to enter your last name (or business name) as currently contained in VNS. The name you should enter is Allred. + +Remember, VNS is an automated system and cannot answer questions. If you have other questions which involve this matter, please contact this office at the number listed above. + +Sincerely, + +Audrey Strauss (Acting) United States Attorney + +![](_page_2_Picture_3.jpeg) + +![](_page_2_Picture_4.jpeg) + +Victim Witness Coordinator \ No newline at end of file diff --git a/marker2/ds9/EFTA00089249/EFTA00089249.metadata.json b/marker2/ds9/EFTA00089249/EFTA00089249.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..14ae14ba734c6b6810199685920360f2e2472967 --- /dev/null +++ b/marker2/ds9/EFTA00089249/EFTA00089249.metadata.json @@ -0,0 +1,130 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089249.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 7866, + 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b/marker2/ds9/EFTA00089252/EFTA00089252.md @@ -0,0 +1,21 @@ +From: " + +To: Brad Edwards + +Cc: + +Subject: July 14th hearing + +Date: Wed, 08 Jul 2020 19:02:19 +0000 + +Attachments: 20cr330\_Order 7.7.20.pdf + +Brad, + +Attached is a copy of the Court's scheduling order, in case this is helpful. + +Best, + +Alison + +Assistant United States Attorney Southern District of New York \ No newline at end of file diff --git a/marker2/ds9/EFTA00089252/EFTA00089252.metadata.json b/marker2/ds9/EFTA00089252/EFTA00089252.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..bb0372d51c82cf8fc6982a44bd3af3acc434ba97 --- /dev/null +++ b/marker2/ds9/EFTA00089252/EFTA00089252.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089252.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", 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+Date: Sun, 12 Jul 2020 23:31:05 +0000 + +Oh great, glad to hear it. I suggested she call the FBI number, but she seemed a little, ah, skeptical, so wasn't sure if she would call. Thanks. + +From: + +Sent: Sunda Jul 12 2020 19:04 + +To: + +Cc: + +Subject: RE: victim call + +All good. It was conference with er. We spoke with her last week. She reached out to the ADIC and we had a video + +On Jul 12 2020 7:01 PM, wrote: + +I got a call this past week from a woman who said that she previously had been sexually assaulted, by a man who she believed was associated with Epstein. She said that she is a high-profile individual and that she would like to speak with someone from the FBI. She gave her name as name, but caller ID showed the name and the caller ID, I think she may be this woman: and gave the numbers She declined to provide a last ' when she called. Based on her brief self-description, + +Though I'm not positive. Could someone please reach out to her this coming week? + +thanks very much, + +Assistant U.S. Attorney Southern District of New York \ No newline at end of file diff --git a/marker2/ds9/EFTA00089253/EFTA00089253.metadata.json b/marker2/ds9/EFTA00089253/EFTA00089253.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..25ef161ecc420a9512b30a2e8ad219574fd6ef08 --- /dev/null +++ b/marker2/ds9/EFTA00089253/EFTA00089253.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089253.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1080, + "elapsed_seconds": 0.82, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 57 + ], + [ + "Line", + 28 + ], + [ + "Text", + 17 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089253" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089254/EFTA00089254.md b/marker2/ds9/EFTA00089254/EFTA00089254.md new file mode 100644 index 0000000000000000000000000000000000000000..34c20b77d13115942e24f7f6a3605b988275d348 --- /dev/null +++ b/marker2/ds9/EFTA00089254/EFTA00089254.md @@ -0,0 +1,215 @@ +# Trust Signature Page + +Al trustees must sign this document. + +By siring below, I acknowledge that I understand and agree with the terms and conditions of the LISS Client Relationship Agreement the Agreements and Disclosures booklet and addendum, and if applicable, the Agreements and Disclosures for IRAs, and the Retirement Plan Disclosures available at wowassomtrettemeatglanetiscksiLes that b enclosed or that I have previously received. I agree that the representations In these documents are accurate and that I will be bound by the terms and conditions In these documents. + +#### Trustee Certification + +By signing below, I represent that ( have reviewed the Trust Agreement and any other documents governing the trust As uustee, I have full power under the Trust Agreement to make this Trust Certification and have consulted with my legal counsel. if necessary. + +Investment and other Powers and Restrictions We represent and warrant that, except as indicated below, we have broad investment and other powers under the trust agreement and applicable law to enter into transactions and to trade, buy, sell, sell short or otherwise acquire, receive, deliver, assign, endorse for transfer, hold or dispose of all manner of securities, futures, currencies and commodities (incluang options or warrants on securities, futures, currencies or commodities) Cr to purchase and surrender insurance policies and annuity contracts or interest in any of the foregoing in whatever form they may take, and whether by dna ownership or by interest in funds, partnerships, pods or other forms of colective ownership, except the types of investments specifically kited below + +LOAM and Other Credit Transactions We represent and warrant that we have broad powers under the trust agreement and applicable law to engage in borrowing and Other loan and credit transactions with or through UBS for Investment and non-investment purposes, including margin loans, other loans, pledges, mortgages, hyputlecations, repurchase and reverse repurchase transactions, letters of credit, credit facilities, and guarantees of the obligations of third parties to UBS On each case, with no !irritations as to amount). We have the authority to pledge, mortgage, assign or subject to asecurity interest or lien in favor of UBS any property of any sort of the trust as security for any liability of the trust or third parties (in each case, with no imitations as to amount). We have the authority to execute any and all relevant documents and bind the trust In respect of any agreements entered into pursuant to this paragraph, except the types of borrowing or other loan or credit transactions listed below + +If the trust has multiple trustees or officers, can one trustee or officer act independently? If No, specify the number of signatures required: (specify number or • air) \ et Yes No + +If trustees do not have authority to hire an investment advisor or other third party, check here + +The person identified below is authorized to act as a successor trustee in the event of the death, resignation or removal of ail of the current trustees: + +Name: Title: + +Address. + +#### Margin Agreement + +tagree that the Margin Agreement in the Client Relationship Agreement applies to a0 of my margin-eligible accounts opened now or in the future. This means that ifI use margin privileges, UBS will heal the securities in the margined accounts as collateral against the amounts borrowed. I agree to keep sufficient positions in margined account to meet any margin calls UBS may issue. I aiso understand that securities in any margined account may be loaned to 1185 or other persons or entities as described in the Margin Agreement. + +Iunderstand that the Margin Agreement is not applicable to retirement accounts or any other accounts that are not eligible for margin privileges at UBS (including IRAs, ERISA plans, Coverdell Education Savings Accounts, 403(bX7) Accounts, UGMAIUTMA, Estate or 529 Accounts). + +## Electronic Delivery Consent + +As requested, I received my Agreements and Disclosures booklet and other account-related documents electronically at jrobertsenuttercorn which is the e-mail address of record for all ov nts. understand that the information is also available at www.ubs.comiaccountdisdosures or by request to my Financial Advisor at + +![](_page_0_Picture_19.jpeg) + +**Montpelier Trust** + +**For Trust Accounts:** + +Y1 45170 +Y1 45172 +Y1 45171 + +**PAYEE CALLS FOR CONSENT** +[REDACTED] + +ENTER SSN HERE + + Check here if you have been notified by the IRS that you are subject to backup withholding, and therefore have crossed out paragraph 2 in the Certification below. + +**Exempt Payee Code (if any)** \_\_\_\_\_ +If your organization is tax exempt please enter the appropriate code (codes 1 through 13 in the W9 instructions) + +**Exemption from FATCA reporting code (if any):** \_\_\_\_\_ + +**W-9 Form Certification** + +Under penalties of perjury, I certify that: (1) the number shown on this form is my correct taxpayer identification number (or I am waiting for a number to be issued to me), and (2) I am not subject to backup withholding because: (a) I am exempt from backup withholding, or (b) I have not been notified by the Internal Revenue Service (IRS) that I am subject to backup withholding as a result of a failure to report all interest and dividends, or (c) the IRS has notified me that I am no longer subject to backup withholding, and (3) I am a U.S. citizen or other U.S. person (defined in the instructions), and (4) The FATCA code(s) entered on this form (if any) indicating that I am exempt from FATCA reporting is correct. + +The Client Relationship Agreement contains a pre-dispute arbitration clause located in the final section under the title "Arbitration." + +**Certification Instruction:** You must cross out item (2) above if you have been notified by the IRS that you are currently subject to backup withholding because you have failed to report all interest and dividends on your tax return. + +The Internal Revenue Service does not require your consent to any provision of this document other than the certifications required to avoid backup withholding. + +X [REDACTED] TRVSTG 12/12/18 +Jeffrey Date + +X [REDACTED] Date + +X [REDACTED] Date + +SIGN AND DATE HERE +Jeffrey Date +Sign and Date +Sign and Date +Sign and Date +Sign and Date +Sign and Date +Sign and Date +Sign and Date + +**Address of Record** + +155 Seaport Boulevard +ATTN: Nutter McClennen & Fish +LLP +Boston, MA 02210-2698 + +**Email Address of Record** + +[REDACTED] + +[REDACTED] + +![](_page_1_Picture_186.jpeg) + +**Montpelier Trust** + +**For Trust Accounts:** + +Y1 45170 +Y1 45172 +Y1 45171 + +ENTER THE FOR TRUST + +![](_page_2_Picture_161.jpeg) + +ENTER SSN HERE + + Check here if you have been notified by the IRS that you are subject to backup withholding, and therefore have crossed out paragraph 2 in the Certification below. + +Exempt Payee Code (if any) \_\_\_\_\_ +If your organization is tax exempt please enter the appropriate code (codes 1 through 13 in the W9 instructions) + +Exemption from FATCA reporting code (if any): \_\_\_\_\_ + +**W-9 Form Certification** + +Under penalties of perjury, I certify that: (1) the number shown on this form is my correct taxpayer identification number (or I am waiting for a number to be issued to me), and (2) I am not subject to backup withholding because: (a) I am exempt from backup withholding, or (b) I have not been notified by the Internal Revenue Service (IRS) that I am subject to backup withholding as a result of a failure to report all interest and dividends, or (c) the IRS has notified me that I am no longer subject to backup withholding, and (3) I am a U.S. citizen or other U.S. person (defined in the instructions), and (4) The FATCA code(s) entered on this form (if any) indicating that I am exempt from FATCA reporting is correct. + +The Client Relationship Agreement contains a pre-dispute arbitration clause located in the final section under the title "Arbitration." + +Certification Instruction: You must cross out item (2) above if you have been notified by the IRS that you are currently subject to backup withholding because you have failed to report all interest and dividends on your tax return. + +The Internal Revenue Service does not require your consent to any provision of this document other than the certifications required to avoid backup withholding. + +X + +![](_page_2_Picture_172.jpeg) + +Date + +X + +![](_page_2_Picture_175.jpeg) + +12/2/2018 + +X + +![](_page_2_Picture_178.jpeg) + +Date + +**Address of Record:** + +155 Seaport Boulevard +ATTN: Nutter McClennen & Fish +LLP +Boston, MA 02210-2698 + +**Email Address of Record:** + +![](_page_2_Picture_183.jpeg) + +![](_page_2_Picture_184.jpeg) + +![](_page_2_Picture_185.jpeg) + +![](_page_2_Picture_187.jpeg) + +#### Montpelier Trust + +#### For Trust Accounts: + +Y1 45170 + +vl 45172 + +Y1 45171 + +![](_page_3_Picture_7.jpeg) + +y u ave peen rotaed by the IRS that you are subject to backup withholding, and therefore have crossed out paragraph 2 in the Certification below. + +#### Exempt Payee Cede (if any) + +if your organktadon is tax exempt please enter the appropriate code (codes 1 through 13 In the NiSintructIons) + +Exemption from FATCA reporting code Of any)! + +#### W-9 Fenn Certification + +Under penalties of peOury. I certify that (1) the number SAN/n on this form is my correct taxpayer identification number (or I am waiting fora number to be issued to me), and 2) 1 am not wbject to backupwithholding because: (a)I am exempt from backup withholding, or (b) I have not been notified by the internal Rewire Service ORS) that I am subject to backup withholding as a result of a Wore to report all intereSt and dividends. or (c) the IRS has notified me that I am no longer subject to backup withholding, and (3) i am a U.S citizen or other U.S person (defined in the instructions). and (4) The FATCA code@ entered on this form Of any) incicabrig that I am exempt from FATCA reporting IS Correct. + +Certification Instruction: You must COSS out item (2) abore if you base been notified by the IRS that you are current)), subject to backup withholding because you have failed to report all interest and dividends on your tax return. + +The Internal Revenue Service does not require your consent to any provision of this document other than the certifications required to avoid backup withholding. + +![](_page_3_Picture_18.jpeg) + +#### Address.of Record + +155 Seaport Boulevard + +ATM: Nutter McCennen & Fish + +uP + +Boston. MA 02210-2698 + +Emalladdress of-Record + +![](_page_3_Picture_29.jpeg) + +![](_page_3_Picture_30.jpeg) + +![](_page_3_Picture_31.jpeg) + +![](_page_3_Picture_33.jpeg) + +The Client Relationship Agreement contains a pre-dispute arbitration clause located in the final section under the title "Arbitration.' \ No newline at end of file diff --git a/marker2/ds9/EFTA00089254/EFTA00089254.metadata.json b/marker2/ds9/EFTA00089254/EFTA00089254.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..2665467a1069a2babeab56b2fb4049e636d6432c --- /dev/null +++ b/marker2/ds9/EFTA00089254/EFTA00089254.metadata.json @@ -0,0 +1,647 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089254.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + 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During that time a review of EPSTEIN's inmate records and activity conducted with the following information obtained: + +- According to computer inquiries conducted at that time by Lt. Doctor EPSTEIN had no phone calls on file with BOP. Lt. Doctor found that inquiry to be odd because she was informed that EPSTEIN had in fact made a call on 08/09/2019. An inquiry of another inmate was conducted to ensure the database was operating correctly or that the inquiry was submitted correctly and phone records were revealed for the "test" inmate run. EPSTEIN's 08/09/2019 call was provided by BOP supervisor Nathaniel Bullock who also reported the call. Lt. Doctor informed that the call was made on an unsecure line or "legal line" which is not recorded. Lt. Doctor informed that the reason the call was placed in that manner was because EPSTEIN related to Bullock that there was an issue with his phone account and he could not make a "normal call". When asked to utilized EPSTEIN's code to make a "test" call to determine the validity of the reason for the unsecure call, Lt. Doctor informed that it would be impossible to test because the system is voice recognizable and voice activated. Lt. Doctor further informed that inmates are given calls once per every 30 days. It is one call that may last 15 minutes max. All calls are made from within the cell and BOP personnel bring in a receiver or headset for the inmate to utilize. Records indicate ' or Mebane notified EPSTEIN next of kin; Mark Epstein at at 1100 hours on 08/10/2019. +- Review of EPSTEIN's commissary yielded him to have funds in the amount of \$566.27 at the time of his death. +- EPSTEIN had no "authorized persons" or any persons listed on his call log. +- Lt. Doctor was able to finally retrieve a record of EPSTEIN's last call. The call was unsecure line at approximately 1900 hours and was made to According to Lt. Doctor EPSTEIN indicated he was calling his mother. Lt. Doctor informed that EPSTEIN's mother is deceased. +- EPSTEIN's last cellmate was Efrain REYES (date of birth 03/10/1969) who + +Investigation on 08/10/2019 at New York, New York, United States (In Person) + +This document contains neither recommendations nor conclusions of the FBI. It is the moµ" ty of the FBI and is loaned to your agency; it and its contents arc no; to be distributed outside your agency. + +(U) Initial Review of EPSTEIN Inmate + +comimu8onamanof Records with Lieutenant Doctor (BOP) oOn 08/10/2019 ,page 2 of 2 + +was released from court on 08/09/2019. + +- EPSTEIN has no recorded visitors to the MCC. \ No newline at end of file diff --git a/marker2/ds9/EFTA00089258/EFTA00089258.metadata.json b/marker2/ds9/EFTA00089258/EFTA00089258.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..5b61b9b2cd7fbe30a9c1b5fdee39fa9a829a727b --- /dev/null +++ b/marker2/ds9/EFTA00089258/EFTA00089258.metadata.json @@ -0,0 +1,142 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089258.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2783, + "elapsed_seconds": 0.7, + "image_assets": [ + "_page_0_Picture_3.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "FEDERAL BUREAU OF INVESTIGATION", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 189.108, + 49.41 + ], + [ + 390.5003662109375, + 49.41 + ], + [ + 390.5003662109375, + 62.4552001953125 + ], + [ + 189.108, + 62.4552001953125 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 94 + ], + [ + "Line", + 45 + ], + [ + "Text", + 7 + ], + [ + "ListItem", + 5 + ], + [ + "PageHeader", + 2 + ], + [ + "SectionHeader", + 1 + ], + [ + "Picture", + 1 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 19 + ], + [ + "Line", + 8 + ], + [ + "Text", + 4 + ], + [ + "PageHeader", + 1 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ], + [ + "ListItem", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089258" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089258/_page_0_Picture_3.jpeg b/marker2/ds9/EFTA00089258/_page_0_Picture_3.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..c07c0c62a9c29fee13f18268ebba1d5c33a5fcc3 --- /dev/null +++ b/marker2/ds9/EFTA00089258/_page_0_Picture_3.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:11ad1c04b5d138859ac4f9542a5d3d8979c23bf32504d7157c41dc2a4000bbf6 +size 4644 diff --git a/marker2/ds9/EFTA00089260/EFTA00089260.md b/marker2/ds9/EFTA00089260/EFTA00089260.md new file mode 100644 index 0000000000000000000000000000000000000000..7b9d987a160451e188a57e5cc9bd23b8d280640d --- /dev/null +++ b/marker2/ds9/EFTA00089260/EFTA00089260.md @@ -0,0 +1,36 @@ +From To:' " Cc: Subject: RE: GHISLAINE MAXWELL TRIAL DATE??? Date: Wed, 15 Jul 2020 16:22:42 +0000 + +In fairness, I'd also like to know whatM -nade of the Satanic child-murder evidence .. . + +Seriously though, I can't imagine the volume of the craziness you guys are getting, and it's horrible online — very hard to understand what causes people to believe such insane stuff. Really depressing, and particularly for random folks who are targeted by it at unbelievable levels of volume — Chrissy Teigen etc. People who have nothing to do with the case whatsoever, but there's nothing that will ever convince the conspiracy theorists. Very unfortunate. + +From: Sent: Wednesda Jul 15 202008:39 To Cc: Subject: Fwd: GHISLAINE MAXWELL TRIAL DATE??? + +Just so you get a flavor of what some of the nuttier conspiracy theorists are saying. This guy is a real nut. In prior emails he "demanded" that you "put Maxwell on the stand" at her arraignment and ask her about the killing of babies and drinking of their blood in Zionist satanic rituals covered up by Mossad, MI5, and the CIA! + +U.S. Attorney's Office, SDNY + +Begin forwarded message: + +From: Francis Richard Conolly < Date: July 15, 2020 at 8:20:16 AM EDT To: Subject: GHISLAINE MAXWELL TRIAL DATE??? + +Dear Could you please inform Judge Nathan that I and many others are obviously delighted to hear that she denied bail to Ghislaine Maxwell. But why do we have to wait another entire year before the trial?? + +If you look at the YT public comments people are already saying something smells about this whole business. + +To give just two examples: a gentleman calling himself Gordoskin wrote "No mugshots, no videos, nor any proof that she is even in custody.. something stinks". Then someone called Sansara follows this up by saying "She is not going to be alive in a year's time.. the Judges should know that, unless they are part of the plot too" + +After what has gone before the public now has absolutely no faith or trust in the American Justice system. +And can you blame them? After Epstein? And Acosta? + +Someone really does need to make it clear to Alison Nathan that she herself, and the justice system she serves, are also on trial. Maxwell and Epstein were clearly mixed up with military intelligence and they could have concocted this entire thing just to mislead the public. + +A few crummy sketches of what we are being told was testimony via video link simply will not suffice in this case. + +Everyone I know is pushing me, as a Writer, to eloquently demand absolute proof that this whole arrest/incarceration is not simply another CIA scam. Will Judge Nathan provide it? And will she accept that the Lawyers, after so much preparation already, must be ready to go to trial right now? Tell the Judge she simply has to re-schedule for no later than the end of September. And if Maxwell is still alive even by that time I will be amazed. + +yours sincerely + +Francis Richard Conolly + +p.s. I'd still like to know what [REDACTED] made of the Satanic child-murder evidence provided by Ronald Bernard and Alissa Dearman?? \ No newline at end of file diff --git a/marker2/ds9/EFTA00089260/EFTA00089260.metadata.json b/marker2/ds9/EFTA00089260/EFTA00089260.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..981b639bb9758b603f0365b2c3ed33b5da524a5b --- /dev/null +++ b/marker2/ds9/EFTA00089260/EFTA00089260.metadata.json @@ -0,0 +1,76 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089260.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 3064, + "elapsed_seconds": 5.62, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 70 + ], + [ + "Line", + 31 + ], + [ + "Text", + 10 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 16 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089260" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089262/EFTA00089262.md b/marker2/ds9/EFTA00089262/EFTA00089262.md new file mode 100644 index 0000000000000000000000000000000000000000..42e08abbd344525c505363c7c3a2ff097479ea8a --- /dev/null +++ b/marker2/ds9/EFTA00089262/EFTA00089262.md @@ -0,0 +1,47 @@ +To: (USANYS + +Subject: Fwd: CBS NEWS TIMELY REQUEST / Ghislaine Maxwell + +Date: Tue, 14 Jul 2020 23:42:03 +0000 + +Inline-Images: Outlook-halnfvja.png + +CBS is asking if you guys indicated today whether Ghislaine is married or not. + +James Margolin + +Chief Public Information Officer + +U.S. Attorne 's Office SDNY + +(cell) + +Begin forwarded message: + +From: "Barth, Sarah" < + +Date: July 14 2020 at 7:37:05 PM EDT + +To: " + +Cc: "Cook, Hilary" , "Gauthier, Cassandra" < + +Subject: CBS NEWS TIMELY REQUEST / Ghislaine Maxwell + +Good evening Mr. Margolin, + +Sarah Barth here with CBS National News. I'm a producer for CBS This Morning with Gayle King. Anthony Mason. and Tony Dokoupil. + +We're seeing reporting online through other news outlets that prosecutors have said Ghislaine Maxwell is married. + +Can you confirm or respond to this? There's some confusion as this was not mentioned in today's hearing. + +Thank you, + +Sarah Barth + +Associate Booking Producer + +CBS This Mornin . CBS News + +![](_page_0_Picture_27.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00089262/EFTA00089262.metadata.json b/marker2/ds9/EFTA00089262/EFTA00089262.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..de3a364bdba3ac6168dfe0d423ce37891dc3b632 --- /dev/null +++ b/marker2/ds9/EFTA00089262/EFTA00089262.metadata.json @@ -0,0 +1,60 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089262.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 997, + "elapsed_seconds": 1.25, + "image_assets": [ + "_page_0_Picture_27.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 61 + ], + [ + "Line", + 29 + ], + [ + "Text", + 27 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089262" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089262/_page_0_Picture_27.jpeg b/marker2/ds9/EFTA00089262/_page_0_Picture_27.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..5268a94219e3ec7e7dc484c32d4b8b740ab3d8c8 --- /dev/null +++ b/marker2/ds9/EFTA00089262/_page_0_Picture_27.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:0826818203e8a2b934512af14542fa07bd67e097ac4ceb36c98d3d7cfcae7762 +size 6092 diff --git a/marker2/ds9/EFTA00089263/EFTA00089263.md b/marker2/ds9/EFTA00089263/EFTA00089263.md new file mode 100644 index 0000000000000000000000000000000000000000..1c995a14205823bd7f699343e252438fdc4b0999 --- /dev/null +++ b/marker2/ds9/EFTA00089263/EFTA00089263.md @@ -0,0 +1,63 @@ +From: ' To: "I Cc: 1 C Subject: RE: US v. Epstein Date: Mon, 20 Jul 2020 13:47:38 +0000 )" (USANYS) [Contractor]" + +Ah okay, thanks. + +From: (USANYS) [Contractor] < Sent: Monday, July 20, 2020 09:47 To: Cc: Subject: RE: US v. Epstein + +Whatever is on the list below is what I sent out for upload to the database. I can't check to make sure as I no longer have the hard drive in my possession as it is on its way to you. + +From: < Sent: Monday, July 20, 2020 9:44 AM To: (USANYS) [Contractor] < Cc: Subject: RE: US v. Epstein 1 Cc: Subject: RE: US v. Epstein + +A couple questions on this list. First, are you sure that NYCO24392 was provided to us? I ask because as of 7/14 (last Tuesday), in an email =said we didn't have that drive yet — see the spreadsheet in the attached email — and I also referred to that number on Wednesday in our call as one we didn't have and CART didn't say anything different. + +The other question is, do you have any info on NYCO24328 in terms of device, serial number, etc? I ask because looking at the same chart that ent in the attached email last Tuesday, there doesn't appear to be \*any\* device with that identifier. The list goes , 327, 329. + +thanks, + +From: (USANYS) [Contractor] .ct > + +Sent: Thursday, July 16, 2020 15:56 + +To: + +Subject: RE: US v. Epstein + +The following folders are being sent out for upload to Relativity: + +NYCO24363 + +NYCO24392 + +NYCO24328 + +NYCO24365 + +NYCO24366 + +NYCO24371 + +NYCO24383 + +Thank you. + +From: (USANYS) [Contractor] + +Sent: Thursday, July 16, 2020 3:00 PM + +To: + +Subject: US v. Epstein + +Hello + +I wanted to know if you have a minute to talk. + +Thank you. \ No newline at end of file diff --git a/marker2/ds9/EFTA00089263/EFTA00089263.metadata.json b/marker2/ds9/EFTA00089263/EFTA00089263.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..1c4f5aa70cf8fba3bb6793e1fb9f477f8f65faf2 --- /dev/null +++ b/marker2/ds9/EFTA00089263/EFTA00089263.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089263.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2509, + "elapsed_seconds": 1.32, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 81 + ], + [ + "Line", + 40 + ], + [ + "Text", + 10 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 57 + ], + [ + "Line", + 28 + ], + [ + "Text", + 27 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089263" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089265/EFTA00089265.md b/marker2/ds9/EFTA00089265/EFTA00089265.md new file mode 100644 index 0000000000000000000000000000000000000000..0bb13fb3a08d956628e5757328f94bedc7216f5b --- /dev/null +++ b/marker2/ds9/EFTA00089265/EFTA00089265.md @@ -0,0 +1,139 @@ +### FEDERAL BUREAU OF INVESTIGATION + +Precedence: ROUTINE + +0/To: Miami + +rom: New York + +C41 + +Contact: + +Approved By: + +Drafted By: + +Case ID #: 31E-MM-108062a0Pending) + +Title: JEFFREY EPSTEIN; + +Attn: + +GHISLAINE N. MAXWELL; WSTA-CHILD PROSTITUTION Date: 04/22/2008 + +Response to lead at Mastic, New York, to interview FD-302 attached. This lead is completed. + +Details: was interviewed regarding above captioned matter. Results set forth in attached FD-302. + +LEAD(s): + +Set Lead 1: (Action) + +MIAMI + +AT PBCRA + +Read and Clear. + +• • + +.tv-Lo'r SW + +# United States District Court + +SOUTHERN + +DISTRICT OF + +FLORIDA + +In the Matter of the Search of +(Name, address or brief description of property or premises to be searched) + +## SEARCH WARRANT + +One PNY Technologies +128 Megabyte CompactFlash memory card, +marked THNCF128MMA(TOOCB) 999223 TAIWAN 0247 +in the custody of the Federal Bureau of Investigation + +CASE NUMBER 08-8068-LRJ + +TO: [REDACTED] FEDERAL BUREAU OF INVESTIGATION, and any Authorized Officer of the United States: + +Affidavit(s) having been made before me by [REDACTED] who has reason to +Affiant + +believe that on the person of or on the premises known as (name, description and/or location) + +One PNY Technologies 128 Megabyte CompactFlash memory card, +marked THNCF128MMA(TOOCB) 999223 TAIWAN 0247 +in the custody of the Federal Bureau of Investigation, +505 S. Flagler Drive, Suite 500, West Palm Beach, Florida + +in the SOUTHERN District of FLORIDA there is now +concealed a certain person or property, namely (describe the person or property) + +the electronic information contained in that CompactFlash memory card, + +which is property that constitutes evidence of the commission of a criminal offense, instrumentalities of such violations; and any fruits of those crimes, that is, violations of 18 U.S.C. §§ 371, 1591, 2252, 2252A, 2422, and 2423. + +I am satisfied that the affidavit(s) and any recorded testimony establish probable cause to believe that the person or property so described is now concealed on the person or premises above-described and establish grounds for the issuance of this warrant. + +YOU ARE HEREBY COMMANDED to search on or before + +3-27-08 +(Date) + +(not to exceed 10 days) the person or place named above for the person or property specified, serving this warrant and making the search (in the daytime - 6:00 A.M. to 10:00 P.M.) (at any time in the day or night as I find reasonable cause has been established) and if the person or property be found there to seize same, leaving a copy of this warrant and receipt for the person or property taken, and prepare a written inventory of the person or property seized and promptly return this warrant to the duty Magistrate Judge as required by law. + +3-17-08 1:43 pm at WEST PALM BEACH, FLORIDA +Date and Time Issued City and State + +LINNEA R. JOHNSON +United States Magistrate Judge +Name and Title of Judicial Officer + +*[Signature]* +Signature of Judicial Officer + +Certified to be a true and +correct copy of the document on file +Steven M. Larimore, Clerk, +U.S. District Court +Southern District of Florida +By *[Signature]* +Date 3-17-08 +Deputy Clerk + +*[Signature]* +3/16-mm-108062 + +RETURN + +| DATE WARRANT RECEIVED
    03/17/2008 | DATE AND TIME WARRANT EXECUTED
    3/19/2008 11:00am | COPY OF WARRANT AND RECEIPT FOR ITEMS LEFT WITH
    [REDACTED] PBSO | +|--------------------------------------------|------------------------------------------------------------|--------------------------------------------------------------------| +|--------------------------------------------|------------------------------------------------------------|--------------------------------------------------------------------| + +| INVENTORY MADE IN THE PRESENCE OF
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We are undecided as to how to phrase the first paragraph and would welcome your thoughts on that and any other part of this draft. Happy to discuss. + +Thanks, +[REDACTED] + +\*\*\*\*\* + +The parties agree that the following facts will be included, without objection, in the Presentence Report for the Court to consider at sentencing: + +First Paragraph Option #1: Between approximately 2001 and 2013, [REDACTED] was employed by Jeffrey Epstein as a personal assistant. [REDACTED] has been evaluated by an expert psychologist who specializes in victims of sex trafficking, who completed a report dated April 20, 2020 regarding [REDACTED] experiences before, during, and after her employment with Epstein. The parties agree that the contents of the expert's report may be considered at sentencing, and the parties do not dispute the contents or conclusions of the report. + +First Paragraph Option #2: Between approximately 2001 and 2013, [REDACTED] was employed by Jeffrey Epstein as a personal assistant. At the time she was hired, [REDACTED] was financially destitute, had a history of being sexually abused by an older male, and had been completely cut off from her family. Shortly after hiring [REDACTED], Epstein began sexually abusing her. That sexual abuse continued for years, and included at least one instance in which Epstein forcibly raped [REDACTED]. Epstein also controlled various aspects of [REDACTED] life, including her diet, her clothing, her hair, and her sleep. [REDACTED] job responsibilities included numerous tasks involving Epstein's daily schedule, travel, and residences. One of those responsibilities involved scheduling massage appointments for Epstein. When [REDACTED] was first hired, she used a directory provided to her by Ghislaine Maxwell to contact women and girls to massage Epstein. Over the ensuing years, [REDACTED] would add new names to the directory when directed to do so by Epstein. + +During the period of her employment between approximately 2002 and 2005, [REDACTED] scheduled hundreds of appointments for women and girls, including dozens of minors, to massage Epstein. At those massage appointments, Epstein sexually abused dozens of minor victims. The majority of the massage appointments that [REDACTED] scheduled took place at Epstein's residence in Palm Beach, Florida, though some took place at Epstein's residence in New York, New York. During that same period, Epstein received approximately two to three massages per day. [REDACTED] was primarily responsible for scheduling those appointments in Palm Beach, but she occasionally scheduled them by phone while she was in New York City. When minor victims arrived for the appointments at Palm Beach, [REDACTED] sometimes met them, walked them up to the massage room, and set up the massage table for the appointment. After at least some of the appointments, [REDACTED] paid minor victims in cash. Epstein encouraged minor victims to bring other girls to massage him, which led to an increasing number of victims coming to massage Epstein at his residences. + +Through the process of arranging and facilitating massage appointments for Epstein, met dozens of underage victims, who ranged in age from 14 to 17 years old. None of those victims explicitly told that they were underage. Some of those victims did not have licenses, and arranged for a driver to pick them up and take them to their appointments with Epstein. Some of those victims told they could not attend certain appointment times because they were attending school. Epstein told that at least one of those victims was studying for the SATs. + +During the massage appointments with minor girls that scheduled, Epstein sexually abused the minor girls by, among other things, masturbating while the victims touched Epstein, touching the victim's genitals, using a sex toy on a victim's genitals, engaging in oral sex, and/or engaging in sexual intercourse. Although was not present for the vast majority of this abuse, she witnessed some of these massages. In particular, was present for and participated in one massage during which Epstein touched a minor victim's genitals. walked in on one instance in which a different minor victim was performing oral sex on Epstein. walked in on at least one additional massage during which a different minor victim was nude while massaging Epstein. At Epstein's direction, took nude or partially nude photographs of more than one minor victim. + +In or about 2005, learned that law enforcement was investigating Epstein for sex crimes involving minors, arising from the massage appointments that had facilitated. After learning about the investigation into Epstein, called multiple minor victims and encouraged them not to talk to law enforcement. At Epstein's direction, offered financial incentives to victims for not speaking with law enforcement. Beginning in approximately 2006, multiple minor victims were interviewed by federal law enforcement officers who were conducting a criminal investigation of Epstein and his associates for sex trafficking of minors, among other federal offenses. 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He says to keep trying her, that she has no problem talking with us it's just an issue of logistics and getting in touch. He also confirmed we have her correct number. + +He also provided a number for who they've spoken to and who is apparently willing to speak with us. If we could schedule her for this coming Wednesday (or Tuesday or Thursday) as well, that would be fantastic. She's apparently expecting our call, and her number is: + +with apologies for asking this while you're off duty, could you please try them today, and over the weekend if you don't connect with them immediately? + +And separately, wanted to follow up on — it was just last week we got the green light to call her, but wanted to refresh that. The original email with her background info is attached, but her number is I think she's safe to call (in terms of keeping it confidential) and if we schedule her for the first or second week of June that would be great. + +Thanks very much, + +From: + +Sent: Friday, May 24, 2019 12:29 + +To: cz > + +Cc: (NY) (FBI) c ) + +Subject: Re: quick update + +Thanks for the update. As of yet we have not heard from =. + +On May 24, 2019, at 12:24, ‹ > wrote: + +I just left voicemails for and MI but just to keep everybody in the loop — I just spoke to Sid Garcia's office (he's the attorney for M), they said that =can't do Tuesday next week and Sid can't do Thursday, so we're still aiming for sometime Wednesday and they're going to call me back this afternoon as soon as possible to finalize a time. I stressed that we have to finalize travel plans so the sooner the better. + +I also spoke to Stan, who said that they'll try to reach out to to ask her to call He also said that is willing to talk with us, and he said they would give her number but would also try to get us her number. With Stan also I stressed the time issue. + +thanks, + +Assistant U.S. Attorney Southern District of New York \ No newline at end of file diff --git a/marker2/ds9/EFTA00089270/EFTA00089270.metadata.json b/marker2/ds9/EFTA00089270/EFTA00089270.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..1128bf272cc1669748c93e433adfbc9aea2b2f4c --- /dev/null +++ b/marker2/ds9/EFTA00089270/EFTA00089270.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089270.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2245, + "elapsed_seconds": 0.96, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 83 + ], + [ + "Line", + 39 + ], + [ + "Text", + 19 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 9 + ], + [ + "Text", + 6 + ], + [ + "Line", + 5 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089270" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089272/EFTA00089272.md b/marker2/ds9/EFTA00089272/EFTA00089272.md new file mode 100644 index 0000000000000000000000000000000000000000..28d6a92bb912ded1c5947ed1e038c4a99e403670 --- /dev/null +++ b/marker2/ds9/EFTA00089272/EFTA00089272.md @@ -0,0 +1,23 @@ +From: ' To: ' Cc: Subject: RE: NY) (FBI)" + +Date: Thu, 06 Jun 2019 00:11:45 +0000 + +Importance: Normal + +Thanks. I checked her number against the tolls we have, and it looks like there are tolls between her number and cell, as well as between her number and Epstein's cell. + +From: (NY) (FBI) ca Sent: Wednesday, June 5, 2019 7:45 PM To: c :'; Cc: < >; Subject: RE: + +Attached is her clear report. Looks like the is the most recent address. + +Special Agent FBI New York VCAC/Human Trafficking + +From: [mato Sent: Wednesday, June 05, 2019 6:08 PM To: (NY) (FBI) + +Subject + +Any chance you could please send us a clear report fo prior address: + +Thanks! Will explain when we talk this evening. + +Assistant United States Attorney Southern District of New York \ No newline at end of file diff --git a/marker2/ds9/EFTA00089272/EFTA00089272.metadata.json b/marker2/ds9/EFTA00089272/EFTA00089272.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..04160f992fae0d978baaba9f871479b43202e167 --- /dev/null +++ b/marker2/ds9/EFTA00089272/EFTA00089272.metadata.json @@ -0,0 +1,80 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089272.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 760, + "elapsed_seconds": 0.99, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 65 + ], + [ + "Line", + 29 + ], + [ + "Text", + 14 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "PageFooter", + 1 + ], + [ + "Line", + 1 + ], + [ + "Span", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089272" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089274/EFTA00089274.md b/marker2/ds9/EFTA00089274/EFTA00089274.md new file mode 100644 index 0000000000000000000000000000000000000000..b7775e66571906251980361d616cf9162e93b41b --- /dev/null +++ b/marker2/ds9/EFTA00089274/EFTA00089274.md @@ -0,0 +1,185 @@ +**To:** "[REDACTED]" <[REDACTED]> + +**Cc:** "[REDACTED]" <[REDACTED]> + +**Subject:** Re: Ghislaine Maxwell (USMS No. 02879-509) + +**Date:** Sun, 12 Jul 2020 17:08:17 +0000 + +--- + +I copied him in the email? Or not sure if you mean trying to call him, I unfortunately don't think I have either of their cells + +Sent from my iPhone + +On Jul 12, 2020, at 12:46, [REDACTED] <[REDACTED]> wrote: + +Do you think it's worth contacting [REDACTED]? + +Sent from my iPhone + +On Jul 12, 2020, at 12:43 PM, [REDACTED] <[REDACTED]> wrote: + +They're going to beat us over the head on this on Tuesday in connection with their access to client arg. + +Sent from my iPhone + +Begin forwarded message: + +**From:** "[REDACTED]" <[REDACTED]> + +**Date:** July 12, 2020 at 12:42:25 EDT + +**To:** [REDACTED] <[REDACTED]> + +**Cc:** "[REDACTED]" <[REDACTED]>, "[REDACTED]" + +<[REDACTED]>, "[REDACTED]" <[REDACTED]> + +**Subject:** Re: Ghislaine Maxwell (USMS No. 02879-509) + +[REDACTED] + +Following up, we heard from defense counsel that they didn't receive a call this morning either and that they filed an emergency request but haven't heard back. Please let us know the status as soon as possible? They also wanted to confirm that they will have calls at 10:00 tomorrow and Tuesday. Again, we realize this is unusual but I'm not aware of any other defendants who are in this circumstance of having a bail hearing pending in just two days. Also copying [REDACTED] in case he's aware of someone else we should contact. + +thank you, + +[REDACTED]. + +Following up on this — we understand that as of Tuesday defense counsel will go through the normal process, but since the client's bail hearing is Tuesday they did anticipate being able to speak with her this weekend and tomorrow in advance. Thanks again and sorry for the bother. + +On Jul 11, 2020, at 17:16, ) < wrote: + +We just were contacted by defense counsel, who said they didn't have a call with their client this morning — I think they expected that the morning calls up until her arraignment on Tuesday would include the weekend. Is it possible to reinstitute the call for tomorrow at 10:00, as well as on Monday? Thanks very much, and sorry for the late notice —we just heard from them a moment ago. + +thanks, + +From: + +Sent: Friday, July 10, 2020 10:34 + +To: < + +Cc: + +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, c > 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, + +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: sc > + +Sent: Tuesday, July 7, 2020 4:23 PM + +To: I + +Cc: + +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. + +Sent: Tuesday, July 7, 2020 2:36 PM + +To: + +Cc: + +Subject: Re: Ghislaine Maxwell (USMS No. 02879-509) + +Hi =, + +!just saw this now. Is this about the legal call issue or something separate? If its 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 + +l St. Andrew's Plaza New York, NY 10007 \ No newline at end of file diff --git a/marker2/ds9/EFTA00089274/EFTA00089274.metadata.json b/marker2/ds9/EFTA00089274/EFTA00089274.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..98197ce6ea0c0cd4494126f50672d9936708e31b --- /dev/null +++ b/marker2/ds9/EFTA00089274/EFTA00089274.metadata.json @@ -0,0 +1,144 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089274.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 4, + "chars": 7304, + "elapsed_seconds": 7.85, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 60 + ], + [ + "Text", + 49 + ], + [ + "Line", + 29 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 63 + ], + [ + "Line", + 27 + ], + [ + "Text", + 23 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 85 + ], + [ + "Line", + 42 + ], + [ + "Text", + 22 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 3, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 81 + ], + [ + "Line", + 40 + ], + [ + "Text", + 39 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089274" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089278/EFTA00089278.md b/marker2/ds9/EFTA00089278/EFTA00089278.md new file mode 100644 index 0000000000000000000000000000000000000000..850a4e666648eb6f6cfc4aed6b218e260e1a2134 --- /dev/null +++ b/marker2/ds9/EFTA00089278/EFTA00089278.md @@ -0,0 +1,15 @@ +To: + +Cc: + +Subject: RE: victim call + +Date: Sun, 12 Jul 2020 23:01:12 +0000 + +I got a call this past week from a woman who said that she previously had been sexually assaulted, by a man who she believed was associated with Epstein. She said that she is a high-profile individual and that she would like to speak with someone from the FBI. She gave her name as and gave the number She declined to provide a last name, but caller ID showed the name when she called. Based on her brief self-description, her accent, and the caller ID, I think she may be this woman: + +Though I'm not positive. Could someone please reach out to her this coming week? + +thanks very much, + +Assistant U.S. Attorney Southern District of New York \ No newline at end of file diff --git a/marker2/ds9/EFTA00089278/EFTA00089278.metadata.json b/marker2/ds9/EFTA00089278/EFTA00089278.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..438012c7b712670ae62db863b68142026bb01c15 --- /dev/null +++ b/marker2/ds9/EFTA00089278/EFTA00089278.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089278.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 715, + "elapsed_seconds": 0.59, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 29 + ], + [ + "Line", + 15 + ], + [ + "Text", + 12 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089278" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089279/EFTA00089279.md b/marker2/ds9/EFTA00089279/EFTA00089279.md new file mode 100644 index 0000000000000000000000000000000000000000..00b4e0d69e5d66aff04d07108bb63b819eb82b63 --- /dev/null +++ b/marker2/ds9/EFTA00089279/EFTA00089279.md @@ -0,0 +1,17 @@ +From: " + +To: "-• (NY) , + +Cc: i nIELMIE>, + +Subject: detention hearing + +Date: Fri, 10 Jul 2020 03:03:25 +0000 + +Attachments: 2020.07.09\_Scheduling\_Order.pdf + +Hi + +Attached is the Court's order for the conference, which includes dial-in information for accessing the audio feed of the conference. + +Assistant United States Attorney Southern District of New York \ No newline at end of file diff --git a/marker2/ds9/EFTA00089279/EFTA00089279.metadata.json b/marker2/ds9/EFTA00089279/EFTA00089279.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..98323f568b53288fa5d570f006dc416f0893e540 --- /dev/null +++ b/marker2/ds9/EFTA00089279/EFTA00089279.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089279.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 365, + "elapsed_seconds": 0.66, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 27 + ], + [ + "Text", + 13 + ], + [ + "Line", + 13 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089279" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089280/EFTA00089280.md b/marker2/ds9/EFTA00089280/EFTA00089280.md new file mode 100644 index 0000000000000000000000000000000000000000..36772c4ff64853c837d66593e11347ae8650e404 --- /dev/null +++ b/marker2/ds9/EFTA00089280/EFTA00089280.md @@ -0,0 +1,39 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +United States of America, + +—v— + +Ghislaine Maxwell, + +Defendant. + +20-CR-330 (MN) + +ORDER + +ALISON J. NATHAN, District Judge: + +As discussed in its previous order, the Court will hold an arraignment, initial conference, and bail hearing in this matter remotely as a video/teleconference on July 14, 2020 at 1 pm. Members of the press and the public in the United States may access the live audio feed of the proceeding by calling 855-268-7844 and using access code 32091812# and PIN 9921299#. Those outside of the United States may access the live audio feed by calling 214-416-0400 and using the same access code and PIN. These phone lines can accommodate approximately 500 callers on a first come, first serve basis. + +The Court will provide counsel for both sides an additional dial-in number to be used to ensure audio access to the proceeding for non-speaking co-counsel, alleged victims, and any family members of the Defendant. The United States Attorney's Office should email Chambers with information regarding any alleged victims who are entitled, pursuant to 18 U.S.C. § 3771(a)(4), to be heard at the bail hearing and who wish to be heard. The Court will then provide information as to the logistics for their dial-in access. + +As the Court described in a previous order, members of the press and public may watch and listen to the live video feed in the Jury Assembly Room, at the Daniel Patrick Moynihan Courthouse, 500 Pearl Street. See Dkt. No. 10. However, in light of COVID-19, seating will be + +limited to approximately 60 seats in order to enable appropriate social distancing and ensure public safety. Counsel for the Defendant and the Government may contact Chambers by email if there is a request to accommodate alleged victims or family members of the Defendant. + +Members of the credentialed in-house press corps may contact the District Executive's Office about seating. Otherwise, all seating will be allocated on a first come, first serve basis and in accordance with the S.D.N.Y. COVID-19 Courthouse Entry Program and this Court's previous order of July 7, 2020. *See* Dkt. No. 10. If conditions change or the Court otherwise concludes that allowing for in-person viewing of the video feed at the courthouse is not consistent with public health, the Court may provide audio access by telephone only. + +Any photographing, recording, or rebroadcasting of federal court proceedings is prohibited by law. Violation of these prohibitions may result in fines or sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. + +SO ORDERED. + +Dated: July 9, 2020 +New York, New York + +![]() + +--- + +ALISON J. NATHAN +United States District Judge \ No newline at end of file diff --git a/marker2/ds9/EFTA00089280/EFTA00089280.metadata.json b/marker2/ds9/EFTA00089280/EFTA00089280.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..530e76ebc0e2e631ebe5bc33ec284974c5073021 --- /dev/null +++ b/marker2/ds9/EFTA00089280/EFTA00089280.metadata.json @@ -0,0 +1,124 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089280.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2843, + "elapsed_seconds": 5.01, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 71.28 + ], + [ + 281.41961669921875, + 71.28 + ], + [ + 281.41961669921875, + 99.603515625 + ], + [ + 68.544, + 99.603515625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 64 + ], + [ + "Line", + 32 + ], + [ + "Text", + 10 + ], + [ + "PageHeader", + 2 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 39 + ], + [ + "Line", + 20 + ], + [ + "Text", + 12 + ], + [ + "PageHeader", + 2 + ], + [ + "Caption", + 2 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089280" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089282/EFTA00089282.md b/marker2/ds9/EFTA00089282/EFTA00089282.md new file mode 100644 index 0000000000000000000000000000000000000000..36772c4ff64853c837d66593e11347ae8650e404 --- /dev/null +++ b/marker2/ds9/EFTA00089282/EFTA00089282.md @@ -0,0 +1,39 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +United States of America, + +—v— + +Ghislaine Maxwell, + +Defendant. + +20-CR-330 (MN) + +ORDER + +ALISON J. NATHAN, District Judge: + +As discussed in its previous order, the Court will hold an arraignment, initial conference, and bail hearing in this matter remotely as a video/teleconference on July 14, 2020 at 1 pm. Members of the press and the public in the United States may access the live audio feed of the proceeding by calling 855-268-7844 and using access code 32091812# and PIN 9921299#. Those outside of the United States may access the live audio feed by calling 214-416-0400 and using the same access code and PIN. These phone lines can accommodate approximately 500 callers on a first come, first serve basis. + +The Court will provide counsel for both sides an additional dial-in number to be used to ensure audio access to the proceeding for non-speaking co-counsel, alleged victims, and any family members of the Defendant. The United States Attorney's Office should email Chambers with information regarding any alleged victims who are entitled, pursuant to 18 U.S.C. § 3771(a)(4), to be heard at the bail hearing and who wish to be heard. The Court will then provide information as to the logistics for their dial-in access. + +As the Court described in a previous order, members of the press and public may watch and listen to the live video feed in the Jury Assembly Room, at the Daniel Patrick Moynihan Courthouse, 500 Pearl Street. See Dkt. No. 10. However, in light of COVID-19, seating will be + +limited to approximately 60 seats in order to enable appropriate social distancing and ensure public safety. Counsel for the Defendant and the Government may contact Chambers by email if there is a request to accommodate alleged victims or family members of the Defendant. + +Members of the credentialed in-house press corps may contact the District Executive's Office about seating. Otherwise, all seating will be allocated on a first come, first serve basis and in accordance with the S.D.N.Y. COVID-19 Courthouse Entry Program and this Court's previous order of July 7, 2020. *See* Dkt. No. 10. If conditions change or the Court otherwise concludes that allowing for in-person viewing of the video feed at the courthouse is not consistent with public health, the Court may provide audio access by telephone only. + +Any photographing, recording, or rebroadcasting of federal court proceedings is prohibited by law. Violation of these prohibitions may result in fines or sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. + +SO ORDERED. + +Dated: July 9, 2020 +New York, New York + +![]() + +--- + +ALISON J. NATHAN +United States District Judge \ No newline at end of file diff --git a/marker2/ds9/EFTA00089282/EFTA00089282.metadata.json b/marker2/ds9/EFTA00089282/EFTA00089282.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..03f5c637095ab4d1e3d050d9e68f043f8f7db915 --- /dev/null +++ b/marker2/ds9/EFTA00089282/EFTA00089282.metadata.json @@ -0,0 +1,124 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089282.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2843, + "elapsed_seconds": 5.01, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 71.28 + ], + [ + 281.41961669921875, + 71.28 + ], + [ + 281.41961669921875, + 99.603515625 + ], + [ + 68.544, + 99.603515625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 64 + ], + [ + "Line", + 32 + ], + [ + "Text", + 10 + ], + [ + "PageHeader", + 2 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 39 + ], + [ + "Line", + 20 + ], + [ + "Text", + 12 + ], + [ + "PageHeader", + 2 + ], + [ + "Caption", + 2 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089282" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089284/EFTA00089284.md b/marker2/ds9/EFTA00089284/EFTA00089284.md new file mode 100644 index 0000000000000000000000000000000000000000..acef68c74b7eb33c014931dc10d0ec6a8a944eae --- /dev/null +++ b/marker2/ds9/EFTA00089284/EFTA00089284.md @@ -0,0 +1,45 @@ +**From:** [REDACTED] > +**To:** File Opening [REDACTED] +**Subject:** Fwd: Steve & Jen Marshal +**Date:** Tue, 05 Nov 2019 19:30:22 +0000 + +--- + +[REDACTED] +Attorney at Law-NH & MA +[REDACTED] +[REDACTED] +[REDACTED] + +--- + +**From:** [REDACTED] +**Sent:** Tuesday, November 5, 2019 2:00:27 PM +**To:** [REDACTED] +**Subject:** Steve & Jen Marshal +Hi Jackie, + +--- + +I have been showing a home, [REDACTED] to a lovely couple from England that wanted to chat with a lawyer. I gave them the office number but wanted to give you a heads up for when they call. I mentioned that I would write up their offer and that your office would handle the closing. + +Talk soon! + +Warmest regards, +Jen + +-- +[REDACTED] +*Real Estate Consultant* +*Realtor ®* + +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] + +**Security Advisory:** Crimes involving Internet, email and wire fraud are a constant threat. **Do not wire funds or send nonpublic personal information**, such as social security numbers, credit card or debit card numbers or bank account and/or routing numbers **to anyone (including your attorney or your Realtor)** who appears to be requesting the same by email **without personal verification of authenticity**. If you should receive such a request by email do not reply to that message. Verify by making alternate direct personal contact. + +**MANDATORY DISCLOSURE CONCERNING REPRESENTATION AND CONFIDENTIALITY:** Licensed real estate professionals are required to disclose information regarding confidentiality and agency status to persons with whom they communicate regarding real estate. Four Seasons Sotheby's International Realty (FSSIR) has elected to practice as a Designated Agency Firm. Within a written Listing Agreement or Buyer Broker Agreement, a specific Designated Agent(s) is appointed to represent you as a client. Your designated agent(s) must keep your confidences and act according to your interests and lawful instructions. Other agents of the firm may represent other buyers or sellers whose interests conflict with yours. Until you have entered into a written Listing Agreement or Buyer Broker Agreement with us, your communications with us are not confidential and we + +are not acting on your behalf as your agent. I am happy to answer any questions you may have or you may access further information regarding confidentiality and designated agency on-line through the Secretary of State/Real Estate Commission web site. This transmission contains information that may be confidential and that may also be proprietary; unless you are the intended recipient of the message (or authorized to receive it for the intended recipient), you may not copy. forward. or otherwise use it, or disclose its contents to anyone else. If you have received this transmission in error. please notify us immediately and delete it from your system. \ No newline at end of file diff --git a/marker2/ds9/EFTA00089284/EFTA00089284.metadata.json b/marker2/ds9/EFTA00089284/EFTA00089284.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..fbfbde113d35acb1ae31c33d31675e6e9f8fc2eb --- /dev/null +++ b/marker2/ds9/EFTA00089284/EFTA00089284.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089284.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2857, + "elapsed_seconds": 7.28, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 55 + ], + [ + "Line", + 28 + ], + [ + "Text", + 25 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 11 + ], + [ + "Line", + 5 + ], + [ + "Text", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089284" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089286/EFTA00089286.md b/marker2/ds9/EFTA00089286/EFTA00089286.md new file mode 100644 index 0000000000000000000000000000000000000000..abab2c418e9961b38bae8e318784a5c3de761ab2 --- /dev/null +++ b/marker2/ds9/EFTA00089286/EFTA00089286.md @@ -0,0 +1,32 @@ +**From:** Rebecca Russo <[REDACTED]> +**To:** Kayla Grimme <[REDACTED]>, Kate Halsted <[REDACTED]> +**Cc:** [REDACTED] <[REDACTED]> + +**Subject:** Granite Reality 2019-2700 12/13 + +**Date:** Thu, 12 Dec 2019 23:05:09 +0000 + +**Attachments:** granite\_reality\_deed.pdf; granite\_reality\_seller\_hlaw\_docs.pdf; +post\_close\_checks\_at\_table\_granite\_reality.pdf; post\_close\_disb\_granite\_realit.pdf + +**Inline-Images:** image001.jpg + +--- + +Seller side/brokers only. Original buyers docs in New London + +*Regards,* + +*Rebecca Russo* + +*Senior Paralegal and Real Estate Processor* + +*Phone* [REDACTED] + +*Assistant to Rebecca Russo, Kristen Sinnott, may be reached at* [REDACTED] + +*Fax* [REDACTED] + +**FRAUD ALERT: DO NOT WIRE FUNDS unless you have called our firm to verify wire instructions. Even if an email appears as if it was generated by this firm or a party to your transaction, CALL US at [REDACTED] to verify the information before transmitting your funds.** + +This email message is intended only for the named recipients. It may contain confidential information that is privileged or that constitutes attorney work product. If you are not the intended recipient, you are hereby notified that any dissemination, distribution or copying of this email and any attachments is not authorized and is strictly prohibited. If you have received this email in error, please notify the sender by replying to this email and delete the message and any attachments from your system. \ No newline at end of file diff --git a/marker2/ds9/EFTA00089286/EFTA00089286.metadata.json b/marker2/ds9/EFTA00089286/EFTA00089286.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..a6890efa368e30dbe4f6bc50ef349d646e50b038 --- /dev/null +++ b/marker2/ds9/EFTA00089286/EFTA00089286.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089286.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1475, + "elapsed_seconds": 5.8, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 44 + ], + [ + "Text", + 28 + ], + [ + "Line", + 22 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089286" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089287/EFTA00089287.md b/marker2/ds9/EFTA00089287/EFTA00089287.md new file mode 100644 index 0000000000000000000000000000000000000000..39c1638f8c3e83b8e2fd891b09a403238ab58038 --- /dev/null +++ b/marker2/ds9/EFTA00089287/EFTA00089287.md @@ -0,0 +1,1526 @@ +1. FHA 2. RHS 3. Conv. Unins 4. VA 5. Conv. Ins 6. Cash 7. Other + +8. File Number 2019-2700 + +9. Loan Number + +10. Mortgage Insurance Case Number + +**C. NOTE:** This form is furnished to give you a statement of actual settlement costs. Amounts paid to and by the settlement agent are shown. Items marked "(p.o.c.)" were paid outside the closing, they are shown here for informational purposes and are not included in the totals. + +**D. NAME AND ADDRESS OF BUYER:** + +**Granite Reality LLC** + +155 Seaport Blvd, c/o Nutter McLennan & Fish LLP, Boston, MA 02210 + +**E. NAME AND ADDRESS OF SELLER:** + +[REDACTED] + +**F. NAME AND ADDRESS OF LENDER:** + +**CASH** + +**G. PROPERTY LOCATION:** + +[REDACTED] Bradford NH 03221 + +**H. SETTLEMENT AGENT** + +Hudkins Law PLLC +9 Newport Road, New London NH 03257 + +**PLACE OF SETTLEMENT** + +[REDACTED] +9 Newport Road, New London NH 03257 + +**I. SETTLEMENT DATE:** 12/13/2019 + +**DISBURSEMENT DATE** + +12/13/2019 + +**J. Summary of Buyer's Transaction** + +**K. Summary of Seller's Transaction** + +**100. Gross Amount Due From Buyer** + +**400. Gross Amount Due To Seller** + +| 101. Contract Sales Price | 1,070,750.00 | 401. Contract Sales Price | 1,070,750.00 | +|----------------------------------------------|--------------|---------------------------|--------------| +| 102. Personal Property | | 402. Personal Property | | +| 103. Settlement charges to buyer (line 1400) | 11,863.55 | 403. | | +| 104. | | 404. | | +| 105. | | 405. | | + +**Adjustments for items paid by seller in advance** + +**Adjustments for items paid by seller in advance** + +| 106. City/Town taxes 12/13/2019 to 03/31/2020 | 6,630.44 | 406. City/Town taxes 12/13/2019 to 03/31/2020 | 6,630.44 | +|-----------------------------------------------|--------------|-----------------------------------------------|--------------| +| 107. County taxes | | 407. County taxes | | +| 108. | | 408. | | +| 109. Oil Proration - Main House | 1,436.35 | 409. Oil Proration - Main House | 1,436.35 | +| 110. Oil Proration - Guest Cottage | 1,511.95 | 410. Oil Proration - Guest Cottage | 1,511.95 | +| 111. Propane Adjustment - Main House | 1,637.65 | 411. Propane Adjustment - Main House | 1,637.65 | +| 112. Propane Adjustment - Equipment Barn | 449.18 | 412. Propane Adjustment - Equipment Barn | 449.18 | +| 120. Gross Amount Due From Buyer | 1,094,279.12 | 420. Gross Amount Due To Seller | 1,082,415.57 | + +**200. Amounts Paid By Or In Behalf Of Buyer** + +**500. Reductions In Amount Due To Seller** + +| 201. Deposit or earnest money Four Seasons Sothebys International Real Estate | 100,000.00 | 501. Excess deposit (see instructions) | | +|-------------------------------------------------------------------------------|------------|-----------------------------------------------|-----------| +| 202. Principal amount of new loan(s) | | 502. Settlement charges to seller (line 1400) | 58,368.50 | +| 203. Existing loan(s) taken subject to | | 503. Existing loan(s) taken subject to | | +| 204. | | 504. Bradford Tax Collector - Taxes Due 12/17 | 11,375.00 | +| 205. | | 505. Law Office of Margaret A. Jacobs | 350.00 | +| 206. | | 506. | | +| 207. | | 507. | | +| 208. | | 508. | | +| 209. | | 509. | | + +**Adjustments for items unpaid by seller** + +**Adjustments for items unpaid by seller** + +| 210. City/Town taxes | | 510. City/Town taxes | | +|----------------------|--|----------------------|--| +| 211. County taxes | | 511. County taxes | | +| 212. Assessments | | 512. Assessments | | +| 213. | | 513. | | +| 214. | | 514. | | +| 215. | | 515. | | +| 216. | | 516. | | +| 217. | | 517. | | +| 218. | | 518. | | +| 219. | | 519. | | + +**220. Total Paid By/For Buyer** + +100,000.00 + +**520. Total Reduction Amount Due Seller** + +70,093.50 + +**300. Cash At Settlement From/To Buyer** + +**600. Cash At Settlement From/To Seller** + +| 301. Gross Amount due from buyer (line 120) | 1,094,279.12 | 601. Gross Amount due to Seller (line 420) | 1,082,415.57 | +|------------------------------------------------|--------------|------------------------------------------------------|--------------| +| 302. Less amounts paid by/for buyer (line 220) | 100,000.00 | 602. Less reductions in amount due seller (line 520) | 70,093.50 | +| 303. CASH From Buyer | 994,279.12 | 603. CASH To SELLER | 1,012,322.07 | + +We, the undersigned, identified in Section D hereof and Seller in Section E hereof, hereby acknowledge receipt of this completed Settlement Statement (Pages 1 and 2) on December 13, 2019. + +| L. SETTLEMENT CHARGES | | | +|---------------------------------------------------------------------|------------------------------------------------|-------------------------------------------------| +| 700. Total Real Estate Broker Fees | | | +| Division of commission (line 700) as follows: | | | +| 701. \$50,287.50 to Four Seasons Sothebys International Real Estate | Paid From
    Buyer's
    Funds at
    Settlement | Paid From
    Seller's
    Funds at
    Settlement | +| 702. \$.00 to Four Seasons Sothebys International Real Estate | | | +| 703. Commission paid at settlement | | 50,287.50 | +| 704. | | | +| 705. | | | +| 706. | | | + +| 800. Items Payable In connection with Loan | | | +|---------------------------------------------------|---------|--| +| 801. Loan Origination Fee | to CASH | | +| 802. Loan Discount | to CASH | | +| 803. | | | +| 804. | | | +| 805. | | | +| 806. | | | + +| 900. Items Required By Lender To Be Paid In Advance | | | +|------------------------------------------------------------|-----------------|---------------| +| 901. Interest from | From 12/13/2019 | To 01/01/2020 | +| 902. Mortgage insurance premium | | | +| 903. Hazard Insurance premium | | | +| 904. | | | +| 905. | | | + +| 1000. Reserves Deposited With Lender | | | +|----------------------------------------------------|--|--| +| 1001. Hazard Insurance | | | +| 1002. Mortgage Insurance | | | +| 1003. City property taxes | | | +| 1004. County property taxes months
    at per month | | | +| 1005. Annual assessments | | | +| 1006. | | | +| 1007. | | | +| 1008. Aggregate Adjustments | | | + +| 1100. Title Charges | | | +|-----------------------------------------------------|-----------------------------------|----------| +| 1101. | | | +| 1102. | | | +| 1103. | | | +| 1104. | | | +| 1105. | | | +| 1106. | | | +| 1107. Attorney's fees | to Hudkins Law PLLC | 1,250.00 | +| 1108. Title Insurance | to Stewart Title Guaranty Company | 2,537.00 | +| 1109. Lender's coverage @ \$ .00 | | | +| 1110. Owner's coverage \$1,070,750.00 @ \$ 2,537.00 | | | +| 1111. | | | +| 1112. | | | +| 1113. | | | + +| 1200. Government Recording and Transfer Charges | | | | | +|--------------------------------------------------------|------------------|----------|----------|----------| +| 1201. Recording fees: | Deed \$45.55 | Mortgage | Releases | 45.55 | +| 1202. City/county tax/stamps | Deed | Mortgage | | | +| 1203. State tax/stamps: | Deed \$16,062.00 | Mortgage | | 8,031.00 | +| 1204. | | | | 8,031.00 | +| 1205. | | | | | + +| 1300. Additional Settlement Charges | | | +|--------------------------------------------|---------------------|--| +| 1301. | to | | +| 1302. | | | +| 1303. Courier/Wire/Fedex Fee | to Hudkins Law PLLC | | +| 1304. | | | +| 1305. | | | + +| 1400. TOTAL SETTLEMENT CHARGES | | | +|---------------------------------------|--|-----------| +| | | 11,863.55 | +| | | 58,368.50 | + +We, the undersigned, identified in Section D hereof and Seller in Section E hereof, hereby acknowledge receipt of this completed Settlement Statement (Pages 1 and 2) on December 13, 2019. + +We, the undersigned, identified in Section D hereof and Seller in Section E hereof, hereby acknowledge receipt of this completed Settlement Statement on **December 13, 2019**. + +The HUD-1 Settlement Statement which I have prepared is a true and accurate account of this transaction. I have caused or will cause the funds to be disbursed in accordance with this statement. + +**Borrower(s)** + +[Redacted Signature] + +Granite Realty LLC, By: Jeffrey W. +Roberts, Manager + +[Redacted Signature] + +Seller(s) + +d + +Settlement Agent: [Redacted Signature] + +Date: 12-13-19 + +*(Handwritten signature)* + +![](_page_2_Picture_115.jpeg) + +Re ivrn To Gran;le Peat 155 Sea ',oil ta Boshn , 02.2)o + +> \$16,062." WARRANTY DEED + +# ORIGINAL DOCUMENT Recording Information + +County:tvLeivu nay Q1t Date/Time. IF I 3. 3t PIBook/Page:365' - 7 3 + +KNOW ALL BY THESE PRESENTS that I, Richard Yospin, Trustee of The Richard Yospin Family Trust u/d/t dated December 28, 2012, of Newton, Massachusetts, for consideration paid, grant to Granite Reality, LLC, a New Hampshire limited liability company, with aprincipal mailing address of 155 Seaport Blvd., Boston, MA 02210, with WARRANTY COVENANTS, + +That certain tract or parcel of land together with the buildings thereon, located in the Town of Bradford, County of Merrimack, State of New Hampshire as being shown on aplan of land entitled "Plan of Land in Bradford, New Hampshire surveyed for Bertha S. Williams" dated 1 November 1977, by Stowers Associates, Inc., Registered Land Surveyors, Methuen, Massachusetts, recorded with the Registry of Deeds for Merrimack County at Concord, New Hampshire as Plan No. 5083, said land being shown upon said plan as being more particularly bounded and described as follows: + +Beginning at the extreme Northwesterly corner of the premises herein described at the end or a stone wall situated on the Southerly side of East Washington Road in the said Town of Bradford; thence running Southerly by and along the center line of said wall 294 feet to apoint in the center line of said wall; thence turning and running slightly West of Southerly by and along the center line of said wall 241 feet to the end of said wall; thence turning and running slightly South of Easterly and along a wire fence 445 feet to the end of astone wall; thence running by and along the center line of said wall in the same direction 1,030 feet to a corner in said wall; thence turning and running slightly West of Southerly by and along the center line of said wall 1,009 feet to a corner of the wall; thence turning and running Easterly by and along the center line of said wall 116feet to a corner of said wall; thence turning and running Southerly by the center line of the wall as the wall now stands 404 feet to a corner of the said wall; thence turning and running Westerly by and along the center line of said wall 109 feet to the corner of said wall; thence turning and running Southwesterly by and along the center line of said wall 113 feet to a corner of said wall; thence turning and running again Southerly by and along the center line of said wall 515 feet as the wall now stands to its intersection with awire fence at the terminus of said wall; thence turning and running Southwesterly, Westerly, again Southwesterly and again Southerly and Southwesterly along the wire fence as it now stands 1,872 feet crossing a travel way to an iron pin at land now or formerly of + +23781wd + +Penhallow Forest Corp.; thence turning and running by and along the remains of awire fence again crossing the travel way Westerly somewhat southerly and again Westerly by and along the remains of said wire fence 686 feet to the end of astone wall; thence running Westerly by and along the center line of said stone wall 468 feet to the end of said wall at its junction with awire fence; thence running still westerly 500 feet by and along said wire fence to its intersection with another wire fence; thence turning and running Northeasterly by and along a wire fence 1,265 feet as the fence now stands to the end of a stone wall; thence running and still Northeasterly by the center line of said stone wall 918 feet to the end of said stone wall at its intersection with awire fence; thence running still Northeasterly by and along said wire fence as the fence now stands 680 feet to a corner in said wire fence; thence turning and running slightly North of Westerly by and along said wire fence as the fence now stands 1,008 feet to the Easterly line of said East Washington Road, said point in the East line of said East Washington Road being situated 90 feet, more or less Northeast of aculvert under the said East Washington Road; thence turning and running by and along the Easterly, still more Easterly and finally the Southerly line of East Washington Road 1,907 feet to the point of beginning. + +Said premises as shown on said plan as being bounded Northerly by land now or formerly of one Neff, Southerly by land now or formerly of one Weld D. Proctor, Easterly by land now or formerly of Penhallow Forest Corp. and Westerly by lands now or formerly of one Rial Rowe, on Hackwell and Northwesterly by the Easterly, more Easterly and Southerly line of said East Washington Road. Said land being shown upon said plan as having an area of 156 acres, more or less. + +Meaning and intending to convey all and the same land and premises conveyed to Richard Yospin, Trustee of The Richard Yospin Family Trust u/d/t dated December 28, 2012, by warranty deed of Donald A. Jackson and Juanita W. Jackson dated December 14, 2017 and recorded in the Merrimack County Registry of Deeds at Book 3580, Page 2552. + +These are not homestead premises. + +# CERTIFICATE IN ACCORDANCE WITH R.S.A. 564-A:7 + +The undersigned Trustee, as Trustee of The Richard Yospin Family Trust u/d/t dated December 28, 2012, has full and absolute power in that trust agreement to convey any interest in real estate and improvements on real estate held in the trust and no purchaser or third party shall be bound to inquire whether the Trustee has that power or is properly exercising that power or to see to the application of any trust asset paid to the Trustee for aconveyance of real estate or improvements on real estate. + +Signed and dated on the 13 day of December 2019. + +![]()STATE of NEW HAMPSHIRE +COUNTY of Mercimack + +The foregoing certificate was acknowledged before me on the 13 day of December 2019 by Richard Yospin, Trustee of The Richard Yospin Family Trust u/d/t dated December 28, 2012. + +![]()![](_page_5_Picture_13.jpeg) + +![](_page_6_Picture_0.jpeg) + +## • New Hampshire Department of Revenue Administration CD-57-S + +![](_page_6_Picture_3.jpeg) + +# REAL ESTATE TRANSFER TAX DECLARATION OF CONSIDERATION REAL ESTATE SELLER (GRANTOR) + +### STEP 1 + +-SELLER Grantor /Assignor / Transferor (use new mailing address) + +Entity Type - (Cheek One) O Individual O Joint + +Seller 'I - Last Name f Entity + +O Partnership + +ICM Original Return O Corporation MI Trust O LLC + +O Amended Return + +First Name / + +FEIN f SSN + +First Name FEIN / SSN + +-- - - --- Richard Yospir. FamilyTrust + +I-- Seger 2 - Last Name I Entity + +Street No. Street Name Apt / Unit Phone Number + +I IIIIIIIIIIII + +Ctly State Zip Code • 4 (or Canadian Postal Code) + +• + +STEP 2 (use - PURCHASER Grantee/ Assignee / Transferee new mailing address) + +Last Name / Entity First Name + +Granite Reality LLC + +Last Name / Entity Fest Name + +### STEP 3 - REAL ESTATE + +Municipality County + +Bradford Merrimack + +Street No. Street Name + +Multi Town Sale? + +0 Yes al No + +### STEP 4 - DEED + +Deed Type (Check One) + +If Yes, list municipalities: + +Transfer Date + +12132019 + +Warranty 0 Quitclaim + +0 Commissioner's + +Apt / Unk + +n + +Recording Date + +0 Mortgage + +❑ Fduclary + +0 Sheriffs + +0 Probate + +Book No. Page No. + +0 Tax 0 Foreclosure + +0 In Lieu of Foreclosure + +• + +emit. Reality Lit + +Braetord 12132019 + +C0414 RireSAGIOMT 155 Seaport Blvd + +![](_page_7_Picture_44.jpeg) + +**New Hampshire** +Department of +Revenue Administration + +![](_page_7_Picture_47.jpeg) + +#0CD57S1528475\* + +**REAL ESTATE TRANSFER TAX DECLARATION OF CONSIDERATION REAL ESTATE SELLER (GRANTOR)** + +**STEP 5 - TAX AMOUNT** + +a) Full price or consideration for the real estate 1070750.00 + +b) Divide Line 5(a) by \$100 10707.50 + +c) Tax rate per \$100 at time of transfer 0.75 + +d) Subtotal of Seller's tax (Minimum of \$20 for all considerations \$4,000 or less, per RSA 78-B:1) 8031 + +e) Total tax paid to County on behalf of Seller and Purchaser 16062 + +Are you claiming tax exemption under RSA 78-B:2? Yes No DO NOT file form CD-57-S for transfers specifically exempted from taxation under RSA 78-B:2, except transfers exempted by RSA 78-B:2, IX. Form CD-57-S must be filed for non-contractual transfers although exempted under RSA 78-b:2, IX. + +**STEP 6 - TAXPAYER'S SIGNATURE & INFORMATION**(Seller's Signature is Required) + +Under penalties of perjury, I declare that I have examined this return and to the best of my belief it is true, correct and complete. + +Seller 1 Signature [REDACTED] MMDDYYYY 12-13-19 + +Seller 1 Printed Name + +Richard Yospin, Trustee of the Richard Yospin Family Trust + +Seller 2 Signature [REDACTED] MMDDYYYY + +Seller 2 Printed Name + +Witness Signature [REDACTED] MMDDYYYY + +Witness Printed Name [REDACTED] 12-13-19 + +![](_page_7_Picture_61.jpeg) + +Granite Reality LLC 155 Seaport Blvd +Bradford 12132019 + +CD-57-S +Rev 3.0 06/2017 + +![](_page_8_Picture_286.jpeg) + +**New Hampshire** +Department of +Revenue Administration + +![](_page_8_Picture_289.jpeg) + +#0CD57S1538475\* + +**REAL ESTATE TRANSFER TAX DECLARATION OF CONSIDERATION REAL ESTATE SELLER (GRANTOR)** + +**STEP 7 - PREPARER'S SIGNATURE & INFORMATION (If prepared by someone other than the Seller)** + + **Power of Attorney (POA):** By checking this box and signing Step 6, you authorize the preparer listed on this return to act on your behalf for this return only, including entering the book and page numbers and filing this return electronically. + +Under penalties of perjury, I declare that I have examined this return and to the best of my belief it is true, correct and complete. (If prepared by a person other than the taxpayer, this declaration is based on all information of which the preparer has knowledge.) + +Preparer's Signature (if other than taxpayer) + +[Redacted Signature] + +MMDDYYYY + +12/13/2019 + +Preparer's Printed Name (required if POA box is checked) + +Rebecca Russo + +Entity + +Hudkins Law PLLC + +Last Name + +Russo + +First Name + +Rebecca + +Street No. + +9 + +Street Name + +Newport Road + +Apt / Unit + +PO Box +719 + +Phone Number + +[Redacted Phone Number] + +City + +New London + +State + +NH + +Zip Code + 4 (or Canadian Postal Code) + +03257 + +![](_page_8_Picture_321.jpeg) + +Granite Reality LLC + +Bradford + +12132019 + +155 + +Seaport Blvd + +CD-57-S +Rev 3.0 06/2017 + +![](_page_9_Picture_0.jpeg) + +# New Hampshire Department of + +![](_page_9_Picture_3.jpeg) + +## INVENTORY OF PROPERTY TRANSFER + +STEP 1 - PURCHASER(S) Grantee (use new primary mailing address) + +Entity Type - (Check One) 0 incimdual 0 Joint 0 Partnership 0 Corporation 0 Trust IJ + +LLC 0 Holding Company + +Last Name / Entity First Name + +Granite Reality LLC + +Last Name/ Entity First Name + +Last Name/ Entity + +Street No. + +155 + +First Name + +Street Name Apt J Unit + +c/o Nutter & Fish LLP + +Seaport Blvd McLennan + +City State Zip Code + 4 (or Canadian Postal Code) + +Boston + +Email (optional) + +STEP 2 - SELLER(S) Grantor (use new primary mailing address) + +Phone Number + +Entity Type - (Check One) 0 Individual 0 Joint 0 Partnership 0 Corporation Egi Trust 0 LLC 0 Holding Company + +Last Name /Entity First Name + +Richard Yospin Family trust + +Last Name / Entity First Name + +Last Name / Entity First Name + +Street No. Street Name Apt/ Unit + +City State Zip Code + 4 (or Canadian Postal Code) + +Email (optional) + +### STEP 3 - REAL ESTATE + +Municipality County + +Bradford Merrimack + +Street No. Street Name + +338East Washington Road + +CsaAlt• hMtrty LLC + +3radfold + +Apt / Unit + +155Seaport Blvd Maple + +12132019 + +Phone Number + +• + +![](_page_10_Picture_0.jpeg) + +## New Hampshire Department of Revenue Administration PA-34 + +![](_page_10_Picture_3.jpeg) + +### STEP 3 • REAL ESTATE (continued) + +| Tax Map | | Block | | Lot | | +|-----------------------------------------------|--|-----------------------------------------------------|--|-----------------------------------------|--| +| | | | | | | +| Acreage | | | | | | +| | | Number of Parcels Purchased | | | | +| Multi Town Sale? | | If Yes, list municipalities: | | | | +| Yes | | No | | | | +| Property Use
    (Check One): | | Residential | | Commercial | | +| Land Only | | Mixed Res / Comm | | Industrial | | +| Property Type
    (Check All That Apply) | | Land Only | | Condo | | +| Manufactured Housing | | Land & Building | | Condex | | +| Manufactured Housing | | Multi-unit | | Timber Rights | | +| Mineral Rights | | Timber Rights | | Mineral Rights | | +| Features
    (Check One): | | Waterfront | | Water Access | | +| Water Access | | If multi-unit building, how many units? | | | | + +### INVENTORY OF PROPERTY TRANSFER + +### STEP 4 - DEED + +• + +| Transfer Date
    12132019 | Recording Date
    12-13-19 | Book No.
    [Redacted] | Page No.
    [Redacted] | Sale Price
    1070750.00 | +|---------------------------------|-------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------|--------------------------------------| +| Type of Transfer
    (Check One) | Warranty
    Quitclaim
    Commissioner's | Mortgage
    Fiduciary
    Probate | Sheriff's
    Tax
    In Lieu of Foreclosure | Foreclosure | + +### STEP +5 - TRANSACTION DETAIL + +| Were there any special circumstances in the transfer which suggest that the full price or consideration of the property was either more or less than its fair market value? | | Yes | No | If Yes, please choose all that apply from the list below or select "other" and fill in an explanation | | +|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------|----------------------------------------------|----------------------------------------|-------------------------------------------------------------------------------------------------------|----------------------------------------------| +| Family Sale | Sheriff's Sale | Business Affiliates | Bank Sale | Easement | Life Estate / Trust | +| Government Sale | Abutter Sale | Other | | | | +| Did the sale transfer 100% interest in the property? | | Yes | No | If no what % interest transfered? | | +| Did the sale price above include a consideration for non-taxable personal property? | | | | Yes | | +| Furnishings | | | | No | | +| Inventory | | | | If yes, indicate value below: | | +| Other | | | | | | +| Timber | | | | | | +| Was the sale price reduced because of a Land Use Change Tax? | | Yes | | No | | +| If yes, by what amount? | | | | | | +| Do you consider the selling price to be fair market value? | | Yes | | No | | +| If no, explain | | | | | | +| Have you or will you make improvements to the property after the purchase but before April 1st? | | Yes | | No | | +| If yes please indicate approximate cost of these improvements | | | | | | +| Occupancy and status of structure | | No Structure | | New Construction (1 yr) | | +| Previously Occupied | | | | | | +| Will the property serve as your primary residence? | | Yes | | No | | + +Cie.:Ate MO I ty l." Bra G Cocci • PAM Rey 16014015 + +155Seaport Blvd Yospin 12132019 + +![](_page_11_Picture_45.jpeg) + +New Hampshire +Department of +Revenue Administration + +**PA-34** + +![](_page_11_Picture_48.jpeg) + +\*00PA341438475\* + +**INVENTORY OF PROPERTY TRANSFER** + +**STEP 6 - PREPARER** + +Entity + +Hudkins Law PLLC + +Last Name + +Russo + +First Name + +Rebecca + +Street No. + +Street Name + +Apt / Unit + +Phone Number + +9 + +Newport Road + +PO Box +719 + +![](_page_11_Picture_65.jpeg) + +City + +State + +Zip Code + 4 (or Canadian Postal Code) + +New London + +NH + +03257 + +Email (optional) + +![](_page_11_Picture_73.jpeg) + +COID +07 + +Book + +Page + +Recording Date + +Granite Reality LLC +Bradford + +155 +12132019 + +Seaport Blvd + +Yospin + +PA34 +Rev 16/01/2015 + +![](_page_12_Picture_0.jpeg) + +• New Hampshire Department of Revenue Administration PA-34 + +## INVENTORY OF PROPERTY TRANSFER + +### Signature Page + +![](_page_12_Picture_3.jpeg) + +### STEP 7 - SIGNATURES + +nPower of Attorney (P0A): By checking this box and signing below, you authorize the prepare: listed on this document to act on your behalf for this document only, including entering the book and page numbers and filing this document electronically. + +TAXPAYER'S SIGNATURE & INF0RMATI0N(Purchasers Signature is Required) Under penalties of penury. I declare that I have examined this return and to the best of my belief It is true, correct and complete. + +Purchaser's Signature MMDDYYYY + +PurchaserS PrIn tilroe ill + +Granite Reality LLC By: Jeffrey W. Roberts, Manager + +Purchaser 2 Signature + +Purchaser 2 Printed Name + +Purchaser 3 Signature + +Purchaser 3 Printed Name + +MMDDYYYY + +MMDDYYYY + +PREPARERS SIGNATURE & INFORNATION(f prepared by someone Other Man the Purchaser) Under pommies of perjury, I declare that ; have examined this document end lo the best of my belief it is true, correct and complete. (If propared byaperson other than the taxpayer. this declaration is based on al information of which the OreParer has knowledge.) + +Preparers Signature (if other than taxpayer) MMDDYYYY + +Preparers Printed Name (required if P0A box is checked) + +Rebecca Russo + +12/13/2019 + +![](_page_12_Picture_29.jpeg) + +CHID Sock Bees ftocordOd Dole + +07 + +Buyer Last Name Buyer Street No Buyer Street Name + +OranIto Roolity LLC 155 Seaport Blvd + +Municipality Transfer Date Tax Map Block Lot + +Bradford 121320/9 + +• PAIS + +Rev100112M Peg 4 era • + +![](_page_13_Picture_361.jpeg) + +**New Hampshire** +Department of +Revenue Administration + +**CD-57-P** + +![](_page_13_Picture_364.jpeg) + +#CD57P1518475\* + +**REAL ESTATE TRANSFER TAX DECLARATION OF CONSIDERATION REAL ESTATE PURCHASER (GRANTEE)** + +**STEP 1 - PURCHASER** Grantee / Assignee / Transferee (use new mailing address) + +Entity Type - (Check One) Individual Joint Partnership Corporation Trust LLC Original Return + Amended Return + +Last Name / Entity First Name FEIN / SSN +Granite Reality LLC [REDACTED] + +Last Name / Entity First Name FEIN / SSN + +Street No. Street Name Apt / Unit Phone Number +155 Seaport Blvd c/o Nutter McLennan & Fish LLP + +City State Zip Code + 4 (or Canadian Postal Code) +Boston MA 02210 + +**STEP 2 - SELLER** Grantor / Assignor / Transferor (use new mailing address) + +Last Name / Entity First Name First Name + +Richard Yospin Family Trust + +Last Name / Entity First Name + +**STEP 3 - REAL ESTATE** + +Municipality County +Bradford Merrimack + +Street No. Street Name Apt / Unit +336 East Washington Road + +Multi Town Sale? If Yes, list municipalities: + Yes No + +**STEP 4 - DEED** + +Transfer Date Recording Date Book No. Page No. +12132019 + +Deed Type (Check One) Warranty Quitclaim Mortgage Sheriff's Tax Foreclosure + Commissioner's Fiduciary Probate In Lieu of Foreclosure + +Granite Reality LLC 155 Seaport Blvd +Bradford 12132019 + +![](_page_14_Picture_42.jpeg) + +**New Hampshire** +Department of +Revenue Administration + +**CD-57-P** + +![](_page_14_Picture_45.jpeg) + +#0CD57P1528475\* + +**REAL ESTATE TRANSFER TAX DECLARATION OF CONSIDERATION REAL ESTATE PURCHASER (GRANTEE)** + +**STEP 5 - TAX AMOUNT** + +a) Full price or consideration for the real estate 1070750.00 + +b) Divide Line 5(a) by \$100 10707.50 + +c) Tax rate per \$100 at time of transfer 0.75 + +d) Subtotal of Purchaser's tax (Minimum of \$20 for all considerations \$4,000 or less, per RSA 78-B:1) 8031 + +e) Total tax paid to County on behalf of Seller and Purchaser 16062 + +Are you claiming tax exemption under RSA 78-B:2? + + Yes No **DO NOT** file form CD-57-P for transfers specifically exempted from taxation under RSA 78-B:2, except transfers exempted by RSA 78-B:2, IX. Form CD-57-P must be filed for non-contractual transfers although exempted under RSA 78-B:2, IX. + +**STEP 6 - TAXPAYER'S SIGNATURE & INFORMATION**(Purchaser's Signature is Required) + +Under penalties of perjury, I declare that I have examined this return and to the best of my belief it is true, correct and complete. + +Purchaser 1 Signature + +MMDDYYYY + +[REDACTED] + +Purchaser 1 Printed Name + +Granite Reality LLC, By: Jeffrey W. Roberts, Manager + +Purchaser 2 Signature + +MMDDYYYY + +Purchaser 2 Printed Name + +Witness Signature + +MMDDYYYY + +Witness Printed Name + +![](_page_14_Picture_65.jpeg) + +Granite Reality LLC +Bradford + +12132019 + +155 + +Seaport Blvd + +![](_page_15_Picture_0.jpeg) + +# New Hampshire Department of CD-57-P + +![](_page_15_Picture_3.jpeg) + +\*008571)1538475\* + +### REAL ESTATE TRANSFER TAX DECLARATION OF CONSIDERATION REAL ESTATE PURCHASER (GRANTEE) Signature Page + +### STEP 7 - PREPARERS SIGNATURE & INFORMATION (If prepared by someone other than the Purchaser) + +nPower of Attorney (POA): By checking this box and signing Step 6, you authorize the prepare( listed on this return to act on your behalf for this return Lionly, including entering the book and page numbers and fifing this return electronically. + +• + +Under penalties of pefury. I declare that I nave examined this return and to the best of my brier it b true. correct and compete. (II prepared by a peson other than me taxpayer, this declaration Is based cn Si irtormat on of which the prepare, has knowledge.) + +Preparers Signature (4 other than taxpayer) SAkIDDYYYY + +Preparers Printed Name (required if POA box is checked) + +Rebecca Russo + +Entity + +Hudkins Law PLLC + +Last Name First Name + +Russo Rebecca + +Street No. Street Name + +9 + +City + +New .And art + +• + +Newport lioad + +:2/13/2019 + +Apt / Unit Phone Number + +90 Box 719 + +State Zip Code • 4 (or Canadian Postal Code) + +03257 + +![](_page_15_Picture_32.jpeg) + +Braaten] + +CD-57-P Rev 30 03/20I7 + +Greelte Reality LUC + +:2132019 + +155 Seaport Blvd + +p..2.3.,3 • + +# No Mortgage Affidavit + +Property Address: Bradford, NH 03221 + +I/We, the undersigned, are the current owner(s) of the referenced property do certify and swear that all mortgages on this property have been paid, are discharged and there are no outstanding mortgages on the property being refinanced/sold by us. + +The Undersigned do so certify, swear and warrant. + +Date: December 13. 2019 + +Richard Yospin, Trustee oYospin Family Trust + +State of New Hampshire + +County of Merrimack, ss. December 13, 2019 + +Personally appeared the above named, Richard Yospin, Trustee of the Richard Yospin Family Trust, acknowledged the foregoing instrument to be his free act and deed, before me + +NotaryLP)iblic== + +![](_page_16_Picture_11.jpeg) + +![](_page_17_Picture_2.jpeg) + +# CERTIFICATION OF NON-FOREIGN STATUS + +(Entity) + +Section 1445 of the Internal Revenue Code provides that atransferee of U.S. real property interest must withhold tax if the transferor is aforeign entity. To inform the transferee that withholding of tax is not required upon our disposition of aU.S. real property interest, I hereby certify the following. + +- 1. Richard Yospin Family Trustis not a foreign entity for purposes of U.S. income taxation. + +- 2. The company Federal Tax ID number is: + +TIN#: ( + +Company mailing address is: + +Seller 4o -rvrAish !D# Ar fru54 Oar C les mi + +![](_page_18_Picture_8.jpeg) + +Iunderstand that this certification may be disclosed to the Internal Revenue Service by the transferee and that any false statement I have made herein could be punished by fine, imprisonment, or both. + +Under penalties of perjury, I declare that I have examined this certification to the best of my knowledge and believe it is true, correct and complete. + +Richard Yospin Family Trust + +By + +Dated: December 13, 2019 + +lAVe Richard Yospin, Trustee of the Richard Yospin Family Trust being first duly sworn, depose and say as follows: + +- I. That 1/We are the true and lawful owners in the fee of the premises situated in the City/Town of Bradford County of Merrimack State of New Hampshire Known as: Bradford, NH 03221. +- 2. Uwe have owned the property now being sold or mortgaged by me/us continuously for years last past, and my/our enjoyment thereof has been peaceable and undisturbed and the title to said property has never been disputed or questioned to my/our knowledge, nor do Uwe know of any facts by reason which the title to. or possession of, said property might be disputed or questioned, or by reason of which any claim to any of said property might be asserted adversely against me/us. +- 3. That within the last one hundred and twenty (120) days, no person or business entity has furnished any labor, services or ¶ttatcrials in connection with the construction or repair of any buildings or improvements on the Property except (if none, state "none"): +- 4. That there are no present tenants, lessees or other parties in possession of the Property except (if none, state "none"). Nn n +- 5. That during the time of ownership of the premises above described, Uwe have conveyed no portion of the premises nor done any act or allowed any act to be done which has changed or could change the boundaries of the Properly. +- 6. That Uwe have not allowed, nor do Uwe have knowledge of, any encroachments onto the Property by any adjoining land owners nor have Uwe created, allowed or maintained any encroachments upon any property of adjoining land owners. +- 7. That I/we have not allowed, nor do Ilive have knowledge of, any easements, rights of way, continuous driveway usage, drain. sewer, water, gas or oil pipeline or other rights of passage to others over the Property by any other persons or entities. +- X. That Uwe have no knowledge of any old highways, abandoned roads, lanes, cemetery or family burial grounds, springs, streams, rivers, ponds, or lakes bordering or running through the Property. +- 9. That i/we have no knowledge of any taxes or special assessments which arc not shown as existing liens by the public records other than as shown in the current Municipal Lien Certificate and/or as reflected in the Closing Settlement Statement. +- 10. 'That 1/we have not created and have no knowledge of any violation of any covenants, restrictions, agreements, conditions or zoning ordinances affecting said premises. +- II. That T/we make this Affidavit for the purpose of inducing a purchase or lease of said premises, and/or for the purpose of inducing the granting of amortgage on said premises, and for the purpose of inducing STEWART TITLE GUARANTY COMPANY, in reliance upon this Affidavit, to issue a policy or policies of title insurance covering the Property and I/we hold harmless and indemnify Stewart Title Guaranty Company from loss or damage incurred due to any misrepresentation made in this affidavit. + +Executed on December 13, 2019. + +Richard Yospin, Trustee o fbc Yospin Family Trust + +State of New Hampshire + +Merrimack. ss. + +On December 13. 2019, before me, the undersigned notary public. personally appeared the above-named and proved to me through satisfactory evidence of identification, which was a driver's license, to be the person whose name is signed on the preceding or attached document, and acknowledged to me that he/she/they signed it voluntaril for its stated se + +Notary ic: ission Expires: + +![](_page_19_Picture_11.jpeg) + +STEWART TITLE GUARANTY COMPANY + +NOTICE OF AVAILABILITY OF OWNERS TITLE INSURANCE + +We, the undersigned, being duly sworn, do hereby depose and say that we are the Buyers/ Borrowers of/on property situated at: + +[REDACTED] +Bradford NH 03221 + +That we do hereby certify that we have no personal knowledge of any unrecorded defects in or claims against the title to said property. + +You may obtain an Owner's Policy of Title Insurance which provides title insurance coverage to you. The additional cost to you for an Owner's Policy of Title Insurance in the amount of \$1,070,750.00 is available at a premium of \$2,537.00 if you request it at this time. + +We further understand that the lender's coverage is for the protection of the lender and that Hudkins Law PLLC is the settlement agent for the lender and does not represent the undersigned in this transaction. + +- A. I/We want to protect our interest by obtaining an Owner's Title Insurance Policy. +- B. I/We have been offered and decided to decline an Owner's Title Policy. +- C. I/We have been offered an "Extended Policy" along with our Owner's Title Policy and have decided not to purchase it. + +Granite Reality LLC / By Jeffrey W. Roberts, Manager + +Dated: December 13, 2019 + +[REDACTED] +Notary Public / Justice of the Peace +My Commission Expires: + +![](_page_20_Picture_26.jpeg) + +## CURRENT USE DISCLOSURE + +Re: II=MINIME Bradford, NH 03221 + +Pursuant to our search of the records for Merrimack, and information provided by the City/Town of Bradford, at least aportion of the above-referenced property is currently subject to "Current Use Taxation." Current Use Taxation typically reduces the amount of property taxes owed to the town. In return, the land owner is restricted from subdividing or improving the land "in current use." The undersigned Buyer understands that in the event the property is improved or subdivided, the City/Town of Bradford may require that aportion or the entirety of the property be removed from current use. Further, if at any time the property is taken out of current use, the City/Town of Bradford may assess apenalty in the form of an additional property tax. The Buyer hereby agrees to hold Hudkins Law PLLC harmless for any liability relating to the above-referenced matter. + +Dated: December 13,2019 + +Granite Reali C, 3y: Jeffrey W. Roberts, Manager + +### Substitute FORM 1099-S Proceeds From Real Estate Transactions For The Tax Year 2019 OMB No. 1545-0997 + +FILER'S name, street address, city or town, state or province, country, ZIP or foreign postal code, and telephone number Hudkins Law PLLC 9 Newport Road New Lon Telephone: Fax + +TRANSFEROR'S name, street address (Including apt. no.), city or town, state or province, country, and ZIP or foreign postal + +| 1 Date of closing
    December 13, 2019 | 2 Gross Proceeds
    \$1,070,750.00 | | +|------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------| +| 3 Address or legal description (including city, state, and ZIP code) | | For Privacy Act and Paperwork Reduction Act Notice, see the 2017 General Instructions for Certain Information Returns . | +|
    Bradford, NH 03221 | | | +| 4 Check here if the transferor received or will receive property or services as part of the consideration >>>>> | 5 Check here if the transferor is a foreign person (nonresident alien, foreign partnership, foreign estate, or foreign trust) >>>>> | 6 Buyer's part of real estate tax
    6,630.44 | + +FILER'S federal identification number Account or escrow number (see instructions) + +TRANSFEROR'S identification number(s) + +This is important tax information and is being furnished to the internal revenue service. If you are required to file a return, a negligence penalty or other sanction may be imposed on you if this tem is required to be reported and the IRS determines that it has not been reported. + +You are required by law to provide Hudkins Law PLLC with your correct federal tax identification number. If you do not provide Hudkins Law PLLC with your coned federal tax identification number, you may be subject to civil or criminal penalties imposed by law. + +Under the penalty of perjury, iAve certify that the number(s) shown above on this statement is/are my/our correct federal tax t of a copy of this statement. + +•spin am + +2. -13- 10 DATE + +Sign and return a copy of thiS form immediately to Hudkins Law PLLC. + +### Instructions for Transferor + +For sales or exchanges of certain real estate, the person responsible for dosing a real estate transaction must report the real estate proceeds to the IRS and must furnish this statement to you. To determine if you have to report the sale or exchange of your main home on your tax return, see the instructions for Schedule D (Form 1040). If the real estate was not your main home, report the transaction on Form 4797, Form 6252, and/or the Schedule O for the appropriate income tax form. If box 4 is checked and you received or will receive like-kind property, you must file Form 8824. + +Federal mortgage subsidy. You may have to recapture (pay back) all or part of a federal mortgage subsidy if all of the following apply. + +- You received a loan provided from the proceeds of a qualified mortgage bond or you received a mortgage credit certificate. Your original mortgage loan was provided after 1990. + - You sold or disposed of your home at a gain during the first 9 years after you received the federal mortgage subsidy. + - Your income for the year you sold or disposed of your home was over a specified amount. This will increase your tax. See Form 8828 and Pub. 523. + +Transferor's taxpayer identification number. For your protection. this form may show only the last four digits of your social security number (SSN), individual taxpayer identification number (ITIN), adoption taxpayer identification number (ATIN), or employer identification number (EIN). However, the issuer has reported your complete identification number to the IRS. Account number. May show an account or other unique number the filer assigned to distinguish your account. + +![](_page_23_Picture_0.jpeg) + +HUDKINS LAW PLLC + +Jacqueline M. Hudkins +M Benjamin E. Percy +Laura M. Tomasello +Emily C. Gearing +Richard G. Anderson + +Martha L. Prizio +Rosma T. Moroun +Dannis P. Vachon +Candica M. O'Neill +Greg Racki + +Admitted to Practice in NH & MA +Admitted to Practice in VT & MA +Admitted to Practice in MA & NJ +Admitted to Practice in NH +Admitted to Practice in MA +Of convert + +Property Tax Disclaimer and Re-Proration Agreement + +In order to complete the HUD Settlement Statement, it was necessary for Hudkins Law PLLC to obtain information concerning real estate property taxes and other municipal charges such as water, sewer, municipal assessments or betterments, insurance, electric, gas, oil or condominium fees as applicable ("Third Party Information"). Although every effort was made to obtain accurate information, we the undersigned Buyer and Seller hereby agree to hold Hudkins Law PLLC harmless for the accuracy of any and all Third Party Information obtained by Hudkins Law PLLC or provided to Hudkins Law PLLC. + +We, Buyer and Seller acknowledge that Hudkins Law PLLC obtains Third Party Information through oral dialogue with various municipal employees and that in many cases, a written statement for Third Party Information is not available. + +We, Buyer and Seller further acknowledge that it is common for a municipal tax collector to provide "estimated" property tax amounts due. Even if an actual tax bill is available, it could be an estimate of the tax payment that will ultimately be due for the current tax year and actual tax bills could contain errors or may not include penalties that could be attributed to the parcel being conveyed from the Seller to the Buyer. Current Use penalties may not be assessed until after the date of closing and may or may not be attributable to the Seller. + +After the date of closing, in the event that such Third Party Information proves to be inaccurate or outdated, or if tax or other obligations or penalties are assessed after the closing date that may be attributable to the Seller, it shall be the responsibility of the Buyer and Seller to cooperatively re-adjust or re-prorate any amounts due or credited. If it is determined that the Buyer, Seller or Hudkins Law PLLC has made a disbursement or payment that should have been attributed to another party (a "Responsible Party"), the Responsible Party shall pay restitution to the party that made the payment on behalf of the Responsible Party. + +Notwithstanding the provisions herein, the Buyer and Seller further represent and agree to the following: + +1. 1. The payments, pro-rations and adjustments which have been computed and set forth on the Settlement Statement represent the good faith effort of the parties to allocate all items adjusted accordingly. +2. 2. Any prorated item which has been incorrectly adjusted in the computation of the pro-rations, upon delivery of such omission or error, shall be promptly readjusted. +3. 3. The undersigned parties agree to hold the Lender, (if applicable), the title insurance company and Hudkins Law PLLC harmless therefrom. +4. 4. The Seller agrees to be responsible for any outstanding water or sewer liens and charges as of the date of closing, and any subsequent final readings. +5. 5. In the event that there are any outstanding real estate taxes, water or sewer liens and charges as of the date of closing, seller agrees to pay them forthwith upon receipt of a bill from the municipality. +6. 6. We, the undersigned Buyer and Seller, agree to indemnify and hold harmless Hudkins Law PLLC, the Buyer's Lender (if applicable), for any adjustments or pro-rations which were made between the Buyer and Seller. Buyer and Seller agree that neither Hudkins Law PLLC or a Lender (if applicable), takes responsibility for these adjustments as they were negotiated. +7. 7. The provisions herein shall survive the delivery of the deed and the closing. + +The Buyer and Seller have read and hereby acknowledge the understanding memorialized in this Property Tax Disclaimer and Re-Proration Agreement and agree to its terms. + +[Redacted Buyer Borrower Signature] + +Buyer/Borrower Date + +[Signature] + +Buyer/Borrower Date + +[Redacted Seller Signature] + +Seller Date + +Seller Date + +12/13/19 + +WINDHAM, NH [Redacted Signature] +25 Indian Rock Road, PO Box 719, 03007 + +CONCORD, NH [Redacted Signature] +Capital Plaza, 57 North Main Street, Suite 104, 03301 + +NEW LONDON, NH [Redacted Signature] +9 Newport Road, PO Box 800, 03257 + +NORWICH, VT [Redacted Signature] +316 Main Street, Suite 201, PO Box 15, 05055 + +ANDOVER, MA [Redacted Signature] +300 Brickstone Square, Suite 201, 01810 + +![](_page_24_Picture_38.jpeg) + +HUDKINS LAW PLLC + +**Josephine M. Hudkins** +**Benjamin E. Percy** +**Laura M. Tomasello** +**Emily C. Goering** +**Richard G. Anderson** + +**Martha L. Prizio** +**Roema T. Maroun** +**Dennis P. Vochen** +**Candice M. O'Heil** +**Greg Rocki** + +Admitted to Practice in NH & MA +Admitted to Practice in VT & MA +Admitted to Practice in MA & NH +Admitted to Practice in NH +Of course + +**Compliance Agreement and Privacy Policy** + +**Compliance Agreement** + +We, the undersigned Buyer and Seller hereby agree to sign, execute and/or resign and re-execute any and all closing documents to correct errors, or to make changes due to mistake or misinformation. + +We, the undersigned Buyer and Seller hereby agree to indemnify and hold Hudkins Law PLLC harmless for any mistake or misinformation, whether obtained by Hudkins Law PLLC or provided to Hudkins PLLC from third parties, used to calculate, pro-rate or otherwise charge, any and all items appearing on the HUD Settlement Statement, including but not limited to the following: property taxes, hazard or homeowner insurance, water, sewer or other municipal charges, fuel pro-rations, electricity pro-rations, or condominium association dues pro-rations. + +**Privacy Policy** + +Hudkins Law PLLC collects nonpublic personal information about you from the following sources: + +1. 1. Information we receive from you, such as your name, address, telephone number and social security number. +2. 2. Information about your transaction from any of the following parties as they apply to your transaction: your lender, Realtor, attorney, spouse, CPA or tax professional, home inspector or various public records. + +Hudkins Law PLLC does not disclose any nonpublic personal information about our clients, or buyers or sellers of real estate, except as permitted or required by law or except as authorized by you. + +Hudkins Law PLLC maintains physical, electronic and procedural safeguards that comply with relevant federal and state regulations regarding privacy. + +We, the undersigned have received and have reviewed Hudkins Law PLLC's Privacy Policy and Compliance Agreement. + +[Redacted Buyer/Borrower Information] +Buyer/Borrower Date + +[Redacted Seller Information] +Seller Date + +12/13/19 + +Front Enterprise Bank: Wire Servicing Dept Sent Thursday, December 12, 20191:24 PM To: Processing Subject Incoming Wire Transfer Notification + +Your wire transfer on 12/12/19, in the amount of \$994,279.12, was received from GRANITE REALITY LLC. Contact ENTERPRISE BANK alif you have any questions regarding this transaction. Refer to wire sequence number 37362295 in your inquiry. + +Credited to account ending with 017 + +Wire Fee: \$0.00 + +Sending Fl CITIZENS BANK, NA OMAD: IMAD: + +Originator Address: C/0 NUTTER MCLENNEN & FISH LLP 155 SEAPORT BLVD BOSTON MA 022102698 + +Originator to Beneficiary Information: + +ATTN: + +This message is intended only for the persons or entities to which it is addressed. The information transmitted herein may contain proprietary or confidential material. Review, reproduction, retransmission, distribution, disclosure or other use, and any consequent action taken by persons or entitles other than intended recipients, are prohibited and may be unlawful. If you are not the intended recipient, please delete this Information from your system and contact the sender. The Information contained herein Is subject to change without notice. Although reasonable precautions have been taken to ensure that no viruses are present, the sender makes no warranty or guaranty with respect thereto, and is not responsible for any loss or damage arising from the receipt or use of this email or attachments hereto. + +From: Margie Weathers Jud
    | | | | | +| | | | | | +| | | | | | +| | | | | | +| | | | | | +| | | | | | +| | | | | | +| | | | | | +| | | | | | +| | | | | | + +**DAY OF CLOSING-PURCHASE** + +| PRE-CLOSING & PARTY INFORMATION | | +|---------------------------------|-------------------------------------------------------------------------------------------------------------------| +| Print Lender Documents | BUYER(S)/BORROWER(S): Jeffrey W. Roberts, Manager of Granite Realty LLC | +| Print HLaw Documents | | +| Recording Sheet | BUYER'S AGENT/AGENCY: Four Seasons Sothobys International Real Estate/Jennifer Johnson | +| MA Documents | | +| MA Notary Clauses | BUYER'S ATTORNEY: | +| CD-57s/PA-34 | | +| HELOC Closeout | LOAN OFFICER/LENDER: /CASH | +| Copy Package(s) | | +| Print Checks | SELLER(S): Richard Yospin, Trustee of the Richard Yospin Family Trust | +| OG Wire Verification | | +| Blank Checks-IOLTA | LISTING AGENT/AGENCY: Four Seasons Sothobys International Real Estate/Margaret Weathers | +| Blank Checks-Recording | PROPERTY ADDRESS: [REDACTED], Bradford, NH
    03221
    PROCESSOR: Rebecca Russo
    SELLER'S ATTORNEY: Alex Garcia | + +| AT CLOSING | | | +|--------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------| +| Taxes | Last Paid (Bill Date):
    Period Covered:
    Paid at Closing (Bill Date): 12/19
    Paid By:
    Period Covered: 7/20
    Next Due: | ___ Quarterly Semi-Annual ___ Annual | +| | | 11,375.00 @ close | +| Identification
    (2 IDs Required) | Collect | | +| Blue Ink Required | | | +| Lender Funding | N/A | ___ Collect ___ Received | +| Buyer/Borrower Funds | # 994,279.12 | ___ Collect Received 12/12 | +| Seller Funds | | ___ Collect ___ Received | +| EMD | # 100,000.00 | ___ Collect From: LA ___ BA ___ SA
    Received ___ Retained 12/12 | +| Collect at Closing-Other | Dued - Margaret Jacobs
    No May Aft.
    *** Nud Sellers SS # Richard Yospin
    Tax ID for trust doesn't use SSN
    *** Seller to bring wire trust to close (please verify) | | +| Obtain instructions for delivery of proceeds (\$25 per wire) | Wire | # 1,012,322.07 | + +| POST-CLOSING | | | +|----------------------------|-----------------------------------------------------|-----------------------------------------------------------| +| Deposit Funds | Enterprise Bank | ***Verified Escrow Account
    Rate (Post Closer Initials) | +| Bank Account:
    Recording | Physical | Merrimack | +| Notes to Post-Closer | | N/A 24 Hour Package
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+|------------|---------|--------|-------------------------------------------------|---------|----------|------------------| +| 12/12/2019 | GRANITE | WIRE | Granite Reality LLC | Cleared | Date | \$994,279 .12 | +| | 1049929 | CFUNDS | Four Seasons Sothebys International Real Estate | Cleared | | \$100,000 .00 | +| | | | | Total | Deposits | \$1 ,094,279 .12 | + +## DISBURSEMENTS + +| Date | Number | Type | Payor/Payee | Status | Cleared Date | Amount | +|------------|------------|-------|---------------------------------------------------|---------|----------------------------|------------------------| +| 12/13/2019 | | WIRE | Merrimack County Registry of Deeds/Transfer Taxes | Cleared | | \$16,062.00 | +| 12/13/2019 | | WIRE | [REDACTED] Trustee of the [REDACTED] | Cleared | | \$1,012,322.07 | +| 12/13/2019 | [REDACTED] | CHECK | Four Seasons Sothebys International Real Estate | Cleared | | \$50,287.50 | +| 12/13/2019 | [REDACTED] | CHECK | Law Office of Margaret A. Jacobs | Cleared | | \$350.00 | +| 12/13/2019 | [REDACTED] | CHECK | Bradford Tax Collector | Cleared | | \$11,375.00 | +| 12/13/2019 | [REDACTED] | CHECK | Stewart Title Guaranty Company | Cleared | | \$507.40 | +| 12/13/2019 | [REDACTED] | CHECK | Hudkins Law PLLC | Cleared | | \$3,329.60 | +| 12/13/2019 | [REDACTED] | CHECK | Hudkins Law PLLC - Registry | Cleared | | \$45.55 | +| | | | | | Total Disbursements | (\$1,094,279.12 | +| | | | | | | | + +Escrow File Balance (.00) + +## Voids, Expected Receipts, etc. + +| Date | Number | Type | Payor/Payee | Status | Cleared Date | Amount | +|------|--------|------|-------------|--------|--------------|--------| +| | | | | | | | + +From: Enterprise Bank Wire Servicing Dept Sent Thursday, December 12, 2019 124 PM To: Processing Subject Incoming • + +Your wire trap On 12/12/19, in the amount of \$994,272.12 was received from GRANITE REALITY LLC Contact ENTERPRISE BANK at IMIEMSf you have anregarding this transaction. Refer to wire sequence number kyour inquiry. + +Credited to account ending with 017Wire Fee: \$0.00 + +Sending FI: OMAD: IMAD: TIZENS BANK. NA + +Originator Address: O NUTTER MCLENNEN & FISH LLP BOSTON MA 022102698 + +Originator to Beneficiary Information: + +ATTN: + +This message is intended only for the persons or entities to which it Is addressed. The information transmitted herein may contain proprietary or confidential material. Review, reproduction, retransmission, distribution, disclosure or other use, and any consequent action taken by persons or entities other than Intended recipients, are prohibited and may be unlawful. If you are not the intended recipient, please delete this information from your system and contact the sender. The information contained herein is subject to change without notice. Although reasonable precautions have been taken to ensure that no viruses are present, the sender makes no warranty or guaranty with respect thereto, and is not responsible for any loss or damage arising from the receipt or use of this email or attachments hereto. + +![](_page_2_Picture_19.jpeg) + +PO BOX 400 +82 MAIN STREET +BAR HARBOR, ME 04609 + +REMITTER: + +[REDACTED] + +N - GRANITE + +PAY TO THE +ORDER OF + +HUDKINS LAW PLLC + +DATE 12/10/19 + +EXACTLY \*\*100,000 AND 00/100 DOLLARS + +\$ \$100,000.00 + +**CASHIERS CHECK** + +THE PUBLICATE OF ALL INDEMNITY BOND WILL BE REQUIRED BEFORE ANY +CASHIER'S CHECK OF THIS BANK WILL BE REPLACED OR REFUNDED IN THE +EVENT IT IS LOST, MISPLACED, OR STOLEN. + +AUTHORIZED SIGNATURE + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +Security features included. Details on back. + +(1) + +**Outgoing Wire Record** + +**File Number:** [REDACTED] + +**Date:** December 13, 2019 + +**Payee:** [REDACTED] Trustee of the [REDACTED] [REDACTED] + +**Amount:** \$1,012,322.07 + +**Escrow Account:** Enterprise Bank + +**Escrow Bank Account #:** [REDACTED] + +*MB +sent on +12/16* + +**Buyer/Borrower Name:** Granite Reality LLC + +**Seller Name:** [REDACTED] Trustee of the [REDACTED] [REDACTED] [REDACTED] + +**Property Address:** [REDACTED] Bradford, NH 03221 + +**Remarks:** Seller Proceeds + +![](_page_3_Picture_83.jpeg) + +From: Molly Betancourt Sent Monday, December 16, 2019 10:46 AM To: Kayla Grimme Cc Tammy Mello-Pontes Subject FW: Outgoing Wire Transfer Notification + +![](_page_4_Picture_2.jpeg) + +Hi Kayla, + +See below for the Seller proceeds wire confirmation for the Granite Realty file. + +Molly + +-----Original Message----- + +From: Enterprise Bank: Wire Servicing Dept. AlIMI=IIMI> Sent: Monday, December 16, 2019 10:20 AM To: Molly Betancourt alEle> Subject: Outgoing Wire Transfer Notification + +Your wire transfer on 12/16/19, in the amount of \$1,012,322.07, was successfully sent to at ROCKLAND TRUST. + +Contact ENTERPRISE BANK at if you have any questions regarding this transaction. Refer to wire sequence number...lin your inquiry. + +Debited from account number ending with 017Wire Fee: \$0.00 + +OMAD: IMADI + +Seller proceeds Trustee , Bradford Hudkins La + +This message is intended only for the persons or entities to which it is addressed. The information transmitted herein may contain proprietary or confidential material. Review, reproduction, retransmission, distribution, disclosure or other use, and any consequent action taken by persons or entities other than intended recipients, are prohibited and may be unlawful. If you are not the intended recipient, please delete this information from your system and contact the sender. The information contained herein is subject to change without notice. Although reasonable precautions have been taken to ensure that no viruses are present, the sender makes no warranty or guaranty with respect thereto, and is not responsible for any loss or damage arising from the receipt or use of this email or attachments hereto. + +![](_page_5_Picture_35.jpeg) + +**HUDKINS LAW** +**HUDKINS TITLE** + +**Attorneys** + +- Josephine M. Hudkins +- Rama T. Marvin +- Norgan O. Jens +- Loyra M. Turnerillo +- Richard G. Anderson +- Martha L. Fitzle +- John P. Rob +- Daniel R. Vachane +- Caroline N. O'Hall +- Gray Rocki + + Admitted to Practice in NH & MA + Admitted to Practice in VT & MA + Admitted to Practice in MA & NJ + Admitted to Practice in NH & VT + Admitted to Practice in NH + Admitted to Practice in MA + Of opened + +3 + +**IF YOU ARE EXPECTING TO RECEIVE PROCEEDS AND WOULD LIKE YOUR PROCEEDS WIRED, PLEASE COMPLETE THIS FORM IN ITS ENTIRETY** + +**PLEASE NOTE THAT A WIRE FEE OF \$50.00 WILL APPLY** + +This form must be filled out in its entirety to ensure a timely wire. Hudkins Law is unable to transmit a wire unless all of the data fields on this form have been completed and verified. + +Name of Wire recipient: \_\_\_\_\_ + Phone Number where you may be reached on the date of the expected wire: \_\_\_\_\_ + +| Name of Receiving Bank | Rockland Trust Co. | +|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------| +| ABA Routing Number of Receiving Bank (9 digit number)
    *This may not be the routing number listed on the bottom of your checks. Please call your bank to verify the number used to receiving an incoming wire* | | +| Address of Receiving Bank | Street: _____
    City/State/Zip: Newton, MA 02460 | +| Phone Number of Receiving Bank | _____ | +| Account Number | _____ | +| Name(s) on Your Account | _____ | +| Address Associated with Your Account (Physical Address; not P.O. Box) | Street: _____
    City/State/Zip: _____ | +| If Applicable, Provide Additional Instructions Here. Example: "For Further Credit to" or "For the Benefit of" | | + +By signing this form, I hereby acknowledge that the information is correct and accurate and I agree to the wire fee of \$50.00. I further agree to verify this information by telephone or in person on the date of the wire transmission. + +I understand that the receiving bank may charge an incoming wire fee to my account. + +Hudkins Law PLLC hereby reserves the right to initiate a "test" wire for a nominal amount to confirm the accuracy of these wiring instructions. I agree to cooperate with the verification of receipt of said "test" wire. + +\_\_\_\_\_ + +Signature \_\_\_\_\_ Date \_\_\_\_\_ Signature \_\_\_\_\_ Date \_\_\_\_\_ + +Internal Use Only: + +\_\_\_\_\_ Telephone Verification by \_\_\_\_\_ Date/Time: \_\_\_\_\_ + + In Person Verification by \_\_\_\_\_ Date/Time: \_\_\_\_\_ + +| WINDHAM, NH | CONCORD, NH | NEW LONDON, NH | KEENE, NH | HORWICH, VT | ANDOVER, MA | +|-------------------|------------------|-------------------|-----------|------------------|------------------| +| PO Box 719, 03007 | Sales 104, 03301 | PO Box 608, 03257 | 03431 | PO Box 15, 05055 | Sales 201, 01810 | + +VOID VOID VOID VOID VOID + +HUDKINS LAW + +IOLTA Account +9 Newport Road +New London, NH 03257 + +Enterprise Bank + +[REDACTED] + +12/13/2019 + +\$\*\*\*\*\*350.00 + +Pay Three Hundred Fifty and 00/100 Dollars + +TO Law Office of Margaret A. Jacobs +THE 45 Lyme Road, Suite 209 +ORDER Hanover NH 03755 +OF [REDACTED] Bradford, NH 03221 + +Borrower: Granite Reality LLC + +[REDACTED] + +*Granite Reality LLC* +Void after 90 days + +MONITOR HAS A COLORED BACKGROUND • BORDER CONTAINS MICROPRINTING + +Paid To The Order Of: + +Law Office of Margaret A. Jacobs + +Date: + +12/13/2019 + +Check No.: + +[REDACTED] + +Amount Of This Check: + +\$\*\*\*\*\*350.00 + +File No.: + +[REDACTED] + +Buyer: + +Granite Reality LLC + +Seller: + +[REDACTED] + +Property: + +[REDACTED] Bradford, NH 03221 + +Settlement Date: + +12/13/2019 + +Disbursement Date: + +12/13/2019 + +Charge Detail: + +Other Payoff + +350.00 + +Paid To The Order Of: + +Date: + +12/13/2019 + +Check No.: + +[REDACTED] + +Amount Of This Check: + +\$\*\*\*\*\*350.00 + +*Sent by +Kayla G.* + +2019-2700 + +R + +![](_page_7_Picture_56.jpeg) + +HUDKINS LAW +HUDKINS TITLE + +Attorneys + +Mr. Jacquelin M. Hudkins +Revenue T. Marton +Missouri B. Jones +Mr. Louise M. Tennanko +Michael G. Anderson + +Mi Martha L. Printz +Mr. Carolina M. O'Neill +John P. Rab +Danish P. Vanders + +Admitted to Prosecution by M. M. MA. +Admitted to Prosecution by P. P. B. MA. +Admitted to Prosecution by MA & MT. +Admitted to Prosecution by MT & VT. +Admitted to Prosecution by MT & VT. +Admitted to Prosecution by MA. +\* OF named + +TAX INFORMATION SHEET + +[Redacted] + +Date Called: \_\_\_\_\_ + +Spoke to: \_\_\_\_\_ + +accord - [Redacted] + +Owners: [Redacted] + +Borrowers/Buyers: Granite Realty + +Property Address: [Redacted] + +Parcel ID: [Redacted] Stap \_\_\_\_\_ Lot \_\_\_\_\_ + +Assessed Value: \$ \_\_\_\_\_ Tax Rate: \$ \_\_\_\_\_ % \_\_\_\_\_ + +TOWN/CITY TAXES + +DUE DATES: 7/1 / 12/1 + + Annual Semi-Annual Quarterly + +2 acres are taxed on + +Date: 7/1 \$ 10,626 Paid Due + +Date: 12/19 \$ 11,375 Paid Due + +Date: \_\_\_\_\_ \$ \_\_\_\_\_ Paid Due + +Date: \_\_\_\_\_ \$ \_\_\_\_\_ Paid Due + +Next Due: \_\_\_\_\_ Annual Amount (Prorations) \$ 22,001 Actual Estimated + +Annual Amount (Escrows) \$ \_\_\_\_\_ Actual Estimated +154 acres INCU + +Outstanding Taxes: \$ \_\_\_\_\_ + +Interest to: \$ \_\_\_\_\_ + +Per Dlem: \$ \_\_\_\_\_ + +Total: \$ \_\_\_\_\_ + +Current Use N Y- \$ \_\_\_\_\_ (est. penalty) + +Exemptions N Y- \$ \_\_\_\_\_ (annual) + +Credits N Y- \$ \_\_\_\_\_ (annual) + +Assessments/ Betterments N Y- \$ \_\_\_\_\_ (annual) + +Well/Ensum Western Bradford Bradford, NH 03221 + +THIS CHECK IS VOID WITHOUT A BLUE, BURGUNDY & GREEN BACKGROUND AND AN ARTIFICIAL WATERMARK ON THE BACK • HOLD AT AN ANGLE TO VIEW + +HUDKINS LAW + +IOLTA Account [Redacted] + +New London, NH 03257 + +Enterprise Bank + +12/13/2019 + +Pay Eleven Thousand Three Hundred Seventy-Five and 00/100 Dollars \$\*\*\*\*11,375.00 + +TO: Bradford Tax Collector +THE PO Box 607 +ORDER 93 West Main Street +OF Bradford NH 03221 +2019-2700 [Redacted] Bradford, NH 03221 +Buyer: Granite Realty LLC + +Garylu Mhudin +Old after 90 days +SIGNATURE HAS A COLORED BACKGROUND • BORDER CONTAINS MICROPRINTING + +**DAY OF CLOSING-PURCHASE** + +| PRE-CLOSING & PARTY INFORMATION | | +|---------------------------------|-----------------------------------------------------------------------------------------------------------------| +| Print Lender Documents | BUYER(S)/BORROWER(S): Jeffrey W. Roberts, Manager of Granite Realty LLC | +| Print HLaw Documents | | +| Recording Sheet | BUYER'S AGENT/AGENCY: Four Seasons Sothonys International Real Estate/Jennifer Johnson | +| MA Documents | | +| MA Notary Clauses | BUYER'S ATTORNEY: | +| CD-57s/PA-34 | | +| HELOC Closeout | LOAN OFFICER/LENDER: /CASH | +| Copy Package(s) | | +| Print Checks | SELLER(S): [REDACTED] Trustee of the [REDACTED] | +| OG Wire Verification | | +| Blank Checks-IOLTA | LISTING AGENT/AGENCY: Four Seasons Sothonys International Real Estate/Margaret Weathers | +| Blank Checks-Recording | PROPERTY ADDRESS [REDACTED] Bradford, NH
    03221
    PROCESSOR: Rebecca Russo
    SELLER'S ATTORNEY: Alex Garcia | + +| AT CLOSING | | | +|--------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------| +| Taxes | Last Paid (Bill Date):
    Period Covered:
    Paid at Closing (Bill Date): 12/19
    Paid By:
    Period Covered:
    Next Due: 7/20 | Quarterly Semi-Annual Annual
    11,375.00 @ close | +| Identification
    (2 IDs Required) | Collect | | +| Blue Ink Required | | | +| Lender Funding | N/A | Collect Received | +| Buyer/Borrower Funds | # 994,279.12 | Collect Received 12/12 | +| Seller Funds | | Collect Received | +| EMD | # 100,000.00 | Collect From: LA BA SA
    Received Retained 12/12 | +| Collect at Closing-Other | Dued - Margaret Jacobs
    No Mtg Aff.
    *** NUED SELLERS SS *** | | +| Obtain instructions for delivery of proceeds (\$25 per wire) | Seller to bring wire Inst to close
    Wire # 1,012,322.07 | | + +| POST-CLOSING | | +|----------------------|-----------------------------------------------------------------------------------------------| +| Deposit Funds | | +| Bank Account: | Enterprise Bank | +| Recording | Record Physical | +| Notes to Post-Closer | | +| | Verified Escrow Account
    (Post Closer Initials)
    Merrimack
    24 Hour Package
    8 payffs | + +![](_page_9_Picture_24.jpeg) + +Attorneys +Attorney Advisor +Advisor Agent +Agent Lease +Receiver Rever +& Govt & Dist + +Attorney Advisor +Attorney Agent +Agent Lease +Receiver Rever +& Govt & Dist + +Attorney Advisor +Attorney Agent +Agent Lease +Receiver Rever +& Govt & Dist + +Recorder please hold until: + +PLEASE FAX RECORDING INFORMATION TO [REDACTED] + +REGISTRY Merrimack + +SELLER(S) [REDACTED] + +BUYER(S) Granite Realty LLC + +PROPERTY ADDRESS Bradford, NH 03221 + +Lender: CASH +MERS: Y or N +Purchase Price: \$1,070,750.00 +Loan Amount: \$.00 +Date of Closing: 12/13/2019 + +Bank Account: Enterprise Bank +\*\*Verified Escrow Account +(Post Closer Initials) + +Tax Stamps: 16,062.00 +Processor: Rebecca Russo + +Underwriter: Stewart Tite +Guaranty Company +Lender's Premium: \$.00 +Owner's Premium: \$2,537.00 + +Variable? Y or N +Condo? Y or N +PUD? Y or N +Plot Plan? Y or N +Construction Holdback? Y or N + +Subordinate Mortgage? Y or N +Lender: +MERS: Y or N +Loan Amount: +Mortgage Date: +Recording Date: + +RUNDOWN FROM 12/13 Recorded by: Molley +Pre E-Record Update Through: 12/13 Date Recorded: 12/13 +Post E-Record Update Through: 12/20 + +| DOCUMENT | TIME | INSTRUMENT # | BOOK | PAGE | +|------------|-------------|---------------------|-------------|-------------| +| Dud | 3:04 | 201900023556 | 3658 | 2315 | +| | | | | | +| | | | | | +| | | | | | +| | | | | | +| | | | | | +| | | | | | +| | | | | | +| | | | | | + +REFEREND IN: [REDACTED] +PRECEDEND IN: [REDACTED] +MINIMUM IN: [REDACTED] +SALES 201, 0000 + +# E-recording Report of Recorded Documents Itemized Fee View + +Prepared for. Hudkins Law PLLC (NHTWFE) + +Cost center: NHTWFE + +Report generated: 12/13/2019 01:07 PM MST + +## Documents Recorded + +| NAME | TYPE | PG | ENTRY | RECORD DATE | SF | AMT | TOTAL | PROCESSED | | +|---------------------------------|------|----|-------------|-------------------------|------|-----------------|-----------|-----------|------------| +| Merrimack County, NH | | | | | | | | | | +| Dec 13, 2019 | | | | | | | | | | +| 2 Granite Realty LLC | | | | 12/13/2019 03:04 PM EST | 4.00 | Recording Fee | 18.00 | 22.00 | 12/13/2019 | +| 4 DEED | | | DEED_DEED 3 | | 0.00 | Surcharge | 2.00 | 2.00 | 12/13/2019 | +| | | | | | 0.00 | LCHIP Fee | 25.00 | 25.00 | 12/13/2019 | +| | | | | | 0.00 | NH Transfer Tax | 16,062.00 | 16,062.00 | 12/13/2019 | +| | | | | | | | 16,107.00 | 16,111.00 | | +| | | | | | | | 16,107.00 | 16,111.00 | | +| Totals for Merrimack County, NH | | | | | | | | | | +| | | | | | 4.00 | | 16,107.00 | 16,111.00 | | + +## Recording Fee Totals + +| COUNTY | RECORD DATE | SF | AMT | TOTAL | +|----------------------------------------|-------------|-------------|------------------|------------------| +| Merrimack County, NH | 12/13/2019 | 4.00 | 16,107.00 | 16,111.00 | +| Totals for Merrimack County, NH | | 4.00 | 16,107.00 | 16,111.00 | +| Total of All Recording Fees | | 4.00 | 16,107.00 | 16,111.00 | + +## Document Count: 1 + +Package Count: 1 + +Questions Contact: Simplrfile Support 800.460.5657, option 3 5072 North 300 West Provo, UT 84604 + +IOLTA Account +9 Newport Road +New London, NH 03257 + +**Enterprise Bank** + +[Redacted] + +[Redacted] + +12/13/2019 + +**Pay** Fifty Thousand Two Hundred Eighty-Seven and 50/100 Dollars + +\$\*\*\*\*50,287.50 + +TO Four Seasons Sothebys International Real Estate +THE 259 Main Street +ORDER New London NH 03257 + +*(Clasting)* + +\_\_\_\_\_ +\_\_\_\_\_ + +OF [Redacted] - [Redacted] Bradford, NH 03221 + +Void after 90 days + +Borrower: Granite Reality LLC + +[Redacted] + +Paid To The Order Of: + +Four Seasons Sothebys International Real Estate + +Date: +12/13/2019 + +Check No.: + +Amount Of This Check: +\$\*\*\*\*50,287.50 + +File No.: + +[Redacted] + +Buyer: + +Granite Reality LLC + +Seller: + +[Redacted] + +Property: + +[Redacted] + +Settlement Date: + +12/13/2019 + +Disbursement Date: + +12/13/2019 + +Charge Detail: + +Commission + +50,287.50 + +Paid To The Order Of: + +Four Seasons Sothebys International Real Estate + +Date: +12/13/2019 + +Check No.: + +Amount Of This Check: +\$\*\*\*\*50,287.50 + +File No.: + +[Redacted] + +Buyer: + +Granite Reality LLC + +Seller: + +[Redacted] + +Property: + +[Redacted] + +Settlement Date: + +12/13/2019 + +Disbursement Date: + +12/13/2019 + +Charge Detail: + +Commission + +50,287.50 + +New London, NH 03257 + +![](_page_12_Picture_206.jpeg) + +![](_page_12_Picture_207.jpeg) + +12/13/2019 + +**Pay** Eleven Thousand Three Hundred Seventy-Five and 00/100 Dollars + +\$\*\*\*\*11,375.00 + +TO Bradford Tax Collector + THE PO Box 607 + ORDER 93 West Main Street + OF Bradford NH 03221 + +*XG* + +\_\_\_\_\_ + \_\_\_\_\_ + +Buyer: Granite Reality LLC Bradford, NH 03221 + +Void after 90 days + +![](_page_12_Picture_216.jpeg) + +Paid To The Order Of: + Bradford Tax Collector + +Date: + 12/13/2019 + +Check No.: + [Redacted] + +Amount Of This Check: + \$\*\*\*\*11,375.00 + +File No.: [Redacted] + Buyer: Granite Reality LLC + Seller: [Redacted] + Property: [Redacted] Bradford, NH 03221 + Settlement Date: 12/13/2019 + Disbursement Date: 12/13/2019 + Charge Detail: + +Payoff - Bradford Tax Collector - Taxes Due 12/17 + +11,375.00 + +Paid To The Order Of: + Bradford Tax Collector + +Date: + 12/13/2019 + +Check No.: + [Redacted] + +Amount Of This Check: + \$\*\*\*\*11,375.00 + +File No.: [Redacted] + Buyer: Granite Reality LLC + Seller: [Redacted] + Property: [Redacted] Bradford, NH 03221 + Settlement Date: 12/13/2019 + Disbursement Date: 12/13/2019 + Charge Detail: + +Payoff - Bradford Tax Collector - Taxes Due 12/17 + +11,375.00 + +New London, NH 03257 + +( ) ( ) ( ) + +[REDACTED] + +12/13/2019 + +**Pay** Five Hundred Seven and 40/100 Dollars + +\$\*\*\*\*\*507.40 + +TO Stewart Title Guaranty Company +THE NH + +ORDER + +OF + +1 [REDACTED] - [REDACTED] Bradford, NH 03221 + +Buyer: Granite Reality LLC + +KG/TP + +Void after 90 days + +[REDACTED] + +Paid To The Order Of: + +Stewart Title Guaranty Company + +Date: +12/13/2019 + +Check No.: + +Amount Of This Check: + +\$\*\*\*\*\*507.40 + +File No.: + +Buyer: + +Seller: + +Property: + +Settlement Date: + +Disbursement Date: + +Charge Detail: + +Title Insurance + +507.40 + +![](_page_13_Picture_185.jpeg) + +IQLTA Account +[Redacted] +New London, NH 03257 +[Redacted] + +Enterprise Bank + +[Redacted] + +[Redacted] + +12/13/2019 + +**Pay** Three Hundred Fifty and 00/100 Dollars + +\$\*\*\*\*\*350.00 + +TO Law Office of Margaret A. 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Hudkins +Margan D. Jones +Reema I. Maraun +Condice M. O'Neil + +Martha L. Prizlo +Theodore P. Prizlo +John P. Rub +Loure M. Tomanello + +Admitted to Practice in NH & MA +Admitted to Practice in VT & MA +Admitted to Practice in MA & RI +Admitted to Practice in NH & VT +Admitted to Practice in NH +Admitted to Practice in MA + +BUYER INFORMATION + +PLEASE PROVIDE THE INFORMATION REQUESTED BELOW AND RETURN VIA FAX OR EMAIL. + +FAX: [REDACTED] EMAIL: [REDACTED] + +Address of Property to be Purchased: [REDACTED] + +Bradford, NH + +FULL NAME OF BUYER #1: Granite Prality LLC + +Social Security Number: c/o Coortney Labbe, + +Daytime phone #: [REDACTED] Evening phone #: Parallegel + +Email Address: [REDACTED] Notter McCleanen ; Fish + +For deed preparation purposes, please respond to the following: + +Please circle: Married or Single + +Will this property serve as your primary residence? No + +FULL NAME OF BUYER #2: + +Social Security Number: + +Daytime phone #: [REDACTED] Evening phone #: + +Email Address: + +For deed preparation purposes, please respond to the following: + +Please circle: Married or Single + +Will this property serve as your primary residence? + +HOMEOWNER INSURANCE INFORMATION FOR PROPERTY TO BE PURCHASED: + +Insurance Company Name: USAA + +Agent Name: [REDACTED] Phone: [REDACTED] + +Annual Premium: TBAD #5,186.83 Policy Effective Dates: 12/13/19 + +It is the practice of Hudkins Law to issue title insurance policies with the maximum coverage available. If you have questions about title insurance, please contact our firm. + +| BEDFORD, NH
    264 South River Road
    03110 | CONCORD, NH
    Capital Plaza, 57 North Main Street
    Suite 104, 03301 | HAMPTON, NH
    58 Winnocunnet Road
    03842 | KEENE, NH
    265 Washington Street
    03431 | NEW LONDON, NH
    9 Newport Road
    PO Box 800, 03257 | WINDHAM, NH
    25 Indian Rock Rd. #9
    PO Box 719, 03087 | NORWICH, VT
    316 Main Street, Suite 201
    PO Box 15, 05055 | ANDOVER, MA
    300 Brickstone Square
    Suite 201, 01810 | +|----------------------------------------------|------------------------------------------------------------------------|---------------------------------------------|---------------------------------------------|-------------------------------------------------------|-----------------------------------------------------------|---------------------------------------------------------------|----------------------------------------------------------| +|----------------------------------------------|------------------------------------------------------------------------|---------------------------------------------|---------------------------------------------|-------------------------------------------------------|-----------------------------------------------------------|---------------------------------------------------------------|----------------------------------------------------------| \ No newline at end of file diff --git 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to **Granite Reality, LLC**, a New Hampshire limited liability company, with a principal mailing address of 155 Seaport Blvd., Boston, MA 02210, with **WARRANTY COVENANTS**, + +That certain tract or parcel of land together with the buildings thereon, located in the Town of Bradford, County of Merrimack, State of New Hampshire as being shown on a plan of land entitled " [REDACTED] + +[REDACTED], said land being shown upon said plan as being more particularly bounded and described as follows: + +[REDACTED] + +[Redacted text block] + +[Redacted text block] + +Meaning and intending to convey all and the same land and premises conveyed to [Redacted], Trustee of The [Redacted] u/d/t dated December 28, 2012, by warranty deed of [Redacted] dated December 14, 2017 and recorded in the [Redacted]. + +These are not homestead premises. + +CERTIFICATE IN ACCORDANCE WITH R.S.A. 564-A:7 + +The undersigned Trustee, as Trustee of The [Redacted] u/d/t dated December 28, 2012, has full and absolute power in that trust agreement to convey any interest in real estate and improvements on real estate held in the trust and no purchaser or third party shall be bound to inquire whether the Trustee has that power or is properly exercising that power or to see to the application of any trust asset paid to the Trustee for a conveyance of real estate or improvements on real estate. + +Signed and dated on the day of December 2019. + +nistee + +STATE of NEW HAMPSHIRE COUNTY of + +The fore oin certificate was acknowled ed before me on the day of December 2019 by Trustee of The -u/d/t dated December 28, 2012. + +> Before me: Notary Public My commission expires: \ No newline at end of file diff --git a/marker2/ds9/EFTA00089333/EFTA00089333.metadata.json b/marker2/ds9/EFTA00089333/EFTA00089333.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..f05deb218ab6792ee300b099fd48ebbd6ce4c7bb --- /dev/null +++ b/marker2/ds9/EFTA00089333/EFTA00089333.metadata.json @@ -0,0 +1,169 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Roberts, Manager of Granite Reality LLC | +| Print HLaw Documents | | +| Recording Sheet | BUYER'S AGENT/AGENCY: Four Seasons Sothebys International Real Estate/Jennifer Johnson | +| MA Documents | | +| MA Notary Clauses | BUYER'S ATTORNEY: | +| CD-57s/PA-34 | | +| HELOC Closeout | LOAN OFFICER/LENDER: /CASH | +| Copy Package(s) | | +| Print Checks | SELLER(S): [REDACTED], Trustee of the [REDACTED] | +| OG Wire Verification | | +| Blank Checks-IOLTA | LISTING AGENT/AGENCY: Four Seasons Sothebys International Real Estate/Margaret Weathers | +| Blank Checks-Recording | | +| | PROPERTY ADDRESS: [REDACTED], Bradford, NH 03221 | +| | PROCESSOR: Rebecca Russo | +| | SELLER'S ATTORNEY: Alex Garcia | + +| AT CLOSING | | | +|--------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------| +| Taxes | Last Paid (Bill Date):
    Period Covered:
    Paid at Closing (Bill Date): 12/19
    Paid By:
    Period Covered:
    Next Due: 7/20 | ___ Quarterly Semi-Annual ___ Annual | +| | | 11,375.00 @ close | +| Identification
    (2 IDs Required) | Collect | | +| Blue Ink Required | | | +| Lender Funding | 7/19 | ___ Collect ___ Received | +| Buyer/Borrower Funds | # 994,279.12 | ___ Collect Received 12/12 | +| Seller Funds | | ___ Collect ___ Received | +| EMD | # 100,000.00 | ___ Collect From: LA ___ BA ___ SA
    Received ___ Retained 12/12 | +| Collect at Closing-Other | Dued - Margaret Jacobs
    No Mtg Aff.
    * * * Need Sellers SS# | | +| Obtain instructions for delivery of proceeds (\$25 per wire) | * * * Seller to bring wire Inst to close
    Wire # 1,012,322.07 | | + +| POST-CLOSING | | | +|----------------------|-----------------------------------------------------|------------------------------------------------------| +| Deposit Funds | Enterprise Bank | ***Verified Escrow Account
    (Post Closer Initials) | +| Bank Account: | | | +| Recording | E-Record ___ Physical | Merrimack | +| Notes to Post-Closer | | ___ 24 Hour Package
    8 payffs | + +![](_page_1_Picture_33.jpeg) + +Minimplex M. Melins + Robert G. Anderson + Margot D. Jones + Robert E. Morrow + # Gender M. O'Neil + +Martin L. Pools + Ronaldo P. Price + John P. Rab + +Selection to Provide to MM & MA + Authorized to Provide to VT & MA + Authorized to Provide to MA & MT + Authorized to Provide to MA & MT + Authorized to Provide to MA + +**Recorder please hold until:** + +**PLEASE FAX RECORDING INFORMATION TO [REDACTED]** + +**REGISTRY**                                  Merrimack + +**SELLER(S)**                                  [REDACTED] Trustee of the [REDACTED] Trust + +**BUYER(S)**                                  Granite Reality LLC + +**PROPERTY ADDRESS**                                  [REDACTED] Bradford, NH 03221 + +Lender: CASH + MERS: Y or N + Purchase Price: \$1,070,750.00 + Loan Amount: \$.00 + Date of Closing: 12/13/2019 + +Bank Account: Enterprise Bank + \*\*Verified Escrow Account + \_\_\_\_\_ (Post Closer Initials) + +Tax Stamps: 16,062.00 + Processor: Rebecca Russo + +Underwriter: Stewart Title + Guaranty Company + Lender's Premium: \$.00 + Owner's Premium: \$2,537.00 + +Variable? Y or N + Condo? Y or N + PUD? Y or N + Plot Plan? Y or N + Construction Holdback? Y or N + +Subordinate Mortgage? Y or N + Lender: + MERS: Y or N + Loan Amount: + Mortgage Date: + Recording Date: + +RUNDOWN FROM \_\_\_\_\_ Recorded by: \_\_\_\_\_ + +Pre E-Record Update Through: \_\_\_\_\_ Date Recorded: \_\_\_\_\_ + +Post E-Record Update Through: \_\_\_\_\_ + +| DOCUMENT | TIME | INSTRUMENT # | BOOK | PAGE | +|------------|------|--------------|------|------| +| Nud | | | | | +| | | | | | +| | | | | | +| | | | | | +| | | | | | +| | | | | | +| | | | | | +| | | | | | +| | | | | | +| | | | | | + +NORWICH, VT + 316 Main Street, Suite 201 + PO Box 15, 05055 + +ANDOVER, MA + 300 Brickstone Square + Suite 201, 01810 + +# Outgoing Wire Record File Number + +Date: December 13, 2019 + +Payee: Trustee of the Trust + +Amount: \$1,012,322.07 + +Escrow Account: Enterprise Bank + +Escrow Bank Account #: + +Buyer/Borrower Name: Granite Reality LLC + +Seller Name: Trustee of the Trust + +Property Address: , Bradford, NH 03221 + +Remarks: Seller Proceeds + +![](_page_3_Picture_0.jpeg) + +# H HUDKINS LAW. HUDKINS TITLE. + +Mew\*. It Hefts SAS@ 1\_ lira + +bast lira• kilt/14 + +bogs O. has Owe P. taki + +a busk knock • Oral M. Old' + +tided G. frodenod frig bdi• + +Adetabli Reg\* 1414 VA + +•AAviW is hulk? b VTR MA • Megalod V /WON le MA Is it + +ebbed to Ps\*, In NH & VT PASS. to Melt.. 1p + +WSW lo Pmto IIA + +• Of ousel + +IF YOU ARE EXPECTING TO RECEIVE PROCEEDS AND WOULD LIKE YOUR PROCEEDS WIRED, PLEASE COMPLETE THIS FORM IN ITS ENTIRETY + +PLEASE NOTE THAT A WIRE FEE OF \$50.00 WILL APPLY + +This form must be filled out in its entirety to ensure a timely wire. Hudkins Law is unable to transmit a wire unless all of the data fields on this form have been completed and verified. + +Name of Wire recipient: + +Phone Number where you may be reached on the date of the expected wire• + +| | Name of Receiving Bank ABA Routing Number of Receiving Bank | +|------------------------------|-----------------------------------------------------------------------| +| (9 digit number) | | +| *This may not he the routing | number listed on | +| the bottom | of your checks Please call your bank | +| to verify the number used | to receiving an | +| incoming | wire* | +| Address of Receiving Bank | Street: City/State/Zip: Phone Number of Receiving Bank Account Number | +| Name(s) | on Your Account Address Associated with Your Account Street: | +| (Physical Address; | not P .O Box) City/State/Zip: | +| If Applicable, | Provide Additional Instructions | +| Here | Example: "For Further Credit to " or "For the Benefit of | + +By signing this form, I hereby acknowledge that the information is correct and accurate and I agree to the wire fee of \$50.00. I further agree to verify this information by telephone or in person on the date of the wire transmission. + +I understand that the receiving bank may charge an incoming wire fee to my account. + +Hudkins Law PLLC hereby reserves the right to initiate a "test" wire for a nominal amount to confirm the accuracy of these wiring instructions. I agree to cooperate with the verification of receipt of said "test" wire. + +Signature Date Signature Date + +Internal Use Only: + +Telephone Verification by Date/Time: + +In Person Verification by tiNN Date/Time: + +PO lot 711, 03017 + +cobal CONCORD. NH NEW CONDOM. NH S000104, 01301 PO In 10, 03257 + +03431 + +NORWIOI. VI 316 1, role IS, NOSS Sal 201, MIN + +From: Enterprise Bank: Wire Servicing Dept < Sent Thursday, December 12, 2019 1:24 PM To: Processing Subject Incoming Wire Transfer Notification + +Your wire transfer on 12/12/19, in the amount of \$994,29.12 was received from GRANITE REALITY LLC. Contact ENTERPRISE BANK if you have any questions regarding this transaction. Refer to wire sequence number 37362295 in your inquiry. + +Credited to account ending with 017 + +Wire Fee: \$0.00 + +Sending FI: OMAD: IMAD: CITIZENS BANK, N.A + +Originator Address: C/O NUTTER MCLENNEN & FISH LLP 155 SEAPORT BLVD BOSTON MA 022102698 + +Originator to Beneficiary Information: + +ATTN: JEN MARSHALL + +This message is intended only for the persons or entities to which it is addressed. The information transmitted herein may contain proprietary or confidential material. Review, reproduction, retransmission, distribution, disclosure or other use, and any consequent action taken by persons or entities other than intended recipients, are prohibited and may be unlawful. If you are not the intended recipient, please delete this information from your system and contact the sender. The Information contained herein is subject to change without notice. Although reasonable precautions have been taken to ensure that no viruses are present, the sender makes no warranty or guaranty with respect thereto, and is not responsible for any loss or damage arising from the receipt or use of this email or attachments hereto. + +From: Margie Weathers Sent Tuesday, December 10, 2019 10:20 AM To: Rebecca Russo Subject: Re: Attachments: Addendum PRICE REDUCTION pdf + +Rebecca- The price has been reduced to \$1,070,750.00 I am not sure why you were not notified. + +The commission is \$50,287.50 to FSSIR. + +My apologies for this, not my clients. + +See attached addendum + +Margaret Weathers Broker Associate Four Seasons Sotheby's International Realty 259 Main Street New London, NH 03257 + +o: c: Explore the New London Lake Sunapee Region + +Four Seasons Sotheby's Living Magazine + +![](_page_5_Picture_9.jpeg) + +'It seems to me that the natural world is the greatest source of excitement; the greatest source of visual beauty; the greatest source of Intellectual interest. It is the greatest source of so much in life that makes life worth living.' David Attenborough + +"The major problems in the world are the result of the difference between how nature works and the way people think." Gregory Bateson + +![](_page_6_Picture_35.jpeg) + +HUDKINS LAW +HUDKINS TITLE + +Attorneys + +Mr. Jacquelin M. Hudkins +Reserve T. Harpers +Mr. Harpers D. Jones +Mr. Laura M. Tannersky +Mr. Richard G. Andersen + +Mr. Martha L. Prizis +Mr. Condice M. O'Hassill +John P. Reis +Dennis P. Vachyan + +Admitted to Prosecution by MR & MA +If Admitted to Prosecution by VT & MA +If Admitted to Prosecution by MA & VT +Admitted to Prosecution by NY & VT +Admitted to Prosecution by ASF +Admitted to Prosecution by MA +\* Of named + +R + +TAX INFORMATION SHEET + +Tax Collector Name & Phone Number: + +Brad Ard T. Hall +associate + +Date Called: \_\_\_\_\_ + +Spoke to: \_\_\_\_\_ + +Owners: + +Richard Family Trust + +Borrowers/Buyers: + +Granite Realty + +Property Address: + +[Redacted] + +Parcel ID: + +[Redacted] + +Map + +Lot + +Assessed Value: \$ \_\_\_\_\_ + +Tax Rate: \$ \_\_\_\_\_ + +\$ \_\_\_\_\_ @ \_\_\_\_\_ % + +TOWN/CITY TAXES + +DUE DATES: + +7/1 / 12/1 + + Annual + + Semi-Annual + + Quarterly + +2 acres are taxed on + +Date: 7/1 + +\$ 10,626 + + Paid Due + +Date: 12/19 + +\$ 11,375 + + Paid Due + +Date: \_\_\_\_\_ + +\$ \_\_\_\_\_ Paid Due + +Date: \_\_\_\_\_ + +\$ \_\_\_\_\_ Paid Due + +Next Due: \_\_\_\_\_ + +Annual Amount (Prorations) \$ 27,001 Actual Estimated + +Annual Amount (Escrows) \$ \_\_\_\_\_ Actual Estimated + +154 acres INCU + +Outstanding Taxes: \$ \_\_\_\_\_ + +Interest to: \$ \_\_\_\_\_ + +Per Diem: \$ \_\_\_\_\_ + +Total: \$ \_\_\_\_\_ + +Current Use N Y- \$ \_\_\_\_\_ (est. penalty) + +Exemptions N Y- \$ \_\_\_\_\_ (annual) + +Credits N Y- \$ \_\_\_\_\_ (annual) + +Assessments/ Betterments N Y- \$ \_\_\_\_\_ (annual) + +Well/Town Water/Private Company Ph: private + +Septic/Town Sewer/Private Company Ph: private + +## Outgoing Wire Record File + +Number: + +![](_page_7_Picture_2.jpeg) + +Date: December 13, 2019 + +Payee: Merrimack County Registry of Dee• 'Transfer Taxes + +Amount: \$16,062.00 + +Escrow Account: Enterprise B.. k + +Escrow Bank Account #: + +![](_page_7_Picture_8.jpeg) + +Buyer/Borrower Name Granite Reality LLC + +Seller Name: + +![](_page_7_Picture_11.jpeg) + +Property Addre + +![](_page_7_Picture_13.jpeg) + +Remarks: St to Tax/Stamps Deed: 16,062.00 + +, Bradford, NH 03221 \ No newline at end of file diff --git a/marker2/ds9/EFTA00089336/EFTA00089336.metadata.json b/marker2/ds9/EFTA00089336/EFTA00089336.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..fdb1252ba1d2ac90d1435b302a464fb845c895a2 --- /dev/null +++ b/marker2/ds9/EFTA00089336/EFTA00089336.metadata.json @@ -0,0 +1,594 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089336.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 8, + "chars": 16940, + "elapsed_seconds": 87.49, + "image_assets": [ + "_page_1_Picture_33.jpeg", + "_page_3_Picture_0.jpeg", + "_page_5_Picture_9.jpeg", + "_page_6_Picture_35.jpeg", + "_page_7_Picture_2.jpeg", + "_page_7_Picture_8.jpeg", + "_page_7_Picture_11.jpeg", + "_page_7_Picture_13.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "DAY OF CLOSING-PURCHASE", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 225.216, + 39.14 + ], + [ + 378.216, + 39.14 + ], + [ + 378.216, + 52.529999999999994 + ], + [ + 225.216, + 52.529999999999994 + ] + ] + }, + { + "title": "Attorneys", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 360.46799999999996, + 37.08 + ], + [ + 403.308, + 37.08 + ], + [ + 403.308, + 48.410000000000004 + ], + [ + 360.46799999999996, + 48.410000000000004 + ] + ] + }, + { + "title": "PLEASE FAX RECORDING INFORMATION TO [REDACTED]", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 79.56, + 109.18 + ], + [ + 312.73199999999997, + 109.18 + ], + [ + 312.73199999999997, + 124.63 + ], + [ + 79.56, + 124.63 + ] + ] + }, + { + "title": "Outgoing Wire Record File Number", + "heading_level": null, + "page_id": 2, + "polygon": [ + [ + 90.576, + 72.9 + ], + [ + 378.79620361328125, + 72.9 + ], + [ + 378.79620361328125, + 94.73736572265625 + ], + [ + 90.576, + 94.73736572265625 + ] + ] + }, + { + "title": "H HUDKINS LAW. 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a/marker2/ds9/EFTA00089344/EFTA00089344.md b/marker2/ds9/EFTA00089344/EFTA00089344.md new file mode 100644 index 0000000000000000000000000000000000000000..a901201c4c5f640ca953dfbed3ef6ffc1785a2e7 --- /dev/null +++ b/marker2/ds9/EFTA00089344/EFTA00089344.md @@ -0,0 +1,66 @@ +From: + +[REDACTED] + +To: + +[REDACTED] + +**Subject:** RE: People v. Maxwell + +**Date:** Wed, 15 Jul 2020 14:24:39 +0000 + +--- + +I think you can forward this to the press office, which fields these types of requests. + +--- + +**From:** [REDACTED] + +**Sent:** Tuesday, July 14, 2020 9:06 PM + +**To:** [REDACTED] + +**Subject:** Fwd: People v. Maxwell + +What should I do. + +Sent from my iPhone + +Begin forwarded message: + +**From:** David Hakimfar <[REDACTED]> + +**Date:** July 14, 2020 at 7:45:41 PM EDT + +**To:** [REDACTED] + +**Subject:** People v. Maxwell + +Good day [REDACTED] + +Can you please advise how I can obtain the arrest record and mugshot of the defendant, Ghislaine Maxwell? + +Thank you, + +-- + +-- + +David Hakimfar, Esq. + +Hakimfar Law, A Professional Law Corporation + +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] + + + +Confidentiality Notice & Disclaimer: This e-mail does not constitute the forming of an attorney-client relationship -- nor should it be construed as such -- and this e-mail has not caused an attorney to represent you in any legal matter unless an attorney-client agreement has been signed. This e-mail may contain information that is privileged, confidential or otherwise protected from disclosure. If you are not the intended recipient or otherwise have received this message in error, you are not authorized to read, print, retain, copy or disseminate this message or any part of it. If you are not the intended recipient or otherwise have received this message in + +error, please help us correct the mistake by letting us know by e-mail, discard any paper copies and delete all electronic files of the message. Thank you. \ No newline at end of file diff --git a/marker2/ds9/EFTA00089344/EFTA00089344.metadata.json b/marker2/ds9/EFTA00089344/EFTA00089344.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..360cc6828e3e4dea70d339f80dc4edf6b9c46086 --- /dev/null +++ b/marker2/ds9/EFTA00089344/EFTA00089344.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089344.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 1830, + "elapsed_seconds": 7.73, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 58 + ], + [ + "Text", + 55 + ], + [ + "Line", + 30 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 5 + ], + [ + "Line", + 3 + ], + [ + "Text", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089344" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089346/EFTA00089346.md b/marker2/ds9/EFTA00089346/EFTA00089346.md new file mode 100644 index 0000000000000000000000000000000000000000..9d4820e5ab669384245a2958efe104f6387e264e --- /dev/null +++ b/marker2/ds9/EFTA00089346/EFTA00089346.md @@ -0,0 +1,22 @@ +**To:** "[REDACTED]" <[REDACTED]> + +**Cc:** Andrew Patel <[REDACTED]>, Jill Shellow <[REDACTED]>, Don Yannella <[REDACTED]> + +**Subject:** [REDACTED]/Epstein + +**Date:** Fri, 20 Dec 2019 13:14:32 +0000 + +--- + +[REDACTED] +Please send us a copy of the disclosure that you are considering as to Mr. [REDACTED]. Seeing the planned disclosure about our client will help us fashion a means of addressing the concerns we discussed last night. Many thanks, +Andy + +Andrew G. Patel +Attorney at Law + +[REDACTED] +[REDACTED] +[REDACTED] + +Sent from my phone \ No newline at end of file diff --git a/marker2/ds9/EFTA00089346/EFTA00089346.metadata.json b/marker2/ds9/EFTA00089346/EFTA00089346.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..1d3219ceac6a1d8bd4dee5458ab997ba217e52d6 --- /dev/null +++ b/marker2/ds9/EFTA00089346/EFTA00089346.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089346.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 545, + "elapsed_seconds": 2.86, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 27 + ], + [ + "Text", + 18 + ], + [ + "Line", + 13 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089346" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089347/EFTA00089347.md b/marker2/ds9/EFTA00089347/EFTA00089347.md new file mode 100644 index 0000000000000000000000000000000000000000..eb1b04f5a474fd9b3aa96831e1f01672ab9785ea --- /dev/null +++ b/marker2/ds9/EFTA00089347/EFTA00089347.md @@ -0,0 +1,212 @@ +**From:** "McGorty, Glen" <[REDACTED]> +**To:** "[REDACTED]" <[REDACTED]> +**Cc:** "Zelenko, Daniel" <[REDACTED]>, "[REDACTED]" <[REDACTED]>, "[REDACTED]" <[REDACTED]>, "Giffuni, Danielle" <[REDACTED]> +**Subject:** Re: Meeting with [REDACTED] +**Date:** Thu, 16 Jul 2020 18:40:10 +0000 + +--- + +Thanks [REDACTED]. We will reach out to our client and follow up as soon as possible. + +--- + +Glen G. McGorty | Crowell & Moring LLP +Managing Partner, New York Office + +[REDACTED] | 20th Floor +[REDACTED] + +[REDACTED] + +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. + +On Jul 16, 2020, at 2:32 PM, [REDACTED] <[REDACTED]> wrote: + +External Email + +Glen, + +Thanks again for following up with us on this issue previously, and we wanted to circle back to take you up on the offer to convey some additional information to your client to see if it causes him to recall anything additional. If you could please advise Mr. [REDACTED] of the following additional information? And then we can have a call similar to our last one to check in. + +The individual whose photo we sent is named [REDACTED] is an employee of the U.S. Customs and Border Protection agency and worked in Saint Thomas for a number of years, and may have had a friendship with Jeffrey Epstein during that time. In particular, [REDACTED] has been to Epstein's home in the Virgin Islands and has accompanied Epstein on boat, helicopter, and/or plane trips. + +Mr. [REDACTED] was listed as a contact in [REDACTED] phone, and [REDACTED] may have introduced one or more individuals to [REDACTED] at a bar or other location in the Virgin Islands. + +From: McGorty, Glen <[REDACTED]> + +Sent: Monday, June 22, 2020 14:27 + +To: [REDACTED] <[REDACTED]> + +Cc: Zelenko, Daniel <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]>; Giffuni, Danielle <[REDACTED]> + +Subject: RE: Meeting with [REDACTED] + +[REDACTED] - + +Would you all be available for a call on Wednesday morning? I think we could do any time before noon. + +We will let you know if Mr. [REDACTED] recognizes the individual in the photo. + +Best, +Glen + +Glen G. McGorty | Crowell & Moring LLP + +Managing Partner, New York Office + +[REDACTED] | 20th Floor | [REDACTED]-2524 + +![](_page_1_Picture_111.jpeg) + +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 + +![](_page_1_Picture_117.jpeg) + +From: [REDACTED] + +<[REDACTED]> + +Sent: Monday, June 22, 2020 12:49 PM + +To: McGorty, Glen <[REDACTED]> + +Cc: Zelenko, Daniel <[REDACTED]>; [REDACTED] + +<[REDACTED]>; [REDACTED] + +<[REDACTED]> + +Subject: RE: Meeting with [REDACTED] + +External Email + +Glen, + +It was indeed quite a weekend, but we continue to do our work as always, and the kind words are appreciated. + +Thanks also for getting back to us, and we're available for a call this week if that would be helpful, and/or if you want to let us know in the first instance about the photo in particular, we can also just go from there. Let us know, and we're around. + +thanks, +[REDACTED] + +From: McGorty, Glen <[REDACTED]> + +Sent: Saturday, June 20, 2020 17:28 + +To: [REDACTED] <[REDACTED]> + +Cc: Zelenko, Daniel <[REDACTED]>; [REDACTED] + +<[REDACTED]>; [REDACTED] + +<[REDACTED]> + +Subject: RE: Meeting with [REDACTED] + +Belated thanks, [REDACTED]. We will circle up with Mr. [REDACTED] and maybe we can have a call early this coming week. + +Crazy times in the Office these days – I hope you are all doing okay. I was on a number of e-mail threads since last night and there are many efforts afoot from generations of alums to publicly support the Office as an institution and all it stands for (and to express profound disappointment over the recent developments). Hang in there. + +Glen G. McGorty | Crowell & Moring LLP +Managing Partner, New York Office + +[REDACTED] | 20th Floor | [REDACTED]-2524 + +![](_page_2_Picture_146.jpeg) + +![](_page_3_Picture_0.jpeg) + +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.conailto:postmaster®crowell.com>) by reply email, and delete this e-mail. + +Unauthorized dissemination, forwarding or copying of this e-mail is strictly prohibited. + +COVID-19 • uestions or Concerns? See Crowell & Morin 's COVID-19 Resource Cente + +![](_page_3_Picture_5.jpeg) + +From: + +mailto: >> + +Sent: Friday, June 19 2020 3:07 PM + +To: McGorty, Glen mailto: + +Cc: Zelenko, Daniel mailto + +mailto: mailto: + +External Email Glen, + +Per my previous email, please see the below. + +Subject: FW: Meeting with + +Sent: Wednesday, June 17, 2020 18:29 + +To: Donnie Murrell [REDACTED] + +Cc: [REDACTED] ) <[REDACTED]; [REDACTED] + +[REDACTED] ) <[REDACTED]; + +Subject: RE: Meeting with [REDACTED] + +Donnie, + +It's been a while since we've been in touch, and obviously our world changed substantially very shortly after the below email exchange from August 9. But we wanted to reach back out because we were wondering if you would be willing to ask Mr. [REDACTED] a couple specific, relatively narrow questions relating to an ongoing investigation. Ordinarily we would ask ourselves, in the context of the discussion we had planned to have—and still hope to schedule, once health and safety permits—but given all of the current circumstances, we'd like to make the request through you. + +The initial question is whether Mr. [REDACTED] recognizes the individual in the attached photo, and if so, generally how he knows the individual. And if Mr. [REDACTED] does know the individual, we may ask you to please convey limited follow-up questions, or to schedule a brief call. If it would be at all useful to discuss this request, please let us know; if that is helpful we can chat at your convenience. + +Thank you, and hope this finds you well. + +[REDACTED] + +[REDACTED] +Assistant U.S. Attorney +Southern District of New York +[REDACTED] + +From: [REDACTED] ) <[REDACTED]; + +Sent: Friday, August 09, 2019 15:20 + +To: Donnie Murrell <[REDACTED]>; + +Cc: [REDACTED] ) <[REDACTED]; + +[REDACTED] ) <[REDACTED]; + +Subject: RE: Meeting with [REDACTED] + +Donnie, + +Our schedule is a bit up in the air right now, but we are tentatively looking at dates during the week of the 19th. We will let you know as soon as our plans firm up, and thanks for being flexible. + +Best, + +[REDACTED] + +From: Donnie Murrell <[REDACTED]>; + +Sent: Friday, August 9, 2019 11:19 AM + +To: [REDACTED] ) <[REDACTED]; + +L.D. MURRELL, P.A. + +Lary Donald "Donnie" Murrell, Jr. + +Board Certified Criminal Trial Lawyer \ No newline at end of file diff --git a/marker2/ds9/EFTA00089347/EFTA00089347.metadata.json b/marker2/ds9/EFTA00089347/EFTA00089347.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..71879892b3aaf8dd539029d4be7c8b942217abc9 --- /dev/null +++ b/marker2/ds9/EFTA00089347/EFTA00089347.metadata.json @@ -0,0 +1,222 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089347.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 6, + "chars": 7720, + "elapsed_seconds": 9.95, + "image_assets": [ + "_page_1_Picture_111.jpeg", + "_page_1_Picture_117.jpeg", + "_page_2_Picture_146.jpeg", + "_page_3_Picture_0.jpeg", + 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2019 15:28:13 +0000 + +We're planning on getting you an initial production this morning, with additional materials to follow after the holidays. + +From: + +Sent: Friday, December 20, 2019 10:26 AM + +To: Quigley, Brendan < >; Lankier, Andrew < + +Cc: + +Subject: RE: subpoena of + +[EXTERNAL EMAIL] + +Hi Brendan and Andy, + +Following up on our call from last week, we wanted to check in to see if you had an updated estimate on when you expect to be able to produce the records we discussed. We understand it's a busy time of year, so we just wanted to get a sense of your timing. + +Thanks, + +Assistant United States Attorney Southern District of New York + +New York, NY 10007 + +From: + +Sent: Thursday, December 12, 2019 11:00 AM + +To: + +Cc: ) + +Subject: RE: subpoena of + +No problem — please call us at office, which is Thanks. + +To: Cc: Subject: Re: subpoena of + +Hey guys + +Andy and I will actually be in different places this morning. Can we call you instead? What's a good number? + +Brendan F. Quigley + +M + +On Dec 11, 2019, at 10:38 AM, wrote: + +[EXTERNAL EMAIL] + +Great, thanks — we'll call you at that number tomorrow at 11:30. + +From: + +Sent: Tuesday, December 10, 2019 21:43 + +To: < + +Cc: + +Subject: Re: subpoena of + +1130 works for us. Can you call Andy's desk I I? Thx. + +Brendan F. Quigley + +M + +On Dec 10, 2019, at 5:07 PM, wrote: + +[EXTERNAL EMAIL] + +Brendan, + +We can do 11:30 on Thursday morning—if there's any issue with that timing we can circle back, otherwise we'll plan to call you then, just let us know the best number to reach you both at. + +thanks, + +Subject: Re: subpoena of + +Is there a time on Thursday that works for you? We've managed to collect some documents. + +Brendan F. Quigley + +M + +On Dec 10, 2019, at 10:48 AM, wrote: + +[EXTERNAL EMAIL] + +Andy and Brendan (good to be in touch!), we wanted to get back to you from your voicemail on Thursday, with apologies for the delay. Is there a good time to have a call sometime in the next few days? I don't expect it will take long, but may be easier to set a time than to try phone tag. Some combination of our team should be generally available, so if you let us know a few times that work for you, hopefully we can get it in the calendar. + +thanks, + +From: + +Sent: Friday, November 22, 2019 13:37 + +To: + +Cc: + +Subject: RE: RE: subpoena of + +Andy, + +Following up on the below, we became somewhat distracted shortly after this email for obvious reasons, but I don't believe we ever got any response, and we haven't received any of the documents pursuant to our subpoena. Can you please let us know the status and let us know if it would be helpful to have a call to get this moving forward again? + +thanks, + +IM• + +From: + +Sent: Tuesday, July 16, 2019 12:59 + +To: + +Cc: + +Subject: RE: RE: subpoena of + +Andy, briefly following up on the below, I just left you a voicemail but also wanted to send a quick email. To expand on our prior discussion, the type of documentary materials we are seeking from in the first instance are any flight manifests, flight plans, or other documents reflecting passengers and/or travel records, dating back to + +2000. And we would like to hear from him about his observations, if any, of young women or girls on flights, as well as any discussions with Mr. Epstein about his relationships with young women or girls, or his legal issues relating to those relationships. We are also interested to know the identities of Epstein's employees and staff whom is aware of, current and previous. + +I hope that's helpful for your continued discussions with him, and please let us know if you have any questions or if any additional info would be useful. + +thank you, + +From: + +Sent: Tuesday, July 16, 2019 11:03 + +To: + +Cc: >; + +Subject: RE: subpoena of + +Andy, + +Following up on our phone conversation a few minutes ago, thank you for being in touch and advising us of your representation of in connection with his receipt of a grand jury subpoena. So you have contact info for our full team, we're all reachable anytime at the copied emails or by phone at: + +(office) (cell) + +(office) (cell) + +(office) (cell) + +As I mentioned on the phone, given the prospect of discussions about continued attorney proffers and a possible voluntary interview, we are prepared to hold in abeyance the current subpoena return date of July 22, 2019. We'll plan to be in touch in the coming days, and if you don't hear from us by the end of the week, please feel free to circle back. + +thank you, + +Assistant U.S. Attorney Southern District of New York + +## Confidentiality Notice: + +The information contained in this email and any attachments is intended only for the recipient[s] listed above and may be privileged and confidential. Any dissemination, copying, or use of or reliance upon such information by or to anyone other than the recipient[s] listed above is prohibited. If you have received this message in error, please notify the sender immediately at the email address above and destroy any and all copies of this message. \ No newline at end of file diff --git a/marker2/ds9/EFTA00089353/EFTA00089353.metadata.json b/marker2/ds9/EFTA00089353/EFTA00089353.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..0f3cd8dc05d83d491283a18dc2b225cf8c456a67 --- /dev/null +++ b/marker2/ds9/EFTA00089353/EFTA00089353.metadata.json @@ -0,0 +1,172 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089353.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 4, + "chars": 5003, + "elapsed_seconds": 1.8, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Confidentiality Notice:", + "heading_level": null, + "page_id": 3, + "polygon": [ + [ + 38.556, + 571.8599999999999 + ], + [ + 169.74513244628906, + 571.8599999999999 + ], + [ + 169.74513244628906, + 586.5840759277344 + ], + [ + 38.556, + 586.5840759277344 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 61 + ], + [ + "Text", + 32 + ], + [ + "Line", + 31 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 57 + ], + [ + "Line", + 29 + ], + [ + "Text", + 28 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 65 + ], + [ + "Line", + 33 + ], + [ + "Text", + 27 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 3, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 65 + ], + [ + "Line", + 33 + ], + [ + "Text", + 19 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089353" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089357/EFTA00089357.md b/marker2/ds9/EFTA00089357/EFTA00089357.md new file mode 100644 index 0000000000000000000000000000000000000000..01ec8b6d18a91f4c891da43e67ce7a63a737a2ef --- /dev/null +++ b/marker2/ds9/EFTA00089357/EFTA00089357.md @@ -0,0 +1,33 @@ +To: + +Subject: Update on your requested records from USAA - Criminal Banking - Ghislaine Maxwell + +Date: Tue, 24 Dec 2019 14:42:27 +0000 + +![](_page_0_Picture_4.jpeg) + +## Your Request is Being Prepared + +The request for records has been received and is being prepared. You will be notified when the invoice is available for pick-up via the ClaimFox Portal. + +Date Of Loss: + +Claimant Name: Ghislaine Maxwell + +Invoice #: 40659875 + +Requested From: USAA - Criminal Banking + +Claim #: 40897182 + +Reference #: + +You can check the status of this and other requests by going to the ClaimFox Portal. + +Powered by ClaimFox, Inc. © 2019 ClaimFox, Inc. - All Rights Reserved SBP 1B + +## Disclaimer + +The information contained in this communication from the sender is confidential. It is intended solely for use by the recipient and others authorized to receive it. If you are not the recipient, you are hereby notified that any disclosure, copying, distribution or taking action in relation of the contents of this information is strictly prohibited and may be unlawful. + +This email has been scanned for viruses and malware, and may have been automatically archived by Mimecast Ltd, an innovator in Software as a Service (SaaS) for business. Providing a safer and more useful place for your human generated data. Specializing in; Security, archiving and compliance. To find out more Click Here. \ No newline at end of file diff --git a/marker2/ds9/EFTA00089357/EFTA00089357.metadata.json b/marker2/ds9/EFTA00089357/EFTA00089357.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..c594fa596505c52b68ed4ce2a6714aba4970ca14 --- /dev/null +++ b/marker2/ds9/EFTA00089357/EFTA00089357.metadata.json @@ -0,0 +1,111 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089357.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1371, + "elapsed_seconds": 0.9, + "image_assets": [ + "_page_0_Picture_4.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Your Request is Being Prepared", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 45.288, + 196.02 + ], + [ + 337.3843994140625, + 196.02 + ], + [ + 337.3843994140625, + 218.70001220703125 + ], + [ + 45.288, + 218.70001220703125 + ] + ] + }, + { + "title": "Disclaimer", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 31.212, + 525.69 + ], + [ + 96.28883361816406, + 525.69 + ], + [ + 96.28883361816406, + 539.3624267578125 + ], + [ + 31.212, + 539.3624267578125 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 45 + ], + [ + "Line", + 23 + ], + [ + "Text", + 16 + ], + [ + "SectionHeader", + 2 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089357" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089357/_page_0_Picture_4.jpeg b/marker2/ds9/EFTA00089357/_page_0_Picture_4.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..923e7b885ab9cb01aeec45ee0e5693f0aae1cbc2 --- /dev/null +++ b/marker2/ds9/EFTA00089357/_page_0_Picture_4.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:fcc8d07e4f24897d95ea92c8fe5d5000046d840e2528781b06dec22cc9d8c24f +size 1066 diff --git a/marker2/ds9/EFTA00089358/EFTA00089358.md b/marker2/ds9/EFTA00089358/EFTA00089358.md new file mode 100644 index 0000000000000000000000000000000000000000..32041f18a4d6e80d01e25a141267fecc60b86be6 --- /dev/null +++ b/marker2/ds9/EFTA00089358/EFTA00089358.md @@ -0,0 +1,59 @@ +From: ' )" H + +To: Sigrid McCawley -1 + +Cc: ' " + +Subject: RE: follow-up request + +Date: Fri, 10 Jan 2020 21:00:53 +0000 + +Thanks very much, Sigrid. Yes, we received the photographs from which we very much appreciate. Anything else she is willing to share, including her journal entries, would be very helpful. + +Best, + +Assistant United States Attorney Southern District of New York l St. Andrew's Plaza New York, NY 10007 + +From: Sigrid McCawley < + +Sent: Friday, January 10, 2020 3:59 PM + +To: + +Cc: >;I < + +Subject: RE: follow-up request + +Hello + +Let me follow up with about her journal. I know she shared some pictures with you from around the time period when she was with Epstein/Maxwell. I will ask her about the journal ASAP and will get back to you and will check with her to see if she has anything else that might be helpful to the investigation. + +All my best, Sigrid + +Sigrid McCawley Partner + +BOIES SCHILLER FLEXNER LLP + +401 E. Las Olas Blvd. Suite 1200 + +Fort Lauderdale. FL. 33301 + +To: Sigrid McCawley + +Cc: + +Subject: follow-up request + +Hi Sigrid, + +Hope you had a wonderful holiday season and very happy New Year. We wanted to follow up on a request we made after interviewing a few months ago. During her interview, referred to several entries in her journal that had helped refresh her recollection of the events involving Epstein and Maxwell. As we mentioned at the end of the interview, it would be very helpful to our investigation if we could review those journal entries, as well as any other records or documents may have that relate to her experiences with Epstein and Maxwell. + +Would be willing to share with us any relevant journal entries (or any other relevant documents she may have) to assist in our investigation? + +Happy to have a call to discuss if that would be helpful. + +Thank you, + +Assistant United States Attorney Southern District of New York l St. Andrew's Plaza New York, NY 10007 + +The information contained in this electronic message is confidential information intended only for the use of the named recipient(s) and may contain information that. among other protections. is the subject of attorney-client privilege, attorney work product or exempt from disclosure under applicable law. If the reader of this electronic message is not the named recipient. or the employee or agent responsible to deliver it to the named recipient, you are hereby notified that any dissemination, distribution, copying or other use of this communication is strictly prohibited and no privilege is waived. If you have received this communication in error, please immediately notify the sender by replying to this electronic message and then deleting this electronic message from your computer. 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I know she shared some pictures with you from around the time period when she was with Epstein/Maxwell. I will ask her about the journal ASAP and will get back to you and will check with her to see if she has anything else that might be helpful to the investigation. + +All my best, + +Partner + +## BOIES SCHILLER FLEXNER LLP + +401 E. Las Olas Blvd. Suite 1200 + +Fort Lauderdale, FL, 33301 + +www.bsfilp.com + +From: [mailto + +Sent: Friday, January 10, 2020 3:30 PM + +To: + +Cc: C + +Subject: follow-up request + +Hi=, + +Hope you had a wonderful holiday season and very happy New Year. We wanted to follow up on a request we made after interviewing -a few months ago. During her interview, referred to several entries in her journal that had helped refresh her recollection of the events involving Epstein and Maxwell. As we mentioned at the end of the interview, it would be very helpful to our investigation if we could review those journal entries, as well as any other records or documents may have that relate to her experiences with Epstein and Maxwell. + +Would be willing to share with us any relevant journal entries (or any other relevant documents she may have) to assist in our investigation? + +Happy to have a call to discuss if that would be helpful. + +Thank you, + +1 St. Andrew's Plaza + +New York, NY 10007 + +![](_page_1_Picture_3.jpeg) + +The information contained in this electronic message is confidential information intended only for the use of the named recipient(s) and may contain information that. among other protections, is the subject of attorney-client privilege, attorney work product or exempt from disclosure under applicable law. lithe reader of this electronic message is not the named recipient or the employee or agent responsible to deliver it to the named recipient. you are hereby notified that any dissemination. distribution, copying or other use of this communication is strictly prohibited and no privilege is waived. 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All others may access the proceeding via telephone conference. + +GHISLAINE MAXWELL Removal Hearing 20mj132-01 7/2/2020 at 3:30 p.m. + +\*\*\*\*\* + +NOTICE: Pursuant to Local Rule 83.8, all persons participating in court proceedings remotely by videoconference or teleconference shall not photograph, broadcast, or televise any of these court proceedings. This prohibition applies to counsel, the parties, the media and any member of the public. + +\*\*\*\*\* + +\*\*\*\*\* + +Counsel shall notify the clerk's office in advance if there are any matters pending before the court that should be presented under seal. + +\*\*\*\*\* + +Join ZoomGov Meeting + + + +Meeting ID: 160 146 2933 + +Password: 182411 + +One tap mobile + ++16692545252,,1601462933#,,1#,182411# US (San Jose) ++16468287666,,1601462933#,,1#,182411# US (New York) + ++1 646 828 7666 US (New York) + +Meeting ID: 160 146 2933 + +Password: 182411 + +Find your local number: https://nhd-uscourts.zoomgov.com/u/adwO3gcwSb + +Join by SIP + +1601462933@sip.zoomgov.com + +Join by H.323 + +161.199.138.10 (US West) + +161.199.136.10 (US East) + +Meeting ID: 160 146 2933 + +Password: 182411 \ No newline at end of file diff --git a/marker2/ds9/EFTA00089362/EFTA00089362.metadata.json b/marker2/ds9/EFTA00089362/EFTA00089362.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..df7a7a52c7f1bb21ad80830a52154d3bec56f867 --- /dev/null +++ b/marker2/ds9/EFTA00089362/EFTA00089362.metadata.json @@ -0,0 +1,104 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089362.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 1956, + "elapsed_seconds": 7.55, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Event: GHISLAINE MAXWELL Removal Hearing 20mj132-01", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 33.660000000000004, + 36.45 + ], + [ + 443.08799999999997, + 36.45 + ], + [ + 443.08799999999997, + 54.269999999999996 + ], + [ + 33.660000000000004, + 54.269999999999996 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 55 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 27 + ], + [ + "Line", + 14 + ], + [ + "Text", + 13 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089362" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089364/EFTA00089364.md b/marker2/ds9/EFTA00089364/EFTA00089364.md new file mode 100644 index 0000000000000000000000000000000000000000..b46cd24e18169346e90be54d0a1f6a1759b1d57d --- /dev/null +++ b/marker2/ds9/EFTA00089364/EFTA00089364.md @@ -0,0 +1,113 @@ +#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +-x + +UNITED STATES OF AMERICA + +20 Cr. 330 (AJN) + +GHISLAINE MAXWELL, + +Defendant. + +\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ ------x + +#### THE GOVERNMENT'S MEMORANDUM IN SUPPORT OF DETENTION + +Acting United States Attorney Southern District of New York Attorney for the United States of America + +Assistant United States Attorneys - Of Counsel - + +#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +-x + +UNITED STATES OF AMERICA + +20 Cr. 330 (AJN) + +GHISLAINE MAXWELL, + +Defendant. + +x + +#### THE GOVERNMENT'S MEMORANDUM IN SUPPORT OF DETENTION + +For the reasons set forth herein, the Government respectfully submits that Ghislaine Maxwell, the defendant, poses an extreme risk of flight; that she will not be able to rebut the statutory presumption that no condition or combination of conditions will reasonably assure the appearance of the defendant as required, 18 U.S.C. § 3 I42(e)(3)(E); and that the Court should therefore order her detained. + +The charges in this case are unquestionably serious: the Indictment alleges that Ghislaine Maxwell, in partnership with Jeffrey Epstein, a serial sexual predator, exploited and abused young girls for years. As a result of her disturbing and callous conduct, Maxwell now faces the very real prospect of serving many years in prison. The strength of the Government's evidence and the substantial prison term the defendant would face upon conviction all create a strong incentive for the defendant to flee. That risk is only amplified by the defendant's extensive international ties, her citizenship in two foreign countries, her wealth, and her lack of meaningful ties to the United States. In short, Maxwell has three passports, large sums of money, extensive international connections, and absolutely no reason to stay in the United States and face the possibility of a lengthy prison sentence. + +### BACKGROUND + +On June 29, 2020, a federal grand jury in the Southern District of New York returned a sealed indictment (the "Indictment") charging the defendant with one count of conspiracy to entice minors to travel to engage in illegal sex acts, in violation of 18 U.S.C. § 371; one count of enticing a minor to travel to engage in illegal sex acts, in violation of 18 U.S.C. § 2422 and 2; one count of conspiracy to transport minors to participate in illegal sex acts, in violation of 18 U.S.C. § 371; one count of transporting minors to participate in illegal sex acts, in violation of 18 U.S.C. § 2423 and 2; and two counts of perjury, in violation of 18 U.S.C. § 1623. + +The charges arise from a scheme to sexually abuse underage girls at Epstein's properties in New York, Florida, and New Mexico, between approximately 1994 and 1997. During that time, Maxwell had a personal and professional relationship with Epstein and was one of his closest associates. + +Beginning in at least 1994, the defendant enticed and groomed multiple minor girls to engage in sex acts with Epstein, through a variety of means and methods. In particular, she played a key role in Epstein's abuse of minors by helping Epstein to identify, groom, and ultimately abuse underage girls. As a part of their scheme, the defendant and Epstein enticed and caused minor victims to travel to Epstein's residences in different states, which the defendant knew and intended would result in their grooming for and subjection to sexual abuse. + +As the Indictment details, the defendant enticed and groomed minor girls to be abused in multiple ways. For example, she attempted to befriend certain victims by asking them about their lives, taking them to the movies or on shopping trips, and encouraging their interactions with Epstein. She put victims at ease by providing the assurance and comfort of an adult woman who seemingly approved of Epstein's behavior. Additionally, to make victims feel indebted to Epstein, + +the defendant would encourage victims to accept Epstein's offers of financial assistance, including offers to pay for travel or educational expenses. The victims were as young as 14 years old when they were groomed and abused by Maxwell and Epstein, both of whom knew that their victims were minors. + +The Indictment further alleges that the defendant lied under oath to conceal her crimes. In 2016, the defendant gave deposition testimony in connection with a civil lawsuit in the Southern District of New York. During the deposition, the defendant was asked questions about her role in facilitating the abuse of minors. The defendant repeatedly lied under oath when questioned about her conduct with minor girls. + +### ARGUMENT + +## I. Applicable Law + +Under the Bail Reform Act, 18 U.S.C. §§ 3141 et seq., federal courts are empowered to order a defendant's detention pending trial upon a determination that the defendant is either a danger to the community or a risk of flight. 18 U.S.C. § 3142(e). A finding of risk of flight must be supported by a preponderance of the evidence. See, e.g., United States v. Patriarca, 948 F.2d 789, 793 (1st Cir. 1991); United States v. Jackson, 823 F.2d 4, 5 (2d Cir. 1987); United States v. Chimurenga, 760 F.2d 400, 405 (2d Cir. 1985). A finding of dangerousness must be supported by clear and convincing evidence. See, e.g., United States v. Ferranti, 66 F.3d 540, 542 (2d Cir. 1995); Patriarca, 948 F.2d at 792; Chimurenga, 760 F.2d at 405. + +The Bail Reform Act lists four factors to be considered in the detention analysis: (1) the nature and circumstances of the crimes charged; (2) the weight of the evidence against the person; (3) the history and characteristics of the defendant, including the person's "character . . . [and] financial resources"; and (4) the seriousness of the danger posed by the defendant's release. See + +18 U.S.C. § 3142(g). Evidentiary rules do not apply at detention hearings, and the Government is entitled to present evidence by way of proffer, among other means. See 18 U.S.C. § 3142(0(2); see also United States v. LaFontaine, 210 F.3d 125, 130-31 (2d Cir. 2000) (Government entitled to proceed by proffer in detention hearings). + +Where a judicial officer concludes after a hearing that "no condition or combination of conditions will reasonably assure the appearance of the person as required and the safety of any other person and the community, such judicial officer shall order the detention of the person before trial." 18 U.S.C. § 3142(e)(1). Additionally, where, as here, a defendant is charged with committing an offense involving a minor victim under 18 U.S.C. §§ 2422 or 2423, it shall be presumed, subject to rebuttal, that no condition or combination of conditions will reasonably assure the appearance of the defendant as required and the safety of the community. 18 U.S.C. § 3142(e)(3)(E). + +## II. Discussion + +For the reasons set forth below, the defendant presents an extreme risk of flight, and therefore she cannot overcome the statutory presumption in favor of detention in this case. Every one of the relevant factors to be considered as to flight risk — the nature and circumstances of the offense, the strength of the evidence, and the history and characteristics of the defendant — counsel strongly in favor of detention. + +# A. The Nature and Circumstances of the Offense and the Strength of the Evidence + +The "nature and circumstances" of this offense favor detention. As the Indictment alleges, the defendant committed serious crimes involving the sexual exploitation of minors. See 18 U.S.C. § 3142(gX1) (specifically enumerating "whether the offense. . . involves a minor victim" as a factor in bail applications). Indeed, the crimes of enticing and transporting minors for illegal sex acts are so serious that both crimes carry a statutory presumption that no condition or combination of conditions will reasonably assure the appearance of the defendant as required. 18 U.S.C. § 3142 (e)(3)(E). The defendant repeatedly engaged in this conduct, targeting girls as young as 14 years old, for a period of years, and involving multiple minors. + +These offenses carry significant penalties, and the defendant faces up to 35 years' imprisonment if convicted. The possibility of a substantial sentence is a significant factor in assessing the risk of flight. See United States v. Moscaritolo, No. 10 Cr. 4 (JL), 2010 WL 309679, at \*2 (D.N.H. Jan. 26, 2010) ("[T]he steeper the potential sentence, the more probable the flight risk is, especially considering the strong case of the government . . . .") (quoting United States v. Alindato—Perez, 627 F. Supp. 2d 58, 66 (D.P.R. 2009)). Here, the defendant is facing a statutory maximum of decades in prison. This fact alone would provide a compelling incentive for anyone to flee from prosecution, but the incentive to flee is especially strong for this defendant, who, at age 58, faces the very real prospect of spending a substantial portion of the rest of her life in prison. + +The strength of the evidence in this case underscores the risk that the defendant will become a fugitive. As the facts set forth in the Indictment make plain, the evidence in this case is strong. Multiple victims have provided detailed, credible, and corroborated information against the defendant. The victims are backed up contemporaneous documents, records, witness testimony, and other evidence. For example, flight records, diary entries, business records, and other evidence corroborate the victims' account of events. This will be compelling evidence of guilt at any trial in this case, which weighs heavily in favor of detention. + +The passage of time between the defendant's conduct and these charges does not counsel otherwise. As an initial matter, all of the conduct is timely charged, pursuant to 18 U.S.C. § 3283, which was amended in 2003 to extend the limitations period for conduct that was timely as of the + +date of the amendment,' to permit a prosecution at any point during the lifetime of the minor victim. See United States v. Chief, 438 F.3d 920, 922-25 (9th Cir. 2006) (finding that because Congress extended the statute of limitations for sex offenses involving minors during the time the previous statute was still running, the extension was permissible); United States v. Pierre-Louis, No. 16 Cr. 541 (CM), 2018 WL 4043140, at \*1 (S.D.N.Y. Aug. 9, 2018) (same). Moreover, while the conduct alleged in the Indictment may have occurred years ago, the risk of a significant term of incarceration — and thus the motive to flee — is of course only very recent. + +Each of these factors — the seriousness of the allegations, the strength of the evidence, and the possibility of lengthy incarceration — creates an extraordinary incentive to flee. And as further described below, the defendant has the means and money to do so. + +## B. The Characteristics of the Defendant + +The history and characteristics of the defendant also strongly support detention. As an initial matter, the defendant's extensive international ties would make it exceptionally easy for her to flee and live abroad. The defendant was born in France and raised in the United Kingdom, where she attended school. Although she became a naturalized citizen of the United States in 2002, she also remains a citizen of the United Kingdom and France. Travel records from United States Customs and Border Protection ("CBP") reflect that she has engaged in frequent international travel, including at least fifteen international flights in the last three years to locations including the United Kingdom, Japan, and Qatar. In addition, CBP records reflect that, consistent with her citizenship status, the defendant appears to possess passports from the United States, France, and the United Kingdom. + +&#x27; Prior to the amendment, the statute of limitations for sexual offenses involving minors ran until the victim reached the age of 25, and as such, all of the relevant charges in the Indictment remained timely as of the 2003 amendment described above. + +In addition, the defendant appears to have access to significant financial resources that would enable her flight from prosecution. Based on the Government's investigation to date, the Government has identified more than 15 different bank accounts held by or associated with the defendant from 2016 to the present, and during that same period, the total balances of those accounts have ranged from a total of hundreds of thousands of dollars to more than \$20 million. During the same period, the defendant engaged in transfers between her accounts of hundreds of thousands of dollars at a time, including at least several such significant transfers as recently as 2019. For example, the defendant transferred \$500,000 from one of her accounts to another in March 2019, and transferred more than \$300,000 from one of her accounts to another in July 2019. She has also reported, including as recently as 2019, that she holds one or more foreign bank accounts containing more than a million dollars. + +The defendant also appears to have reaped substantial income from a 2016 property sale. In particular, in 2016, the defendant appears to have sold a New York City residence for \$15 million through a limited liability company. On or about the date of the sale, amounts totaling more than \$14 million were then deposited into an account for which the defendant was listed as the owner. Several days later, more than \$14 million was transferred from that account into another account opened in the name of the defendant.2 In short, the defendant's financial resources appear to be substantial, and her numerous accounts and substantial money movements render her total financial picture opaque and indeterminate, even upon a review of bank records available to the Government. + +2 The Government additionally notes that, somewhat further back in time, in transactions occurring between 2007 and 2011, approximately more than \$20 million was transferred from accounts associated with Jeffrey Epstein to accounts associated with the defendant, including amounts in the millions of dollars that were then subsequently transferred back to accounts associated with Epstein. + +The defendant's international connections and significant financial means would present a clear risk of flight under normal circumstances, but in this case, the risk of flight is exacerbated by the transient nature of defendant's current lifestyle. In particular, the defendant has effectively been in hiding for approximately a year, since an indictment against Epstein was unsealed in July 2019. Thereafter, the defendant — who had previously made many public appearances - stopped appearing in public entirely, instead hiding out in locations in New England. Moreover, it appears that she made intentional efforts to avoid detection, including moving locations at least twice, switching her primary phone number (which she registered under the name "G Max") and email address, and ordering packages for delivery with a different person listed on the shipping label. Most recently, the defendant appears to have been hiding on a 156-acre property acquired in an all-cash purchase in December 2019 (through a carefully anonymized LLC) in Bradford, New Hampshire, an area to which she has no other known connections. + +The defendant appears to have no ties that would motivate her to remain in the United States. She has no children, does not reside with any immediate family members, and does not appear to have any employment that would require her to remain in the United States. Nor does she appear to have any permanent ties to any particular location in the United States. As such, the Government respectfully submits that the defendant will not be able to meet her burden of overcoming the presumption of detention, because there are no bail conditions that could reasonably assure the defendant's continued appearance in this case. + +In particular, home confinement with electronic monitoring would be inadequate to mitigate the high risk that the defendant would flee, as she could easily remove a monitoring device. At best, home confinement with electronic monitoring would merely reduce her head start should she decide to flee. See United States v. Zarger, No. 00 Cr. 773, 2000 WL 1134364, at \*1 + +(E.D.N.Y. Aug. 4, 2000) (Gleeson, J.) (rejecting defendant's application for bail in part because home detention with electronic monitoring "at best . . . limits a fleeing defendant's head start"); United States v. Benatar, No. 02 Cr. 099, 2002 WL 31410262, at \*3 (E.D.N.Y. Oct. 10, 2002) (same); see also United States v. Casteneda, No. 18 Cr. 047, 2018 WL 888744, at \*9 (N.D. Cal. Feb. 2018) (same); United States v. Anderson, 384 F. Supp. 2d 32, 41 (D.D.C. 2005) (same). + +### CONCLUSION + +As set forth above, the defendant is an extreme risk of flight. The Government respectfully submits that the defendant cannot meet her burden of overcoming the statutory presumption in favor of detention. There are no conditions of bail that would assure the defendant's presence in court proceedings in this case. Accordingly, any application for bail should be denied. + +Dated: New York, New York July 2, 2020 + +Respectfully submitted, + +Assistant United States Attorneys \ No newline at end of file diff --git a/marker2/ds9/EFTA00089364/EFTA00089364.metadata.json b/marker2/ds9/EFTA00089364/EFTA00089364.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..d3833ba34f5697d427f4b70b4a789bb475f98784 --- /dev/null +++ b/marker2/ds9/EFTA00089364/EFTA00089364.metadata.json @@ -0,0 +1,654 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089364.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 10, + "chars": 17226, + "elapsed_seconds": 1.7, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 71.28 + ], + [ + 281.8329772949219, + 71.28 + ], + [ + 281.8329772949219, + 99.603515625 + ], + [ + 68.544, + 99.603515625 + ] + ] + }, + { + "title": "THE GOVERNMENT'S MEMORANDUM \nIN SUPPORT OF DETENTION", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 190.332, + 332.90999999999997 + ], + [ + 421.48797607421875, + 332.90999999999997 + ], + [ + 421.48797607421875, + 362.1035461425781 + ], + [ + 190.332, + 362.1035461425781 + ] + ] + }, + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 68.544, + 72.08999999999999 + ], + [ + 281.8329772949219, + 72.08999999999999 + ], + [ + 281.8329772949219, + 99.603515625 + ], + [ + 68.544, + 99.603515625 + ] + ] + }, + { + "title": "THE GOVERNMENT'S MEMORANDUM \nIN SUPPORT OF DETENTION", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 190.332, + 264.06000000000006 + ], + [ + 421.48797607421875, + 264.06000000000006 + ], + [ + 421.48797607421875, + 293.10357666015625 + ], + [ + 190.332, + 293.10357666015625 + ] + ] + }, + { + "title": "BACKGROUND", + "heading_level": null, + "page_id": 2, + "polygon": [ + [ + 260.712, + 71.28 + ], + [ + 351.4015808105469, + 71.28 + ], + [ + 351.4015808105469, + 86.103515625 + ], + [ + 260.712, + 86.103515625 + ] + ] + }, + { + "title": "ARGUMENT", + "heading_level": null, + "page_id": 3, + "polygon": [ + [ + 268.668, + 319.14000000000004 + ], + [ + 342.9721374511719, + 319.14000000000004 + ], + [ + 342.9721374511719, + 334.3535461425781 + ], + [ + 268.668, + 334.3535461425781 + ] + ] + }, + { + "title": "I. 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b/marker2/ds9/EFTA00089374/EFTA00089374.md @@ -0,0 +1,39 @@ +From: Aaron Mysliwiec + +To:' + +Cc: "Erica + +Subject: Checking in + +Date: Thu, 02 Jul 2020 17:07:13 +0000 + +Greetings, + +In light of events that were reported in the news today, we wanted to reconfirm our continued interest in and efforts to work with your office. Please let us know if you have any questions or would like to speak at some point. + +Thanks, Aaron and Erica + +Sent from my iPhone + +On May 15, 2020, at 12:23 PM, > wrote: + +Understood, and that's helpful, thanks. Please don't hesitate to follow up with us later this month or early next, and we'll see what we can learn on our end. + +From: Aaron Mysliwiec + +Sent: Friday, May 15, 2020 08:30 + +To: + +Cc: Erica T. Dubno, Esq. + +Subject: a + +![](_page_0_Picture_18.jpeg) + +![](_page_1_Picture_0.jpeg) + +Please let us know if you have additional questions. + +Thanks, Aaron \ No newline at end of file diff --git a/marker2/ds9/EFTA00089374/EFTA00089374.metadata.json b/marker2/ds9/EFTA00089374/EFTA00089374.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..5065fa5a246558adc17745c22f1c6e4016e40604 --- /dev/null +++ b/marker2/ds9/EFTA00089374/EFTA00089374.metadata.json @@ -0,0 +1,95 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089374.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 814, + "elapsed_seconds": 0.94, + "image_assets": [ + "_page_0_Picture_18.jpeg", + "_page_1_Picture_0.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 41 + ], + [ + "Line", + 21 + ], + [ + "Text", + 18 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 7 + ], + [ + "Line", + 4 + ], + [ + "Text", + 2 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089374" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089374/_page_0_Picture_18.jpeg b/marker2/ds9/EFTA00089374/_page_0_Picture_18.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..0958ccf049620c898a27bd3ea9d55206b62f515e --- /dev/null +++ b/marker2/ds9/EFTA00089374/_page_0_Picture_18.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:d7a1760bed59a8b50939dfd8449d1c3c0d046ad89da32a35e8ee613abacc6180 +size 17324 diff --git a/marker2/ds9/EFTA00089374/_page_1_Picture_0.jpeg b/marker2/ds9/EFTA00089374/_page_1_Picture_0.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..86fe55e9af3214dbc021e61da85537f9fa5b6edf --- /dev/null +++ b/marker2/ds9/EFTA00089374/_page_1_Picture_0.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:2bb31183875d023328948dc3a47b3788e22010134b3bb903222c7b6453e42860 +size 15209 diff --git a/marker2/ds9/EFTA00089376/EFTA00089376.md b/marker2/ds9/EFTA00089376/EFTA00089376.md new file mode 100644 index 0000000000000000000000000000000000000000..e2f24553b6126e4841a94fafa3611d48a0748f3f --- /dev/null +++ b/marker2/ds9/EFTA00089376/EFTA00089376.md @@ -0,0 +1,51 @@ +To: + +Subject: Final Voucher has received final approval + +Date: Tue, 24 Mar 2020 15:11:13 +0000 + +Importance: Normal + +Dear + +Final voucher has received final approval. + +Trip ID: + +Voucher ID: 1 + +Voucher type: Final + +Traveler name: + +Minor Customer name: OBD-USA-USANYS-NEW YORK SOUTHERN (UNYS) (JO2104) + +Purpose: R20NYS 13402 - Epstein Investigation - Witness interview + +Destination: Beverly Hills, CA, United States + +Dates: 2020-02-26 - 2020-02-29 + +Current status: Voucher Awaiting Payment + +Voucher total expenses: 1059.52 + +Estimated trip cost: 1621.65 + +E2 Single Sign On Login (within DOJ Network Only): + +https://dojnet.doj.ggAmd/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# V0008 + +This e-mail and any attachments may contain confidential and/or proprietary information. 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Please let me know if you would like to discuss, or if you need anything else from our end to move this forward. + +Best, + +[REDACTED] + +[REDACTED] + +Assistant United States Attorney +Southern District of New York +1 St. Andrew's Plaza +New York, NY 10007 + +[REDACTED] + +[REDACTED] + +--- + +**From:** [REDACTED] + +**Sent:** Wednesday, March 4, 2020 1:21 PM + +**To:** [REDACTED] >; [REDACTED] + +[REDACTED] + +**Subject:** RE: MLAT/ Interview Request + +Here is the current model. + +Thx, + +[REDACTED] + +--- + +[REDACTED] +US Department of Justice Attaché +United States Embassy +33 Nine Elms Lane +London SW11 7US + +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] + +## SBU -LAW ENFORCEMENT + +From: + +Sent: Wednesday, March 4, 2020 5:41 PM + +To: + +Cc: + +Subject: RE: MLAT/ Interview Request + +Just tried your desk but got your voicemail. I'm on my cell if you have time to talk before you leave. + +Thanks, + +From: + +Sent: Wednesday, March 4, 2020 12:36 PM + +To: 1"; + +Cc: + +Subject: RE: MLAT/ Interview Request + +If you call before 6 pm GMT, you can get me at my desk. After that by cell, but between 6-7:30 I won't be in a place I can talk privately. + +From: + +Sent: Wednesday, March 4, 2020 5:04 PM + +To: + +Cc: + +Subject: RE: MLAT/ Interview Request + +## SI3U -LAW ENFORCEMENT + +Thanks very much. I'll give you a call in a couple minutes. + +Assistant United States Attorney + +Southern District of New York + +1 St. Andrew's Plaza + +New York. NY 10007 + +From: + +Sent: Wednesday, March 4, 2020 11:29 AM + +To: + +Cc: >; < + +l'S Department of Justice Attache United States Embassy 31 Nine Elms Lane London SW I t 7US Desk Mobile :alter hours) From CS Ext Email: + +## SBU -LAW ENFORCEMENT + +From: C + +Sent: Wednesday, March 4, 2020 3:57 PM + +To: + +Cc: 4: ); + +Subject: RE: MLAT/ Interview Request + +Thanks very much you? For now, I'd be grateful if we could speak this afternoon. Would a call around 1pm work for + +Hopefully I can schedule a call withMhen he is available as well. + +From: + +Sent: Wednesday, March 4, 202010:55 AM + +To: + +Cc: › + +Subject: Re: MLAT/ Interview Request + +Hi, . I'm available this afternoon, but you are probably better off with first, as you will work most closely with him on the ground in London. + +US Dal, Criminal Division Office of International Affairs + +On Mar 4, 2020, at 10:52 AM, wrote: + +Thank you very much, Apologies for the delayed reply—our team has been traveling for other witness interviews, but we are now back in the office. + +Assistant United States Attorney Southern District of New York I St. Andrew's Plaza New York, NY 10007 + +From: + +Sent: Wednesday, February 26, 2020 7:11 PM + +To: > + +Cc: + +Subject: MLAT/ Interview Request + +Importance: High + +Putting you on an email chain with OIA/London, and S OIA Director for UK/Europe. and are aware of the underlying matter, as well as its sensitivity, and look forward to working with you on the MLAT request. + +Best, \ No newline at end of file diff --git a/marker2/ds9/EFTA00089377/EFTA00089377.metadata.json b/marker2/ds9/EFTA00089377/EFTA00089377.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..8120d0b021374f1286bf9b560c474b4b2c478bd5 --- /dev/null +++ b/marker2/ds9/EFTA00089377/EFTA00089377.metadata.json @@ -0,0 +1,222 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089377.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 4, + "chars": 3200, + "elapsed_seconds": 5.71, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "SBU -LAW ENFORCEMENT", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 241.74, + 53.46 + ], + [ + 374.8144226074219, + 53.46 + ], + [ + 374.8144226074219, + 66.2052001953125 + ], + [ + 241.74, + 66.2052001953125 + ] + ] + }, + { + "title": "SI3U -LAW ENFORCEMENT", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 241.74, + 383.13 + ], + [ + 370.4493713378906, + 383.13 + ], + [ + 370.4493713378906, + 395.9676208496094 + ], + [ + 241.74, + 395.9676208496094 + ] + ] + }, + { + "title": "SBU -LAW ENFORCEMENT", + "heading_level": null, + "page_id": 2, + "polygon": [ + [ + 241.12800000000001, + 255.96000000000004 + ], + [ + 370.4548034667969, + 255.96000000000004 + ], + [ + 370.4548034667969, + 269.21759033203125 + ], + [ + 241.12800000000001, + 269.21759033203125 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 53 + ], + [ + "Text", + 50 + ], + [ + "Line", + 25 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 69 + ], + [ + "Line", + 34 + ], + [ + "Text", + 32 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 74 + ], + [ + "Line", + 35 + ], + [ + "Text", + 21 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 3, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 35 + ], + [ + "Line", + 17 + ], + [ + "Text", + 14 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089377" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089381/EFTA00089381.md b/marker2/ds9/EFTA00089381/EFTA00089381.md new file mode 100644 index 0000000000000000000000000000000000000000..8593551ef06ff3c5aab17a281fb9c2cf8e0a5482 --- /dev/null +++ b/marker2/ds9/EFTA00089381/EFTA00089381.md @@ -0,0 +1,41 @@ +![](_page_0_Picture_2.jpeg) + +## FEDERAL BUREAU OF INVESTIGATION + +Macacmry 07/02/2020 + +Martin Anthony Jackson, date of birth (DOB) , of II cell phone , email address was interviewed at . After being advised of the identity of the interviewing Agent and the nature of the interview, Jackson provided the following information: + +Jackson, a former member of the British Army (retired /C , had been contacted by Matthew Hellyer whom Jackson served in the British Army with about a body guard type position guarding Ghislaine Maxwell recently. Hellyer had been retained by Maxwell's brother (Kevin) to arrange for former British Army members (from his former unit) to provide a security service for Maxwell at her residence in Bradford, NH. Jackson would contact Matthew Hellyer, who is residing in Poole, United Kingdom, at telephone related to the Maxwell assignment. Jackson is being paid \$350.00/day by Hellyer, who makes the deposits directly into Jackson's Lloyd's of London account ). Jackson's contract, like the others before him, was on an open ended monthly basis. + +Jackson arrived at Maxwell's house in Bradford, from his South Carolina home, on or about 05/08/2020. Prior to Jackson's arrival, Marcus Wakefield (former British Army), telephone +447792352073, was providing the security for Maxwell under the same arrangements as Jackson. Jackson, Wakefield, and Hellyer ware all friends from their time together in the British Army, but only Hellyer is in contact with Kevin Maxwell for Bradford (NH) security detail. Before Wakefield providing security to Maxwell another person by the name of Steve (NFI) provided the security. Jackson was under the impression, from his conversations with Maxwell, that she had + +UNCLASSIFIED//F0U0 + +Investigation on 07/02/2020 4 , United States (In Person) + +This document contains neither recommendations nor conclusions of the FBI. It is the moµ" ty of the FBI and is loaned to your agency; it and its contents arc no; to be distributed outside your agency. + +5OD-NY-3O27571 + +(O//FOUO) Interview of Martin Anthony + +Continuation of FD-302 of Jackson p, 07/02/2020 i ns, 2 of 3 + +been at her current location since before Christmas 2O19 without interruption. + +Jackson advised that Maxwell does not leave the property, that he uses a 2O19 Ford F-15O (black), bearing Massachusetts registration 1FDF19, to go into town to run errands. Maxwell provided Jackson with a business debit card from Citizen's Bank in the name of to pay for any items needed. Jackson has observed Scott Borgerson, to whom the above Ford F-15O is registered to, on several occasion at the Maxwell house. Jackson noted that the gate on the driveway has a combination lock and several times Jackson has had to go down to the gate and unlock the gate for Borgerson when he would forget the combination. Maxwell has chosen her current location to hide from the press and Jackson was fully aware of Maxwell's background and the allegations against her when taking this assignment. + +Jackson provided not only the Citizen's account mentioned above, provided to him by Maxwell, but his own accounts which are: + +- 1) + +Jackson advised that to the best of his knowledge there were no weapons on the Maxwell property, although Jackson did provide the interviewing + +50D-NY-3027571 + +(U//FOUO) Interview of Martin Anthony + +Continuation of FD-302 of Jackson ion 07/02/2020 i ns. 3 of 3 + +Agent(s) with a Concealed Weapons Permit ) from South Carolina. \ No newline at end of file diff --git a/marker2/ds9/EFTA00089381/EFTA00089381.metadata.json b/marker2/ds9/EFTA00089381/EFTA00089381.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..190f61b775daa1e881289288d278464692452af8 --- /dev/null +++ b/marker2/ds9/EFTA00089381/EFTA00089381.metadata.json @@ -0,0 +1,168 @@ +{ + 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X-PERSONAL + +Comment: + +Date Created: 2020-07-02 22:52:07 +0000 + +Date Modified: 2020-07-02 22:52:07 +0000 + +Priority: 5 + +DTSTAMP: 2020-07-02 17:16:56 +0000 + +Attendee: Kathleen DuPont > \ No newline at end of file diff --git a/marker2/ds9/EFTA00089384/EFTA00089384.metadata.json b/marker2/ds9/EFTA00089384/EFTA00089384.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..153086a05603af07069e52a204287ab7f99bd11d --- /dev/null +++ b/marker2/ds9/EFTA00089384/EFTA00089384.metadata.json @@ -0,0 +1,82 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089384.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 264, + "elapsed_seconds": 0.49, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Event: Accepted: GHISLAINE MAXWELL Removal Hearing 2Omj132-01", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 32.436, + 35.64 + ], + [ + 519.9335327148438, + 35.64 + ], + [ + 519.9335327148438, + 55.08000000000001 + ], + [ + 32.436, + 55.08000000000001 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 21 + ], + [ + "Line", + 11 + ], + [ + "Text", + 9 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089384" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089385/EFTA00089385.md b/marker2/ds9/EFTA00089385/EFTA00089385.md new file mode 100644 index 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diff --git a/marker2/ds9/EFTA00089386/EFTA00089386.md b/marker2/ds9/EFTA00089386/EFTA00089386.md new file mode 100644 index 0000000000000000000000000000000000000000..8059cf6895f584ce5babf50580ca188857f33a92 --- /dev/null +++ b/marker2/ds9/EFTA00089386/EFTA00089386.md @@ -0,0 +1,67 @@ +![](_page_0_Picture_112.jpeg) + +# UNITED STATES ATTORNEY'S OFFICE + +## *Southern District of New York* + +ACTING U.S. ATTORNEY AUDREY STRAUSS + +FOR IMMEDIATE RELEASE +Thursday, July 2, 2020 + + +CONTACT: U.S. ATTORNEY'S OFFICE + +![](_page_0_Picture_117.jpeg) + +NYPD + +![](_page_0_Picture_119.jpeg) + +FBI + +![](_page_0_Picture_121.jpeg) + +### **GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS** + +*Maxwell is Alleged to Have Facilitated, Participated in Acts of Abuse* + +*Additionally Charged With Perjury in Connection With 2016 Depositions* + +Audrey Strauss, the Acting United States Attorney for the Southern District of New York, William F. Sweeney Jr., the Assistant Director-in-Charge of the New York Field Office of the Federal Bureau of Investigation ("FBI"), and Dermot Shea, Commissioner of the New York City Police Department ("NYPD"), announced that GHISLAINE MAXWELL was arrested this morning and charged with enticing a minor to travel to engage in criminal sexual activity, transporting a minor with the intent to engage in criminal sexual activity, conspiracy to commit both of those offenses, and perjury in connection with a sworn deposition. The Indictment unsealed today alleges that between at least in or about 1994 through 1997, MAXWELL and co-conspirator Jeffrey Epstein exploited girls as young as 14, including by enticing them to travel and transporting them for the purpose of engaging in illegal sex acts. As alleged, knowing that Epstein had a preference for young girls, MAXWELL played a critical role in the grooming and abuse of minor victims that took place in locations including New York, Florida, and New Mexico. In addition, as alleged, MAXWELL made several false statements in sworn depositions in 2016. MAXWELL is expected to be presented this afternoon in the in federal court in New Hampshire. This case is assigned to U.S. District Judge Alison J. Nathan. + +Acting U.S. Attorney Audrey Strauss said: "As alleged, Ghislaine Maxwell facilitated, aided, and participated in acts of sexual abuse of minors. Maxwell enticed minor girls, got them to trust her, and then delivered them into the trap that she and Jeffrey Epstein had set. She pretended to be a woman they could trust. All the while, she was setting them up to be abused + +sexually by Epstein and, in some cases, Maxwell herself. Today, after many years, Ghislaine Maxwell finally stands charged for her role in these crimes." + +FBI Assistant Director William F. Sweeney Jr. said: "Preserving the innocence of children is among the most important responsibilities we carry as adults. Like Epstein, Ms. Maxwell chose to blatantly disregard the law and her responsibility as an adult, using whatever means she had at her disposal to lure vulnerable youth into behavior they should never have been exposed to, creating the potential for lasting harm. We know the quest for justice has been met with great disappointment for the victims, and that reliving these events is traumatic. The example set by the women involved has been a powerful one. They persevered against the rich and connected, and they did so without a badge, a gun, or a subpoena - and they stood together. I have no doubt the bravery exhibited by the women involved here has empowered others to speak up about the crimes of which they've been subjected." + +NYPD Commissioner Dermot Shea said: "The heinous crimes these charges allege are, and always will be abhorrent for the lasting trauma they inflict on victims. I commend our investigators, and law enforcement partners, for their continuing commitment to bringing justice to the survivors of sexual assault, everywhere." + +If you believe you are a victim of the sexual abuse perpetrated by Jeffrey Epstein, please contact the FBI at 1-800-CALL FBI, and reference this case. + +According to the Indictment' unsealed today in Manhattan federal court: + +From at least 1994 through at least 1997, GHISLAINE MAXWELL assisted, facilitated, and participated in Jeffrey Epstein's abuse of minor girls by, among other things, helping Jeffrey Epstein to recruit, groom, and ultimately abuse victims known to MAXWELL and Epstein to be under the age of 18. The victims were as young as 14 years old when they were groomed and abused by MAXWELL and Epstein, both of whom knew that their victims were in fact minors. As a part and in furtherance of their scheme to abuse minor victims, MAXWELL and Epstein enticed and caused minor victims to travel to Epstein's residences in different states, which MAXWELL knew and intended would result in their grooming for and subjection to sexual abuse. + +As alleged, MAXWELL enticed and groomed minor girls to be abused in multiple ways. For example, MAXWELL attempted to befriend certain victims by asking them about their lives, taking them to the movies or taking them on shopping trips, and encouraging their interactions with Epstein. MAXWELL also acclimated victims to Epstein's conduct simply by being present for victim interactions with Epstein, which put victims at ease by providing the assurance and comfort of an adult woman who seemingly approved of Epstein's behavior. Additionally, to make victims feel indebted to Epstein, MAXWELL would encourage victims to accept offers of financial assistance from Epstein, including offers to pay for travel or educational expenses. + +As the introductory phrase signifies, the entirety of the text of the Indictment, and the description of the Indictment set forth herein, constitute only allegations, and every fact described therein should be treated as an allegation. The defendant is presumed innocent unless and until proven guilty. + +MAXWELL also normalized and facilitated sexual abuse by discussing sexual topics with victims, encouraging them to massage Epstein, and undressing in front of a victim. + +As MAXWELL and Epstein intended, these grooming behaviors left minor victims vulnerable and susceptible to sexual abuse by Epstein. MAXWELL was then present for certain sexual encounters between minor victims and Epstein, such as interactions where a minor victim was undressed, and ultimately MAXWELL was oresent for sex acts Deroetrated by Epstein on minor victims. + +MAXWELL and Epstein's victims were groomed or abused at Epstein's residences in New York, Florida, and New Mexico, as well as MAXWELL's residence in London, England. + +Additionally, in 2016, while testifying under oath in a civil proceeding, MAXWELL repeatedly made false statements, including about certain specific acts and events alleged in the Indictment. + +GHISLAINE MAXWELL, 58, is charged with one count of enticing a minor to travel to engage in illegal sex acts, which carries a maximum sentence of five years in prison, one count of conspiracy to entice a minor to travel to engage in illegal sex acts, which carries a maximum sentence of five years in prison, one count of transporting a minor with the intent to engage in criminal sexual activity, which carries a maximum sentence of 10 years in prison, one count of conspiracy to transport a minor with the intent to engage in criminal sexual activity, which carries a maximum sentence of five years in prison, and two counts of perjury, each of which carries a maximum sentence of five years in prison. + +The statutory maximum penalties are prescribed by Congress and are provided here for informational purposes only, as any sentencing of the defendant would be determined by the judge. + +Ms. Strauss praised the outstanding investigative work of the FBI and the NYPD. + +This case is bein handled b the Office's Public Corruption Unit. Assistant U.S. Attorneys and are in charge of the prosecution. + +The charges contained in the Indictment are merely accusations. 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/dev/null +++ b/marker2/ds9/EFTA00089386/_page_0_Picture_119.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:d8a99a53161131482a55db3621273b64dc1c71ed41f7c196434ff87cb226dc7c +size 1542 diff --git a/marker2/ds9/EFTA00089386/_page_0_Picture_121.jpeg b/marker2/ds9/EFTA00089386/_page_0_Picture_121.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..a9603ed95ce62ce40fdef68380c1baa261393611 --- /dev/null +++ b/marker2/ds9/EFTA00089386/_page_0_Picture_121.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:c880c3316f2f5d341d3c0e485434788c517aa4fd199afc9a4516ee24d0b845a9 +size 2469 diff --git a/marker2/ds9/EFTA00089389/EFTA00089389.md b/marker2/ds9/EFTA00089389/EFTA00089389.md new file mode 100644 index 0000000000000000000000000000000000000000..dc5ab00fb6d4842987eec93a3bbeadff5c4b85c0 --- /dev/null +++ b/marker2/ds9/EFTA00089389/EFTA00089389.md @@ -0,0 +1,69 @@ +To: + +Subject: FW: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS + +Date: Thu, 02 Jul 2020 17:25:22 +0000 + +Attachments: U.S.\_v.\_Ghislaine\_Maxwell\_Indictment.pdf; Ghislaine\_Maxwell\_Indictment\_PR.pdf + +Inline-Images: image001.png + +Congrats, team! + +From: + +Sent: Thursday, July 2, 20201:22 PM + +Subject: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS + +![](_page_0_Picture_10.jpeg) + +## UNITED STATES ATTORNEY'S OFFICE Southern District of New York + +## GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS + +Maxwell is Alleged to Have Facilita- ted, Participated in Acts of Abuse + +Additionally Charged With Perjury in Connection With 2016 Depositions + +Audrey Strauss, the Acting United States Attorney- for the Southern District of New York, William F. Sweeney Jr., the Assistant Director-in-Charge of the New York Field Office of the Federal Bureau of Investigation ("FBI"), and Dermot Shea, Commissioner of the New York City Police Department ("NYPD"), announced that GHISLANE MAXWELL was arrested this morning and charged with enticing a minor to travel to engage in criminal sexual activity, transporting a minor with the intent to engage in criminal sexual activity, conspiracy to commit both of those offenses, and perjury in connection with a sworn deposition. The Indictment unsealed today alleges that between at least in or about 1994 through 1997, MAXWELL and co-conspirator Jeffrey Epstein exploited girls as young as 14, including by enticing them to travel and transporting them for the purpose of engaging in illegal sex acts. As alleged, knowing that Epstein had a preference for young girls, MAXWELL played a critical role in the grooming and abuse of minor victims that took place in locations including New York, Florida, and New Mexico. In addition, as alleged, MAXWELL made several false statements in sworn depositions in 2016. MAXWELL is expected to be presented this afternoon in the in federal court in New Hampshire. This case is assigned to U.S. District Judge Alison J. Nathan. + +Acting U.S. Attorney Audrey Strauss said: "As alleged, Ghislaine Maxwell facilitated, aided, and participated in acts of sexual abuse of minors. Maxwell enticed minor girls, got them to trust her, and then delivered them into the trap that she and Jeffrey Epstein had set. She pretended to be a woman they could trust. All the while, she was setting them up to be abused sexually by Epstein and, in some cases, Maxwell herself. Today, after many years, Ghislaine Maxwell finally stands charged for her role in these crimes." + +FBI Assistant Director William F. Sweeney Jr. said: "Preserving the innocence of children is among the most important responsibilities we carry as adults. Like Epstein, Ms. Maxwell chose to blatantly disregard the law and her responsibility as an adult, using whatever means she had at her disposal to lure vulnerable youth into behavior they should never have been exposed to, creating the potential for lasting harm. We know the quest for justice has been met with great disappointment for the victims, and that reliving these events is traumatic. The example set by the women involved has been a powerful one. They persevered against the rich and connected, and they did so without a badge, a gun, or a subpoena - and they stood together. I have no doubt the bravery exhibited by the women involved here has empowered others to speak up about the crimes of which they've been subjected." + +NYPD Commissioner Dermot Shea said: "The heinous crimes these charges allege are, and always will be abhorrent for the lasting trauma they inflict on victims. I commend our investigators, and law enforcement partners, for their continuing commitment to bringing justice to the survivors of sexual assault, everywhere." + +If you believe you are a victim of the sexual abuse perpetrated by Jeffrey Epstein, please contact the FBI at 1-800-CALL FBI, and reference this case. + +According to the Indictment[ 11 unsealed today in Manhattan federal court: + +From at least 1994 through at least 1997, GHISLAINE MAXWELL assisted, facilitated, and participated in Jeffrey Epstein's abuse of minor girls by, among other things, helping Jeffrey Epstein to recruit, groom, and ultimately abuse victims known to MAXWELL and Epstein to be under the age of 18. The victims were as young as 14 years old when they were groomed and abused by MAXWELL and Epstein, both of whom knew that their victims were in fact minors. As a part and in furtherance of their scheme to abuse minor victims, MAXWELL and Epstein enticed and caused minor victims to travel to Epstein's residences in different states, which MAXWELL knew and intended would result in their grooming for and subjection to sexual abuse. + +As alleged, MAXWELL enticed and groomed minor girls to be abused in multiple ways. For example, MAXWELL attempted to befriend certain victims by asking them about their lives, taking them to the movies or taking them on shopping trips, and encouraging their interactions with Epstein. MAXWELL also acclimated victims to Epstein's conduct simply by being present for victim interactions with Epstein, which put victims at ease by providing the assurance and comfort of an adult woman who seemingly approved of Epstein's behavior. Additionally, to make victims feel indebted to Epstein, MAXWELL would encourage victims to accept offers of financial assistance from Epstein, including offers to pay for travel or educational expenses. MAXWELL also normalized and facilitated sexual abuse by discussing sexual topics with victims, encouraging them to massage Epstein, and undressing in front of a victim. + +As MAXWELL and Epstein intended, these grooming behaviors left minor victims vulnerable and susceptible to sexual abuse by Epstein. MAXWELL was then present for certain sexual encounters between minor victims and Epstein, such as interactions where a minor victim was undressed, and ultimately MAXWELL was present for sex acts perpetrated by Epstein on minor victims. That abuse included sexualized massages during which a minor victim was fully or partially nude, as well as group sexualized massages of Epstein involving a minor victim where MAXWELL was present. + +As alleged, minor victims were subjected to sexual abuse that included, among other things, the touching of a victim's breasts or genitals, placing a sex toy such a vibrator on a victim's genitals, directing a victim to touch Epstein while he masturbated, and directing a victim to touch Epstein's genitals. MAXWELL and + +Epstein's victims were groomed or abused at Epstein's residences in New York, Florida, and New Mexico, as well as MAXWELL's residence in London, England. + +Additionally, in 2016, while testifying under oath in a civil proceeding, MAXWELL repeatedly made false statements, including about certain specific acts and events alleged in the Indictment. + +GHISLAINE MAXWELL, 58, is charged with one count of enticing a minor to travel to engage in illegal sex acts, which carries a maximum sentence of five years in prison, one count of conspiracy to entice a minor to travel to engage in illegal sex acts, which carries a maximum sentence of five years in prison, one count of transporting a minor with the intent to engage in criminal sexual activity, which carries a maximum sentence of 10 years in prison, one count of conspiracy to transport a minor with the intent to engage in criminal sexual activity, which carries a maximum sentence of five years in prison, and two counts of perjury, each of which carries a maximum sentence of five years in prison. + +The statutory maximum penalties are prescribed by Congress and are provided here for informational purposes only, as any sentencing of the defendant would be determined by the judge. + +Ms. Strauss praised the outstanding investigative work of the FBI and the NYPD. + +This case is being handled by the Office's Public Corruption Unit. Assistant U.S. Attorneys and are in charge of the prosecution. + +The charges contained in the Indictment are merely accusations. The defendant is presumed innocent unless and until proven guilty. + +20-138 + +DO NOT REPLY TO THIS MESSAGE. IF YOU HAVE QUESTIONS, PLEASE CALL THE PRESS OFFICE AT + +Follow us on Facebook 'Follow us on Twitter ISDNY website IYouTube + +[1] As the introductory phrase signifies, the entirety of the text of the Indictment, and the description of the Indictment set forth herein, constitute only allegations, and every fact described therein should be treated as an allegation. 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    + +Subject: FW: SDNY Premises Search Warrant Bundle (second revised) copy + +Date: Thu, 02 Jul 2020 20:16:40 +0000 + +Attachments: SDNY Premises\_Search\_Warrant\_Bundleisecond\_revisedLcopy.pdf; ATT00001.txt + +Here's the other + +c=IMINI M> From: + +Ori coal Messa e + +Sent: Ihursday. Jul 2, 2020 8:12 AM + +To: (USANH) (USANH) + +Subject: FW: SDNY Premises Search Warrant Bundle (second revised) copy + +Case Number is 20-mj-131-0 I -AJ + +Ori inal Messa e + +From: + +Sent: Thursday. July 2. 2020 8:08 AM + +To: + +Subject: SDNY Premises Search Warrant Bundle (second revised) copy + +Signed documents attached \ No newline at end of file diff --git a/marker2/ds9/EFTA00089392/EFTA00089392.metadata.json b/marker2/ds9/EFTA00089392/EFTA00089392.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..181dac9230b8b6897639918c8b47df827f1fcaaa --- /dev/null +++ b/marker2/ds9/EFTA00089392/EFTA00089392.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089392.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 593, + "elapsed_seconds": 0.79, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 45 + ], + [ + "Line", + 22 + ], + [ + "Text", + 18 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089392" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089393/EFTA00089393.md b/marker2/ds9/EFTA00089393/EFTA00089393.md new file mode 100644 index 0000000000000000000000000000000000000000..ac9d03412c7a05598c724ee87e228ba439cd8c5b --- /dev/null +++ b/marker2/ds9/EFTA00089393/EFTA00089393.md @@ -0,0 +1,307 @@ +![](_page_0_Picture_1.jpeg) + +United States Attorney Southern District of New York + +The Silvio J. Mollo Building One Saint Andrew's Plaza New York. New York 10007 + +July 12, 2019 + +## VIA ECF + +The Honorable Richard M. Berman United States District Court Southern District of New York United States Courthouse 500 Pearl Street New York, New York 10007 + +Re: United States v. Jeffrey Epstein, 19 Cr. 490 (RMB) + +Dear Judge Berman: + +The Government respectfully submits this letter in response to the defendant's Motion for Pretrial Release (the "Release Motion"), dated July 11, 2019 (Dkt. 6), and in further support of its Memorandum in Support of Detention (the "Detention Memo"), submitted to Magistrate Judge Pitman on July 8, 2019, which is attached hereto and incorporated herein (Ex. A). + +## PRELIMINARY STATEMENT + +The defendant is a serial sexual predator who is charged with abusing underage girls for years. A grand jury has returned an indictment alleging that he sexually exploited dozens of minors, including girls as young as 14 years old, in New York and Florida. To this day, he is a registered sex offender designated by New York State in the highest category of risk to reoffend, despite unsuccessfully attempting to have that classification lowered. And any doubt that the defendant is unrepentant and unreformed was eliminated when law enforcement agents discovered hundreds or thousands of nude and seminude photographs of young females in his Manhattan mansion on the night of his arrest, more than a decade after he was first convicted of a sex crime involving a juvenile. + +The defendant also faces substantial evidence of his guilt, founded on the corroborated testimony of numerous victims, and this case presents the very real possibility that he will go to prison for the rest of his life. The defendant has at his disposal a vast fortune, the details of which remain largely concealed from the Court. He also has a history of obstruction and manipulation of witnesses, including, as detailed herein, as recently as within the past year, when media reports about his conduct reemerged. And he continues to show a shocking lack of understanding of the gravity of the harm he has perpetrated, including through the minimization of his conduct and casual disparagement of victims in his arguments. + +Against this backdrop of significant—and rapidly-expanding—evidence, serious charges, and the prospect of a lengthy prison sentence, the defendant proposes to be released on conditions that are woefully inadequate. The Release Motion misconstrues and misunderstands the relevant + +law, seeks to diminish and demean the harm caused to the many victims of the defendant's appalling sexual abuse, and utterly fails to meet its burden of rebutting the presumption that no condition or combination of conditions will reasonably assure the appearance of the defendant as required and the safety of the community. Rather than even attempting to address the grave risks of releasing a defendant with extraordinary financial resources and a history of abusing minors, the defendant instead proposes a bail package that amounts to little more than a barely-secured bond masquerading as a 14-point plan. The Court should reject the defendant's application and order him detained pending trial. + +Among other things, the proposed bail package contemplates the defendant pledging as the principal security a property that has already been identified by the Government as subject to forfeiture upon the defendant's conviction, and which therefore is of no value as collateral. His proposed global waiver of extradition is unenforceable, and even if enforceable would be little comfort to victims forced to wait additional years while the defendant is located and returned to this country. The promise to "deregister or otherwise ground" his private jet is meaningless given his wealth and ability to easily secure other means of travel. The two co-signers he proposes only further highlight his minimal community ties, including his lack of any family in or near the District. Electronic monitoring would merely give the defendant less of a head start in fleeing and does not guard against the risk of him endangering victims in the very home where he has continued to hoard nude images of young women and girls. And the private security force he proposes to guard his gilded cage, a proposal already rejected by this Court in similar circumstances, simply reinforces the obvious fact that the defendant should be housed where he can be secured at all times: a federal correctional center. + +The defendant faces a presumption of detention, Pretrial Services has recommended detention, and victims of the defendant seek his detention. Because there are no set of conditions short of incarceration that can reasonably assure the appearance of the defendant or reasonably protect the community from the dangers he poses if released, the Court should order him detained. + +# BACKGROUND + +As previously set forth, a federal grand jury in this District returned an indictment (the "Indictment") charging the defendant with violating Title 18, United States Code Section 1519, and conspiracy to commit the same. + +As charged by the grand jury, the facts giving rise to those counts involve a years-long scheme to sexually abuse underage girls. Specifically, the defendant enticed and recruited dozens of minor girls to engage in sex acts with him, for which he paid the victims hundreds of dollars in cash, in at least two different states. Victims were initially recruited to provide "massages" to the defendant, which would be performed nude or partially nude, would become increasingly sexual in nature, and would typically include one or more sex acts, including groping and direct or indirect contact with victims' genitals. To perpetuate this exploitation of underage girls, the defendant actively encouraged certain victims to recruit additional girls to be similarly sexually abused. He paid these victim-recruiters hundreds of dollars for each additional girl they brought to him, creating a network of underage victims for him to exploit in New York and Palm Beach. + +The defendant, through counsel, continues to evidence a complete lack of appreciation for the gravity of the offenses with which he is charged.' As an initial matter, there can be no plausible suggestion that the allegations against the defendant involve isolated or aberrational conduct; they involve repeated, regular acts of sexual abuse committed over a period of many years. And following the defendant's prior conviction, as described previously by the Government, the defendant continued to maintain at least hundreds and possibly thousands of nude photos of young subjects. The defendant's victims in this case, often particularly vulnerable girls, were as young as 14 years old when he abused them. The defendant knew he was abusing minors, including because victims told him directly they were underage. And he preyed on his victims habitually and repeatedly—day after day, month after month, year after year. + +The defense calls these disturbing alleged acts "simple prostitution!' Mag. Tr. 12:12; see also D. Tr. at 6:15-19 ("This is basically the Feds today . . . redoing the same conduct that was investigated 10 years ago and calling it, instead of prostitution, calling it sex trafficking"). That characterization is not only offensive but also utterly irrelevant given that federal law does not recognize the concept of a child prostitute—there are only trafficking victims—because a child cannot legally consent to being exploited. Defense counsel's repeated assertion that the Government's case is infirm because no threats or coercion are alleged—e.g., Mag. Tr. at 12 ("There was no coercion. There were no threats. There was no violence."), 17 ("there was no coercion. There was no intimidation. There is no deception."); Release Motion at 2 ("There are no allegations . . . that he forced, coerced, defrauded, or enslaved anybody . . . .")—is equally irrelevant because the offense with which the defendant has been charged requires no such proof. See, e.g., United States v. Afyare, 632 F. App'x 272, 278 (6th Cir. 2016) ("We hold that § 1591(a) criminalizes the sex trafficking of children (less than 18 years old) with or without any force, fraud, or coercion, and it also criminalizes the sex trafficking of adults (18 or older), but only if done by force, fraud, or coercion."). + +Far more important, the defense has already effectively conceded that the Government will be able to present evidence of the actual primary elements of the charged offense—i.e., that the defendant engaged in sex acts for money with girls he knew were underage. See Release Motion at 2. On this record, the Government agrees with Pretrial Services that the defendant should be detained pending trial. He poses a tremendous risk of flight and a danger to the community, and he cannot overcome the statutory presumption in favor of detention in this case. + +&#x27; Such arguments are unsurprising from a defendant who previously compared himself to a "person who steals a bagel" or a tragic mythical figure. See, e.g., Amber Southerland, Billionaire Jeffrey Epstein: I'm a sex offender, not a predator, N.Y. Post (2011) ("I'm not a sexual predator, I'm an "offender," the financier told The Post yesterday. 'It's the difference between a murderer and a person who steals a bagel.'"); Philip Weiss, The Fantasist, NY Magazine (2007) ("It's the Icarus story, someone who flies too close to the sun,' I said. 'Did Icarus like massages?' Epstein asked."). + +2 "Mag. Tr." refers to the transcript of the hearing before Magistrate Judge Pitman on July 8, 2019; "D. Tr." refers to the transcript of the hearing before this Court on July 8, 2019. + +#### ARGUMENT + +The Government respectfully submits that the defendant cannot overcome the statutory presumption in favor of detention in this case for the following reasons, among others: + +#### I. Victims Seek Detention + +Pursuant to the Crime Victims' Rights Act ("CVRA"), a crime victim has the right to be reasonably heard at certain public proceedings in the district court, including proceedings involving release. 18 U.S.C. § 3771(a)(4). Consistent with that requirement, the Government has been in contact with victims and counsel identified through this investigation in connection with the argument regarding bail. + +Multiple victims and/or their counsel have asked the Government to seek detention (and to inform the Court of their views in that respect) for multiple reasons. First, they believe that the defendant's continued detention is necessary under the CVRA's right to be reasonably protected from the accused. 18 U.S.C. § 3771(a)(1). They have specifically conveyed to the Government that they would be fearful for their safety if the defendant were released. For the reasons articulated herein, the Government believes those concerns to be well-founded. + +Additionally, certain victims have asked the Government to advise the Court that they are specifically concerned about the defendant's proposal to be released even if under conditions that included home detention and full-time private guards. They believe it would be unfair to victims of a wealthy defendant, like Epstein, if he were to be given greater freedoms than others would be in similar circumstances, and that such an arrangement would be inconsistent with their rights. They specifically asked the Government to advise the Court that they believed such an arrangement could result in harassment and abuse by the defendant. 3 + +#### II. The Defendant's Proposal Does Nothing to Mitigate His Flight Risk + +Each of the relevant factors to be considered as to flight risk—the nature and circumstances of the offense, the strength of the evidence, and the history and characteristics of the defendant counsel strongly in favor of detention, and the defendant's proposed package would do nothing whatsoever to mitigate those risks. + +#### A. Defendant Proposes No Infringement Upon His Ability to Use his Vast Wealth to Flee + +It might not be immediately apparent to a reader of the Release Motion that the defendant is extravagantly wealthy and worth, according to records relating to the defendant recently obtained by the Government from a financial institution ("Institution-1"), more than \$500 million. + +3 The Government is aware of at least one additional attorney for a victim who has publicly stated that her client supports the pretrial detention of the defendant. The Government is unaware of any victim who has expressed support for the defendant being granted pretrial release on bail. + +Indeed, while the defendant has still not filled out a financial affidavit, under penalty of perjury, in connection with his application for bail, his token effort to account for his finances makes painfully clear the need for detention. The defendant reports having an extraordinary amount of money in both total assets and cash or cash-equivalent holdings. And while the defendant repeatedly represents in his Release Motion that his assets are "in the United States," there is absolutely nothing in the defendant's minimal financial submission to verify that. + +Indeed, and as discussed further below, even assuming the defendant's assets are presently in the United States, nothing in the proposed package would prevent the defendant from transferring liquid assets out of the country quickly and in anticipation of flight or relocation. The defendant is an incredibly sophisticated financial actor with decades of experience in the industry and significant ties to financial institutions and actors around the world. He could easily transfer funds and holdings on a moment's to places where the Government would never find them so as to ensure he could live comfortably while a fugitive. + +But perhaps most important, even were the defendant to sacrifice literally all of his current assets, there is every indication that he would immediately be able to resume making millions or tens of millions of dollars per year outside of the United States. He already earns at least \$10,000,000 per year, according to records from Institution-1, while living in the U.S. Virgin Islands, traveling extensively abroad, and residing in part in Paris, France; there would be little to stop the defendant from fleeing, transferring his unknown assets abroad, and then continuing to do whatever it is he does to earn his vast wealth from a computer terminal beyond the reach of extradition.4 + +That the defendant faces up to 45 years of incarceration on the current counts with which he is charged provides the motive for him do so and is another significant factor in assessing the risk of flight. See United States v. Jackson, 823 F.2d 4, 7 (2d Cir. 1987). So too is the strength of the evidence, detailed above and in the Government's Detention Memo. Indeed, that evidence, already robust less than a week ago when the Indictment was unsealed, is growing stronger by the day. Just since the Indictment was unsealed, several additional women, in multiple jurisdictions, have identified themselves to the Government as having been victimized by the defendant when they were minors. Moreover, pursuant to judicially-authorized search warrants, the Government has discovered and seized a significant volume of photographs of nude and seminude young women and girls in the defendant's Manhattan residence, and is in the process of reviewing dozens of electronic discs that contain still more such photos? And dozens of individuals have called the Government in recent days to convey information regarding the defendant and the allegations + +4 As noted in the Government's Detention Memo, the defendant is a frequent traveler and regularly travels to and from the United States, including approximately more than 20 flights in which he traveled to or from a foreign country since 2018 alone. Extensive international travel of this nature further demonstrates a significant risk of flight. See, e.g., United States v. Anderson, 384 F. Supp. 2d 32, 36 (D.D.C. 2005). + +5 The Government's review of these materials, seized earlier this week, remains ongoing. + +contained in the Indictment. All this in less than a week, and all in addition to an Indictment that already alleges the existence of dozens of victims in New York and dozens of victims in Florida. + +## B. The Proposed Bond is Inadequate to Overcome the Presumption of Detention + +The defendant's "slate of highly restrictive" measures which purportedly "amply suffice to secure his release" are neither highly restrictive nor amply sufficient. Rather, they are effectively standard conditions of home confinement, monitoring, and bond unsecured by the defendant's assets—broken out into 14 pieces. The Government will address the most concerning and salient elements of the defendant's proposal below. + +# I. Lack of Meaningful Bond Security + +The defendant proposes that the Court accept his Manhattan mansion as the primary security for a personal recognizance bond of an indeterminate amount, to be co-signed by the defendant's brother and a friend. Release Motion at 4. This is plainly insufficient. + +As an initial matter, and as noted above, the defendant's Manhattan mansion has been identified in the Indictment as subject to forfeiture because it is alleged to have been used to commit or facilitate the commission of the sex trafficking offenses charged there. See 18 U.S.C. § 1594(c)(1). Because the defendant would thus be likely to lose that property following a conviction, it provides no value whatsoever as collateral. See 18 U.S.C. § 3142(g)(4) ("In considering the conditions of release described . . . the judicial officer . . . shall decline to accept the designation, or the use as collateral, of property that, because of its source, will not reasonably assure the appearance of the person as required."). And while the defendant offers to also pledge his private jet as additional collateral, there is absolutely no reason to assume that the defendant would not readily trade his private plane for his freedom. Indeed, the defendant, who has a net worth of more than \$500 million, by his own admission recently sold a second plane and thus presumably has cash on hand to replace the posted aircraft without difficulty if need be. + +Nor does the proposed security of properties owned by two identified co-signers meaningfully change the calculus. As further described below, the defendant provides no information about the value or equity of the property of his brother, Mark (the "Palm Beach Property"), or the significance of that property in the context of his brother's own net worth!' Similarly, the defendant provides no details regarding the "investment interests" of his friend Mr. Mitchell, nor any reason to believe the loss of those "interests" would be meaningful to Mr. Mitchell, let alone the defendant. More generally, given the defendant's proffered net worth, the defendant could easily make his co-signers whole — and even reward them — were he to flee. + +The proposed security, in sum, should give the Court little comfort the defendant would appear in Court if released on bail. + +6 In fact, the defendant's own submission makes clear that the Palm Beach Property is not his brother's exclusive residence and that his brother lives elsewhere for half of the year. + +## 2. Co-Signers, Moral Suasion, and Ties to the Community + +The dearth of detailed financial information about the defendant himself, much less his brother or friend, further shows the hollowness of the proposal. The Court cannot possibly evaluate whether there would be any incentive whatsoever for those the two proposed co-signers to exercise moral suasion over the defendant—or whether, as noted above, the defendant could easily compensate them, perhaps many times over, for any loss they incurred through the defendant's flight from justice. The defendant provides no information about his brother other than that he lives half the year in the home he purportedly would pledge, and even less information about Mr. Mitchell, other than that he is "Mr. Epstein's friend," his "close personal friend of decades," and his "close personal friend." Release Motion at 4, 9. Their willingness to "guarantee" his appearance, Release Motion at 9, is meaningless in the absence of such information. + +Moreover, the notion that any individual co-signer could meaningfully secure a bond for this defendant strains credulity. Given the defendant's wealth and his extraordinary risk of flight, any bond for this defendant would assuredly have to be in the hundreds of millions of dollars to even be claimed to be sufficient to guard against the risks posed by the defendant's release. The defendant offers no reason to believe any co-signers could meaningfully sign such a bond, much less these two particular individuals, which is yet another reason the proposed package is patently insufficient. + +## 3. The Defendant's "Consent" to Extradition is Unenforceable and Impractical + +The defendant's offer to sign a so-called "consent" to extradition provides no additional reassurance whatsoever. As an initial matter, the Government would need to find and re-arrest the defendant before such a waiver would even come into play. Moreover, even assuming the Government could locate and apprehend the defendant, numerous courts have recognized that such purported waivers are unenforceable and effectively meaningless because any defendant who signs such a purported waiver and then flees will assuredly contest the validity and/or voluntariness of the waiver, and will get to do so in the jurisdiction of his choosing (Le., the one to which he chose to flee). See, e.g., United States v. Morrison, No. 16-MR-118, 2016 WL 7421924, at \*4 (W.D.N.Y. Dec. 23, 2016); United States v. Kazeem,No. 15 Cr. 172, 2015 WL 4645357, at \*3 (D. Or. Aug. 3, 2015); United States v. Young, Nos. 12 Cr. 502, 12 Cr. 645, 2013 WL 12131300, at \*7 (D. Utah Aug. 27, 2013); United States v. Cohen, No. C 10-00547, 2010 WL 5387757, at \*9 n.11 (N.D. Cal. Dec. 20, 2010); United States v. Bohn, 330 F. Supp. 2d 960, 961 (W.D. Tenn. 2004); United States v. Stroh, No. 396 Cr. 139, 2000 WL 1832956, at \*5 (D. Conn. Nov. 3, 2000); United States v. Botero, 604 F. Supp. 1028, 1035 (S.D. Fla. 1985). . The Department of Justice's Office of International Affairs is unaware of any country anywhere in the world that would consider an anticipatory extradition waiver binding. And, of course, the defendant could choose to flee to a jurisdiction with which the United States does not have an extradition treaty. + +Beyond being impossible to guarantee, extradition is typically a lengthy, complicated and expensive process, and the possibility that it would be successful neither provides any real deterrent to the defendant's incentive to flee nor any measure of justice to the victims who would be required to wait years for his return. + +#### 4. Home Confinement and Electronic Monitoring Provide No Assurance + +The defendant's proposal of ankle-bracelet monitoring should be of no comfort to the Court. In particular, the defendant's endorsement of a GPS monitoring bracelet rather than a radio frequency bracelet is farcical because neither one is useful or effective after it has been removed. At best, home confinement and electronic monitoring would reduce his head start should he decide to cut the bracelet and flee. See United States v. Zarger, No. 00 Cr. 773, 2000 WL 1134364, at \*1 (E.D.N.Y. Aug. 4, 2000) (rejecting defendant's application for bail in part because home detention with electronic monitoring "at best . . . limits a fleeing defendant's head start"); see also United States v. Casteneda, No. 18 Cr. 047, 2018 WL 888744, at \*9 (N.D. Cal. Feb. 2018) (same); United States v. Anderson, 384 F. Supp.2d 32, 41 (D.D.C. 2005) (same); United States v. Benatar, No. 02 Cr. 099, 2002 WL 31410262, at \*3 (E.D.N.Y. Oct. 10, 2002) (same). + +# 5. Private Security is Inadequate, Unfair, and Impractical Here + +The defendant also proposes the use of a private security force to march him to and from court under the threat of deadly force. This proposal should be rejected. + +At the outset, it is far from clear that private jail, which seeks to replicate the conditions of a government-run detention facility in the defendant's home, is a condition of "release" that implicates the Bail Reform Act. "[T]here is a debate within the judiciary over whether a defendant, if she is able to perfectly replicate a private jail in her own home at her own cost, has a right to do so under the Bail Reform Act and the United States Constitution." United States v. Valerio, 9 F. Supp. 3d 283, 292 (E.D.N.Y. 2014) (Bianco, J.) (collecting cases). The Second Circuit has never directly addressed this issue. See United States v. Sablmani, 493 F.3d 63, 78 n.18 (2d Cir. 2007) ("The government has not argued and, therefore, we have no occasion to consider whether it would be `contrary to the principles of detention and release on bail' to allow wealthy defendants `to buy their way out by constructing a private jail." (citations omitted)). Indeed, a decision by this Court reasoned that "the very severe restrictions" in the private jail proposal presented to him did "not appear to contemplate `release' so much as it describes a very expensive form of private jail or detention." United States v. Zarrab, 2016 WL 3681423, at \*10 (S.D.N.Y. June 16, 2016). + +Courts have long been troubled by private jail proposals like the defendant's which, "at best `elaborately replicate a detention facility without the confidence of security such a facility instills."' United States v. Orena, 986 F.2d 628, 632 (2d Cir. 1993) (quoting United States v. Gotti, 776 F. Supp. 666, 672 (E.D.N.Y. 1991) (rejecting private jail proposal)); see also Valerio, 9 F. Supp. 3d at 295 ("The questions about the legal authorization for the private security firm to use force against defendant should he violate the terms of his release, and the questions over whether the guards can or should be armed, underscore the legal and practical uncertainties—indeed, the imperfections-of the private jail-like concept envisioned by defendant, as compared to the more secure option of an actual jail."). A private security firm simply cannot replicate the controlled environment of a federal correctional facility, in which, typically, all of the needs to the prisoner can be attended to without placing the prisoner in the community at large; the defendant's proposed private jail arrangement would have the effect of permanently placing him in just such a highflight-risk circumstance. The risk of a public escape attempt while in the community and involving + +armed private guards attempting to stop the defendant, potentially by force—rather than the defendant being in the environment of a federal facility—also greatly magnifies the danger of the defendant's flight to the public. See United States v. Boustani, 356 F. Supp. 3d 246, 257 (E.D.N.Y. 2019). "This is why, as the Government correctly notes, federal prisoners should be detained in facilities run by trained personnel from federal correctional facilities." Id. at 258 (citing Sabhnani, 493 F.3d at 74 n.13 ("To the extent [armed private guards] implies an expectation that deadly force may need to be used to assure defendant['s] presence at trial... [s]uch a conclusion would, in fact, demand a defendant's detention")). + +The Second Circuit has held it is not legal error "for a district court to decline to accept," as "a substitute for detention," a defendant hiring private security guards to monitor him. United States v. Banki, 369 Fed. App'x 152, 153-54 (2d Cir. 2010). In the same decision, the Second Circuit noted that it was "troubled" by the possibility of "allow[ing] wealthy defendants to buy their way out by constructing a private jail." (internal quotation marks omitted)). Id.; accord, e.g., United States v. Cilins, No. 13 Cr. 315 (WHP), 2013 WL 3802012, at \*3 (S.D.N.Y. July 19, 2013) ("it is contrary to underlying principles of detention and release on bail that individuals otherwise ineligible for release should be able to buy their way out by constructing a private jail, policed by security guards not trained or ultimately accountable to the Government, even if carefully selected' (quoting Borodin v. Ashcroft, 136 F. Supp. 2d 125, 134 (E.D.N.Y. 2001))); Valerio, 9 F. Supp. 3d at 293-94 (E.D.N.Y. 2014) ("There is nothing in the Bail Reform Act that would suggest that a defendant (or even, hypothetically, a group of defendants with private funding) has a statutory right to replicate or construct a private jail in a home or some other location."). + +The defendant's payment of his guards also raises the conflict of interest inherent in having the defendant having extraordinary influence over a private security company tasked with guarding him, leaving the company's incentives entirely aligned with the defendant. See, e.g., Boustani, 356 F. Supp. 3d at 257 (in finding that private armed guards would not reasonably assure the appearance of a defendant, noting a "clear conflict of interest—private prison guards paid by an inmate" and noting that in a recent S.D.N.Y. case involving private security guards the defendant "was outside of his apartment virtually all day, every weekday; was visited by a masseuse for a total of 160 hours in a 30-day period; and went on an unauthorized visit to a restaurant in Chinatown with his private guards in tow"); see also United States v. Tajideen, 17 Cr. 046, 2018 WL 1342475, at \*5-6 (D.D.C. Mar. 15, 2018) (finding Zarrab "particularly instructive" and further noting: "While the Court has no reason to believe that the individuals selected for the defendant's security detail would intentionally violate federal law and assist the defendant in fleeing the Court's jurisdiction, it nonetheless is mindful of the power of money and its potential to corrupt or undermine laudable objectives. And although these realities cannot control the Court's ruling, they also cannot be absolutely discounted or ignored."). + +Finally, in Zarrab this Court found that "the Defendant's privately funded armed guard proposal is unreasonable because it helps to foster inequity and unequal treatment in favor of a very small cohort of criminal defendants who are extremely wealthy, such as Mr. Zarrab." 2016 WL 3681423, at \*13; see also Boustani, 356 F. Supp. 3d at 258 ("although this Defendant has vast financial resources to construct his own `private prison,' the Court is not convinced 'disparate treatment based on wealth is permissible under the Bail Reform Act"') (quoting United States v. + +Bruno, 89 F. Supp. 3d 425, 432 (E.D.N.Y. 2015) ("Even if Defendant had the financial capacity to replicate a private jail within his own home, this Court is not convinced that such a set of conditions would be sufficiently effective in this case to protect the community from Defendant, or that such disparate treatment based on wealth is permissible under the Bail Act.")); Borodin, 136 F. Supp. 2d at 134 (E.D.N.Y. 2001) (Nickerson, J.) ("It is contrary to underlying principles of detention and release on bail that individuals otherwise ineligible for release should be able to buy their way out by constructing a private jail, policed by security guards not trained or ultimately accountable to the government, even if carefully selected."). + +If the defendant's appearance can only be assured through use of round-the-clock guards, the defendant belongs in a federal detention center, not released under bail conditions that effectively create a private prison of one, using guards to be paid by the defendant himself. It is frankly outrageous for the defendant to suggest that preventing him from using his vast wealth to duplicate a private prison that cannot control, monitor, and contain him consistent with the requirements of the Bail Act would cause him to somehow "bear a special disadvantage." Release Motion at 12 n.9. Indeed: "What more compelling case for an order of detention is there than a case in which only an armed guard and the threat of deadly force is sufficient to assure the defendant's appearance?" Zarrab, 2016 WL 3681432, at \*12 (quoting United States v. Vaierio, 9 F. Supp. 3d at 295). + +#### HI. The Defendant Provides No Assurance He is Not a Danger to the Community and a Risk to Obstruct Justice + +## A. Danger to the Community + +In the first instance, the defendant's argument that 14 years without a criminal conviction eliminates "any danger presumption" should be rejected. Were that the case—which is certainly is not—a lack of criminal record for any defendant would automatically rebut the presumption applicable to crimes such as sex trafficking. That is manifestly incorrect. See United States v. Artis, 607 F. App'x 95, 97 (2d Cir. 2015) (finding that a defendant's lack of criminal record was "not so compelling as to defeat the presumption or to manifest clear error in the district court's determination that no combination of release conditions . . . could reasonably assure against dangerousness and the risk of flight"). Moreover, here, the defendant not only has a criminal record, but has been convicted of a sex crime involving a minor. + +But the ongoing and forward-looking danger posed by the defendant is further demonstrated by the defendant's maintenance of a substantial collection of photographic trophies of his victims and other young females in his mansion, as discovered by the Government through its search warrants. As indicated in the Detention Memo, the many discs found in the defendant's residence included those with hand-written labels including the following: "Young [Name] + [Name]," "Misc nudes I," and "Girl pies nude." Not surprisingly, the Government has found that such discs contain photographs of sexually suggestive photographs of fully- or partially-nude females appearing to be underage. + +#### B. Danger to Obstruct Justice + +The defendant has also already demonstrated a willingness to use intimidation and aggressive tactics in connection with a criminal investigation. Far from being "musty," Release Motion at 6 n.6, the defendant's past behavior in connection with being investigated for sexually abusing children is the best predictor of his likely incentives and activities in connection with being charged with sexually abusing children. For example, in the incident the defendant now claims was not attributable to or authorized by him, the contemporaneous police report indicates that pressure tactics were at the very least coordinated closely with individuals in the defendant's orbit. See Palm Beach Police Report (the "Police Report") (Ex. B). According to the Police Report, the parent of one of the defendant's victims was driven off the road by a private investigator. The Police Report provides further information regarding victim and witness threats and intimidation reported against an individual who was directly in contact with an assistant of the defendant, followed "immediately" by a call to that same individual from a phone number associated with the defendant's businesses and associates. + +Separately, and in addition, there are also extensive allegations of obstruction and tampering in connection with civil lawsuits brought against the defendant following his 2008 conviction. See Doe v. United States, 08 Civ. 80736 (S.D. Fla.), Dkt. 291-15 at 21-23, 31. Moreover, police reports suggest that an associate of Epstein's was offering to buy victims' silence during the course of the prior investigation. Specifically, one victim reported that "she was personally contacted through a source that has maintained contact with Epstein," who "assured [the victim] that she would receive monetary compensation for her assistance in not cooperating with law enforcement." Indeed, the victim reported having been told: "Those who help him will be compensated and those who hurt him will be dealt with." See Palm Beach Police Report (Ex. C). + +And Epstein's efforts to influence witnesses continue to this day. As in the past, within recent months. he paid significant amounts of money to influence individuals who were close to him during the time period charged in this case and who might be witnesses against him at a trial. By way of background, on or about November 28, 2018, the Miami Herald began publishing a series of articles relating to the defendant, his conduct, and the circumstances of his prior conviction and the non-prosecution agreement ("NPA"). Records obtained by the Government from Institution-1 appear to show that just two days later, on or about November 30, 2018, the defendant wired \$100,000 from a trust account he controlled to an individual named as a possible co-conspirator in the NPA. The same records appear to show that just three days after that, on or about December 3, 2018, the defendant wired \$250,000 from the same trust account to another individual named as a possible co-conspirator in the NPA and also identified as one of the defendant's employees in the Indictment. Neither of these payments appears to be recurring or repeating during the approximately five years of bank records presently available to the Government. This course of action, and in particular its timing, suggests the defendant was attempting to further influence co-conspirators who might provide information against him in light of the recently re-emerging allegations + +#### IV. The Defendant Raises Legal Arguments Not Relevant Here + +Finally, the defendant raises certain legal arguments he contends he will litigate at the appropriate stage and which he further suggests mitigate in favor of bail. None is meritorious, and certainly none should give the Court any comfort whatsoever that the defendant would, if granted bail, refrain from fleeing so he could attempt to vindicate himself via dubious legal strategies. Nevertheless, the Government will address the defendant's arguments briefly in turn. + +## A. The Non-Prosecution Agreement Does Not Preclude Prosecution + +As an initial matter, as the Court itself noted at the parties' initial appearance earlier this week, and as the defendant appears to concede, the instant Indictment charges conduct well beyond the scope of the NPA — that is, alleged conduct that occurred here in New York and involving New York based victims. D. Tr. 6-8; Release Motion at 2. For present purposes, that alone is sufficient to put this issue to rest, because even assuming the defendant were to mount a meritorious challenge to the NPA, he would still have to stand trial on Count Two of the Indictment and additional charges brought based on New York conduct. + +But more generally, the reasons the defendant can be prosecuted in the Southern District of New York—or anywhere else outside the SDFL—are manifold. The language of the NPA overwhelmingly refers to the SDFL, and the core terms and text of the agreement are limited to the SDFL. The prefatory language states: "THEREFORE, on the authority of R. Alexander Acosta, United States Attorney for the Southern District of Florida, prosecution in this District for these offenses shall be deferred in favor of prosecution by the State of Florida."' The final paragraph of the prefatory language also states, among other things, that after fulfilling the terms of the agreement, "no prosecution for the [sex abuse] offenses set out on pages 1 and 2 of this Agreement, nor any other offenses that have been the subject of the joint investigation by the Federal Bureau of Investigation and the United States Attorney's Office, nor any offenses that arose from the Federal Grand Jury investigation will be instituted in this District." + +In its terms section, the NPA further states that Epstein's signature "is not to be construed as an admission of civil or criminal liability or a waiver of any jurisdictional or other defense" as to any victim whose identity was not disclosed by SDFL to Epstein, as provided for in the NPA, and additionally states that neither Epstein's signature nor any resulting waivers or civil settlements "are to be construed as admissions or evidence of civil or criminal liability or a waiver of any jurisdictional or other defense as to any person." These provisions show the parties contemplated possible criminal prosecutions in other jurisdictions and/or based on victims not initially identified in the Florida investigations (whether in Florida or elsewhere). The final substantive paragraph of the NPA states that "Epstein hereby requests that the United States Attorney for the Southern District of Florida defer [...] prosecution." + +It is well settled in the Second Circuit that "a plea agreement in one U.S. Attorney's office does not, unless otherwise stated, bind another." United States v. Prisco, 391 F. App'x 920, 921 + +All emphases relating to the NPA are added unless otherwise specified. + +United States District Judge + +July 12, 2019 + +Page 13 + +(2d Cir. 2010) ("A plea agreement binds only the office of the United States Attorney for the district in which the plea is entered unless it affirmatively appears that the agreement contemplates a broader restriction.") (citing United States v. Annabi, 771 F.2d 670, 672 (2d Cir. 1985) (per curiam)). Moreover, any references in an NPA to the "Government" or the "United States" do not abrogate these principles. Annabi, 771 F.2d at 672 ("[A] plea agreement whereby a federal prosecutor agrees that 'the Government' will dismiss counts of an indictment .. . might be thought to bar the United States from reprosecuting the dismissed charges in any judicial district unless the agreement expressly limits the scope of the agreement . . . . However, the law has evolved to the contrary."). "The mere use of the term 'government' in the plea agreement does not create an affirmative appearance that the agreement contemplated barring districts other than the particular district entering into the agreement." United States v. Salameh, 152 F.3d 88, 120 (2d Cir. 1998) (citations and internal quotation marks omitted); see also United States v. Brown, No. 99-1230, 2002 WL 34244994, at \*2 (2d Cir. Apr. 26, 2002) (in analyzing an SDFL plea agreement, reiterating the holding of Annabi and noting that it applies "even if the plea agreement purports to bind 'the Government' or the "United States") (summary order); United States v. Bruno, 159 F. Supp. 3d 311, 321 (E.D.N.Y. 2016) ("The Court disagrees with Defendant's argument that the phrase 'United States' shows an intent to bind all United States Attorney's Offices. Rather, the plea agreement covers only Defendant's liability in the SDFL."). + +In sum, this issue is a distraction that has little relevance to the bail determination and does nothing to address the defendant's risk of flight or mitigate the danger he poses to the community. + +## B. The Defendant Wrongly Argues the Statute Does Not Apply to His Sex Trafficking + +Next, the defendant wrongly argues that the "principal conduct" giving rise to the charges is his payment of underage girls for sex acts, and that such conduct could not possibly fall under the charged statutes. As the defendant implicitly concedes, Release Motion at 14, this is an issue for a motion to dismiss. Nevertheless, the defendant's argument is incorrect for two reasons. + +First, although the defendant undoubtedly participated on the demand side of the crime, he was also instrumental on the supply side given his role in recruiting and causing others to recruit additional victims. He organized, funded, and perpetuated a sex trafficking scheme in two states, including with co-conspirators. The fact that he did so for his own eventual and frequent sexual gratification does not vitiate his role in enticing and recruiting victims, consistent with the elements of the offense with which he is charged. The defendant was the leader of a sex-trafficking enterprise, not a mere consumer. + +This analysis similarly extends to a non-prosecution agreement. See United States v. Laskow, 688 F. Supp. 851, 854 (E.D.N.Y. 1988) ("Defendant's argument, in effect, is that unless there is an explicit statement to the contrary, it is presumed that a non-prosecution agreement binds offices of the United States Attorney that are not parties to the agreement. This position is at odds with the law in this Circuit, which presumes a narrow reading of the boundaries of a plea agreement unless a defendant can affirmatively establish that a more expansive interpretation was contemplated.") (citing Annabi, 771 F.2d at 672). + +Second, he is also wrong on the law. Courts have found that Section 1591 applied to both suppliers and consumers of commercial sex acts. See, e.g., United States v. Jungers, 702 F.3d 1066, 1069 (8th Cir. 2013) (upholding the conviction of a defendant who attempted to pay for oral sex from an underage girl and explaining: "The sole issue raised on appeal is whether 'Nile plain and unambiguous provisions of 18 U.S.C. § 1591 apply to both suppliers and consumers of commercial sex acts.' We conclude they do.") (alteration in original). The lone case cited by the defendant, Fierro v. Taylor, No. 11 Civ. 8573, 2012 WL 13042630 (S.D.N.Y. July 2, 2012), relied heavily on the statutory interpretation undertaken by two district courts in the District of South Dakota, United States v. Bonestroo, No. 11 Cr. 40016, 2012 WL 13704 (D.S.D. Jan. 4, 2012), and United States v. Jungers, II Cr. 40018, 2011 WL 6046495 (D.S.D. Dec. 5, 2011), both of which were explicitly overruled by the Eighth Circuit decision in Jungers, 702 F.3d 1066. In the seven years since Fierro has been decided, it does not appear to have been cited by a single other court. Additionally, other cases in this Circuit and elsewhere have upheld convictions of procurers or customers. See United States v. O'Connor, 650 F.3d 839 (2d Cir. 2011) (upholding convictions under Section 1591 of both the buyer and seller of a child); United States v. Cook, 782 F.3d 983 (8th Cir. 2015) (rejecting a constitutional challenge that Section 1591 would be void for vagueness if applied to purchasers); United States v. Mikoloyck, No. 09 Cr. 036, 2009 WL 4798900 (W.D. Mo. Dec. 7, 2009) ("contrary to defendant's argument, 18 U.S.C. § 1591 clearly applies to those who attempt to purchase underage sex, not merely the pimps of actual exploited children") (citing United States v. Roberts, 174 F. App's 475 (1 I th Cir. 2006) (in which defendant was convicted under sections 1591(a) and 1594(a) even though no actual children were involved)). + +## CONCLUSION + +As set forth above, the defendant's proposed bail package is insufficient and insubstantial. Pretrial Services, victims, and the Government all recommend pretrial detention due to the unusual and concerning confluence of factors in this case, including the defendant's extraordinary wealth, demonstrated willingness to interfere with victims and witnesses, continued possession of lewd photographs of young females, and both the incentive and means to flee prosecution. + +Very truly yours, + +By + +![](_page_13_Picture_7.jpeg) + +Cc: Martin Weinberg, Esq., and Reid Weingarten, Esq., counsel for defendant + +![](_page_14_Picture_1.jpeg) + +United States Attorney Southern District of New York + +The Silvio J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 + +July 8, 2019 + +### VIA ECF + +The Honorable Henry Pitman United States District Court Southern District of New York United States Courthouse 500 Pearl Street New York, New York 10007 + +Re: United States v. Jeffrey Epstein, 19 Cr. 490 (RMB) + +Dear Judge Pitman: + +The Government respectfully submits this letter in advance of the bail hearing scheduled for July 8, 2019, in the above-captioned case. For the reasons set forth herein, the Court should order that the defendant be detained pending trial; he cannot meet his burden of overcoming the presumption that there is no combination of conditions that would reasonably assure his continued appearance in this case or protect the safety of the community were he to be released. + +As set forth below, the charges in this case are exceptionally serious: the defendant is alleged to be a serial sexual predator who preyed on dozens of minor girls over a period of years, and he now faces a potentially massive prison sentence predicated on substantial and multifaceted evidence of his guilt. In light of the strength of the Government's evidence and the substantial incarceratory term the defendant would face upon conviction, there is an extraordinary risk of flight, particularly given the defendant's exorbitant wealth, his ownership of and access to private planes capable of international travel, and his significant international ties. Indeed, the arrest of the defendant occurred when he arrived in the United States on his private jet after having returned from a multi-week stay abroad. + +Finally, and as detailed herein, the Government has real concerns—grounded in past experience with this defendant—that if allowed to remain out on bail, the defendant could attempt to pressure and intimidate witnesses and potential witnesses in this case, including victims and their families, and otherwise attempt to obstruct justice. As a result, he poses both an acute danger to the community, including some of its most vulnerable members, and a significant risk of flight. The defendant thus cannot overcome the statutory presumption that detention is appropriate in this case, and the Court should order that he be detained pending trial. + +## BACKGROUND + +## A. Overview + +On July 2, 2019, a federal grand jury in the Southern District of New York returned a sealed indictment (the "Indictment") charging the defendant with one count of sex trafficking of minors, in violation of 18 U.S.C. § 1591, and one count of conspiracy to commit sex trafficking of minors, in violation of 18 U.S.C. § 371. + +As charged by the grand jury, the facts underlying the charges in the Indictment arise from a years-long scheme to sexually abuse underage girls. In particular, beginning in at least 2002, the defendant enticed and recruited dozens of minor girls to engage in sex acts with him, for which he paid the victims hundreds of dollars in cash. + +He undertook this activity in at least two different locations, including his mansion in Manhattan, New York (the "New York Residence") and his estate in Palm Beach, Florida (the "Palm Beach Residence"). In both New York and Florida, the defendant perpetuated this abuse in similar ways. Victims were initially recruited to provide "massages" to the defendant, which would be performed nude or partially nude, would become increasingly sexual in nature, and would typically include one or more sex acts, including groping and direct or indirect contact with victims' genitals. The defendant paid his victims hundreds of dollars in cash for each separate encounter. + +Moreover, the defendant actively encouraged certain of his victims to recruit additional girls to be similarly sexually abused. He incentivized his victims to become recruiters by paying these victim-recruiters hundreds of dollars for each additional girl they brought to him. In this fashion, the defendant created a vast network of underage victims for him to exploit, in locations including New York and Palm Beach. + +The defendant's victims were as young as 14 years old when he abused them. Many of his victims were, for various reasons, often particularly vulnerable to exploitation. The defendant intentionally sought out—and knew that he was abusing—minors. Indeed, in some instances, his victims expressly told him they were underage before or during the period in which he abused them. + +In creating and maintaining a network of minor victims whom he abused, the defendant worked with others, including employees and associates who facilitated his exploitation of minors by, among other things, contacting victims and scheduling their sexual encounters with the defendant, both in New York and in Florida. + +# B. The Defendant + +Jeffrey Epstein designed, financed, and perpetrated this scheme, both as its main participant and through his direction of others, including certain of his employees, to further facilitate his rampant abuse of underage girls. + +As has been widely reported, the defendant is extraordinarily wealthy, and he owns and maintains luxury properties and residences around the world, including in Manhattan, New York; Palm Beach, Florida; Stanley, New Mexico; and Paris, France. Additionally, Epstein owns a private island in the U.S. Virgin Islands which, as noted above, is believed to be his primary residence in the United States. His mansion in Manhattan alone—a multi-story townhouse reported to be one of the largest single residences in all of Manhattan, which previously housed a school and which he owns through an LLC—has been valued at approximately \$77 million. Entities controlled by the defendant also own at least two private jets in active service, at least one of which is capable of intercontinental travel. + +As described further below, the defendant possesses three active United States passports, and his international connections and travels are extensive. For example, in addition to maintaining a residence in Paris, France, as described above, in the past 18 months alone, the defendant has traveled abroad, via private jet, either into or out of the country on approximately more than 20 occasions. + +## C. The Prior Florida Investigation + +In or about 2005, the defendant was investigated by local police in Palm Beach, Florida, in connection with allegations that he had committed similar sex offenses against minor girls. The investigation ultimately also involved federal authorities, namely the U.S. Attorney's Office for the Southern District of Florida ("SDFL") and the FBI's Miami Office, and included interviews with victims based in the Palm Beach area, including some of the alleged victims relevant to Count One of the instant Indictment.' + +In fall 2007, the defendant entered into a non-prosecution agreement with the SDFL in connection with the conduct at issue in that investigation, which the non-prosecution agreement identified as including investigations into the defendant's abuse of minor girls in the Palm Beach area. The Southern District of New York was not a signatory to that agreement, and the defendant was never charged federally.2 In June 2008, the defendant pled guilty in state court to one count of procuring a person under the age of 18 for prostitution, a felony, and one count of solicitation of prostitution, a felony. As a result, the defendant was designated as a sex offender with registration requirements under the national Sex Offender Registration and Notification Act. + +&#x27; The non-prosecution agreement, further discussed below, was entered into at the conclusion of the SDFL investigation and did not purport to cover any victims outside of the State of Florida. As noted above, the instant Indictment expressly alleges the existence of dozens of victims who were abused in this District in addition to dozens of victims who were abused in Florida.

    2 While beyond the scope of a bail hearing, as discussed further below, it is well-established in the Second Circuit that absent an express provision to the contrary in the agreement, one District is not bound by the terms of an agreement entered into between a defendant and a U.S. Attorney's Office in another district. See page 6, infra.

    ARGUMENT

    I. Applicable Law

    Under the Bail Reform Act, 18 U.S.C. §§ 3141 et seq., federal courts are empowered to order a defendant's detention pending trial upon a determination that the defendant is either a danger to the community or a risk of flight. 18 U.S.C. § 3142(e) ("no condition or combination of conditions would reasonably assure the appearance of the person as required and the safety of any other person and the community"). A finding of risk of flight must be supported by a preponderance of the evidence. See, e.g., United States v. Jackson, 823 F.2d 4, 5 (2d Cir. 1987); United States v. Chinmrenga, 760 F.2d 400, 405 (2d Cir. 1985). A finding of dangerousness must be supported by clear and convincing evidence. See, e.g., United States v. Ferranti, 66 F.3d 540, 542 (2d Cir. 1995); Chinmrenga, 760 F.2d at 405. In addition, a court may also order detention if there is "a serious risk that the [defendant] will . . . attempt to obstruct justice, or . . . to threaten, injure, or intimidate, a prospective witness or juror." 18 U.S.C. § 3142(0(2)(B); see also United States v. Friedman, 837 F.2d 48 (2d Cir. 1988).

    The Bail Reform Act lists four factors to be considered in the detention analysis: (1) the nature and circumstances of the crimes charged; (2) the weight of the evidence against the person; (3) the history and characteristics of the defendant, including the person's "character . . . [and] financial resources"; and (4) the seriousness of the danger posed by the defendant's release. See 18 U.S.C. § 3142(g). Evidentiary rules do not apply at detention hearings and the government is entitled to present evidence by way of proffer, among other means. See 18 U.S.C. § 3142(0(2); see also United States v. LaFontaine, 210 F.3d 125, 130-31 (2d Cir. 2000) (government entitled to proceed by proffer in detention hearings); Ferranti, 66 F.3d at 542 (same); United States v. Martir, 782 F.2d 1141, 1145 (2d Cir. 1986) (same).

    Where a judicial officer concludes after a hearing that "no condition or combination of conditions will reasonably assure the appearance of the person as required and the safety of any other person and the community, such judicial officer shall order the detention of the person before trial." 18 U.S.C. § 3142(e)(1). Additionally, where, as here, a defendant is charged with committing an offense involving a minor victim under 18 U.S.C. § 1591, it shall be presumed, subject to rebuttal, that no condition or combination of conditions will reasonably assure the appearance of the defendant as required and the safety of the community. 18 U.S.C. § 3142(e)(3)(E).

    II. Discussion

    The defendant should be detained pending trial. For the reasons set forth below, it is difficult to overstate the risk of flight and danger to the community if the defendant is released, and for those reasons, the defendant cannot overcome the statutory presumption in favor of detention in this case.

    A. The Defendant Poses an Extreme Flight Risk

    Each of the relevant factors to be considered as to flight risk — the nature and circumstances of the offense, the strength of the evidence, and the history and characteristics of the defendant counsel strongly in favor of detention.

    I. The Nature and Circumstances of the Offense and the Strength of the Evidence

    The "nature and circumstances" of this offense plainly favor detention. 18 U.S.C. § 3I42(g)( I ) (specifically enumerating "whether the offense. . . involves a minor victim" as a factor in bail applications). Indeed, the crime of sex trafficking of a minor is so serious that for a defendant charged with that offense, there is a presumption that no condition or combination of conditions will reasonably assure the appearance of the defendant as required and the safety of the community. 18 U.S.C. § 3142 (e)(3)(E). Here, as specified in the Indictment, the defendant's conduct was committed serially, over a period of years, and affected dozens of victims.

    The seriousness of the charge is also reflected in the penalties the defendant faces, which include up to 45 years of incarceration for Counts One and Two of the Indictment.' As the Second Circuit has noted, the possibility of a severe sentence is a significant factor in assessing the risk of flight. See Jackson, 823 F.2d at 7; see also United States v. Cisneros, 328 F.3d 610, 618 (10th Cir. 2003) (defendant was a flight risk because her knowledge of the seriousness of the charges against her gave her a strong incentive to abscond); United States v. Townsend, 897 F.2d 989, 995 (9th Cir. 1990) ("Facing the much graver penalties possible under the present indictment, the defendants have an even greater incentive to consider flight."). Here, the defendant is facing a statutory maximum of decades in prison. Even in the absence of means—which, as discussed in detail below, the defendant has in abundance—this fact alone would provide a compelling incentive for anyone to fail to appear. It is particularly compelling for a defendant who is 66 years old and therefore faces the very real prospect of spending the rest of his life in prison if convicted.

    The likelihood of a substantial period of incarceration is buttressed by the strength of the evidence. As set forth in the Indictment, the evidence in this case is strong. The Indictment alleges that the defendant sexually abused dozens of minor victims, and the conspiracy count lists numerous overt acts committed in furtherance of the defendant's crimes.'

    The current penalties for violations of 18 U.S.C. § 1591 include a 10 year mandatory minimum sentence. However, that punishment was created through an amendment to the statute in 2006. The penalty for a violation of Section 1591 during the period charged in the Indictment, and therefore relevant here, was a maximum of 40 years' imprisonment.

    With respect to the evidence in this case, the Court should start its analysis by accepting that the Indictment is sufficient, on its own, to establish probable cause that the defendant committed the crimes of sex trafficking and sex trafficking conspiracy. Contreras, 776 F.2d at 54. ("Were an evidentiary hearing addressing the existence of probable cause required in every § 3142(e) case in which an indictment had been filed, the court would spend scarce judicial resources considering that which a grand jury had already determined, and have less time to focus on the application of

    Multiple victims, including several specified in the Indictment, have provided information against the defendant. That information is detailed, credible, and corroborated, in many instances, by other witnesses and contemporaneous documents, records and other evidence—including, as further detailed below, evidence from a search of the New York Residence on the night of the defendant's arrest that reflects an extraordinary volume of photographs of nude and partially-nude young women or girls. Such corroborating evidence also includes documents and other materials, such as contemporaneous notes, messages recovered from the defendant's residence that include names and contact information for certain victims, and call records that confirm the defendant and his agents were repeatedly in contact with various victims during the charged period. Put simply, all of this evidence — the voluminous and credible testimony of individuals who were sexually abused by the defendant as minors, each of whom are backed up by other evidence — will be devastating evidence of guilt at any trial in this case and weighs heavily in favor of detention.

    Finally, it bears noting that neither the age of the conduct nor the defendant's previous nonprosecution agreement ("NPA") with a different federal district pose any impediment to his conviction. As an initial matter, all of the conduct is timely charged, pursuant to 18 U.S.C. § 3283, which was amended in 2003 to extend the limitations period for conduct that was timely as of the date of the amendment, to any time during the lifetime of the minor victim. See United States v. Chief, 438 F.3d 920, 922-25 (9th Cir. 2006) (finding that because Congress extended the statute of limitations for sex offenses involving minors during the time the previous statute was still running, the extension was permissible); United States v. Pierre-Louis, No. 16 Cr. 541 (CM), 2018 WL 4043140, at \*1 (S.D.N.Y. Aug. 9, 2018) (same).

    Moreover, with respect to the NPA, that agreement, to which the Southern District of New York was not a party, which by its express language pertained exclusively to the SDFL investigation, and which did not purport to bind any other Office or District, does not preclude prosecution in this District for at least two reasons. First, it is well settled in the Second Circuit that "a plea agreement in one U.S. Attorney's office does not, unless otherwise stated, bind another." United States v. Prisco, 391 F. App'x 920, 921 (2d Cir. 2010) ("A plea agreement binds only the office of the United States Attorney for the district in which the plea is entered unless it affirmatively appears that the agreement contemplates a broader restriction.") (citing United States v. Annahi, 771 F.2d 670, 672 (2d Cir. 1985) (per curiam)). This is true even if the text of the agreement purports to bind "the Government." See Annabi, 771 F.2d at 672. This analysis similarly extends to a non-prosecution agreement. See United States v. Laskow, 688 F. Supp. 851, 854 (E.D.N.Y. 1988) ("Defendant's argument, in effect, is that unless there is an explicit statement to the contrary, it is presumed that a non-prosecution agreement binds offices of the United States Attorney that are not parties to the agreement. This position is at odds with the law in this Circuit, which presumes a narrow reading of the boundaries of a plea agreement unless a defendant can affirmatively establish that a more expansive interpretation was contemplated.") (citing Annabi, 771 F.2d at 672). Second, the Indictment charges conduct not covered by the NPA, namely

    the presumptions and the § 3142(g) factors in deciding whether the defendant should be detained.").

    conduct that occurred in New York. The prior NPA included a list of several dozen victims identified in the prior investigation, all of whom were abused in the State of Florida, and none of whom are a part of the conduct charged in Count Two of the instant Indictment.

    Each of these factors—the seriousness of the allegations, the strength of the evidence, and the possibility of lengthy incarceration—creates an extraordinary incentive to flee. And as further described below, the defendant has the means and money to do so.

    2. The Characteristics of the Defendant

    The history and characteristics of the defendant also strongly support detention. The defendant is extraordinarily wealthy and has access to vast financial resources to fund any attempt to flee. Indeed, his potential avenues of flight from justice are practically limitless.

    As the defendant acknowledged in his most recent New York State sex offender registration, he has six residences, including two in the U.S. Virgin Islands (including his own private island), and one each in Palm Beach, Florida; Paris, France; New York, New York; and Stanley, New Mexico. The most recent estimated value of the defendant's New York City mansion alone is more than \$77 million. The most recent tax-assessed value of the defendant's Palm Beach estate is more than \$12 million. The defendant's primary residence is a private island in the U.S. Virgin Islands, a place where any sort of meaningful supervision would be all but impossible.

    Moreover, the defendant has access to innumerable means to flee. His sex registration documentation of "current vehicles" lists no fewer than 15 motor vehicles, including seven Chevrolet Suburbans, a cargo van, a Range Rover, a Mercedez-Benz sedan, a Cadillac Escalade, and a Hummer II. These cars are registered in various states and territories including the Virgin Islands, New York, Florida, and New Mexico. The defendant also has access to two private jets, giving him the ability to leave the country secretly and on a moment's notice and to go virtually anywhere he wants to travel. He is a very frequent international traveler and regularly travels to and from the United States by private plane. In particular, between January 1, 2018, and the present, U.S. Customs and Border Patrol has logged approximately more than 20 flights in which Epstein was traveling to or from a foreign country. Indeed, he was arrested at Teterboro Airport arriving on just such a private international flight after having spent approximately three weeks abroad. Extensive international travel of this nature further demonstrates a significant risk of flight. See, e.g., United States v. Anderson, 384 F. Supp. 2d 32, 36 (D.D.C. 2005). There can be no assurance that, upon release, the defendant would suddenly lack access to such means of travel.

    Finally, the defendant has no meaningful ties that would keep him in this country. The defendant has no known immediate family. He is not married and has no children. He has friends and associates worldwide, as demonstrated by his extensive international travel, and his professional obligations, if any, can and seemingly are plainly capable of being handled by the defendant remotely. Simply put, there would be no meaningful reason for the defendant to remain in the country, while he would have every incentive (and every resource needed) to flee.

    Nor would home confinement with electronic monitoring reasonably assure the defendant's presence as required. At best, home confinement with electronic monitoring would

    merely reduce his head start should he decide to flee. See United States v. Zarger, No. 00 Cr. 773, 2000 WL 1134364, at \*1 (E.D.N.Y. Aug. 4, 2000) (Gleeson, J.) (rejecting defendant's application for bail in part because home detention with electronic monitoring "at best . . . limits a fleeing defendant's head start"); see also United States v. Casteneda, No. 18 Cr. 047, 2018 WL 888744, at \*9 (N.D. Cal. Feb. 2018) (same); United States v. Anderson, 384 F.Supp.2d 32, 41 (D.D.C. 2005) (same); United States v. Benatar, No. 02 Cr. 099, 2002 WL 31410262, at \*3 (E.D.N.Y. Oct. 10, 2002) (same).

    Finally, there can be little doubt that the defendant is in a position to abandon millions of dollars in cash and property securing any potential bond and still live comfortably for the rest of his life. These resources, and the ease with which the defendant could flee and live outside the reach of law enforcement—particularly considering his vast wealth and lack of meaningful ties to this District—make the risk of flight exceptionally high in this case, particularly when considered in conjunction with the strength of the government's case and the lengthy sentence the defendant could receive if convicted.

    B. The Defendant Poses a Risk of Danger to the Community and of Engaging in Obstruction of Justice

    The release of the defendant, under any conditions, would pose a significant threat to the community and to the ongoing investigation.

    As described above, where there is probable cause to believe that an individual has committed an offense under 18 U.S.C. § 1591, it is presumed that no condition or combination of conditions can reasonably assure the safety of the community. 18 U.S.C. § 3142(e)(3). Here, not only is the defendant charged with very serious sex crimes against minors, he has already previously admitted to—and been convicted of—engaging in related conduct. Specifically, in June 2008, the defendant pled guilty in state court to one count of procuring a person under the age of 18 for prostitution, a felony, and he currently is a registered sex offender, under classification level three in New York—defined as presenting a "high" risk of committing another sex crime and harm to the community. While the conduct presently alleged does not post-date the 2008 conviction, it nevertheless underscores the risk he poses to the community if released.

    Additionally, and in connection with the investigation of the defendant's offense in Florida, there were credible allegations that the defendant engaged in witness tampering, harassment, or other obstructive behaviors. In fact, according to publicly-filed court documents, there were discussions between prosecutors and the defendant's then-counsel about the possibility of the defendant pleading guilty to counts relating to "obstruction," as well as "harassment," with reference to 18 U.S.C. § 1512, which criminalizes "[t]ampering with a witness, victim, or informant." For example, in a communication from the defendant's then-counsel to prosecutors in SDFL, his counsel set forth a possible factual proffer that included statements that the defendant had "attempted to harass both [redacted] delay and hinder their receipt of a [redacted] to attend an official proceeding" and that the defendant "in particular, changed travel plans and flew with both [redacted] to the United States Virgin Islands rather than to an airport in New Jersey in order to attempt to delay their receipt of what Mr. Epstein expected to be a [redacted]" and "further verbally

    harassed both [redacted] in connection to this attempt to delay their voluntary receipt of process all in violation of 18 USC 1512(d)(1)."5 Doe v. United States, 08 Civ. 80736 (S.D. Fla.), Dkts. 361 at 3-4, 361-7 through 361-11. In addition to 18 U.S.C. § 1512(d), prosecutors also proposed that the defendant could plead guilty to 18 U.S.C. § 403, that is, a knowing or intentional violation of the privacy protection of child victims and child witnesses, to which the defendant's thencounsel replied: "Already thinking about the same statutes." Id. Dkt. 361-11. They also discussed a possible obstruction plea that "could rely on the incident where Mr. Epstein's private investigators followed [redacted] father, forcing off the road." Id. Dkt. 361-10.

    The defendant's apparent previous willingness to obstruct a federal investigation, harass or tamper with witnesses, and hire private investigators that "forcied] off the road" the father of an individual relevant in the investigation is alarming. It should especially weigh on the Court's consideration here because the defendant was apparently willing to take those steps before even being charged and thus facing federal indictment; the incentive to interfere in the Government's case here, where an Indictment has been returned, is exponentially greater. And as discussed above, the defendant has nearly limitless means to do so.

    Finally, despite having been previously convicted of a sex offense involving an underage victim, the defendant has continued to maintain a vast trove of lewd photographs of young-looking women or girls in his Manhattan mansion. In a search of the New York Residence on the night of his arrest, on July 6-7, 2019, pursuant to judicially-authorized warrants, law enforcement officers discovered not only specific evidence consistent with victim recollections of the inside of the mansion, further strengthening the evidence of the conduct charged in the Indictment, but also at least hundreds—and perhaps thousands-of sexually suggestive photographs of fully- or partiallynude females. While these items were only seized this weekend and are still being reviewed, some of the nude or partially-nude photographs appear to be of underage girls, including at least one girl who, according to her counsel, was underage at the time the relevant photographs were taken. Additionally, some of the photographs referenced herein were discovered in a locked safe, in which law enforcement officers also found compact discs with hand-written labels including the following: "Young [Name] + [Name]," "Misc nudes 1," and "Girl pics nude." The defendant, a registered sex offender, is not reformed, he is not chastened, he is not repentant;6 rather, he is a continuing danger to the community and an individual who faces devastating evidence supporting deeply serious charges.

    The redactions above are contained in the publicly filed version of the quoted document.

    6 See, e.g., Amber Southerland, Billionaire Jeffrey Epstein: I'm a sex offender, not a predator, N.Y. Post (2011) ("I'm not a sexual predator, I'm an "offender," the financier told The Post yesterday. `It's the difference between a murderer and a person who steals a bagel."'); Philip Weiss, The Fantasist, New York Magazine (2007) ("`It's the Icarus story, someone who flies too close to the sun,' I said. `Did Icarus like massages?' Epstein asked.").

    CONCLUSION

    As set forth above, in this case, the risk of flight in this case is extraordinarily real. The defendant is extremely wealthy, has extensive foreign contacts, and is charged with serious offenses that carry a potential statutory sentence of up to 45 years' imprisonment—even a fraction of which could result in the defendant, who is 66 years old, spending the rest of his life in jail. In sum, the defendant's transient lifestyle, his lack of family or community ties, his extensive international travel and ties outside the country, and his vast wealth, including his access to and ownership of private planes, all provide the defendant with the motive and means to become a successful fugitive. Further, the nature of the offenses he is alleged to have perpetrated—the abuse dozens of underage, vulnerable girls—along with his demonstrated willingness to harass, intimidate and otherwise tamper with victims and other potential witnesses against him, render his dangerousness readily apparent.

    Accordingly, the Government respectfully submits that the defendant cannot and will not be able to meet his burden of overcoming the strong presumption in favor of detention, that there are no conditions of bail that would assure the defendant's presence in court proceedings in this case or protect the safety of the community, and that any application for bail should be denied.

    Very truly yours,

    Cc: Martin Weinberg, Esq., and Reid Weingarten, Esq., counsel for defendant Hon. Richard M. Berman, United States District Judge

    Case No

    Entered By.:

    (Continued

    On 2006, I received several phone calls throughout the day from who stated he had been followed aggressively by a private investigator. stated that as he drove to and from work and running errands throughout the county, the same vehicle was behind him running other vehicles off the road in an attempt not to lose sight of 's vehicle.

    I explained to him as Mr. Epstein had retained new legal council it was possible it would be new private investigators following him to observe his daily activities. I also ex lained to him that there was a meeting scheduled with and at scheduled on I attempted to call to inform of the private investigators following however;

    I received. other phone calls from and who advised they were able to acquire the private investigators license plate information. The subject following them was again driving very aggressively and caused to run off the road. stated the vehicle is a green Chevy bearing Florida tag of Florida. is employed with Investigations from Florida. is a licensed Private Investigator in the state of Florida. The vehicle is registered to

    Since the discovery of the threat made against one of the victims in received from during the month of March 2006 for her this case I re ested subpoenas for all calls made to and cell hone and home phone. I had confirmed with Florida State he exact dates of Spring Break .. The Spring Break was from March 4, 2006 through March 12, 2006. I received a sub oena from with all calls made during the month of . I reviewed the 989 calls made and received during the month of March 2006. I observed on , 2006, made and received thirty five calls during that day.

    + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + +
    DateTimeSecondsIn/OutTo/From
    ██████11:03AM492██████████
    ██████11:16AM6██████████
    ██████11:22AM887.2██████████
    ██████11:37AM48██████████
    ██████11:39AM28.2██████████
    ██████12:02PM727.2██████████

    The table reflects the date of the calls, time of day (EST), duration

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

    On [REDACTED], 2006, [REDACTED] telephoned me to inform me of the meeting that occurred with Atty. [REDACTED] and [REDACTED] reference this case. [REDACTED]

    Inv Continues.

    ate: 7/19/06 PALM BEACH POLICE DEPARTMENT Page: 82 Incident Report Program: CMS301L

    ime: 15:01:37

    1\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*NARRATIVE # 42 \*\*\*\*\*\*\*\*\* \*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\*\* Reported By: RECARSY, JOSEPH 4/14/06 Entered By.: ALTOMARO, NICKIE A. 4/18/06

    The Grand Jury Subpoenas were personally served to the individuals they were issued to. On April 5, 2006, at approximately 7:30 p.m., I oersonally served the parents ofellawho had informed me that the )rivate investigators were still photographing the family. On April

    ate: 7/19/06
    ime: 15:01:37

    PALM BEACH POLICE DEPARTMENT
    Incident Report

    Page: 83
    Program: CMS301L

    ise No. . . : 1-05-000368

    (Continued)

    10, 2006, at approximately 2:30 p.m., I served [REDACTED] at her residence in [REDACTED]. The subpoena was given to her mother, [REDACTED].

    I learned through one of the victims [REDACTED] that she was personally contacted through a source that has maintained contact with Epstein. The source assured [REDACTED] she would receive monetary compensation for her assistance in not cooperating with law enforcement. [REDACTED] also stated she was told, "Those who help him will be compensated and those who hurt him will be dealt with." I told [REDACTED] that tampering with a witness/victim is an arrestable offense and very serious. I asked her who approached her during this encounter. [REDACTED] originally was reluctant to provide the name of the person who approached her to offer her not to testify because she felt they were still friends.

    On April 11, 2006, Det Dawson and I traveled to Tallahassee, Florida and met with the victim, [REDACTED] identified [REDACTED] W/F, [REDACTED], as the person who approached her in Royal Palm Beach while she was home during Spring Break in March 2006. [REDACTED] also stated she did not want to pursue the intimidation charges on [REDACTED] was concerned that the defense attorney was given a copy of the report as certain things she had told me in confidence were repeated to her by [REDACTED]

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+size 38918 diff --git a/marker2/ds9/EFTA00089393/_page_27_Picture_20.jpeg b/marker2/ds9/EFTA00089393/_page_27_Picture_20.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..31373cfbb34f95db8b77e1d8d5ee0d9ee3b663f8 --- /dev/null +++ b/marker2/ds9/EFTA00089393/_page_27_Picture_20.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:8360e2e036d2e6a7eba4497ec2832f96d6de1ab86340bf66a71e1135bd7af0a9 +size 22733 diff --git a/marker2/ds9/EFTA00089421/EFTA00089421.md b/marker2/ds9/EFTA00089421/EFTA00089421.md new file mode 100644 index 0000000000000000000000000000000000000000..6218c0fc8f335286fb5fd4231a410cd32788f6b8 --- /dev/null +++ b/marker2/ds9/EFTA00089421/EFTA00089421.md @@ -0,0 +1,137 @@ +From: I MM E)' To: "S" Cc: " 11 + +Subject: Re: Notification - Pretrial Services Intake + +Date: Mon, 06 Jul 2020 18:20:46 +0000 + +No worries, thanks. I'll be in touch with defense counsel later as well. + +U.S. Pretrial Services + +> On Jul 6, 2020, at 1:58 PM, a) a wrote: > Apologies, I had already sent the email to defense counsel before receiving your request below. > AUSA will be arguing on behalf of the Government at the bail hearing and would be the best person to speak with regarding this case. You can reach her this evening at + +> Thanks, + +> + +> Original Message + +> From: + +> Sent: Monday,July 6, 2020 1:34 PM + +> To: + +> Cc: + +> Subject: Re: Notification - Pretrial Services Intake + +> Please provide a contact number where I can call you about this case this evening. + +> Also when you reach out to defense counsel, only copy me from my office. + +> Thanks + +> retnaServices + +>> On Jul 6, 2020, at 1:30 PM, a) a wrote: + +>> Below please find the completed form for defendant Ghislaine Maxwell (DOB USMS No. 02879-509). We expect Maxwell will be arraigned and have a bail hearing before Judge Nathan this Friday 7/10. + +>> Maxwell arrived in SDNY approximately this morning, and we expect she will be housed at the MDC. I will send a separate email cc'ing Maxwell's attorneys so that they can coordinate with your office to set up an interview. + +>> + +>> Please let me know if you have any questions or need any additional information. + +» Thank + +» AUSA NAME: + +» PHONE NO: + +>> CELL: + +>> + +>> + +>> + +» PHONE NO: + +>> CELL: + +>> + +>> + +>> + +» PHONE NO: + +>> CELL: + +>> Docket No.: + +» 20 Cr. 330 (AJN) + +» If Indicted: Yes + +>> USDJ: Nathan + +>> Referred to Mag Court for Arraignment: [Yes/No] + +>> Charge(s): + +>> 18 U.S.C. 371 (conspiracy to entice minors to travel to engage in + +» illegal sex acts) + +>> 18 U.S.C. 2422 (enticement of a minor to travel to engage in illegal + +>> sex acts) + +>> 18 U.S.C. 371 (conspiracy to transport minors with intent to engage in + +» illegal sex acts) + +>> 18 U.S.C. 2423(a) (transportation of a minor with intent to engage in + +» illegal sex act) + +» 18 U.S.C. 1623 (perjury) + +>> \*\* attach Complaint/Indictment to this email " + +» D Counsel Name + +» D Counsel Contact Info + +» + +>> Ghislaine Maxwell + +» Retained + +>> Chris Everdell + +» Mark Cohen + +» Interpreter Required? No + +» If Yes, Language: + +>> Location/ETA of Defendant(s): MDC + +>> Other Remarks: + +» Please see attached motion for detention + +»Assistant United States Attorney + +>> Southern District of New York + +>> c2020-07-02, United States + +>> v. Maxwell, 20 Cr. 330 (AJN), detention memorandum.pdf> \ No newline at end of file diff --git a/marker2/ds9/EFTA00089421/EFTA00089421.metadata.json b/marker2/ds9/EFTA00089421/EFTA00089421.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..eb8c7978b91197035d4b8d7f1f561213c3297b1a --- /dev/null +++ b/marker2/ds9/EFTA00089421/EFTA00089421.metadata.json @@ -0,0 +1,114 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089421.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 2599, + "elapsed_seconds": 2.46, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 63 + ], + [ + "Line", + 29 + ], + [ + "Text", + 26 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 77 + ], + [ + "Text", + 52 + ], + [ + "Line", + 39 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 35 + ], + [ + "Text", + 31 + ], + [ + "Line", + 18 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089421" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089424/EFTA00089424.md b/marker2/ds9/EFTA00089424/EFTA00089424.md new file mode 100644 index 0000000000000000000000000000000000000000..0d3fff9029c9f719fe08e7c5a0bdf2217c456217 --- /dev/null +++ b/marker2/ds9/EFTA00089424/EFTA00089424.md @@ -0,0 +1,37 @@ +To: Cc: + +Subject: RE: Ghislaine Maxwell + +Date: Mon, 06 Jul 2020 21:35:00 +0000 + +On a lighter note, the other day when I first saw this email, I hadn't seen the initial one from -nd just saw on my phone a response from to what looked to me, at a glance, to be from a "NYMag" email address, and I was ... very confused by the response, for like a half a second. + +From + +Sent: Thursda , Jul 02, 2020 17:23 + +To + +Subject: RE: Ghislaine Maxwell + +Thank you very much for reaching out. We very much appreciate your support, and we will reach out should we learn of viable state-level charges that are not already covered by our federal investigation. + +dim + +Assistant United States Attorney Southern District of New York I St. Andrew's Plaza New York. NY 10007 + +From + +Sent: Thursday, July 2, 2020 10:15 AM + +To: + +Cc: + +Subject: Ghislaine Maxwell + +■ + +**I learned through the media that Ghislaine Maxwell was arrested today and is facing Federal charges. Please know that the New Mexico Office of the Attorney General stands ready to assist with this Federal prosecution as needed, and also stands willing to move forward on any State-level charges, should any viable charges exist.** + +**Please do not hesitate to contact myself or Chief Deputy District Attorney (included on this email) should you wish to discuss this matter. Have a good day.** \ No newline at end of file diff --git a/marker2/ds9/EFTA00089424/EFTA00089424.metadata.json b/marker2/ds9/EFTA00089424/EFTA00089424.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..9d1c79c20e1603a4e6ea20424b6a858bae729d29 --- /dev/null +++ b/marker2/ds9/EFTA00089424/EFTA00089424.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089424.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 1333, + "elapsed_seconds": 0.97, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 66 + ], + [ + "Line", + 31 + ], + [ + "Text", + 22 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 5 + ], + [ + "Line", + 3 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089424" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089426/EFTA00089426.md b/marker2/ds9/EFTA00089426/EFTA00089426.md new file mode 100644 index 0000000000000000000000000000000000000000..2832470363d104ccb2aa8839cc5a84cbc6523a60 --- /dev/null +++ b/marker2/ds9/EFTA00089426/EFTA00089426.md @@ -0,0 +1,39 @@ +Cc: " < + +Subject: Notification - Pretrial Services Intake + +Date: Mon, 06 Jul 2020 17:29:10 +0000 + +Attachments: Maxwell\_Indietment,\_20\_Cr.\_330\_(AJN).pdf: 2020-07- 02,\_United\_States\_v.ffiaxwell,\_20\_Cr.\_330\_(AJN),\_detention\_memorandum.pdf + +Good afternoon, + +Below please find the completed form for defendant Ghislaine Maxwell (DOB -; USMS No. 02879-509). We expect Maxwell will be arraigned and have a bail hearing before Judge Nathan this Friday 7/10. Attached please find the indictment and the Government's motion for detention. + +Maxwell arrived in SDNY approximately this morning, and we expect she will be housed at the MDC. I will send a separate email cc'ing Maxwell's attorneys so that they can coordinate with your office to set up an interview. + +Please let me know if you have any questions or need any additional information. + +Thank you, Maurene + +| AUSA NAME: | [REDACTED] | PHONE NO:
    CELL: | [REDACTED] | [REDACTED] | [REDACTED] | +|-------------------|------------|----------------------------------|------------|------------|------------| +| | [REDACTED] | PHONE NO:
    CELL: | [REDACTED] | [REDACTED] | [REDACTED] | +| | [REDACTED] | PHONE NO:
    CELL: | [REDACTED] | [REDACTED] | [REDACTED] | + +| Docket No.: | 20 Cr. 330 (MN) | +|------------------|-------------------------------------------------------------------------------------| +| If Indicted: Yes | USDJ: Nathan Referred to Mag Court for | +| Charge(s): | 18 U.S.C. 371 (conspiracy to entice minors to travel to engage in illegal sex acts) | + +| | DEFENDANT | D Counsel | | | +|---|---------------------|-----------|----------------|-----------| +| | | | D Counsel Name | D Counsel | +| 1 | I Ghislaine Maxwell | Retained | Chris Everdell | | + +| | | Mark Cohen | | +|------------------------------------------|--|-------------------------------------------------------------------|--| +| Interpreter Required? No | | If Yes, Language: | | +| Location/ETA of Defendant(s): MDC | | Other Remarks:
    Please see attached motion for detention | | + +Assistant United States Attorney Southern District of New York \ No newline at end of file diff --git a/marker2/ds9/EFTA00089426/EFTA00089426.metadata.json b/marker2/ds9/EFTA00089426/EFTA00089426.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..8ee32c938a0b4da19b0ba014e0f56f2f91075e80 --- /dev/null +++ b/marker2/ds9/EFTA00089426/EFTA00089426.metadata.json @@ -0,0 +1,92 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089426.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2551, + "elapsed_seconds": 1.35, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 79 + ], + [ + "Line", + 39 + ], + [ + "Text", + 9 + ], + [ + "Table", + 3 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 13 + ], + [ + "Line", + 7 + ], + [ + "Text", + 6 + ], + [ + "Table", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089426" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089428/EFTA00089428.md b/marker2/ds9/EFTA00089428/EFTA00089428.md new file mode 100644 index 0000000000000000000000000000000000000000..7187b81ee4caa86b683a841d73b3a005038fcb22 --- /dev/null +++ b/marker2/ds9/EFTA00089428/EFTA00089428.md @@ -0,0 +1,13 @@ +From: ' (USANYS)" <=EIMIE> + +To: ' ,. .. + +Subject: called and wants to do a claim for Crime Victims compensation + +Date: Thu, 09 Jul 2020 16:45:17 +0000 + +Victim of Epstein. + +I sent her the Florida application and will follow up with her. + +Victim Witness Coordinator United States Attorney's Office Southern District of New York \ No newline at end of file diff --git a/marker2/ds9/EFTA00089428/EFTA00089428.metadata.json b/marker2/ds9/EFTA00089428/EFTA00089428.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..3f6452b5edcdaa5d6f16240b563a259c74fdd119 --- /dev/null +++ b/marker2/ds9/EFTA00089428/EFTA00089428.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089428.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 325, + "elapsed_seconds": 0.44, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 23 + ], + [ + "Line", + 11 + ], + [ + "Text", + 8 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089428" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089429/EFTA00089429.md b/marker2/ds9/EFTA00089429/EFTA00089429.md new file mode 100644 index 0000000000000000000000000000000000000000..d319d9d4764a623893497f19f683c8fde748a7ff --- /dev/null +++ b/marker2/ds9/EFTA00089429/EFTA00089429.md @@ -0,0 +1,29 @@ +**From:** "[REDACTED]" <[REDACTED]> +**To:** "[REDACTED] (USANYS)" <[REDACTED]>, "[REDACTED]" <[REDACTED]> +<[REDACTED]>, "[REDACTED]" <[REDACTED]> +**Subject:** RE: [REDACTED] called and wants to do a claim for Crime Victims compensation +**Date:** Thu, 09 Jul 2020 16:45:59 +0000 + +--- + +Got it – thanks very much + +--- + +**From:** [REDACTED] (USANYS) <[REDACTED]> +**Sent:** Thursday, July 09, 2020 12:45 +**To:** [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] +[REDACTED] <[REDACTED]> +**Subject:** [REDACTED] called and wants to do a claim for Crime Victims compensation + +Victim of Epstein. + +I sent her the [REDACTED] application and will follow up with her. + +[REDACTED] +Victim Witness Coordinator +United States Attorney's Office +Southern District of New York +[REDACTED] +[REDACTED] +[REDACTED] \ No newline at end of file diff --git a/marker2/ds9/EFTA00089429/EFTA00089429.metadata.json b/marker2/ds9/EFTA00089429/EFTA00089429.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..04b4bece6647a93fa961c1b51a1cdd83b903511f --- /dev/null +++ b/marker2/ds9/EFTA00089429/EFTA00089429.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089429.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 827, + "elapsed_seconds": 3.54, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 41 + ], + [ + "Text", + 19 + ], + [ + "Line", + 19 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089429" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089430/EFTA00089430.md b/marker2/ds9/EFTA00089430/EFTA00089430.md new file mode 100644 index 0000000000000000000000000000000000000000..58d992027b4155fd03f52fa11a79badab879e293 --- /dev/null +++ b/marker2/ds9/EFTA00089430/EFTA00089430.md @@ -0,0 +1,43 @@ +**From:** [REDACTED] > +**To:** [REDACTED] > +**Cc:** [REDACTED] >, [REDACTED] >, [REDACTED] >, [REDACTED] >, [REDACTED] >, [REDACTED] >, [REDACTED] >, [REDACTED] > + [REDACTED] > + + +**Subject:** RE: Epstein Evidence status +**Date:** Thu, 23 Jul 2020 22:08:23 +0000 +**Attachments:** evidenceStatus.xlsx + + +[REDACTED], + +This is very helpful, thank you. Comparing this to the prior spreadsheet, and leaving aside the "Nothing for Southern" designations as well as the NYC numbers that look like they're for the desktops that held the actual drives we're looking at (such as NYC024385, 387, 389, 391, and 393, and NYC027909), I think there are just three additional devices listed here that weren't on the spreadsheet you previously sent. I have those as: + +- - NYC024328 (row 10) +- - NYC024367 (row 62) +- - NYC027910 (row 96) + +Could you please confirm that I have those additions correct, and that I'm not missing any? And it looks like all of those were included in the drive you provided today. + +I also see there are some drives that are still being processed, including NYC024376 through 380 and several drives in NYC024395 – could you please let us know what that means? + +Thanks very much, and we'll circle back if any issues with anything we received today, which should get to [REDACTED] in the next day or two. + +thanks again, + +[REDACTED]. + +-----Original Message----- + +**From:** [REDACTED] > +**Sent:** Thursday, July 23, 2020 14:44 +**To:** [REDACTED] > +**Cc:** [REDACTED] >; [REDACTED] > +**Subject:** Epstein Evidence status + + +[REDACTED] + +Here is the up to date spreadsheet. I color coded things to hopefully make it easier. There are 5 items I have to get you (as we discussed this morning) Those should take another day or 2, so looking at Monday/Tuesday for that. 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a.m. + +Assistant United States Attorney + +Acting Grand Jury Reporter + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +(10:05 a.m.) + +MS. Let the record reflect that there are 17 grand jurors present and that the foreperson is present. + +Good morning, ladies and gentlemen. My name is and I am an Assistant United States Attorney here in the Southern District of New York. + +Can everyone hear me okay? All right. I SP everybody's heads nodding. Thank you. + +I am here today to present for your consideration a proposed superseding indictment charging Ghislaine Maxwell in six counts. This indictment is virtually identical to the indictment that you returned last week charging Maxwell in those same six counts except that it corrects two clerical errors, or two typographical errors that were contained in Counts Five and Six which are the perjury charges. + +As a result, I will not be presenting any net,. evidence or new witnesses today. Instead, I will identify for you those two clerical errors in the indictment. I will point out the portion of the exhibits that you saw last week that provide the correct information. Then I will identify the corrected portion of the superseding indictment in the proposed superseding indictment. + +Before I do that though, I must ask you all the + +1 2 3 4 same preliminary questions that we went over last week. First, do any of you believe that you personally know or have met the proposed defendant, Ghislaine Maxwell? I see no hands. + +5 6 7 8 9 Next, have you any heard or read about, or learned anything Ghislaine Maxwell, Jeffrey Epstein or anyone else related to this case, if you could just raise your hand? I see a number of hands. Virtually every hand is in the air. You can all put your hands down. Thank you. + +10 11 12 13 14 15 16 17 As you know, you must make your determination as a grand jury based on the evidence presented before you in the grand jury, in this room alone. Accordingly, you must set aside any other knowledge you may have about this case or the people involved in it, and base your decision solely on the evidence presented to this grand jury to determine whether there is probable cause to believe that the charges in the proposed indictment were committed. + +18 19 20 21 22 23 Is there any grand juror here today who cannot follow these instructions? I see no hands. Just to be sure, is there any grand juror here who would have any difficulty setting aside the outside information you may have about the defendant or the facts of this case? I see no hands. + +24 25 Finally, do any of you believe you know me in anything other than my professional capacity? I see no + +2 3 4 5 6 7 Now, as I mentioned, I will not be calling any witnesses today. Instead I will present you with the exhibits from last week, the transcript of the testimony you heard from last week and the proposed superseding indictment. I will then walk you through the error that the superseding indictment seeks to correct. + +8 9 10 11 12 13 Please keep in mind though that what I say is not evidence. Only the testimony of the witnesses and the exhibits are evidence. So as I'm walking you through thescexhibits, your understanding of them and your understanding of the evidence controls. I am just trying to provide you with an overview. + +14 15 16 17 18 With that instruction in mind, I am going to put up onto the Elmo what was previously received and marked as Grand Jury Exhibit 1. That is the proposed six-count indictment that you voted to return last week. A copy of it will be available for review when you deliberate. + +19 20 21 22 23 24 You also received what has been marked as Grand Jury Exhibit 2, which I will not put up on the Elmo. That was a PowerPoint presentation containing photographs and excerpts of certain documents that was shown to you during the testimony last week. You also heard testimony from FBI Special Agent- + +25 Today I am marking, as Grand Jury Exhibit 3, + +1 2 3 4 copy of the transcript of that testimony. It is up on tnr Elmo now and it will be available for you to review if you would like as you deliberate. I will not read it back to you now, but you can read through it as you deliberate. + +5 6 7 8 9 Finally, I am marking, as Grand Jury Exhibit 4, the proposed superseding indictment, which I have now placed up on the Elmo. As I mentioned, this proposed superseding indictment corrects two clerical errors and is otherwise identical to the original indictment, Grand Jury Exhibit 1. + +10 11 12 13 14 15 16 I'm now going to walk you through the errors that we're going to correct starting on Grand Jury Exhibit 1. Page 15 contains the beginning of Count Five which charges Maxwell with perjury. Paragraph 21 on that page refers to the civil case in which Maxwell gave deposition testimony on April 22nd, 2016, as 15 Civ. 7344. That is the error we are going to correct. + +17 18 19 20 21 Similarly, page 16 contains the beginning of Count Six which charges another count of perjury. Paragraph 23 on that page refers to the civil case in which Maxwell gave deposition testimony on July 22nd, 2016, under the same number, 15 Civ. 7344. + +22 23 24 25 Turning now to Grand Jury Exhibit 2. Slide 22 of that exhibit contains the first page of the deposition transcript from the testimony that Maxwell gave on April 22nd, 2016. As you can see here, the docket number + +2 3 4 5 Similarly, slide 25 contains the first page of the transcript from the July 22nd, 2016 deposition that Maxwell gave. As you can see here, again, the docket number for that case is 15 Civ. 7433 not 7344. + +6 7 8 9 Finally, I will turn to the proposed indictment, Grand Jury Exhibit 4. On page 15, you have again the same perjury count with one change. Paragraph 21 corrects the docket number for the civil case to be 15 Civ. 7433. + +10 11 12 13 Similarly, on page 16, which contains the second perjury count for the July 22nd, 2016 deposition, the docket number is corrected to 15 Civ. 7433. There are otherwise no changes to the substance of this indictment. + +14 15 16 That is my presentation. Before I leave you to deliberate, would anyone like me to read the full proposed superseding indictment out loud? I see no hands. + +17 18 19 20 21 22 I must advise you that you must independently find probable cause, again, for each count in the superseding indictment. The evidence before you in support of the charges in the superseding indictment is the same evidence that was before you when you considered the indictment last week. + +23 24 Does anyone have any questions about that evidence? I see no hands. + +25 The legal instructions that you received before + +1 2 3 4 voting on the indictment last week are the same instructions that apply to your consideration of the proposed superseding indictment. Would anyone like me to read those instructions out loud for you again? I see no hands. + +5 6 Does anyone have any questions about the legal instructions? I see no hands. + +7 8 9 10 11 12 I will leave you now with the exhibits to deliberate. As always, if you have any questions or concerns about the proposed indictment, please let me kno.v, before you vote so that I may answer any questions you may have on the law, or bring any additional evidence before you to consider. Thank you, all. + +13 (Matter concluded) + +14 (Time Noted: 10:14 a.m.) + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +I hereby certify that the foregoing is a true and accurate transcription, to the best of my skill and ability, from my electronic notes of this proceeding. + +July 22, 2020 + +Date + +Acting Grand Jury Reporter Free State Reporting, Inc. \ No newline at end of file diff --git a/marker2/ds9/EFTA00089439/EFTA00089439.metadata.json b/marker2/ds9/EFTA00089439/EFTA00089439.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..b9977c487aaef237189ed3b2aee1ba062cc71e5f --- /dev/null +++ b/marker2/ds9/EFTA00089439/EFTA00089439.metadata.json @@ -0,0 +1,393 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089439.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + 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States government's memorandum and notably pages 15 to 17 alongside the French Minister of Justice's letter dated 11 December 2020 produced as Exhibit B to this memorandum. + +## 1 The French Minister of Justice's letter (Exhibit B) + +The letter of the French Minister of Justice, on which the US government relies to argue that the French government does not extradite its citizens outside the European Union and thus to the United States, quotes Article 696-2 of the French Code of Criminal Procedure, which provides that France can extradite "any person not having French nationality". + +It remains unclear whether the author of such letter had actually access to my opinion which is not even quoted, and more generally it seems the letter responds to a question which unexpectedly was not disclosed. + +The letter fails to mention, however, that Article 696 of the same Code provides that provisions of the French Code of Criminal Procedure on the conditions of extradition apply in the absence of an international agreement providing otherwise (Article 696 of the French Code of Criminal Procedure: "In the absence of an international agreement stipulating otherwise, the conditions, procedure and effects of extradition shall be determined by the provisions of this chapter'. These provisions shall also apply to matters which would not have been regulated by international conventions"). The provisions of Article 696 of the French Code of Criminal Procedure are a reminder that under Article 55 of the French Constitution, international agreements prevail over national legislation (Article 55 of the French Constitution: "Treaties or agreements that have been duly ratified or approved have, upon their publication, an authority superior to that of laws, subject, for each agreement or treaty, to its application by the other party"). It follows from these provisions that the key question is whether France may extradite a French national under the Extradition Treaty between the USA and France and/or under the Extradition Treaty between the European Union and the USA, not whether France extradites its citizens under French legislation. + +In accordance with this French constitutional rule, the administrative circular of 11 March 2004, published by the French Ministry of Justice, which aims at specifying how the then recently amended legal provisions regarding extradition should apply and be understood, states the following: "Article 696 of the Code of Criminal Procedure reaffirms this principle of + +I The relevant chapter includes Articles 696- I to Article 696.47-1 of the French Code of Criminal Procedure, and thus includes Article 696.2. + +subsidiarity of domestic law in relation to international instruments as stated by the aforementioned law of 10 March 1927: the legislative provisions on extradition are applicable only in the silence or in the absence of international conventions.' + +It follows from the provisions of Article 696 of the French Code of Criminal Procedure that the key question is whether France may extradite a French national under the Extradition Treaty between the USA and France and/or under the Extradition Treaty between the European Union and the USA, not whether France may extradite its citizens under French legislation. + +As previously outlined, the Extradition Treaty between the USA and France does not preclude the French government from extraditing a French national and must therefore be distinguished from a number of other international agreements signed by France which contain a clear prohibition to that extent. The Treaty between the USA and France gives the French government discretion as to whether or not to extradite its own citizens to the USA. + +It is noted that the letter of the French Minister does not provide any answer on this issue. + +## 2 The DOJ Memorandum and the Peterson Case + +In support of its argument that the French government would not extradite Ms Ghislaine Maxwell to the USA, the government relies on the case of Mr Hans Peterson, a dual French American citizen whose extradition to the US was denied by France in 2007. + +The Peterson precedent should only be cited with great caution. First, I am not aware that this case has given rise to a published judicial decision, therefore it should not be interpreted as the support of any legal rule or principle. In addition, in regards to the documents that the DOJ has referred to in its memorandum, I doubt that a judicial decision has ever occurred in this case: as mentioned by the 2007 letter of US Senators Richard J. Durbin and Barack Obama to the French Minister of Foreign Affairs, the French Minister of Justice communicated its decision refusing extradition on August 22nd 2007, only a few days after the suspect was arrested (at the beginning of August 2007). This decision is not a Court decision but a discretionary decision from the French Ministry of Justice. It actually seems very unlikely that a court decision could have been rendered in this timeframe. This indicates that the case must not have been handed on to the court by the Ministry of Justice in the earliest stage of the extradition process. + +A refusal to extradite may possibly be challenged by the requesting government before the French Conseil d'Etat, which is the French Supreme Court for administrative matters, as for example the United Kingdom and Hong Kong successfully challenged a decision from the French authorities not to extradite an individual whose extradition they had requested (Conseil d'Etat, 15 October1993, no. 142578). In the Peterson case, the American government did not + +2 Circulaire Mandat d'arret europeen et Extradition n° CRIM-04-2/CAB-I 1.03.2004 du I I mars 2004 + +challenge the refusal before French courts, while such challenge could have led to a judicial review of the request, in accordance with the ordinary extradition procedure. + +Secondly, in the absence of a published judicial decision, it is impossible to determine what the outcome of this case would have been if it had come before the courts. + +Third, as was rightly pointed out by US Senators Richard J. Durbin and Barack Obama in their aforementioned letter to the French Minister of Foreign Affairs, which the government cites in its memorandum: + +"Article 3 of the Extradition Treaty between the United States and France provides in pertinent pan that "There is no obligation upon the Requested State to grant the extradition of a person who is a national of the Requested State". While this Article does not require the extradition of a national to a requesting state, it also does not appear to preclude extradition. To the extent there is discretion available in such extradition decisions, we urge the French government to exercise that discretion in favor of extradition". + +I am satisfied that this is the right interpretation of Article 3, as this is exactly the conclusion I came to in my first report. To the extent that there is a discretion, there can be no absolute rule against the extradition of nationals under French law. A discretionary power is not a legal rule. Indeed, there is no constitutional principle against the extradition of nationals. For these reasons, the Peterson case does not alter my view that under the specific and unique facts of this case, it is highly unlikely that the French government would refuse to issue and execute an extradition decree against Ms. Maxwell, particularly if Ms. Maxwell has signed an irrevocable waiver in the USA. + +Finally, if an extradition request were to be issued against a French citizen today, the obligations of the French government under the Extradition Treaty between the USA and France would also need to be read in light of the Agreement on extradition between the European Union and the United States of America, which came into force on February I', 2010, several years after the Peterson case. Article 1 of this Agreement, which enhances cooperation between Contracting Parties, provides that: "The Contracting Parties undertake, in accordance with the provisions of this Agreement, to provide for enhancements to cooperation in the context of applicable extradition relations between the Member States and the United States of America governing extradition of offenders". The existence of this Agreement would need to be taken into account by the French government in the exercise of its discretion as to whether or not to grant the extradition of a French national to the USA. + +William JULIE \ No newline at end of file diff --git a/marker2/ds9/EFTA00089447/EFTA00089447.metadata.json b/marker2/ds9/EFTA00089447/EFTA00089447.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..58ad8078fadc54c3e1f2cd3d82d9724de8780ef8 --- /dev/null +++ b/marker2/ds9/EFTA00089447/EFTA00089447.metadata.json @@ -0,0 +1,265 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089447.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 4, + "chars": 8669, + "elapsed_seconds": 0.86, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Exhibit A", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 206.24400000000003, + 203.31 + ], + [ + 411.98773193359375, + 203.31 + ], + [ + 411.98773193359375, + 255.03216552734375 + ], + [ + 206.24400000000003, + 255.03216552734375 + ] + ] + }, + { + "title": "Response to the government's memorandum in opposition to the defendant's renewed \nmotion for release.", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 67.23500000000001, + 127.57600000000001 + ], + [ + 512.6263427734375, + 127.57600000000001 + ], + [ + 512.6263427734375, + 159.603515625 + ], + [ + 67.23500000000001, + 159.603515625 + ] + ] + }, + { + "title": "1 The French Minister of Justice's letter (Exhibit B)", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 67.23500000000001, + 234.46400000000003 + ], + [ + 366.4849548339844, + 234.46400000000003 + ], + [ + 366.4849548339844, + 251.103515625 + ], + [ + 67.23500000000001, + 251.103515625 + ] + ] + }, + { + "title": "2 The DOJ Memorandum and the Peterson Case", + "heading_level": null, + "page_id": 2, + "polygon": [ + [ + 66.64, + 359.454 + ], + [ + 350.1539001464844, + 359.454 + ], + [ + 350.1539001464844, + 376.3535461425781 + ], + [ + 66.64, + 376.3535461425781 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 3 + ], + [ + "Line", + 2 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 87 + ], + [ + "Line", + 40 + ], + [ + "Text", + 6 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "Footnote", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 82 + ], + [ + "Line", + 39 + ], + [ + "Text", + 7 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "SectionHeader", + 1 + ], + [ + "Footnote", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 3, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 77 + ], + [ + "Line", + 39 + ], + [ + "Text", + 8 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089447" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089451/EFTA00089451.md b/marker2/ds9/EFTA00089451/EFTA00089451.md new file mode 100644 index 0000000000000000000000000000000000000000..e5fe8193d92d82b97548d747b4dbb9b431f6f26d --- /dev/null +++ b/marker2/ds9/EFTA00089451/EFTA00089451.md @@ -0,0 +1,228 @@ +Thurgood Marshall U.S. Courthouse 40 Foley Square, New York, NY 10007 Telephone: 212-857-8500 + +MOTION INFORMATION STATEMENT + +Docket Number(s): 21-770/21-58 + +Caption [use short title] + +Motion for: Renewed Motion for Pretrial Release + +Set forth below precise, complete statement of relief sought: + +Ghislaine Maxwell renews her motion for pretrial + +release or in the alternative, remand for an evidentiary + +hearing. + +United States of America v. Ghislaine Maxwell + +MOVING PARTY: Ghislaine Maxwell + +OPPOSING PARTY: United States of America + + Plaintiff + + Defendant + + Appellant/Petitioner + + Appellee/Respondent + +MOVING ATTORNEY: David Oscar Markus + +OPPOSING ATTORNEY: [REDACTED], AUSA + +[name of attorney, with firm, address, phone number and e-mail] + +Markus/Moss PLLC + +United States Attorney's Office, So. Dist. of NY + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +Court- Judge/ Agency appealed from: Alison J. Nathan, Southern District of New York + +Please check appropriate boxes: + +Has movant notified opposing counsel (required by Local Rule 27.1): + + Yes No (explain): + +Opposing counsel's position on motion: + + Unopposed Opposed Don't Know + +Does opposing counsel intend to file a response: + + Yes No Don't Know + +Is oral argument on motion requested? + + Yes No (requests for oral argument will not necessarily be granted) + +Has argument date of appeal been set? + + Yes No If yes, enter date: + +Signature of Moving Attorney: + +/s/ David Oscar Markus + +Date: 5/17/2021 + +Service by: CM/ECF Other [Attach proof of service] + +--- + +No. 21-770 & 21-58 + +In the +**United States Court of Appeals** +**for the Second Circuit** + +**UNITED STATES OF AMERICA,** + +Appellee, + +v. + +**GHISLAINE MAXWELL,** + +Appellant. + +On Appeal from the United States District Court +for the Southern District of New York, 20-CR-330 (AJN) + +--- + +**Appellant Ghislaine Maxwell's Renewed +Motion for Pretrial Release** + +--- + +Leah S. Saffian +**LAW OFFICES OF LEAH SAFFIAN** + +[REDACTED] + +[REDACTED] + +David Oscar Markus +*\*Counsel of Record* + +[REDACTED] + +[REDACTED] + +[REDACTED] + +markuslaw.com + +--- + +## Appellant Ghislaine Maxwell's Renewed Motion for Bond + +Although this Court denied Ghislaine Maxwell's motion for bond (see Ex. A, Order, April 27, 2021), it appeared concerned with the conditions of her confinement during oral argument and instructed Ms. Maxwell that "[t]o the extent Appellant seeks relief specific to her sleeping conditions, such request should be addressed to the District Court." (Id.). + +Ms. Maxwell did just that, explaining again to the trial judge the grueling conditions of her confinement, which includes shining a flashlight in Ms. Maxwell's eyes every 15 minutes, over the past 318 days in solitary confinement, even though she is not suicidal and even though no other inmate suffers such abuse. Ex. C, Doc. 256. The government responded, Ex. D, and although it previously intimated that Ms. Maxwell might be suicidal (she's not), it now said that the sleep deprivation was justified because she is housed alone, because of the nature of the charges, and because the case is high-profile. Not one of these reasons makes any sense upon any examination. The government did not provide an affidavit from anyone at the jail or explain why depriving Ms. Maxwell + +of sleep would alleviate her stress instead of exacerbate it. Ms. Maxwell replied. Ex. E, Doc. 272. + +The district court then issued an order saying that it would not tell the Bureau of Prisons what to do but "admonishe[d] the MDC and the Government to continue to ensure that Maxwell is subjected to only those security protocols that BOP determines are necessary for her safety and security, based upon neutral and applicable factors, and consistent with the treatment of similarly situated pre-trial detainees." Ex. B, Doc. 282. + +But Ms. Maxwell is not being treated like any other detainee. And the horrific conditions make it impossible to prepare for trial. Accordingly, we renew our motion for bond and seek relief from this Court. Ms. Maxwell simply wants a fair opportunity to fight the charges against her at trial. + +Currently, she (1) can't sleep because the guards wake her every 15 minutes; (2) oftentimes can't drink the water because it is brown and contains particles; (3) can't meet in person with her lawyers because the guards use a handheld camera to video and audio tape record the meetings; (4) can't manage the smell of overflowing sewage that comes up from the drain in her unit; (5) can't keep the guards from seizing and going through her attorney-client materials; and (6) can't search, print, highlight, or sort the discovery because the "computer" she was given was stripped down and does not have the proper software or hardware capabilities. The truth is that Ms. Maxwell is not being treated in a humane fashion and cannot prepare for trial under these horrific conditions. She has been in solitary confinement with no sleep for almost a year. The presumption of innocence has been turned on its head. This Court should either order her temporary release under 18 U.S.C. 3142(i) or remand this matter and order the trial court to conduct an evidentiary hearing on the conditions of her confinement. + +It is important to underscore that the government has made a number of representations to the trial court and to this Court about the conditions of Ms. Maxwell's detention that have proven to be false. + +1. Government misrepresentation to the district court: "The defendant wears an eye mask when she sleeps, limiting the disturbance caused by the flashlight [every fifteen minutes]." Doc. 196 (April 6, 2021, gov't letter to district court). But the truth is that she has no "eye mask" and the government has now admitted that eye masks are "contraband" in the jail and that she cannot have one. Doc. 270 (May 5, 2021, gov't + +letter to district court) ("MDC legal counsel has informed the government that the defendant cannot be provided with an eye mask."). So Ms. Maxwell tries to shield her eyes with a sock or towel. Trying to sleep with an unsecured sock over your eyes in an attempt to shield yourself from flashlights searches every 15 minutes makes restful sleep impossible. + +![](_page_5_Picture_1.jpeg) + +The above picture shows how Ghislaine Maxwell looked before her arrest in July 2020 (left) and how she looks now after 10 debilitating months of tortuous conditions at MDC Brooklyn where, just as an example, she is not permitted to sleep. Ex. C, Doc. 256. + +2. Government misrepresentation to this Court during oral argument when asked if shining lights in Ms. Maxwell's face every fifteen minutes during the night was routine: "My understanding, Your Honor, is that that is a routine; it is routine by BOP officials." But then in a letter to the district court, the government admitted that Ms. Maxwell is the only inmate who receives these targeted flashlight checks every 15 minutes. Doc. 270 ("MDC staff conduct flashlight checks every fifteen minutes [only for Ms. Maxwell] because the defendant, while not on suicide watch, is on an enhanced security schedule."). + +In a response that would make Orwell's Ministry of Truth proud, the government tries to spin this and argue that other inmates are also periodically checked throughout the night. Doc. 270 (stating — without an affidavit or other actual sworn testimony — that in general population, checks are usually done about once an hour). + +But try as it might, the government cannot escape the bottom line that Ms. Maxwell is the only person who is treated this way and wakened every 15 minutes while in solitary confinement. In fact, the government then tries to justify the treatment by saying — again without support or an affidavit — that even though Ms. Maxwell is not suicidal, she should be singled out in this way because she is alone, the nature of the charges, and that this is high profile case. But those reasons, individually or collectively, do not justify torturing someone by depriving them of sleep. Nevertheless, the district judge did not conduct a hearing or otherwise question BOP. It simply allowed the government to file a letter saying that this is what was relayed to the government from the jail lawyer from the jail guards. Even if that hearsay was true (which should be questioned based on other representations made by BOP to the government to the court), it is not at all sufficient for this type of treatment. + +3. Government misrepresentation to the district court: Ms. Maxwell "caused [her] cell to smell" by not flushing the toilet. Doc. 196, n.2 (April 6, 2021, gov't letter to district court). This claim is absurd, of course, and was again made without any sworn statement. Ms. Maxwell responded and explained that the smell of sewage was caused by the conditions in MDC and not by her. + +This was recently corroborated by another MDC inmate, Tiffany Days, who explained to Judge McMahon the sorts of conditions that are present at MDC: "I also survived the disgusting feces flood that we were + +actually told to clean with our own hands. It was humiliating. Floating, dead water bugs, mice, chunks of defecation coming out of the pipes and urine-filled water gushing all through the area. The water was as high as my ankles, and the smell was as bad. It was so bad, the inmates were vomiting due to nausea. Chunks of feces. And officers telling us that we had to clean it and clean it quick because lunch was on the way." She continued: "MCC and MDC are the most degrading and humiliating memories of my life. I will hold onto these memories forever, but these memories are my motivation to stay out of trouble, your Honor." United States v. Tiffany Days, April 29, 2021, which can be accessed at: https://tinyurl.com/ytf8cyw5. The judge in that case was upset, finding: "it is the finding of this Court that the conditions to which [Tiffany Days] was subjected are as disgusting, inhuman as anything I've heard about in any Colombian prison, but more so because we're supposed to be better than that." See transcript of sentencing hearing, United States v. Tiffany Days, April 29, 2021, which can be accessed at: https://tinyurl.com/48yw29px. + +4. BOP false accusation to the district court concerning Ms. Maxwell's lawyers: "Those [privileged] materials that defense counsel + +gave to Ms. Maxwell contrary to MDC Brooklyn's legal visit procedures were confiscated by staff..." Doc. 259. Ms. Maxwell's lawyers showed this was false and that they did not give anything to Ms. Maxwell. Doc. 258. In addition, there was a videotape of the incident. But the government refused to review it and refused to provide it to the court. The defense insisted on having a hearing and that it be provided with the videotape of the attorney-client visit so that it could show that the MDC statements to the government were false. The court declined to have a hearing or order the videotape turned over. The truth is actually out there. We simply want an opportunity to demonstrate it at a hearing. + +Ironically, the court then blamed the defense for failing to provide proof of its claims. The defense has, over and over again, requested hearings and that the videotapes of what is occurring in jail be produced. But the district court said that the defense "describes generalized grievances but makes no additional specific and supported application for relief." Doc. 282. This is an odd reason to deny Ms. Maxwell relief, especially where even the government admits that guards flash a light in Ms. Maxwell's cell every 15 minutes and that she is not provided an eye mask. We have said and continue to say that we would like production of the evidence and a hearing so that we may demonstrate our other claims. These requests have been denied. In any event, the government does not even deny most of the allegations we have made — Ms. Maxwell is being kept up at night, that oftentimes the water is undrinkable, that the food is not delivered or inedible, that her computer cannot perform the necessary tasks to prepare for trial, and so on. + +Instead, the government simply says that the district judge is managing Ms. Maxwell's conditions. Again, that is just not true. The district court has made it clear — again in its latest order — that it won't tell BOP what to do, even though BOP has not justified in any way the treatment that Ms. Maxwell is receiving. As we have said from the start, everyone knows the real reason she is being subjected to these abusive tactics: because Jeffrey Epstein died on BOP's watch and it is going to treat Ms. Maxwell as though she is Epstein. + +In sentencing another woman who was held at MDC, District Judge Colleen McMahon said the defendant "shouldn't have to suffer for the incompetence of the United States Department of Justice and its subsidiary agency, the Bureau of Prisons. I will do what I can to bring your situation to the people who, if they give a damn, might do + +something." See transcript of sentencing hearing, United States v. Tiffany Days, April 29, 2021, which can be accessed at: https://tinyurl.com/48yw29px. + +We are appealing to this Court to do something, as Judge McMahon pleaded. Ghislaine Maxwell has a Constitutional right to be able to prepare effectively for trial. The conditions of her pretrial detention deprive her of that right. For almost a year, she has been held in the equivalent of solitary confinement, in deteriorating health and mental condition from lack of sleep because she is intentionally awakened every 15 minutes by lights shined directly into her small cell, inadequate water and food, the constant glare of neon light, and intrusive searches, including having hands forced into her mouth in a squalid facility where COVID has run rampant. + +Ms. Maxwell understands that she and the government are not going to agree on the facts. This is an adversary system, of course. But when the government's representations about the conditions of confinement continue to be demonstrably and admittedly false, there needs to be an intervention. If the Court is not prepared to temporarily release Ms. Maxwell on bond so that she can prepare for trial, it should + +order the district court to conduct a hearing on the conditions of her confinement so that the defense can make the appropriate showing. + +Respectfully submitted, + +**LAW OFFICES OF LEAH SAFFIAN** + +[REDACTED] +[REDACTED] +[REDACTED] + +**MARKUS/MOSS PLLC** + +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] + +By: /s/ Leah S. Saffian + +markuslaw.com + +LEAH S. SAFFIAN + +California Bar Number [REDACTED] + +By: /s/ David Oscar Markus + +DAVID OSCAR MARKUS + +Florida Bar Number [REDACTED] + +dmarkus@markuslaw.com + +## CERTIFICATE OF COMPLIANCE + +I CERTIFY that this petition complies with the type-volume limitation of FED. R. APP. P. 27. 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Saffian LAW OFFICES OF LEAH SAFFIAN 15546 Meadowgate Road Encino, California 91436-3429 Tel: (858)488-2765 + +David Oscar Markus \*Counsel of Record MARKUS/MOSS PLLC 40 N.W. Third Street, PH 1 Miami. Florida 33128 Tel: mar aw.com + +### Appendix\* + +| App. 86 | Second Circuit Court Order
    April 27, 2021.....A | +|----------|------------------------------------------------------------------------------------------------------------------| +| Doc. 282 | Lower Court Order
    May 14, 2021.....B | +| Doc. 256 | Ghislaine Maxwell letter regarding conditions at
    Metropolitan Detention Center
    April 29, 2021.....C | +| Doc. 270 | Government's Response to Ghislaine Maxwell's conditions
    at Metropolitan Detention Center
    May 5, 2021.....D | +| Doc. 272 | Ghislaine Maxwell's Reply regarding conditions at
    Metropolitan Detention Center
    May 7, 2021.....E | + +\* App. refers to the Appellate docket and Doc. refers to the district docket. + +Respectfully submitted, + +### LAW OFFICES OF LEAH SAFFIAN + +15546 Meadowgate Road Encino, California 91436-3429 Tel: (858)488-2765 + +By: /s/ Leah S. Saffian + +LEAH S. SAFFIAN California Bar Number 121796 + +### MARKUS/MOSS PLLC + +\*Counsel of Record 40 N.W. Third Street, PH 1 Miami. Florida 33128 + +Tel: + +mar us aw.com + +By: /s/ David Oscar Markus DAVID OSCAR MARKUS Florida Bar Number 19318 + +### CERTIFICATE OF SERVICE + +I CERTIFY that a true and correct copy of the foregoing was e-filed this 17th day of May, 2021. + +> /s/ David Oscar Markus David Oscar Markus + +## Exhibit A + +App. 86 + +Second Circuit Court Order + +April 27, 2021 + +21-58-cr (L), 21-770-cr +United States v. Maxwell + +## United States Court of Appeals + +FOR THE +SECOND CIRCUIT + +--- + +At a stated term of the United States Court of Appeals for the Second Circuit, held at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 27th day of April, two thousand twenty-one. + +PRESENT: PIERRE N. LEVAL, +RAYMOND J. LOHIER, JR., +RICHARD J. SULLIVAN, +*Circuit Judges.* + +--- + +United States of America, + +*Appellee,* + +v. + +21-58-cr (L) +21-770-cr + +Ghislaine Maxwell, AKA Sealed Defendant 1, + +*Defendant-Appellant.* + +--- + +Defendant-Appellant Ghislaine Maxwell appeals from orders of the District Court entered December 28, 2020 and March 22, 2021, which denied her renewed requests for bail pending trial. See Dkts. 1, 20. Upon due consideration, it is hereby ORDERED that the District Court's orders are AFFIRMED and that Appellant's motion for bail, or in the alternative, temporary pretrial release pursuant to 18 U.S.C. § 3142(i), Dkt. 39, is DENIED. During oral argument, counsel for Appellant expressed concern that Appellant was improperly being deprived of sleep while incarcerated. To the extent Appellant seeks relief specific to her sleeping conditions, such request should be addressed to the District Court. + +FOR THE COURT: + +Catherine O'Hagan Wolfe, Clerk of Court + +![]() + +### Exhibit B + +Doc. 282 + +Lower Court Order May 14, 2021 + +#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +United States of America, + +—v— + +Ghislaine Maxwell, + +Defendant. + +| USDC SDNY | | +|----------------------|---------| +| DOCUMENT | | +| ELECTRONICALLY FILED | | +| DOC #: | | +| DATE FILED: | 5/14/21 | + +20-CR-330 (MN) + +ORDER + +ALISON J. NATHAN, District Judge: + +On April 29, 2021, counsel for Ghislaine Maxwell wrote to the Court requesting that the Court address her sleeping conditions, with particular emphasis on counsel's representation, unsupported by affidavit or other factual showing, that guards are shining a flashlight in Maxwell's eyes every 15 minutes at night. Dkt. No. 256. Defense counsel claims that the flashlight surveillance in Maxwell's eyes is disrupting her sleep, which in turn is impacting her ability to prepare for and withstand trial. The Court sought more information by ordering the Government to confer with legal counsel for the Bureau of Prisons and to respond to certain questions. Dkt. No. 257. In response, the Government states that MDC staff conduct flashlight checks of all inmates as a matter of course. Dkt. No. 270. As reported by the Government, inmates housed with cell mates in the Special Housing Unit are checked with flashlights every 30 minutes. Inmates housed with others in the general population are checked multiple times per night at regular intervals. The Government further reports that to conduct the checks, flashlights are pointed at the ceiling of the cell to confirm that the inmate is present, breathing, and not in distress. As the Government explains, there are a number of neutral reasons why GOP's flashlight checks of Maxwell are relatively more frequent than those of other inmates, including that Maxwell is housed alone, the nature of the charges, and the potential stress for inmates that + +can arise in high-profile cases. The MDC has determined that these factors necessitate more frequent safety and security checks. The Government also indicates that the prohibition on eye masks is a generally applicable policy, but that Maxwell, like other inmates, may use other noncontraband items to cover her eyes. + +To the extent that Maxwell's April 29, 2021 letter asks the Court to override BOP's determination as to the frequency of appropriate safety and security check procedures, that request is denied as factually unsubstantiated and legally unsupported. Certainly nothing in the record plausibly establishes that current protocols interfere with Maxwell's ability to prepare for her trial and communicate with her lawyers. Defense counsel's May 7, 2021 letter, Dkt. No. 272, describes generalized grievances but makes no additional specific and supported application for relief. Nevertheless, the Court urges the MDC to consider whether sleep disruption for pretrial detainees can be reduced. The Court also admonishes the MDC and the Government to continue to ensure that Maxwell is subjected to only those security protocols that BOP determines are necessary for her safety and security, based upon neutral and applicable factors, and consistent with the treatment of similarly situated pre-trial detainees. + +The Government shall provide a copy of this Order to the Warden and General Counsel for the MDC. + +A 46 Q t Al + +SO ORDERED. + +Dated: May 14, 2021 + +New York, New York ALISON J. NATHAN United States District Judge + +## Exhibit C + +Doc. 256 + +Ghislaine Maxwell letter regarding conditions at Metropolitan Detention Center April 29, 2021 + +![](_page_9_Picture_2.jpeg) + +• Main • cell • Fax + +Honorable Alison J. Nathan United States District Judge United States Courthouse 40 Foley Square New York, NY 10007 + +Dear Judge Nathan: + +33 West 19th Street - 4th Floor New York, New York 10011 + +April 29, 2021 + +Re: United States v. Ghislaine Maxwell S2 20 Cr. 330 (AJN) + +During oral argument of Ghislaine Maxwell's bail appeal before the Circuit, Ms. Maxwell's appellate counsel expressed concern that she was improperly deprived of sleep while detained in the MDC, an issue that has been raised in filings before this Court. In its brief denial of her appeal, the Circuit stated: "To the extent Appellant seeks relief specific to her sleeping conditions, such request should be addressed to the District Court." See Exhibit A. We press our concerns regarding disruption of Ms. Maxwell's sleep and the deleterious effect sleep deprivation is having on her health, well-being, and ability to prepare for and withstand trial. + +Ms. Maxwell continues to be disrupted throughout the night by guards shining a flash/strobe light into her cell, claiming that her breathing must be checked. The myth that Ms. Maxwell's conditions of confinement are related to her being a suicide risk was laid to rest during the oral argument: There is nothing to support that contrived claim. In fact, Ms. Maxwell is classified with the standard CC1-Mh designation: inmate with no significant mental health care. (See Dkt. 159 at 3.) + +Contrary to the report that Ms. Maxwell "wears an eye mask when she sleeps" (Dkt. 196 at 4), an item neither available for purchase through MDC commissary nor provided to her, she resorts to using a sock or towel to cover her eyes in an awkward attempt to shield them from disrupting illumination every 15 minutes. Last night, she was confronted by MDC staff due a visible bruise over her left eye. The "black eye" is depicted in Exhibit B. Despite 24/7 camera surveillance (except when guards elect to exert authority in an intimidating way off-camera, as they did in Saturday's bathroom incident), no guard addressed the bruise until Ms. Maxwell, who has no mirror, caught a reflection of her aching eye in the glean of a nail clipper. At that point, MDC staff confronted Ms. Maxwell regarding the source of the bruise, threatening to place her in the SHU if she did not reveal how she got it. While Ms. Maxwell is unaware of the cause of the bruise, as reported to medical and psych staff, she has grown increasingly reluctant to report information to the guards for fear of retaliation, discipline, and punitive chores. However, there is concern that the bruise may be related to the need for Ms. Maxwell to shield her eyes from the lights projected into her cell throughout the night. + +The MDC routinely places inmates in the SHU if they have engaged in physical altercation with other inmates or to protect inmates who are the subject of abuse. It would be ironic if the MDC follows through with its threat to place Ms. Maxwell in the SHU: It would signal that Ms. Maxwell needs protection from the very staff so intent on protecting her, since she has no contact with anyone but staff. + +As suggested by the Circuit, we ask the Court to address Ms. Maxwell's sleeping conditions by directing the MDC to cease 15-minute light surveillance of Ms. Maxwell or justify the need for the disruptive flashlight surveillance. + +Very truly yours, + +go/ 4z C. 5124.4devn. + +BOBBI C. STERNHEIM + +Encs. + +cc: All counsel of record + +21-58-cr (L), 21-770-cr +United States v. Maxwell + +## United States Court of Appeals + +FOR THE +SECOND CIRCUIT + +--- + +At a stated term of the United States Court of Appeals for the Second Circuit, held at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 27th day of April, two thousand twenty-one. + +PRESENT: PIERRE N. LEVAL, +RAYMOND J. LOHIER, JR., +RICHARD J. SULLIVAN, +*Circuit Judges.* + +--- + +United States of America, + +*Appellee,* + +v. + +21-58-cr (L) +21-770-cr + +Ghislaine Maxwell, AKA Sealed Defendant 1, + +*Defendant-Appellant.* + +--- + +Defendant-Appellant Ghislaine Maxwell appeals from orders of the District Court entered December 28, 2020 and March 22, 2021, which denied her renewed requests for bail pending trial. See Dkts. 1, 20. Upon due consideration, it is hereby ORDERED that the District Court's orders are AFFIRMED and that Appellant's motion for bail, or in the alternative, temporary pretrial release pursuant to 18 U.S.C. § 3142(i), Dkt. 39, is DENIED. During oral argument, counsel for Appellant expressed concern that Appellant was improperly being deprived of sleep while incarcerated. To the extent Appellant seeks relief specific to her sleeping conditions, such request should be addressed to the District Court. + +FOR THE COURT: + +Catherine O'Hagan Wolfe, Clerk of Court + +![]()![](_page_12_Picture_1.jpeg) + +EXHIBIT B + +## Exhibit D + +Doc. 270 + +Government's Response to Ghislaine Maxwell's conditions at Metropolitan Detention Center May 5, 2021 + +![](_page_14_Picture_1.jpeg) + +United States Attorney Southern District of New York + +The Silvio J. Motto Building One Saint Andrew's Plaza New York, New York 10007 + +May 5, 2021 + +#### BY ECF + +The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 + +Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +Dear Judge Nathan: + +The Government respectfully submits this letter in response to the Court's Order dated April 29, 2021, which directed the Government to confer with legal counsel at the Metropolitan Detention Center ("MDC") regarding the use of flashlights in security checks at MDC. (Dkt. No. 257). The Government has conferred with legal counsel at MDC in accordance with the Court's Order, and legal counsel provided the information set forth herein. + +MDC staff conduct flashlight checks at night as a matter of course throughout the facility for the safety and security of the inmates at the institution. During these flashlight checks, MDC staff point a flashlight at the ceiling of each cell to illuminate the cell sufficiently to confirm that the inmate is present in the cell, breathing, and not in distress. MDC staff conduct flashlight checks every 30 minutes for inmates housed in the Special Housing Unit (the "SHU") and conduct flashlight checks of inmates in the general population multiple times each night at irregular intervals, but at an average of at least once per hour. + +With respect to the defendant, MDC staff conduct flashlight checks every fifteen minutes because the defendant, while not on suicide watch, is on an enhanced security schedule. That is because MDC has identified a number of factors that raise heightened safety and security concerns with respect to this defendant, including: (1) the nature of the charges, (2) the potential stress for inmates that can arise in high-profile cases, and (3) the need to ensure the defendant's safety while she is incarcerated in a cell by herself—a housing determination made by MDC staff based on various factors, including the defendant's expressed concern for her safety if she were to be housed in the general population.' + +As to the Court's question whether the defendant can be provided with "appropriate eye covering," MDC legal counsel has informed the Government that the defendant cannot be provided with an eye mask. Eye masks are not available for purchase in commissary and are not issued to inmates and, therefore, are considered contraband. The defendant is permitted, however, to use non-contraband items to cover her eyes at night. + +Should the Court have any questions or require any additional details regarding this topic, the Government will promptly confer with legal counsel at MDC and provide additional tbrmation. + +Respectfully submitted, + +AUDREY STRAUSS United States Attorney + +By: s/ Assistant United States Attorneys Southern District of New York + +Cc: Defense Counsel (By ECF) + +&#x27; The MDC has determined the defendant's current housing assignment based, in part, on her concerns about being housed in the general population and as an alternative to her being housed in the SHU. By contrast, in the SHU, most inmates have a cellmate which provides an additional check should something go wrong or should an inmate need medical attention in the middle of the night. + +## Exhibit E + +Doc. 272 + +Ghislaine Maxwell's Reply regarding conditions at Metropolitan Detention Center May 7, 2021 + +• Main • Cell • Fax + +Honorable Alison J. Nathan United States District Court United States Courthouse 40 Foley Square New York, NY 10007 + +Dear Judge Nathan: + +33 West 19th Street - 4th Floor Now York New York ICM1 1 + +May 7, 2020 + +Re: United States v. Ghislaine Maxwell S2 20 Cr. 330 (AJN) + +Once again, the government reports second- and third-hand information from the MDC, the reliability of which becomes increasingly questionable. In its May 5th letter regarding the MDC's flashlight security checks of Ms. Maxwell (Dkt. 270), the government contradicts a previous report that Ms. Maxwell "has an eye mask." This allegation, immediately refuted by her counsel, was a focus of the Second Circuit's questioning during oral argument of Ms. Maxwell's bail appeal. Now, the government reports that the MDC cannot provide an eye mask to Ms. Maxwell and that an eye mask is considered contraband. This alone is a basis for the Court to question the veracity of representations made by the MDC. + +To justify the 15-minute flashlight surveillance that is causing Ms. Maxwell's disruptive sleep and sleep deprivation, the MDC claims that Ms. Maxwell is on "an enhanced security schedule." The reasons given to support the need for "heightened safety and security concerns" with respect to Ms. Maxwell are spurious. They single out Ms. Maxwell to the detriment of other pretrial detainees who face even more serious charges and potential stress (La, defendants charged with murder and terrorism offenses subjected to life sentences without possibility of release and the death penalty) and who are incarcerated in cells by themselves. The MDC attempts to shift the focus of its conduct by claiming that it is responsive to Ms. Maxwell's "expressed concern for her safety if she were housed in general population." + +The MDC should fact check its records before making bold assertions. The Intake Screening Form completed by Ms. Maxwell upon entry to the MDC on July 6, 2020 posed the following question: "Do you know of any reason why you should not be placed in general population?" Ms. Maxwell responded "No." It is the MDC, not the inmate, who makes the determination regarding general population or degree of segregation. The Intake Screening + +Form listed "psych alerts," which are baseless, and "broad publicity," which is accurate and concerns risk of harm to Ms. Maxwell via violence, extortion, and feed information to the press by other inmates. Ironically, it is the MDC staff who leaked to the press that Ms. Maxwell had been vaccinated. + +Further, in her desire to interact and be helpful with other inmates, Ms. Maxwell completed two programs to assist other inmates- (1) to qualify as a teacher aide and offered to help update MDC learning curriculum and (2) to qualify as companion for suicide watch. Her de facto solitary confinement prevents her from utilizing that training to assist others. + +Ms. Maxwell's segregation and surveillance go way beyond the concerns posited by the MDC. It is not only other inmates who may harm Ms. Maxwell, but also the very guards tasked to her security detail who have already done harm to her: failing to provide adequate food or feed her at all in a 20-hour period, damaging her discovery hard drive, seizing her confidential legal documents, erasing her CorrLinks emails, physically abusing her. The list goes on and on. In an effort to advocate in compliance with BOP procedure, she has filed hundreds of BP-8s, BP-9s and BP-10s only to receive a response that is less than helpful, or in the absence of any response was told the form was either lost or never filed, Each and every day of her detention, she is guarded by at least three officers who watch and record, by writing and via a handheld camera, her every move: when she eats, showers, cleans her clothes, brushes her teeth, etc. As the guards feverishly write while observing Ms. Maxwell during videoconferencing with counsel, it appears that they go beyond their routine continual 15-minute reporting. + +Further, her non-legal phone calls are monitored in real time. It was the staff who confronted Ms. Maxwell about the death of someone whom she was close to within hours on her learning about it, information derived from her phone calls. Ms. Maxwell does not discuss personal matters with MDC guards and did not provide information concerning the passing of someone quite dear to her. It was psychological services who confronted her regarding that information, which could only have been obtained through telephone surveillance. We invite the Court and government to review the calls which contradict the unsupported allegation that Ms. Maxwell is a flight risk and support her family strong ties. Her monitored communication with family and friends evidences her strong ties in the United States, her strong desire to return to her family in the United States, and her intention to establish her innocence at her trial in the United States. + +In the face of the Epstein's death on the GOP's watch, the MDC would not risk a repeat of the debacle that occurred in the MCC. There can be no doubt that the MDC was following directives from Attorney General William Barr and the Director of the BOP in determining that Ms. Maxwell should not be placed in general population, not Ms. Maxwell. Regardless, the MDC would never risk security to Ms. Maxwell or the institution by placing her in general population, knowing the difficulties it would face in protecting Ms. Maxwell from assault and extortion by other inmates given that they do not protect her from physical abuse by guards. But that decision does not justify the degree to which the MDC overmanages Ms. Maxwell's detention and its detrimental effect on her health, well-being, and ability to prepare for trial. + +We have repeatedly expressed our concern for Ms. Maxwell's health and the impact her conditions of confinement are having on her health and well-being, her ability to prepare for trial, and the overall impact the severe conditions will have on her stamina to withstand trial, which we moved to the fall. With each passing day, it becomes increasingly more obvious that Ms. Maxwell's extreme conditions of detention will not be improved and health deteriorate commensurate with the unprecedented conditions of confinement unparalleled in the MDC. + +Very truly yours, + +gaga a. Siman. BOBBI C. 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you + +United States Pretrial Officer Southern District of New York + +New York, New York 10007 \ No newline at end of file diff --git a/marker2/ds9/EFTA00089485/EFTA00089485.metadata.json b/marker2/ds9/EFTA00089485/EFTA00089485.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..b45b72357339a77e9e06d81734ffba1897763983 --- /dev/null +++ b/marker2/ds9/EFTA00089485/EFTA00089485.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089485.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 352, + "elapsed_seconds": 0.52, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + 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Tova Noel Indictment 19 cr 830 (AT) Collateral Consequences of a Felony Conviction + +Dear Counsel: + +This letter is being provided in response to your email requesting more specific information regarding the collateral consequences a felony conviction will create for Ms. Noel. + +Since Ms. Noel was charged in this case and placed on administrative leave from her position with the BOP, she has applied to two employment opportunities. In the Fall of 2020, she applied for a Claims Specialist position with the Social Security Administration. She has not received an acceptance or rejection yet. In January 2021, she applied for a Contact Tracer position with an organization called Public Consulting Group. Other than acknowledging her application, she has not heard back. There is a possibility that the pending criminal charges have affected her ability to successfully land one of these two positions. + +If Ms. Noel receives a felony conviction, she will automatically be terminated from her current position with the BOP. Ms. Noel intends to continue building her career in law enforcement and intends on applying for positions with the United States Department of Veterans Affairs Police, U.S. Customs and Border Patrol, Transportation Security Administration ("TSA"), and private security companies. A felony conviction would legally prohibit her from obtaining any of these employment opportunities. The inability to possess a firearm would also prohibit her from these opportunities. + +Ms. Noel is also interested in exploring employment opportunities in the health care field. In 2013, Ms. Noel obtained a New York State Emergency Medical Technician ("EMT') certificate when she was employed as a Patient Administrative Specialist in the Army. See Tova Noel EMT Certificate, attached hereto as Exhibit A. She is interested in renewing her EMT certification and applying to become a paramedic. A felony conviction would prevent + +PAGE 2 + +her from pursuing this opportunity and exploring other health care related opportunities that require state licenses or certifications. + +The collateral consequences of a felony conviction and the prohibition from exploring these opportunities would significantly limit Ms. Noel's ability to make a living to care and provide for her family. + +Thank you for your thoughtful consideration. + +Sincerely, + +FOY & SEPLOWITZ LLC + +ewe 6:14r + +ERIC J. 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Tova Noel, 19 Cr. 830 (AD' + +AUSAs: + +— Federal Bureau of Investigation + +Agent: — Department of Justice, Office of the Inspector General + +Defendant: Tova Noel + +Age: • al + +Noel graduated from high school in 2005 at the age of 16. At age 18, she began taking classes at the Borough of Manhattan Education: Community College. She enlisted in the Army National Guard in 2008 and in 2012 was deployed to Kuwait for active duty in support of Operation Enduring Freedom. During her military service, Noel took courses at ASA College in New York City and earned an + +Prior to charging this case, we gave defense counsel for Noel an opportunity to meet with the case team, unit supervisors, and the United States Attorney. During the meeting, defense counsel urged a declination or deferred prosecution, but did not raise the majority of the arguments set forth in the deferred prosecution request (the "Request"). The defendant did not make a written deferred prosecution submission prior to charging. As is discussed in more detail below, the Request provides multiple facts not known to us at the time of the charging decision, as well as a discussion of how similar cases have been handled in other districts. In particular, the Request explains that Noel intended to do the counts and rounds but could not do so because her codefendant refused to assist her, and it was against BOP regulations for her to perform them on her own. Noel's counsel also identified a case in the Western District in which non-prosecution agreements were offered to the defendants, correctional officers who were charged for falsely representing that they completed rounds in the SHU when an inmate homicide took place. Noel's counsel also provided additional information about United States v. Hernandez, a case from the Northern District of Texas that we relied upon as precedent in making the charging decision in the instant case. In Hernandez, the only guard with a felony disposition was an experienced officer who was watching pornography instead of doing rounds and made false statements during the investigation after an inmate death. + +Associate of Applied Science degree in Criminal Justice in 2014. After being honorably discharged from the military, Noel enrolled in John Jay College of Criminal Justice, where she majored in criminal justice and minored in law. She graduated in 2017 with a Bachelor of Science degree in Criminal Justice. + +The deferred prosecution request (the "Request," which is attached Drugs: hereto) is silent on drug use, and we do not know of any drug use by Noel. + +> According to the Request, Noel has been diagnosed with a number of medical conditions as a result of her military service in a war zone, including the following: major depressive disorder; generalized anxiety; insomnia disorder; post-traumatic stress disorder; contact dermatitis, posterior neck; bronchial asthma; right ankle posterior tibial tendinopathy (ankle injury sustained in Kuwait); dysmenorrhea and irregular menstruation with pedunculated fibroid status post-myomectomy (related to environmental hazard in Gulf War); breast lesion (residual painful scar, right breast, sip excisional biopsy); degenerative spondylosis; irritable bowel syndrome with nausea (related to environmental hazard in Gulf War); and migraines. She was receiving disability benefits from the military until she was suspended from her employment at the Bureau of Prisons ("BOP") due to the instant + +Health: charges. + +According to the Request, there is significant use of synthetic marijuana (K2) by inmates throughout the Metropolitan Correctional Center ("MCC"), including in the Special Housing Unit ("SHU"). Noel has experienced illness, including headaches, lightheadedness, and nausea, that she believes is associated with breathing in secondhand smoke from the inmates. + +Noel has various mental health conditions, which began during her military service and were exacerbated due to family tragedy (discussed below) and the instant case. Noel's counsel has told us that since he met her in connection with this case, she has struggled with serious and lengthy bouts of depression, sometimes spending multiple days in bed. In November 2019, Noel was referred to the New York Center for Neuropsychology & Forensic Behavioral Science for therapy to assist with stress stemming from the instant case. + +Despite believing that she could not become pregnant due to certain medical conditions, Noel is currently pregnant, with a due date in late April 2021. Noel is scheduled for a cesarean section on April 1, 2021. + +Noel was born in Antigua, where she was raised by her single mother, her grandparents, and other relatives. Noel's mother left Antigua to pursue her education; at age 13, Noel joined her mother in the United States. Before Noel joined her, Noel's mother got married in the United States and had a son, who is approximately 11 years younger than Noel and is currently attending college. + +Noel married in 2007; she and her husband separated in 2011 and are now divorced. + +Family: In 2013, Noel's 7-year-old half-brother and his mother were murdered in St. Croix. The perpetrators were never arrested. This event exacerbated Noel's mental health issues, including anxiety; she attended mental health treatment and managed her condition with medication. + +> In March 2020, Noel rekindled a friendship with Lloyd Gunnings, whom she previously dated. Noel and Gunnings are currently in a romantic relationship, and Gunnings is the father of Noel's child, due in April 2021. + +Immigration Status: As of 2009, Noel is a naturalized American citizen. + +Employment: + +Noel attempted to join the military at age 17, but her mother refused to allow Noel to enlist as a minor. Noel then attended some college classes and worked low-level jobs in New York City. + +As noted above, in 2008, at age 19, Noel enlisted in the Army National Guard. She served for six years before her honorable discharge in 2014, eventually gaining the rank of E4 Specialist. Noel was deployed to Kuwait for active duty in 2012 in support of Operation Enduring Freedom. + +During her military service, Noel also worked other jobs, including the following: security at Macy's (October 2008 — January 2009); EMT-B at Transcare Ambulance (January 2009 - July 2011); Life Skills Instructor at Ability Beyond Disability (November 2011 - January 2013). + +While attending John Jay College from 2014 through 2017, Noel held the following positions: Intern/Case Manager for EAC Bronx TASC (summer 2014); Toll Booth Cashier for the MTA Bridge and Tunnel (June 2014 - April 2016); Cashier for Home Depot (January 2017 — August 2017). + +After graduating from John Jay in May 2017, Noel began working as a mail handler assistant with the United States Postal Service (the "USPS") in White Plains. Noel left the USPS to join the BOP. She began working at MCC on June 24, 2018. She received two weeks of training after joining the BOP and attended another training course in August 2018 that was supposed to last for three weeks but was cut short due to a hurricane. + +According to the Request, and as confirmed from our review of her work history, Noel and her MCC colleagues were forced or "mandated" to work many overtime shifts, including working two eight-hour shifts back-to-back. Due to difficulties finding parking near the MCC, Noel often drove to work at 5:00 a.m. and slept in her car before beginning her 8:00 a.m. shift. Noel was required to work so many overtime shifts that in a six-month period she earned the entirety of her annual base salary. + +According to the Request, during her employment at MCC, Noel received multiple threats from inmates, including threats of violence and sexual assault. When she reported the threats, she did not always feel supported by her superiors. + +As is set forth in the Request, or about March 15, 2019, Noel had an accident and fell at work. She was injured and did not return to work until June 26, 2019. When she returned to the MCC, she was assigned to the 4:00 p.m. — 12:00 a.m. shift in the SHU. According to the Request, Noel had never worked in the SHU before and did not receive the required SHU-specific training. When she reported for work at the SHU, her lieutenant asked her to sign documentation + +indicating that she had received the SHU training. Even though Noel informed the lieutenant that she had not received the training, the lieutenant told Noel that she needed to sign so that the facility could pass program review. + +Noel was suspended from the BOP in 2019 due to the pending charges. Since the fall of 2020, Noel has been applying for jobs, but she has not received any employment offers to date. + +Potentially disqualifying factor: as a guard at the MCC who made Potentially Disqualifying false statements relating to the performance of her duties, Noel may Factors:\* qualify as "a public official or former public official accused of an offense arising out of an alleged violation of a public trust." + +Criminal History: None (convictions or arrests). + +Offenses: + +Conspiring to knowingly defraud the United States and to knowingly make and use a false writing or document, in violation of 18 U.S.C. § 371 (one count). + +Knowingly making and using a false writing or document, in violation of 18 U.S.C. § 1001 (five counts). + +At approximately 6:33 a.m. on August 10, 2019, correction officer Michael Thomas, Noel's codefendant, found Jeffrey Epstein dead in cell L220 in the ninth floor SHU at MCC. Although Epstein Summary of Offense: committed suicide by hanging himself, two significant failures at the MCC created the conditions in which Epstein could do so: the failure to reassign Epstein a cellmate, and the failure to perform any of the required rounds and counts during the overnight shift. + +\* Pursuant to USAM 9-22.100 Eligibility Criteria, pretrial diversion (deferred prosecution) is not available against any individual against whom a prosecutable case exists and who is: (1) accused of an offense which, under existing Department guidelines, should be diverted to the State for prosecution; (2) a person with two or more prior felony convictions; (3) a public official or former public official accused of an offense arising out of an alleged violation of a public trust; or (4) accused of an offense related to national security or foreign affairs. Please consult with your unit chief and a deputy chief of the Criminal Division regarding the applicability of these provisions, including the status of any individual as an addict. + +Epstein had allegedly attempted to commit suicide on July 23, 2019, and after he was removed from suicide watch, he was required to have a cellmate. Thomas was aware of Epstein's history, having been one of the officers who responded to that earlier alleged suicide attempt. However, Epstein's cellmate was released from the MCC on August 9, 2019, and despite being aware of that directive and the fact that Epstein did not have a cellmate, numerous correction officers and at least one lieutenant took no steps to assign a new cellmate to Epstein. + +During the overnight shift on August 10, 2019, Thomas and Noel were assigned to the SHU from midnight to 8 a.m. Both were on overtime, and had worked 8 of the previous 24 hours at the start of their overnight shift: Noel had worked her regular shift in the SHU between 4 p.m. and midnight, and was on a voluntary overtime shift; Thomas had worked the overnight shift the night before, and while he had not worked during the day, he was on a mandatory overtime shift. Thomas was a material handler who worked in the warehouse, although he had previously worked as a senior correction officer for six years. Noel had worked for the BOP for a year, although she was injured during part of that period and spent less than two months working in the SHU. + +While on duty in the SHU, Noel and Thomas were required to perform rounds every 30 minutes, and institutional counts at 12 a.m., 3 a.m., and 5 a.m. Because Noel had worked the previous shift from 4 p.m. to midnight, she was also required to conduct the 4 p.m. and 10 p.m. institutional counts, in addition to the required 30-minute rounds during that shift. Based on the investigation, it appears that the last time that any correction officer checked on Epstein in his cell was between 8:45 and 9:15 p.m. on August 9, 2019, which was approximately nine hours before he was found dead. It appears that the 4 p.m., 10 p.m., 12 a.m., 3 a.m., and 5 a.m. counts were not completed, and it appears that rounds—which were required every 30 minutes—were largely not completed after approximately 9:30 p.m. Prior to learning that Epstein had committed suicide, Thomas and Noel falsified forms showing that they had performed the required rounds and counts overnight, although they did not actually do so. Thomas and Noel appeared to be performing other tasks, using the computer, talking, or sleeping during their overnight shift. Epstein's cell was approximately ten to fifteen feet away from where they sat throughout the night. On the morning of August 10, while making + +preparations to serve breakfast, Thomas discovered Epstein's body. After sounding their body alarms, Thomas and Noel told a lieutenant, in sum and substance, that they had made a mistake in not checking on Epstein. + +Guidelines: + +Defendant's Submission: + +- Counts One through Six are grouped into a single Group because they involve substantially the same harm (§§ 3D1.1(a) and 3D1.2(b)) Base offense level: 6, because the offense has a statutory maximum term of imprisonment of less than 20 years (§§ 2B1.1(a)(2), 2X1.1(a)) Because the defendant or a co-conspirator completed all the acts the conspirators believed necessary on their part for the successful completion of the substantive offense, a 3-level decrease is not warranted (U.S.S.G. § 2X1.1(b)(2)) +- Offense involved the conscious or reckless risk of death or serious bodily injury: increased to 14 (§ 2B1.1(b)(16)) Offense level for Group: 14 (§ 3D1.3(a)) Acceptance of responsibility: -2 (§ 3E1.1) +- Total offense level: 12 + +Criminal history category: I + +GUIDELINES RANGE: 10-16 months' imprisonment + +Although not itemized as such, the defendant's deferred prosecution submission (the Request) offers seven reasons for leniency. + +First, Noel has lived a law-abiding, admirable life prior to and after the incident that gave rise to the criminal charges against her. She pursued an education despite difficult family circumstances and enlisted in the Army National Guard, serving overseas. She accomplished this despite considerable personal tragedies, including the murder of close family members, and medical and mental health issues traceable, at least in part, to her military service. + +Second, the nature and circumstances of the crime favor leniency. Noel had been working at the MCC for a relatively short period, and had only spent about 6 weeks working in the SHU without any meaningful training. She had been working mandated overtime shifts for weeks and was fatigued. The strain from her job was causing mental health issues. She was not seeing family or friends, and she was spending some of her time sleeping in her car. At work, she faced threats and harassment, and was not supported by supervisors or more experienced colleagues. The SHU, where she had been assigned, was routinely understaffed and it was common for guards to skip rounds and counts. It is against that backdrop that Noel allegedly committed the charged offenses. On the night in question, Noel and her co-defendant had worked multiple overtime shifts in the prior 48 hours. There was no other guard assigned. After Noel pulled out the forms they would need to complete during their shift, Noel's co-defendant allegedly refused to assist her in conducting the counts and rounds. Under BOP regulations, Noel was not permitted to conduct rounds and counts in the SHU on her own. She did, however, assist another guard in conducting a count in a unit neighboring the SHU, evidencing the fact that she was willing to conduct counts and rounds. Noel also knew that it was common for guards in the SHU—particularly those working the night shift when all inmates were locked in their cells to not complete required counts and rounds. While none of those circumstances excuse the falsification of records, Noel argues they show why she made the decision she did. + +Third, Noel argues that the absence of obstructive intent favors a deferred prosecution. Specifically, according to the Request, there was never a discussion or agreement between the defendants that they would falsify the count and round forms. Rather, Noel filled out the initial information on the forms, and when it became time to complete the forms, she filled them in while Thomas slept. Noel acknowledges while she acted wrongfully in filling in the forms without doing the rounds and counts, she did not do it to obstruct any oversight or investigation. Indeed, Noel correctly notes that she filled out the forms before Epstein's body was discovered. Moreover, after he was discovered, Noel and Thomas admitted to their supervisor that they made a mistake in not doing rounds. There is no evidence in the case that the defendants attempted to conceal the fact that they had not done rounds after they found out by the suicide. There is also no evidence that the defendants tried to obstruct any investigation. + +Fourth, Noel acknowledges that she made a mistake and what she did was wron . While her counsel has told us that he has advised her to go to trial, her submission accepts responsibility for her involvement in the conduct at issue in the Indictment. + +Fifth, Noel argues that historically failure to complete rounds and counts, or falsely completing paperwork about doing rounds and counts, is addressed administratively by the BOP. The few precedents for criminal prosecution have largely resulted in deferral, diversion, or dismissal of charges. Specifically, in United States v. Hernandez, a case from the Northern District of Texas involving the falsification of round and count slips following an inmate death, the case against one of the guards was dismissed (after entry into a diversion program was not feasible) and another guard pled to a misdemeanor. Only one defendant was convicted of a felony charge. But the facts involving that defendant were different than in the instant case: the defendant, who was an experienced officer, was watching pornography instead of doing rounds and made false statements during the investigation after the inmate death. In another case, United States v. Marshall in the Western District of Virginia, in which four correctional officers were indicted for falsely representing they completed rounds in the SHU when an inmate homicide took place, the U.S. Attorney's Office dismissed all the charges. Each of the defendants entered into a nonprosecution agreement. Thus, according to Noel, a deferred prosecution would be consistent with the outcomes for other similarly-situated defendants. + +Sixth, the Indictment has already caused significant collateral consequences. Noel has been subject to public shaming and intense media scrutiny, which has exacerbated her depression. She has struggled to find employment. She will lose her BOP job, and the very fact of the Indictment will make it difficult for her to obtain future employment. A felony conviction would result in significant additional collateral consequences. Specifically, Noel will likely lose her Army disability benefits and will likely be unable to obtain future employment that she would be potentially qualified for, including other government positions . She will be legally prohibited from working for TSA, U.S. Customs and Border Patrol, and private security companies. She will not be able to possess a firearm, which would also prevent her from holding those positions. A felony conviction would also prevent her from becoming an EMT, a position that she would like to pursue at the conclusion of this case. A felony conviction could, of course, result in her going to prison, which would mean she would be separated from her newborn baby. A felony conviction would also result in general + +collateral consequences such as losing the right to vote and entitlement to certain public benefits. In short, the collateral consequences of a felony conviction and prohibition from exploring these opportunities would significantly limit her ability to make a living and provide for her child. + +Finally, defense counsel has indicated that Noel is prepared to accept responsibility for her conduct pursuant to a deferred prosecution agreement, and that she would be prepared to meet with and provide information to the Department of Justice, Office of the Inspector General ("DOJ-OIG"), which office is still working on a report about the conditions at the BOP that led to Epstein's suicide. + +Although the Request does not seek a misdemeanor disposition, there is a potentially applicable misdemeanor, 18 U.S.C. § 1018, which provides in relevant part that, "[w]hoever, being a public officer or other person authorized by any law of the United States to make or give a certificate or other writing, knowingly makes and delivers as true such a certificate or writing, containing any Citation and Description statement which he knows to be false, in a case where the of Proposed punishment thereof is not elsewhere expressly provided by law, Misdemeanor: shall be fined under this title or imprisoned not more than one year, or both." + +> There is precedent bringing this misdemeanor charge against a BOP corrections officer who knowingly made a false statement in a BOP memo. See United States v. Rodas Castro, No. 5:15-cr-25 (M.D. Fla., Jan. 13, 2016), 2016 WL 270157 (plea agreement). + +FBI Special Agent is the lead agent on the case. She reviewed the Request with her supervisors. Special Agent has informed us that the FBI supports a deferred prosecution. Special Agent provided two principal reasons why they believe a deferred prosecution is appropriate. First, when the FBI Agent Recommendation: opened the investigation, the focus was on whether Epstein was murdered, whether he was given an opportunity to commit suicide because of a bribe, and/or whether obstruction was committed after Epstein's suicide. Having concluded that Epstein committed suicide without the assistance of any person, and that no obstruction was committed after the fact, the FBI believes that this type of matter is best handled administratively and a criminal resolution is + +not necessary. Second, the FBI believes a deferred prosecution is appropriate because Noel did attempt to do some aspects of her job (e.g., she assisted another officer in doing a count that night), but failed to do some specific tasks that night at least because Thomas was sleeping. Special Agent also said that avoiding a trial will be helpful to the FBI because they will have a number of trials later this year, but that was not one of the primary reasons they support a deferred prosecution. + +AUSA Deferred prosecution. Recommendation: + +AUSA Rationale: + +As an initial matter, the nature and seriousness of the offense mitigate in favor of a deferred prosecution. Noel is charged with falsifying BOP forms during a period that spanned less than 24 hours. She falsified the documents before Epstein was discovered dead, and her alleged motive to conceal was to hide the fact that she had not performed a job duty--conducting rounds and counts—not obstruct a government investigation. Additionally, as noted above, Noel immediately told her supervisor that she had made a mistake and admitted that she had not completed the rounds, further evidencing that she did not intend to obstruct any government inquiry following Epstein's death. Notably, Noel did nothing to attempt to hide her conduct, and in fact consented to the Government's search of her phone months before she was arrested. Moreover, while the circumstances at the MCC do not excuse her conduct, Noel was a relatively inexperienced employee at the MCC (especially in the SHU); she was forced to work very long hours; and she claims to not have been supported by her supervisors or more senior colleagues. Indeed, because of the dangers associated with the SHU, the protocol in the SHU is that one officer (who controls the keys) unlocks the door to go down a range and stands at the door, while the other guard goes down the range and inspects the cells. If it is true that Noel asked Thomas to do the rounds and counts and he refused, it was impossible for her to complete the rounds and counts in the manner specified in BOP regulations. + +Further, prosecution here is also unlikely to be necessary to advance the interests in specific or general deterrence. Noel has no criminal history, and given the adverse employment consequences and intense public scrutiny, it is highly unlikely that she will recidivate. Further prosecution is also unlikely to significantly advance general deterrence. This case has already garnered substantial media attention, which has furthered interests in deterrence. The filing of charges already sent the message that Thomas and Noel committed serious crimes, which provides some degree of deterrence for any correction officer tasked with ensuring the safety of the prisoners in his or her care. In the course of our investigation, we learned that even before charges were brought, the MCC and its employees had begun taking rounds and counts more seriously. And given the low advisory Guidelines range, and thus the anticipated sentence, it is unlikely that any sentence imposed would deter others contemplating the same conduct. + +Moreover, a deferred prosecution would result in an outcome consistent with most cases in which falsification of round or count forms has occurred. According to information provided by defense counsel and the correctional officers' union, most instances of failing to complete counts are addressed administratively. That seems to be borne out by the fact that there have been relatively few criminal cases relating to falsely certifying the completion of rounds and counts, while the practice appears, unfortunately, to be not uncommon. In the few cases in which officers have been criminally charged, most defendants had their cases dismissed or resolved through deferred prosecution. Indeed, all four of the defendants in the Western District of Virginia case discussed above—which we were not aware of when we charged this case had their cases dismissed pursuant to deferred prosecution agreements. In the case in Texas, only one defendant was convicted of a felony, and he undertook obstructive conduct after an inmate's death. We are not aware of any felony conviction for an officer who falsified count or round slips but did not take subsequent obstructive conduct or make false statements. Put another way, while deferred prosecutions have been the outcome in other cases, a felony conviction in this case would be basically unprecedented: never before, to our knowledge, has a correctional officer been convicted of a felony for making false certification on BOP forms without any other obstructive conduct. + +While Noel, on the advice of counsel, intends to proceed to trial if her deferred prosecution application is not granted, she has acknowledged since the beginning of our investigation, largely through counsel, that she falsified the BOP forms. She has acknowledged that her conduct was wrong. She has also offered to provide information to the DOJ-OIG about conditions at the MCC that may have contributed to Epstein's death. On that + +question, while the guards' failure to conduct rounds and counts were certainly a contributing factor, there is no question that larger systematic issues, as well as the MCC's failure to assign a new cellmate to Epstein, contributed significantly to the circumstances that led to his suicide. Noel has offered to provide information to the OIG about those circumstances. + +Next, since charging the case, we have learned more about the significant collateral consequences to Noel of taking a guilty plea. Those include, most notably, that she will be effectively precluded from pursuing work in areas for which she is otherwise qualified. Specifically, as noted in the Request, a felony conviction will likely bar her from certain government positions (like TSA) and prevent her from getting private security jobs. Even if she was legally qualified for those positions, the prohibition on her possession of a firearm will prevent her from obtaining those jobs. A felony conviction will also likely prevent her from looking for employment in other fields, such as becoming an EMT. And, as noted in the Request and supporting materials, a felony conviction will prevent Noel from obtaining certain disability benefits related to her military service overseas. These potential collateral consequences are particularly concerning because Noel will soon be a mother who will need to provide financially for her child. (It is worth noting that while Noel became pregnant during the pendency of this case, she previously believed that she was unable to become pregnant due to certain medical conditions). + +Given that a likely sentence if Noel is convicted following a guilty plea or a trail would be a term of probation, it does appear that prosecution resources could be better allocated to matters other than a trial against Noel. Further, there is non-trivial litigation risk at trial as Noel can credibly argue that she lacked criminal or obstructive intent, and was in fact put in a position where it was impossible for her to carry out her job. Noel is also certainly likely to make a number of arguments to attempt to nullify a verdict, including, but not limited to, that the U.S. Attorney's Office acted irregularly in bringing this case; the case attempts to scapegoat Noel because the Department of Justice is upset that Epstein died; these types of failures at the MCC are routine; and this prosecution was only brought because it relates to Epstein. + +Finally, it is worth noting that the September 25, 2019, prosecution memo by the case team recommended a deferred prosecution in this case. The memorandum noted that while it was a "close case," a + +deferred prosecution was appropriate because provide a public accounting of the events that led to Epstein's death and would promote general deterrence, but it would not carry with it the collateral consequences of a felony conviction. That recommendation was not adopted at the time. As noted above, prior to charging the defendants, their attorneys made presentations to us, but did not submit written deferred prosecution applications. Noel's attorney's presentation focused on why, in his view, a charge was unwarranted. (Thomas's attorney stated that his client was willing to plead guilty, but then after the charging decision was made, reversed course and said his client would go to trial.) Since the case was charged, we have learned additional information about the circumstances of the offense, the outcome in comparable cases, and the collateral consequences to the defendant. In particular, we have learned about Noel's factual claim that she was unable to do the counts because Thomas refused to wake up. We have also learned about at least one other similar prosecution that resulted in deferred prosecutions, as well as additional information about the disposition and factual circumstances in the Texas case we previously cited to as precedent. And we have now obtained new information about the potential collateral consequences to Noel information that is new to us now because Noel's attorney did not make a formal deferred prosecution application previously. Based on those subsequent developments, we no longer view this as a "close case," and believe a felony disposition is not necessary or appropriate in light of the circumstances. Indeed, in light of the applicable precedents, we believe a deferred prosecution is appropriate, and that a felony conviction would be unnecessarily punitive. + +Finally, as noted above, there is a potential misdemeanor charge that could apply to the facts here. While, in our view, a misdemeanor disposition would be preferable to a felony conviction following a trial, it would not be necessary to achieve specific or general deterrence, and it is not consistent with the majority of cases in which the conduct at issue here was prosecuted. Moreover, while we have not offered a misdemeanor disposition, defense counsel has stated that Noel would likely not take a misdemeanor plea because some of the same collateral consequences, particularly those related to employment, would still result from such a plea. + +For the foregoing reasons, we believe a diversionary disposition would be appropriate, particularly if it included a requirement that Noel meet with the DOJ-OIG and provide information about the circumstances that led to Epstein's death. + +**Decision** + +| DP Committee
    Member
    | Dismissal/
    Nolle
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STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +UNITED STATES OF AMERICA, + +Plaintiff, + +INDICTMENT NO.: 19 Cr. 830 (AT) + +v. + +TOVA NOEL, + +Defendant. + +## TOVA NOEL DEFERRED PROSECUTION APPLICATION + +![](_page_0_Picture_9.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00089505/EFTA00089505.metadata.json b/marker2/ds9/EFTA00089505/EFTA00089505.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..14e9ca4dce5b05275a772f6ed8247744951c959f --- /dev/null +++ b/marker2/ds9/EFTA00089505/EFTA00089505.metadata.json @@ -0,0 +1,88 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089505.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 341, + "elapsed_seconds": 0.54, + 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b/marker2/ds9/EFTA00089505/_page_0_Picture_9.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..8f872180e23fdea748aefd501779ab3861ca771f --- /dev/null +++ b/marker2/ds9/EFTA00089505/_page_0_Picture_9.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:9a8bb43a3378afe30435ff1a69b6a6300cb09d29010865042c50f22141b3bbae +size 34394 diff --git a/marker2/ds9/EFTA00089506/EFTA00089506.md b/marker2/ds9/EFTA00089506/EFTA00089506.md new file mode 100644 index 0000000000000000000000000000000000000000..d1a22e279510da033a980a3cb4368f75084662e8 --- /dev/null +++ b/marker2/ds9/EFTA00089506/EFTA00089506.md @@ -0,0 +1,36 @@ +**To:** "Berman, Geoffrey (USANYS)" <[REDACTED]>, [REDACTED] (USANYS)" + +<[REDACTED]>, [REDACTED] (USANYS)" <[REDACTED]>, [REDACTED] + +[REDACTED] (USANYS)" <[REDACTED]> + +**Cc:** "[REDACTED] (USANYS)" <[REDACTED]> + +**Subject:** Briefings + +**Date:** Tue, 19 Feb 2019 23:23:52 +0000 + +**Importance:** Normal + +--- + +I have asked the teams to get [REDACTED] detailed briefing memos by tomorrow, and will turn them to you by Thursday morning, on the following: + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +- Epstein + +If there's anything else you'd like to include [REDACTED], let us know. + +[REDACTED] +*Chief, Public Corruption Unit* +*United States Attorney's Office for the* +*Southern District of New York* +*1 St. Andrew's Plaza* +t. [REDACTED] \ No newline at end of file diff --git a/marker2/ds9/EFTA00089506/EFTA00089506.metadata.json b/marker2/ds9/EFTA00089506/EFTA00089506.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..93d19547ac249bbf5f0c2cd54ddb2ef544b4da55 --- /dev/null +++ b/marker2/ds9/EFTA00089506/EFTA00089506.metadata.json @@ -0,0 +1,58 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089506.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 747, + "elapsed_seconds": 3.89, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 41 + ], + [ + "Text", + 25 + ], + [ + "Line", + 20 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089506" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089507/EFTA00089507.md b/marker2/ds9/EFTA00089507/EFTA00089507.md new file mode 100644 index 0000000000000000000000000000000000000000..f286e074b468b38f2bae7361daa141d87fc5aaef --- /dev/null +++ b/marker2/ds9/EFTA00089507/EFTA00089507.md @@ -0,0 +1,34 @@ +**From:** + +[REDACTED] + +**To:** + +[REDACTED] + +**Cc:** + +[REDACTED] + +**Subject:** Epstein FBI case agent + +**Date:** Thu, 16 Jul 2020 19:51:30 +0000 + +[REDACTED] + +Thanks very much for speaking this afternoon. As discussed, I am cc'ing [REDACTED] who is the lead FBI Special Agent on the Epstein investigation. I've filled her in on our conversation, and she should be reaching out to you to coordinate receiving the materials we discussed. + +- + +Take care, + +[REDACTED] + +[REDACTED] + +Assistant United States Attorney +Southern District of New York +1 St. Andrew's Plaza +New York, NY 10007 + +[REDACTED] \ No newline at end of file diff --git a/marker2/ds9/EFTA00089507/EFTA00089507.metadata.json b/marker2/ds9/EFTA00089507/EFTA00089507.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..26fbaa2ea6eb62c1040c0bf23ce8f0aeedd35153 --- /dev/null +++ b/marker2/ds9/EFTA00089507/EFTA00089507.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089507.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 594, + "elapsed_seconds": 3.24, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 27 + ], + [ + "Span", + 25 + ], + [ + "Line", + 13 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089507" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089508/EFTA00089508.md b/marker2/ds9/EFTA00089508/EFTA00089508.md new file mode 100644 index 0000000000000000000000000000000000000000..20bb891425c397597aad7d6b9462d5d849c73ee3 --- /dev/null +++ b/marker2/ds9/EFTA00089508/EFTA00089508.md @@ -0,0 +1,39 @@ +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, I'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: + +M, 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 + +PWIW + +https://okmagazine.corn/exclusives/jeffrey-epstein-video-recordings-darren-indyke/ + +Sent from my iPhone \ No newline at end of file diff --git a/marker2/ds9/EFTA00089508/EFTA00089508.metadata.json b/marker2/ds9/EFTA00089508/EFTA00089508.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..450fb614a2c006bbce8acdf2938bb89b18dc1aba --- /dev/null +++ b/marker2/ds9/EFTA00089508/EFTA00089508.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089508.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 914, + "elapsed_seconds": 0.9, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 49 + ], + [ + "Line", + 25 + ], + [ + "Text", + 20 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089508" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089509/EFTA00089509.md b/marker2/ds9/EFTA00089509/EFTA00089509.md new file mode 100644 index 0000000000000000000000000000000000000000..f0a79a7d5aa32da19473e7ddc4967ee2526b7100 --- /dev/null +++ b/marker2/ds9/EFTA00089509/EFTA00089509.md @@ -0,0 +1,157 @@ +## LAST WILL AND TESTAMENT + +## OF + +JEFFREY E. EPSTEIN + +I, JEFFREY E. EPSTEIN, a resident and domiciliary of St. Thomas, United States Virgin Islands, do make, publish and declare this to be my Will hereby revoking all prior Wills and Codicils made by me. + +FIRST: A. I direct my Executor to pay from my estate all expenses of my last illness, my funeral and burial expenses, the administration expenses of my estate and all of my debts duly proven and allowed against my estate. + +B. I direct my Executor to pay from my estate, as compensation to each Executor for serving as Executor hereunder, the sum of Two Hundred Fifty Thousand Dollars (\$250,000) to each Executor upon the completion of probate of my estate. No Executor shall receive any other compensation for serving as Executor hereunder; provided, however, that my Executor shall be reimbursed from my estate for all reasonable costs, expenses, charges, and liabilities incurred or paid in respect thereto, including fees and expenses of counsel or any other agents hired by my Executor, and my Executor shall not be liable therefor individually. + +C. I direct my Executor to pay from my estate the federal and state transfer taxes described in Paragraph B(1) of Article SEVENTH. + +D. I direct my Executor to pay from my estate all expenses of storing, insuring, packing, shipping and delivering my tangible personal property in accordance with the provisions of Article SECOND. + +SECOND: I give all of my property, real and personal, wherever situated, after the payments and distributions provided in Article FIRST, to the then acting Trustees of The Jeffrey E. Epstein 2018 Trust ("Trust") created under that certain Trust Agreement of of The Jeffrey E. Epstein 2018 Trust (the "Trust Agreement") dated May 8, 2018, as the same may be amended from time to time, to be held in accordance with the provisions comprising the Trust Agreement at the time of my death. + +THIRD: A. I appoint DARREN K. INDYKE and RICHARD D. KAHN to serve as the Executors of this Will. If any one or more of my Executors fails to qualify, is unable or unwilling to serve or ceases to act, I appoint KATHRYN H. RUEMMLER, as successor Executor. If any successor Executor fails to qualify, is unable or unwilling to serve or ceases to act, I authorize the last acting Executor to designate his or her successor. Such designation shall be made by written instrument delivered to such designated successor Executor. + +B. If my estate must be administered in whole or in part in any jurisdiction other than the state or territory of my domicile at the date of my death, and if my + +Executor is unable or unwilling to serve in such jurisdiction, then I appoint the successor Executor of my estate designated in Paragraph A of Article THIRD as successor Executor in such jurisdiction only, provided that he or she is able and willing to serve in such jurisdiction. If no Executor or successor Executor is able and willing to serve in such jurisdiction, my Executor shall designate a successor Executor to serve in such jurisdiction. Such designation shall be made by written instrument delivered to such successor Executor. + +C. No bond or other security shall be required of any Executor in any jurisdiction. + +D. Any Executor may resign in the manner provided for by the governing statutes of the state or territory having jurisdiction of the administration of my estate or in the absence of such statutory guidance, by filing a written notice of resignation with the Court having jurisdiction of the administration of my estate. Any Executor who resigns shall not be entitled to any compensation hereunder for any services rendered as Executor prior to his or her resignation. + +E. My Executor shall not be accountable or responsible to any person interested in my estate for the manner in which my Executor in good faith exercises or declines to exercise any discretionary authority or power of my Executor. My Executor shall not be liable for any loss or depreciation in value occasioned by reason of any negligence, error or mistake of judgment in entering into any transaction, in making any sale or investment, in continuing to hold any property or by reason of any action or omission, whether by my Executor or any other fiduciary, unless my Executor has acted in bad faith. In the absence of proof by affirmative evidence to the contrary, each Executor shall be deemed to have acted within the scope of my Executor's authority, to have exercised reasonable care, diligence and prudence and to have acted impartially as to all interested persons. An Executor shall not be liable for the acts or defaults of another Executor. + +FOURTH: The following provisions shall apply to my estate and to my Executor, except as is otherwise specifically provided in this Will: + +A. My Executor has the entire care and custody of all assets of my estate. My Executor has the power to do everything my Executor in good faith deems advisable without necessity of any judicial authorization or approval, even though but for this power it would not be authorized or appropriate for fiduciaries under any statutory or other rule of law. My Executor shall exercise my Executor's best judgment and discretion for what my Executor believes to be in the best interests of the beneficiaries hereunder. Except as otherwise specifically provided in this Will, if two Executors are empowered to participate in the decision to exercise or not to exercise any fiduciary power granted by this Will or by law, such decision shall be made by such Executors acting unanimously. If more than two Executors are empowered to participate in the decision to exercise or not exercise any fiduciary power granted by this Will or by law, a majority of such Executors shall be empowered to make such decision. + +B. Except as otherwise provided herein, my Executor shall have the power: + +(1) to enter upon and take possession of the assets of my estate and collect the income and profits from such assets, and to invest and reinvest such assets in real, personal or mixed assets (including the common trust funds of a corporate fiduciary) or in undivided interests therein without being limited by any present or future investment laws; + +(2) to retain all or any part of the assets of my estate (without regard to the proportion that any one asset or class of assets may bear to the whole) in the form in which such assets were received or acquired by my Executor; + +(3) to sell or dispose of, exchange, transfer, invest or loan all or any part of the assets of my estate which may, at any time, be held by my Executor for such sums or upon such terms as to payment, security or otherwise as my Executor determines, either by public or private transactions; + +(4) to buy and sell options, warrants, puts, calls or other rights to purchase or sell (collectively "options") relating to any security or securities, regardless of whether such security or securities are then held by my Executor, and whether such options are purchased or sold on a national securities exchange, and to exercise with respect to such options all powers which an individual owner thereof could exercise, including, without limitation, the right to allow the same to expire; + +(5) with respect to oil, natural gas, minerals, and all other natural resources and rights to and interests therein (together with all equipment pertaining thereto), including, without limiting the generality of the foregoing, oil and gas royalties, leases, or other oil and gas interests of any character, whether owned in fee, as lessee, lessor, licensee, concessionaire or otherwise, or alone or jointly with others as partner, joint tenant, or joint venture in any other noncorporate manner, (a) to make oil, gas and mineral leases or subleases; (b) to pay delay rentals, lease bonuses, royalties, overriding royalties, taxes, assessments, and all other charges; (c) to sell, lease, exchange, mortgage, pledge or otherwise hypothecate any or all of such rights and interests; (d) to surrender or abandon, with or without consideration, any or all of such rights and interests; (e) to make farm-out, pooling, and unitization agreements; (f) to make reservations or impose conditions on the transfer of any such rights or interests; (g) to employ the most advantageous business form in which properly to exploit such rights and interests, whether as corporations, partnerships, limited partnerships, mining partnerships, limited liability companies, joint ventures, co-tenancies, or otherwise exploit any and all such rights and interests; (h) to produce, process, sell or exchange all products recovered through the exploitation of such rights and interests, and to enter into contracts and agreements for or in respect of the installation or operation of absorption, reprocessing or other processing plants; (i) to carry any or all such interests in the name or names of a nominee or nominees; (j) to delegate, to the extent permitted by law, any or all of the powers set forth herein to the operator of such property; and (k) to employ personnel, rent office space, buy or lease office equipment, contract and pay for geological surveys and studies, procure appraisals, and generally to conduct and engage in any and all activities incident to the foregoing powers, with full power to borrow and pledge in order to finance such activities; together with the power to allocate between principal and income any net proceeds received as consideration, whether as royalties or + +otherwise, for the permanent severance from lands of oil, natural gas, minerals, and all other natural resources; + +(6) to hold all or any part of the assets of my estate in cash or in bank accounts without the necessity of investing the same; + +(7) subdivide all or any part of the assets of my estate; to improve, repair, partition, plat or + +(8) to litigate, defend, compromise, settle, abandon or submit to arbitration on such terms and conditions as my Executor determines any claims in favor of or against my estate or the assets of my estate; + +(9) to loan or borrow money in such amounts and upon such terms and conditions as my Executor determines, assume such obligations or give such guarantees as my Executor determines, for the purpose of the acquisition, improvement, protection, retention or preservation of the assets of my estate, or for the welfare of the beneficiaries of my estate; + +(10) to carry on for as long and in such manner as my Executor determines any business enterprise in which I owned any interest at my death, either individually, or as a partner, member, joint venture, stockholder or trust beneficiary; to sell such business enterprise as an ongoing business; to consolidate, merge, encumber, dissolve, liquidate or undertake any other extraordinary corporate transaction relating to such business enterprise; + +(11) to vote in person or by proxy any and all stock or securities and to become a party to any voting trusts, reorganization, consolidation or other capital or debt readjustment of any corporation, association, partnership, limited liability partnership, limited liability company or individual with respect to stocks, securities or debts held by my estate; + +(12) except as provided for in Sections (20) and (21) of this Article Fourth, to enter into any good faith transactions with any Executor individually or with any corporation, partnership or other entity in which any Executor has an ownership interest; + +(13) To purchase from my estate any stocks, bonds, securities, real or personal property, or other assets, or make loans to my estate even though the same person or persons occupy the office of my Trustee and the office of the Executor of my estate; + +(14) to lease, mortgage, pledge, grant a security interest in or otherwise encumber all or any part of the assets of my estate for any term of years whether or not beyond the duration of my estate (including, without limitation, any such action for the benefit of any of the beneficiaries of my estate); + +(15) to abandon any property of my estate, real or personal, which my Executor may deem worthless or not of sufficient value to warrant keeping or protecting; to abstain from the payment of taxes, water rents or assessments and to forego making repairs, maintaining or keeping up any such property; and to permit such property to be lost by tax sale or other proceedings or to convey any such property for a nominal consideration or without consideration so as to prevent the imposition of any liability by reason of the continued ownership thereof; + +(16) to elect the mode of distribution of the proceeds payable to my estate from any profit-sharing plan, pension plan, employee benefit plan, individual retirement plan, insurance contract or annuity contract pursuant to the terms of such plan; + +(17) to allocate, in my Executors discretion, any adjustment to basis provided to my estate under the provisions of Federal and State law with respect to property comprising my estate, without any obligation to make a compensatory adjustment among the beneficiaries hereunder on account of such allocation; + +(18) to conduct any audit, assessment or investigation with respect to any asset of my estate regarding compliance with any law or regulation having as its object protection of public health, natural resources or the environment ("Environmental Laws"); to pay from the assets of my estate to remedy any failure to comply with any Environmental Law (even to the exhaustion of all of the assets of my estate); and, as may be required in my Executor's judgment by any Environmental Law, to notify any governmental authority of any past, present or future non-compliance with any Environmental Law; and + +(19) to sell to the Trustee under the Trust Agreement any stocks, bonds, securities, real or personal property or other assets or borrow from the Trustee under the Trust Agreement even though the same person or persons occupy the office of the Executor of my estate and the Trustee under the Trust Agreement. + +(20) No executor shall directly or indirectly buy or sell any property for the estate from or to himself, or from or to his relative, employer, employee, partner, or other business associate. + +(21) No executor shall lend estate funds to himself, or to his relative, employer, employee, partner, or other business associate. + +C. Except as otherwise provided herein, my Executor shall have the power: + +(1) to employ agents, attorneys-at-law, consultants, investment advisers (to whom my Executor has discretion to delegate my Executor's investment authority and responsibility), other executors and other fiduciaries in the administration of my Executor's duties; to delegate to such persons, or to one or more of my Executors, the custody, control or management of any part of my estate as my Executor determines and to pay for such services from the assets of my estate, without obtaining judicial authorization or approval; + +(2) to delegate, in whole or in part, to any person or persons the authority and power to (a) sign checks, drafts or orders for the payment or withdrawal of funds, securities and other assets from any bank, brokerage, custody or other account in which funds, securities or other assets of my estate shall be deposited, (b) endorse for sale, transfer or delivery, or sell, transfer or deliver, or purchase or otherwise acquire, any and all property, stocks, stock warrants, stock rights, options, bonds or other securities whatsoever, (c) gain access to any safe deposit box or boxes in which my assets or assets of my estate may be located or which may be in the name of my Executor and remove part or all of the contents of any such safe deposit box or boxes and release and surrender the same, and (d) take any other action that my Executor may have the power to take with respect to my estate and the property thereof; no person or corporation acting in reliance on any such delegation shall be charged with notice of any revocation or change of such delegation unless such person or corporation receives actual notice thereof; + +(3) to pay any property distributable to a beneficiary under a legal disability or who has not attained the age of 21, without liability to my Executor, by paying such property (a) to such beneficiary, (b) for the use of such beneficiary, (c) to a legal representative of such beneficiary appointed by a court or if none, to a relative for the use of such beneficiary, or (d) to a custodian for such beneficiary designated by my Executor, to hold until age 21 or such earlier age as shall be the maximum permitted under applicable law; + +(4) to distribute to any of the beneficiaries of my estate in kind or in cash, or partly in kind and partly in cash, and to allocate different kinds or disproportionate shares of assets or undivided interests in assets among all of such beneficiaries; + +(5) to have evidence of ownership of any security maintained in the records of a Federal Reserve Bank under the Federal Reserve Book Entry System; to deposit funds in any bank or trust company; to carry in the name of my Executor or the nominee or nominees of my Executor and with or without designation of fiduciary capacity, or to hold in bearer form, securities or other property requiring or permitting of registration; and to cause any securities to be held by a depository corporation of which an Executor is a member or by an agent under a safekeeping contract; provided, however, that the books and records of my Executor shall at all times show that such investments are part of my estate; + +(6) to renounce and disclaim, in whole or in part, and in accordance with applicable law, any assets, interests, rights or powers (including any power of appointment) which are payable to (or exercisable by) me or my estate, which are includible in my estate or Gross Estate or over which I have any right, title, interest or power; and + +(7) to make, execute and deliver any and all such instruments in writing as shall be necessary or proper to carry out any power, right, duty or obligation of my Executor or any disposition whatsoever of my estate or any asset of my estate and to exercise any and all other powers incidental or necessary to carry out or to fulfill the terms, provisions and purposes of my estate. + +D. In connection with any insurance policy or annuity on the + +life of an Executor which is included in my estate, such Executor shall not participate in the decision to exercise or not exercise any fiduciary power in connection with any incidents of ownership for such policy or annuity, including, without limitation, any decision to continue, assign, terminate or convert such policy or annuity or to name the beneficiary of such policy or annuity. + +E. An Executor hereunder may by a written notice delivered to the other Executor decline to participate in the decision to exercise or not exercise any fiduciary power granted by this Will or by law. + +F. If an Executor is not empowered (because of a conflict of interest, declination to act or otherwise) to participate in the decision to exercise or not exercise any fiduciary power granted by this Will or by law, then the remaining Executor shall be empowered to make such decision. If no Executor is empowered to participate in such decision, then the successor Executor of my estate designated in Paragraph A of Article THIRD and able and willing to act shall be empowered to make such decision. If no Executor or successor Executor is empowered to participate in such decision, my Executor may designate a successor Executor to serve as Executor of my estate who shall be empowered to make such decision but shall have no other power or authority of my Executor. Such designation shall be by written notice delivered to such successor Executor. + +G. (1) Except as otherwise specifically provided in this Paragraph G(1) of this Article, and except as provided in Paragraph G(2) of this Article, my Executor shall allocate receipts and disbursements in accordance with sound trust accounting principles and shall have discretion to allocate receipts and disbursements when the treatment is uncertain under applicable laws or generally accepted accounting principles in the judgment of my Executor. + +(2) Except as otherwise specifically provided in this Will, my Executor shall not treat any part of the principal amount of the proceeds of sale of any asset of my estate as income distributable to or for the benefit of any beneficiary entitled to distributions of income; provided, however, that my Executor shall treat a portion of any proceeds of sale of any financial instrument originally issued or acquired at a discount equal to the amount which (a) has previously been characterized as ordinary income for income tax purposes or (b) will be characterized as ordinary income for income tax purposes in the year of such sale, as income for trust accounting purposes. + +FIFTH: Where a party to any proceeding with respect to my estate has the same interest as a person under a disability, it shall not be necessary to serve legal process on the person under a disability. + +SIXTH: If any beneficiary under the Trust shall in any way directly or indirectly (a) contest or object to the probate of my Will or to the validity of any disposition or provision of my Will or of the Trust or (b) institute or prosecute, or be in any way directly or indirectly instrumental in the institution or prosecution of, any action, proceeding, contest, objection or claim for the purpose of setting aside or invalidating my Will or the Trust or any disposition therein or provision thereof, then I direct that (a) any and all provisions in the Trust + +for such beneficiary and his issue in any degree shall be null and void and (b) my estate, whether passing under my Will or the Trust or pursuant to the laws of intestacy, shall be disposed of as if such beneficiary and his issue in any degree had all failed to survive me. + +SEVENTH: A. As used herein: + +(1) The term “Executor” of a person’s estate means all persons or entities who occupy the office of executor, administrator, personal representative, or ancillary administrator while such persons or entities occupy such office, whether one or more persons or entities occupy such office at the same time or times, and includes any successor or successors to that office. The term “Trustee” means all persons or entities who occupy the office of Trustee under the Trust Agreement while such persons or entities occupy such office, whether one or more persons or entities occupy the office of Trustee at the same time or times, and includes any successor Trustee or Trustees. A reference to a person’s estate or probate estate means that person’s estate which is subject to probate administration. A reference to a person’s Will means such person’s Last Will and Testament and any Codicil or Codicils thereto. + +(2) The term “IRC section” means a section of the Internal Revenue Code of 1986, as amended, or the corresponding provision of any successor Internal Revenue law, as in effect as of the date of my death. + +(3) A reference to any tax also includes any interest or penalties thereon. A reference to a person’s “Gross Estate” means such person’s gross estate as finally determined for purposes of computing such person’s federal estate tax. + +(4) Whenever the singular number is used, the same shall include the plural, and the masculine gender shall include the feminine and neuter genders. + +B. (1) The federal and state transfer taxes which my Executor shall be obligated to pay pursuant to Paragraph B of Article FIRST shall consist of all federal and state estate, inheritance, succession, and similar taxes (including any federal or state generation-skipping transfer tax) imposed upon my probate estate or by reason of my death in respect to all assets which pass under this Will or the Trust Agreement. Subject to Paragraph B(2) of this Article, all federal estate taxes with respect to assets not passing under this Will or the Trust Agreement (such assets are referred to as the “Apportionment Assets”) and any applicable state estate taxes with respect to the Apportionment Assets shall be apportioned among all persons interested in the Apportionment Assets. My Executor shall make reasonable efforts to collect all federal estate taxes and state estate, inheritance, succession and similar taxes allocable to the Apportionment Assets from the recipients of the Apportionment Assets. Without changing the apportionment of taxes in this Paragraph B(1), my Executor has discretion, but is not required, to pay all or part of such taxes allocable to the Apportionment Assets. To the extent my Executor pays such taxes allocable to the Apportionment Assets, my Executor shall seek reimbursement for such taxes from the recipients of the Apportionment Assets. My Executor shall not be + +personally liable for any of such taxes if my Executor is unable, with reasonable efforts, to collect payment (or reimbursement) from any recipient of any Apportionment Assets for any or all of such taxes allocable to such assets. + +(2) My Executor has discretion to direct the Trustee of the Trust Agreement to pay all or any portion of the taxes which my Executor is directed or obligated to pay pursuant to Paragraph B of Article FIRST and this Paragraph B pursuant to a written direction delivered to the Trustee under the Trust Agreement. Any taxes which my Executor directs the Trustee under the Trust Agreement to pay shall be allocated and paid from the trusts under the Trust Agreement as provided under the Trust Agreement. + +C. Except as otherwise specifically provided in this Will, a bequest or devise to an individual who does not survive me shall lapse notwithstanding any law to the contrary. + +D. To the extent that the distribution to the Trustee under the Trust Agreement pursuant to Article SECOND shall not be effective, I give all the rest of my property, real and personal, wherever situated, after the payments and distributions provided in Article FIRST, to the person or persons named as Trustee or Trustees under the Trust Agreement, be to held in trust under this Will in accordance with the provisions comprising the Trust Agreement at the time of my death, which provisions are incorporated in this Will by reference. + +IN WITNESS WHEREOF, I have duly executed this Will this 8th day of May, 2018. + +![]()The foregoing written instrument was, on the date thereof, signed, published and declared by the Testator therein named as the Testator's Will in the presence of us and of each of us, who, at the Testator's request, in the Testator's presence, and in the presence of each other have subscribed our names as witnesses thereto. + +![]()![]()![]()![]()AFFIDAVIT + +We, JEFFREY E. EPSTEIN, Karyn Ashulick and Lesley Groff, the Testator and the witnesses, respectively, whose names are signed to the foregoing instrument, having been + +sworn, declared to the undersigned officer that the Testator, in the presence of the witnesses, signed the instrument as his Will, that he signed, and that each of the witnesses, in the presence of the Testator and in the presence of each other, signed the Will as a witness. + +![]()STATE OF NEW YORK ) +)ss: +COUNTY OF NEW YORK ) + +Subscribed and sworn to before me by JEFFREY E. 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EPSTEIN + +I, JEFFREY E. EPSTEIN, a resident and domiciliary of St. Thomas, United States Virgin Islands, do make, publish and declare this to be my Will hereby revoking all prior Wills and Codicils made by me. + +FIRST: A. I direct my Executor to pay from my estate all expenses of my last illness, my funeral and burial expenses, the administration expenses of my estate and all of my debts duly proven and allowed against my estate. + +B. I direct my Executor to pay from my estate, as compensation to each Executor for serving as Executor hereunder, the sum of Two Hundred Fifty Thousand Dollars (\$250,000) to each Executor upon the completion of probate of my estate. No Executor shall receive any other compensation for serving as Executor hereunder; provided, however, that my Executor shall be reimbursed from my estate for all reasonable costs, expenses, charges, and liabilities incurred or paid in respect thereto, including fees and expenses of counsel or any other agents hired by my Executor, and my Executor shall not be liable therefor individually. + +C. I direct my Executor to pay from my estate the federal and state transfer taxes described in Paragraph B(1) of Article SEVENTH. + +D. I direct my Executor to pay from my estate all expenses of storing, insuring, packing, shipping and delivering my tangible personal property in accordance with the provisions of Article SECOND. + +SECOND: I give all of my property, real and personal, wherever situated, after the payments and distributions provided in Article FIRST, to the then acting Trustees of The Jeffrey E. Epstein 2019 Trust ("Trust") created under that certain Trust Agreement of The Jeffrey E. Epstein 2019 Trust (the "Trust Agreement") dated January 18, 2019, as the same may be amended from time to time, to be held in accordance with the provisions comprising the Trust Agreement at the time of my death. + +THIRD: A. I appoint DARREN K. INDYKE and RICHARD D. KAHN to serve as the Executors of this Will. If any one or more of my Executors fails to qualify, is unable or unwilling to serve or ceases to act, I appoint KATHRYN H. RUEMMLER, as successor Executor. If any successor Executor fails to qualify, is unable or unwilling to serve or ceases to act, I authorize the last acting Executor to designate his or her successor. Such designation shall be made by written instrument delivered to such designated successor Executor. + +B. If my estate must be administered in whole or in part in any jurisdiction other than the state or territory of my domicile at the date of my death, and if my + +Executor is unable or unwilling to serve in such jurisdiction, then I appoint the successor Executor of my estate designated in Paragraph A of Article THIRD as successor Executor in such jurisdiction only, provided that he or she is able and willing to serve in such jurisdiction. If no Executor or successor Executor is able and willing to serve in such jurisdiction, my Executor shall designate a successor Executor to serve in such jurisdiction. Such designation shall be made by written instrument delivered to such successor Executor. + +C. No bond or other security shall be required of any Executor in any jurisdiction. + +D. Any Executor may resign in the manner provided for by the governing statutes of the state or territory having jurisdiction of the administration of my estate or in the absence of such statutory guidance, by filing a written notice of resignation with the Court having jurisdiction of the administration of my estate. Any Executor who resigns shall not be entitled to any compensation hereunder for any services rendered as Executor prior to his or her resignation. + +E. My Executor shall not be accountable or responsible to any person interested in my estate for the manner in which my Executor in good faith exercises or declines to exercise any discretionary authority or power of my Executor. My Executor shall not be liable for any loss or depreciation in value occasioned by reason of any negligence, error or mistake of judgment in entering into any transaction, in making any sale or investment, in continuing to hold any property or by reason of any action or omission, whether by my Executor or any other fiduciary, unless my Executor has acted in bad faith. In the absence of proof by affirmative evidence to the contrary, each Executor shall be deemed to have acted within the scope of my Executor's authority, to have exercised reasonable care, diligence and prudence and to have acted impartially as to all interested persons. An Executor shall not be liable for the acts or defaults of another Executor. + +FOURTH: The following provisions shall apply to my estate and to my Executor, except as is otherwise specifically provided in this Will: + +A. My Executor has the entire care and custody of all assets of my estate. My Executor has the power to do everything my Executor in good faith deems advisable without necessity of any judicial authorization or approval, even though but for this power it would not be authorized or appropriate for fiduciaries under any statutory or other rule of law. My Executor shall exercise my Executor's best judgment and discretion for what my Executor believes to be in the best interests of the beneficiaries hereunder. Except as otherwise specifically provided in this Will, if two Executors are empowered to participate in the decision to exercise or not to exercise any fiduciary power granted by this Will or by law, such decision shall be made by such Executors acting unanimously. If more than two Executors are empowered to participate in the decision to exercise or not exercise any fiduciary power granted by this Will or by law, a majority of such Executors shall be empowered to make such decision. + +B. Except as otherwise provided herein, my Executor shall have the power: + +(1) to enter upon and take possession of the assets of my estate and collect the income and profits from such assets, and to invest and reinvest such assets in real, personal or mixed assets (including the common trust funds of a corporate fiduciary) or in undivided interests therein without being limited by any present or future investment laws; + +(2) to retain all or any part of the assets of my estate (without regard to the proportion that any one asset or class of assets may bear to the whole) in the form in which such assets were received or acquired by my Executor; + +(3) to sell or dispose of, exchange, transfer, invest or loan all or any part of the assets of my estate which may, at any time, be held by my Executor for such sums or upon such terms as to payment, security or otherwise as my Executor determines, either by public or private transactions; + +(4) to buy and sell options, warrants, puts, calls or other rights to purchase or sell (collectively "options") relating to any security or securities, regardless of whether such security or securities are then held by my Executor, and whether such options are purchased or sold on a national securities exchange, and to exercise with respect to such options all powers which an individual owner thereof could exercise, including, without limitation, the right to allow the same to expire; + +(5) with respect to oil, natural gas, minerals, and all other natural resources and rights to and interests therein (together with all equipment pertaining thereto), including, without limiting the generality of the foregoing, oil and gas royalties, leases, or other oil and gas interests of any character, whether owned in fee, as lessee, lessor, licensee, concessionaire or otherwise, or alone or jointly with others as partner, joint tenant, or joint venture in any other noncorporate manner, (a) to make oil, gas and mineral leases or subleases; (b) to pay delay rentals, lease bonuses, royalties, overriding royalties, taxes, assessments, and all other charges; (c) to sell, lease, exchange, mortgage, pledge or otherwise hypothecate any or all of such rights and interests; (d) to surrender or abandon, with or without consideration, any or all of such rights and interests; (e) to make farm-out, pooling, and unitization agreements; (f) to make reservations or impose conditions on the transfer of any such rights or interests; (g) to employ the most advantageous business form in which properly to exploit such rights and interests, whether as corporations, partnerships, limited partnerships, mining partnerships, limited liability companies, joint ventures, co-tenancies, or otherwise exploit any and all such rights and interests; (h) to produce, process, sell or exchange all products recovered through the exploitation of such rights and interests, and to enter into contracts and agreements for or in respect of the installation or operation of absorption, reprocessing or other processing plants; (i) to carry any or all such interests in the name or names of a nominee or nominees; (j) to delegate, to the extent permitted by law, any or all of the powers set forth herein to the operator of such property; and (k) to employ personnel, rent office space, buy or lease office equipment, contract and pay for geological surveys and studies, procure appraisals, and generally to conduct and engage in any and all activities incident to the foregoing powers, with full power to borrow and pledge in order to finance such activities; together with the power to allocate between principal and income any net proceeds received as consideration, whether as royalties or + +otherwise, for the permanent severance from lands of oil, natural gas, minerals, and all other natural resources; + +(6) to hold all or any part of the assets of my estate in cash or in bank accounts without the necessity of investing the same; + +(7) to improve, repair, partition, plat or subdivide all or any part of the assets of my estate; + +(8) to litigate, defend, compromise, settle, abandon or submit to arbitration on such terms and conditions as my Executor determines any claims in favor of or against my estate or the assets of my estate; + +(9) to loan or borrow money in such amounts and upon such terms and conditions as my Executor determines, assume such obligations or give such guarantees as my Executor determines, for the purpose of the acquisition, improvement, protection, retention or preservation of the assets of my estate, or for the welfare of the beneficiaries of my estate; + +(10) to carry on for as long and in such manner as my Executor determines any business enterprise in which I owned any interest at my death, either individually, or as a partner, member, joint venture, stockholder or trust beneficiary; to sell such business enterprise as an ongoing business; to consolidate, merge, encumber, dissolve, liquidate or undertake any other extraordinary corporate transaction relating to such business enterprise; + +(11) to vote in person or by proxy any and all stock or securities and to become a party to any voting trusts, reorganization, consolidation or other capital or debt readjustment of any corporation, association, partnership, limited liability partnership, limited liability company or individual with respect to stocks, securities or debts held by my estate; + +(12) except as provided for in Sections (20) and (21) of this Article Fourth, to enter into any good faith transactions with any Executor individually or with any corporation, partnership or other entity in which any Executor has an ownership interest; + +(13) To purchase from my estate any stocks, bonds, securities, real or personal property, or other assets, or make loans to my estate even though the same person or persons occupy the office of my Trustee and the office of the Executor of my estate; + +(14) to lease, mortgage, pledge, grant a security interest in or otherwise encumber all or any part of the assets of my estate for any term of years whether or not beyond the duration of my estate (including, without limitation, any such action for the benefit of any of the beneficiaries of my estate); + +(15) to abandon any property of my estate, real or personal, which my Executor may deem worthless or not of sufficient value to warrant keeping + +or protecting; to abstain from the payment of taxes, water rents or assessments and to forego making repairs, maintaining or keeping up any such property; and to permit such property to be lost by tax sale or other proceedings or to convey any such property for a nominal consideration or without consideration so as to prevent the imposition of any liability by reason of the continued ownership thereof; + +(16) to elect the mode of distribution of the proceeds payable to my estate from any profit-sharing plan, pension plan, employee benefit plan, individual retirement plan, insurance contract or annuity contract pursuant to the terms of such plan; + +(17) to allocate, in my Executors discretion, any adjustment to basis provided to my estate under the provisions of Federal and State law with respect to property comprising my estate, without any obligation to make a compensatory adjustment among the beneficiaries hereunder on account of such allocation; + +(18) to conduct any audit, assessment or investigation with respect to any asset of my estate regarding compliance with any law or regulation having as its object protection of public health, natural resources or the environment ("Environmental Laws"); to pay from the assets of my estate to remedy any failure to comply with any Environmental Law (even to the exhaustion of all of the assets of my estate); and, as may be required in my Executor's judgment by any Environmental Law, to notify any governmental authority of any past, present or future non-compliance with any Environmental Law; and + +(19) to sell to the Trustee under the Trust Agreement any stocks, bonds, securities, real or personal property or other assets or borrow from the Trustee under the Trust Agreement even though the same person or persons occupy the office of the Executor of my estate and the Trustee under the Trust Agreement. + +(20) No executor shall directly or indirectly buy or sell any property for the estate from or to himself, or from or to his relative, employer, employee, partner, or other business associate. + +(21) No executor shall lend estate funds to himself, or to his relative, employer, employee, partner, or other business associate. + +C. Except as otherwise provided herein, my Executor shall have the power: + +(1) to employ agents, attorneys-at-law, consultants, investment advisers (to whom my Executor has discretion to delegate my Executor's investment authority and responsibility), other executors and other fiduciaries in the administration of my Executor's duties; to delegate to such persons, or to one or more of my Executors, the custody, control or management of any part of my estate as my Executor determines and to pay for such services from the assets of my estate, without obtaining judicial authorization or approval; + +(2) to delegate, in whole or in part, to any person or persons the authority and power to (a) sign checks, drafts or orders for the payment or withdrawal of funds, securities and other assets from any bank, brokerage, custody or other account in which funds, securities or other assets of my estate shall be deposited, (b) endorse for sale, transfer or delivery, or sell, transfer or deliver, or purchase or otherwise acquire, any and all property, stocks, stock warrants, stock rights, options, bonds or other securities whatsoever, (c) gain access to any safe deposit box or boxes in which my assets or assets of my estate may be located or which may be in the name of my Executor and remove part or all of the contents of any such safe deposit box or boxes and release and surrender the same, and (d) take any other action that my Executor may have the power to take with respect to my estate and the property thereof; no person or corporation acting in reliance on any such delegation shall be charged with notice of any revocation or change of such delegation unless such person or corporation receives actual notice thereof; + +(3) to pay any property distributable to a beneficiary under a legal disability or who has not attained the age of 21, without liability to my Executor, by paying such property (a) to such beneficiary, (b) for the use of such beneficiary, (c) to a legal representative of such beneficiary appointed by a court or if none, to a relative for the use of such beneficiary, or (d) to a custodian for such beneficiary designated by my Executor, to hold until age 21 or such earlier age as shall be the maximum permitted under applicable law; + +(4) to distribute to any of the beneficiaries of my estate in kind or in cash, or partly in kind and partly in cash, and to allocate different kinds or disproportionate shares of assets or undivided interests in assets among all of such beneficiaries; + +(5) to have evidence of ownership of any security maintained in the records of a Federal Reserve Bank under the Federal Reserve Book Entry System; to deposit funds in any bank or trust company; to carry in the name of my Executor or the nominee or nominees of my Executor and with or without designation of fiduciary capacity, or to hold in bearer form, securities or other property requiring or permitting of registration; and to cause any securities to be held by a depository corporation of which an Executor is a member or by an agent under a safekeeping contract; provided, however, that the books and records of my Executor shall at all times show that such investments are part of my estate; + +(6) to renounce and disclaim, in whole or in part, and in accordance with applicable law, any assets, interests, rights or powers (including any power of appointment) which are payable to (or exercisable by) me or my estate, which are includible in my estate or Gross Estate or over which I have any right, title, interest or power; and + +(7) to make, execute and deliver any and all such instruments in writing as shall be necessary or proper to carry out any power, right, duty or obligation of my Executor or any disposition whatsoever of my estate or any asset of my estate and to exercise any and all other powers incidental or necessary to carry out or to fulfill the terms, provisions and purposes of my estate. + +D. In connection with any insurance policy or annuity on the + +life of an Executor which is included in my estate, such Executor shall not participate in the decision to exercise or not exercise any fiduciary power in connection with any incidents of ownership for such policy or annuity, including, without limitation, any decision to continue, assign, terminate or convert such policy or annuity or to name the beneficiary of such policy or annuity. + +E. An Executor hereunder may by a written notice delivered to the other Executor decline to participate in the decision to exercise or not exercise any fiduciary power granted by this Will or by law. + +F. If an Executor is not empowered (because of a conflict of interest, declination to act or otherwise) to participate in the decision to exercise or not exercise any fiduciary power granted by this Will or by law, then the remaining Executor shall be empowered to make such decision. If no Executor is empowered to participate in such decision, then the successor Executor of my estate designated in Paragraph A of Article THIRD and able and willing to act shall be empowered to make such decision. If no Executor or successor Executor is empowered to participate in such decision, my Executor may designate a successor Executor to serve as Executor of my estate who shall be empowered to make such decision but shall have no other power or authority of my Executor. Such designation shall be by written notice delivered to such successor Executor. + +G. (1) Except as otherwise specifically provided in this Paragraph G(1) of this Article, and except as provided in Paragraph G(2) of this Article, my Executor shall allocate receipts and disbursements in accordance with sound trust accounting principles and shall have discretion to allocate receipts and disbursements when the treatment is uncertain under applicable laws or generally accepted accounting principles in the judgment of my Executor. + +(2) Except as otherwise specifically provided in this Will, my Executor shall not treat any part of the principal amount of the proceeds of sale of any asset of my estate as income distributable to or for the benefit of any beneficiary entitled to distributions of income; provided, however, that my Executor shall treat a portion of any proceeds of sale of any financial instrument originally issued or acquired at a discount equal to the amount which (a) has previously been characterized as ordinary income for income tax purposes or (b) will be characterized as ordinary income for income tax purposes in the year of such sale, as income for trust accounting purposes. + +FIFTH: Where a party to any proceeding with respect to my estate has the same interest as a person under a disability, it shall not be necessary to serve legal process on the person under a disability. + +SIXTH: If any beneficiary under the Trust shall in any way directly or indirectly (a) contest or object to the probate of my Will or to the validity of any disposition or provision of my Will or of the Trust or (b) institute or prosecute, or be in any way directly or indirectly instrumental in the institution or prosecution of, any action, proceeding, contest, objection or claim for the purpose of setting aside or invalidating my Will or the Trust or any disposition therein or provision thereof, then I direct that (a) any and all provisions in the Trust + +for such beneficiary and his issue in any degree shall be null and void and (b) my estate, whether passing under my Will or the Trust or pursuant to the laws of intestacy, shall be disposed of as if such beneficiary and his issue in any degree had all failed to survive me. + +SEVENTH: A. As used herein: + +(1) The term "Executor" of a person's estate means all persons or entities who occupy the office of executor, administrator, personal representative, or ancillary administrator while such persons or entities occupy such office, whether one or more persons or entities occupy such office at the same time or times, and includes any successor or successors to that office. The term "Trustee" means all persons or entities who occupy the office of Trustee under the Trust Agreement while such persons or entities occupy such office, whether one or more persons or entities occupy the office of Trustee at the same time or times, and includes any successor Trustee or Trustees. A reference to a person's estate or probate estate means that person's estate which is subject to probate administration. A reference to a person's Will means such person's Last Will and Testament and any Codicil or Codicils thereto. + +(2) The term "IRC section" means a section of the Internal Revenue Code of 1986, as amended, or the corresponding provision of any successor Internal Revenue law, as in effect as of the date of my death. + +(3) A reference to any tax also includes any interest or penalties thereon. A reference to a person's "Gross Estate" means such person's gross estate as finally determined for purposes of computing such person's federal estate tax. + +(4) Whenever the singular number is used, the same shall include the plural, and the masculine gender shall include the feminine and neuter genders. + +B. (1) The federal and state transfer taxes which my Executor shall be obligated to pay pursuant to Paragraph B of Article FIRST shall consist of all federal and state estate, inheritance, succession, and similar taxes (including any federal or state generation-skipping transfer tax) imposed upon my probate estate or by reason of my death in respect to all assets which pass under this Will or the Trust Agreement. Subject to Paragraph B(2) of this Article, all federal estate taxes with respect to assets not passing under this Will or the Trust Agreement (such assets are referred to as the "Apportionment Assets") and any applicable state estate taxes with respect to the Apportionment Assets shall be apportioned among all persons interested in the Apportionment Assets. My Executor shall make reasonable efforts to collect all federal estate taxes and state estate, inheritance, succession and similar taxes allocable to the Apportionment Assets from the recipients of the Apportionment Assets. Without changing the apportionment of taxes in this Paragraph B(1), my Executor has discretion, but is not required, to pay all or part of such taxes allocable to the Apportionment Assets. To the extent my Executor pays such taxes allocable to the Apportionment Assets, my Executor shall seek reimbursement for such taxes from the recipients of the Apportionment Assets. My Executor shall not be + +personally liable for any of such taxes if my Executor is unable, with reasonable efforts, to collect payment (or reimbursement) from any recipient of any Apportionment Assets for any or all of such taxes allocable to such assets. + +(2) My Executor has discretion to direct the Trustee of the Trust Agreement to pay all or any portion of the taxes which my Executor is directed or obligated to pay pursuant to Paragraph B of Article FIRST and this Paragraph B pursuant to a written direction delivered to the Trustee under the Trust Agreement. Any taxes which my Executor directs the Trustee under the Trust Agreement to pay shall be allocated and paid from the trusts under the Trust Agreement as provided under the Trust Agreement. + +C. Except as otherwise specifically provided in this Will, a bequest or devise to an individual who does not survive me shall lapse notwithstanding any law to the contrary. + +D. To the extent that the distribution to the Trustee under the Trust Agreement pursuant to Article SECOND shall not be effective, I give all the rest of my property, real and personal, wherever situated, after the payments and distributions provided in Article FIRST, to the person or persons named as Trustee or Trustees under the Trust Agreement, be to held in trust under this Will in accordance with the provisions comprising the Trust Agreement at the time of my death, which provisions are incorporated in this Will by reference. + +IN WITNESS WHEREOF, I have duly executed this ill this 18th day of January, 2019. + +JEFFREY . EPSTEIN + +The foregoing written instrument was, on the date thereof, signed, published and declared by the Testator therein named as the Testator's Will in the presence of us and of each of us, who, at the Testator's request, in the Testator's presence, and in the presence of each other have subscrilapfl our names as witnesses thereto. + +residing at residing at + +AFFIDAVIT + +ro c\_r-71 gift le4.4 diso)Ical-MO 7, hed) in. 32\_901, + +We, JEFFREY E. EPSTEIN. and n 1 12 tZthe Testator and the witnesses, respectively, whose names are signed to the foregoing instrument, having been + +sworn, declared to the undersigned officer that the Testator, in the presence of the witnesses, signed the instrument as his Will, that he signed, and that each of the witnesses, in the presence of the Testator and in the presence of each other, signed the Will as a witness. + +![]()STATE OF ~~NEW YORK~~ Florida ) +)ss: +COUNTY OF ~~NEW YORK~~ Palm Beach ) + +Subscribed and sworn to before me by JEFFREY E. 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EPSTEIN + +I, JEFFREY E. EPSTEIN, of Little St. James Island, St. Thomas, United States Virgin Islands, being of sound mind, do make, publish and declare this to be my Will hereby revoking all prior Wills and Codicils made by me. + +FIRST: A. I direct my Executor to pay from my estate all expenses of my last illness, my funeral and burial expenses, the administration expenses of my estate and all of my debts duly proven and allowed against my estate. + +B. I direct my Executor to pay from my estate, as compensation to each Executor for serving as Executor hereunder, the sum of Two Hundred Fifty Thousand Dollars (\$250,000) to each Executor upon the completion of probate of my estate. No Executor shall receive any other compensation for serving as Executor hereunder; provided, however, that my Executor shall be reimbursed from my estate for all reasonable costs, expenses, charges, and liabilities incurred or paid in respect thereto, including fees and expenses of counsel or any other agents hired by my Executor, and my Executor shall not be liable therefor individually. + +C. I direct my Executor to pay from my estate the Federal and state transfer taxes described in Paragraph B(1) of Article SEVENTH. + +D. I direct my Executor to pay from my estate all expenses of storing, insuring, packing, shipping and delivering my tangible personal property in accordance with Article SECOND. + +SECOND: I give, bequeath and devise all of my property, real and personal, wherever situated, which I won at my death or of which I have the power to dispose after the payments and distributions provided in Article FIRST, to the then acting Trustees of The Jeffrey E. Epstein 2014 Trust (the "Trust") created under that certain Trust Agreement (the "Trust Agreement") dated November 2014, as the same may be amended from time to time, to be held in accordance with the provisions comprising the Trust Agreement at the time of my death. + +THIRD: A. I appoint DARREN K. INDYKE, DAVID MITCHELL and JAMES E. STALEY to be the Executors of this Will. If any one or more of my Executors fails to qualify or ceases to act, I appoint LAWRENCE H. SUMMERS as successor Executor. I authorize the last acting Executor to designate his successor as Executor. + +B. If my estate must be administered in whole or in part in any jurisdiction other than the state or territory of my domicile at the date of my death and if my Executor is unable or unwilling to serve in such jurisdiction, then I appoint the successor Executor of my estate designated in Paragraph A of Article THIRD provided that he is able and willing to serve in such jurisdiction. If no Executor or successor Executor is able and willing to serve in such jurisdiction, my Executor shall designate a successor Executor to serve in such jurisdiction. Such designation shall be made by written instrument delivered to such successor Executor. + +C. No bond or other security shall be required of any Executor in any jurisdiction. + +D. Any Executor may resign in the manner provided for by the governing statutes of the state or territory having jurisdiction of the administration of my estate or, in the absence of such statutory guidance, by filing a written notice of resignation with the Court having jurisdiction of the administration of my estate. Any Executor who resigns shall not be entitled to any compensation hereunder for any services rendered as Executor prior to his resignation. + +E. My Executor shall not be accountable or responsible to any person interested in my estate for the manner in which my Executor in good faith exercises or declines to exercise any discretionary authority or power of my Executor. My Executor shall not be liable for any loss or depreciation in value occasioned by reason of any negligence, error or mistake of judgment in entering into any transaction, in making any sale or investment, in continuing to hold any property or by reason of any action or omission, whether by my Executor or any other fiduciary, unless my Executor has acted in bad faith. In the absence of proof by affirmative evidence to the contrary and affirmative evidence of my Executor acting in bad faith, each Executor shall be deemed to have acted within the scope of my Executor's authority, to have exercised reasonable care, diligence and prudence and to have acted impartially as to all interested persons. An Executor shall not be liable for the acts or defaults of another Executor. + +FOURTH: The following provisions shall apply to my estate and to my Executor, except as is otherwise specifically provided in this Will: + +A. My Executor has the entire care and custody of all assets of my estate. My Executor has the power to do everything my Executor in good faith deems advisable without necessity of any judicial authorization or approval, even though but for this power it would not be authorized or appropriate for fiduciaries under any statutory or other rule of law. My Executor shall exercise my Executor's best judgment and discretion for what my Executor believes to be in the best interests of the beneficiaries hereunder. If more than two Executors are empowered to participate in the decision to exercise or not exercise any fiduciary power granted by this Will or by law, a majority of such Executors shall be empowered to make such decision. + +B. Except as otherwise provided herein, my Executor shall have the power: + +(1) to enter upon and take possession of the assets of my estate and collect the income and profits from such assets, and to invest and reinvest such assets in real, personal or mixed assets (including the common trust funds of a corporate fiduciary) or in undivided interests therein without being limited by any present or future investment laws; + +(2) to retain all or any part of the assets of my estate (without regard to the proportion that any one asset or class of assets may bear to the whole) in the form in which such assets were received or acquired by my Executor; + +(3) to sell or dispose of, exchange, transfer, invest or loan all or any part of the assets of my estate which may, at any time, be held by my Executor for such sums or upon such terms as to payment, security or otherwise as my Executor determines, either by public or private transactions; + +(4) to buy and sell options, warrants, puts, calls or other rights to purchase or sell (collectively "options") relating to any security or securities, regardless of whether such security or securities are then held by my Executor, and whether such options are purchased or sold on a national securities exchange, and to exercise with respect to such options all powers which an individual owner thereof could exercise, including, without limitation, the right to allow the same to expire; + +(5) with respect to oil, natural gas, minerals, and all other natural resources and rights to and interests therein (together with all equipment pertaining thereto) including, without limiting the generality of the foregoing, oil and gas royalties, leases, or other oil and gas interests of any character, whether owned in fee, as lessee, lessor, licensee, concessionaire or otherwise, or alone or jointly with others as partner, joint tenant, or joint venture in any other noncorporate manner, (a) to make oil, gas and mineral leases or subleases; (b) to pay delay rentals, lease bonuses, royalties, overriding royalties, taxes, assessments, and all other charges; (c) to sell, lease, exchange, mortgage, pledge or otherwise hypothecate any or all of such rights and interests; (d) to surrender or abandon, with or without consideration, any or all of such rights and interests; (e) to make farm-out, pooling, and unitization agreements; (f) to make reservations or impose conditions on the transfer of any such rights or interests; (g) to employ the most advantageous business form in which properly to exploit such rights and interests, whether as corporations, partnerships, limited partnerships, mining partnerships, joint ventures, co-tenancies, or otherwise exploit any and all such rights and interests; (h) to produce, process, sell or exchange all products recovered through the exploitation of such rights and interests, and to enter into contracts and agreements for or in respect of the installation or operation of absorption, reprocessing or other processing plants; (i) to carry any or all such interests in the name or names of a nominee or nominees; (j) to delegate, to the extent permitted by law, any or all of the powers set forth herein to the operator of such property; and (k) to employ personnel, rent office space, buy or lease office equipment, contract and pay for geological surveys and studies, procure appraisals, and generally to conduct and engage in any and all activities incident to the foregoing powers, with full power to borrow and pledge in order to finance such activities; together with the power to allocate between principal and income any net proceeds received as consideration, whether as royalties or otherwise, for the permanent severance from lands of oil, natural gas, minerals, and all other natural resources; + +(6) to hold all or any part of the assets of my estate in cash or in bank accounts without the necessity of investing the same; + +(7) to improve, repair, partition, plat or subdivide all or any part of the assets of my estate; + +(8) to litigate, defend, compromise, settle, abandon or submit to arbitration on such terms and conditions as my Executor determines; to propose or accept a compromise with respect to any claims in favor of or against my estate or the assets of my estate; + +(9) to loan or borrow money in such amounts and upon such terms and conditions as my Executor determines, assume such obligations or give such guarantees as my Executor determines, for the purpose of the acquisition, improvement, protection, retention or preservation of the assets of my estate, or for the welfare of the beneficiaries of my estate; + +(10) to carry on for as long and in such manner as my Executor determines any business enterprise in which I owned any interest at my death, either individually, or as a partner, joint venture, stockholder or trust beneficiary; to sell such business + +enterprise as an ongoing business; to consolidate, merge, encumber, dissolve, liquidate or undertake any other extraordinary corporate transaction relating to such business enterprise; + +(11) to vote in person or by proxy any and all stock or securities and to become a party to any voting trusts, reorganization, consolidation or other capital or debt readjustment of any corporation, association, partnership, limited liability partnership, limited liability company or individual with respect to stocks, securities or debts held by my estate; + +(12) except as provided in paragraphs B(19) and B(20) of this Article FOURTH, to enter into any good faith transactions with my Executor individually or with any corporation, partnership or other entity in which my Executor has an ownership interest; + +(13) to lease, mortgage, pledge, grant a security interest in or otherwise encumber all or any part of the assets of my estate for any term of years whether or not beyond the duration of my estate (including, without limitation, any such action for the benefit of any of the beneficiaries of my estate); + +(14) to abandon any property of my estate, real or personal, which my Executor may deem worthless or not of sufficient value to warrant keeping or protecting; to abstain from the payment of taxes, water rents or assessments and to forego making repairs, maintaining or keeping up any such property; and to permit such property to be lost by tax sale or other proceedings or to convey any such property for a nominal consideration or without consideration so as to prevent the imposition of any liability by reason of the continued ownership thereof; + +(15) to elect the mode of distribution of the proceeds payable to my estate from any profit-sharing plan, pension plan, employee benefit plan, individual retirement plan, insurance contract or annuity contract pursuant to the terms of such plan; + +(16) to allocate, in my Executors discretion, any adjustment to basis provided to my estate under the provisions of Federal and state law with respect to property comprising my estate, without any obligation to make a compensatory adjustment among the beneficiaries hereunder on account of such allocation; + +(17) to conduct any audit, assessment or investigation with respect to any asset of my estate regarding compliance with any law or regulation having as its object protection of public health, natural resources or the environment ("Environmental Laws"); to pay from the assets of my estate to remedy any failure to comply with any Environmental Law (even to the exhaustion of all of the assets of my estate); and, as may be required in my Executor's judgment by any Environmental Law, to notify any governmental authority of any past, present or future non-compliance with any Environmental Law; and + +(18) to sell to the Trustee under the Trust Agreement any stocks, bonds, securities, real or personal property or other assets or borrow from the Trustee under the Trust Agreement even though the same person or persons occupy the office of the Executor of my estate and the Trustee under the Trust Agreement. + +(19) No executor shall directly or indirectly buy or sell any property for the estate from or to himself, or from or to his relative, employer, employee, partner, or other business associate. + +(20) No executor shall lend estate funds to himself, or to his relative, employer, employee, partner, or other business associate. + +C. Except as otherwise provided herein, my Executor shall have the power: + +(1) to employ agents, attorneys-at-law, consultants, investment advisers (to whom my Executor has discretion to delegate my Executor's investment authority and responsibility), other executors and other fiduciaries in the administration of my Executor's duties; to delegate to such persons, or to one or more of my Executors, the custody, control or management of any part of my estate as my Executor determines and to pay for such services from the assets of my estate, without obtaining judicial authorization or approval; + +(2) to delegate, in whole or in part, to any person or persons the authority and power to (a) sign checks, drafts or orders for the payment or withdrawal of funds, securities and other assets from any bank, brokerage, custody or other account in which funds, securities or other assets of my estate shall be deposited, (b) endorse for sale, transfer or delivery, or sell, transfer or deliver, or purchase or otherwise acquire, any and all property, stocks, stock warrants, stock rights, options, bonds or other securities whatsoever, (c) gain access to any safe deposit box or boxes in which my assets or assets of my estate may be located or which may be in the name of my Executor and remove part or all of the contents of any such safe deposit box or boxes and release and surrender the same, and (d) take any other action that my Executor may have the power to take with respect to my estate and the property thereof; no person or corporation acting in reliance on any such delegation shall be charged with notice of any revocation or change of such delegation unless such person or corporation receives actual notice thereof; + +(3) to pay any property distributable to a beneficiary under a legal disability, without liability to my Executor, by paying such property (a) to such beneficiary, (b) for the use of such beneficiary, (c) to a legal representative of such beneficiary appointed by a court or if none, to a relative for the use of such beneficiary, or (d) to a custodian for such beneficiary designated by my Executor; + +(4) to distribute to any of the beneficiaries of my estate in kind or in cash, or partly in kind and partly in cash, and to allocate different kinds or disproportionate shares of assets or undivided interests in assets among all of such beneficiaries; + +(5) to have evidence of ownership of any security maintained in the records of a Federal Reserve Bank under the Federal Reserve Book Entry System; to deposit funds in any bank or trust company; to carry in the name of my Executor or the nominee or nominees of my Executor and with or without designation of fiduciary capacity, or to hold in bearer form, securities or other property requiring or permitting of registration; and to cause any securities to be held by a depository corporation of which an Executor is a member or by an agent under a safekeeping contract; provided, however, that the books and records of my Executor shall at all times show that such investments are part of my estate; + +(6) to renounce and disclaim, in whole or in part, and in accordance with applicable law, any assets, interests, rights or powers (including any power of appointment) which are payable to (or exercisable by) me or my estate, which are includible in my estate or Gross Estate or over which I have any right, title, interest or power; and + +(7) to make, execute and deliver any and all such instruments in writing as shall be necessary or proper to carry out any power, right, duty or obligation of my Executor or any disposition whatsoever of my estate or any asset of my estate and to exercise any and all other powers incidental or necessary to carry out or to fulfill the terms, provisions and purposes of my estate. + +D. In connection with any insurance policy or annuity on the life of an Executor which is included in my estate, such Executor shall not participate in the decision to exercise or not exercise any fiduciary power in connection with any incidents of ownership for such policy or annuity, including, without limitation, any decision to continue, assign, terminate or convert such policy or annuity or to name the beneficiary of such policy or annuity. + +E. An Executor hereunder may by a written notice delivered to the other Executor (or Executors) decline to participate in the decision to exercise or not exercise any fiduciary power granted by this Will or by law. + +F. If an Executor is not empowered (because of a conflict of interest, declination to act or otherwise) to participate in the decision to exercise or not exercise any fiduciary power granted by this Will or by law, then the remaining Executor or Executors shall be empowered to make such decision. If no Executor is empowered to participate in such decision, then the successor Executor of my estate designated in Paragraph A of Article THIRD and able and willing to act shall be empowered to make such decision. If no Executor or successor Executor is empowered to participate in such decision, my Executor may designate a successor Executor to serve as Executor of my estate who shall be empowered to make such decision but shall have no other power or authority of my Executor. Such designation shall be by written notice delivered to such successor Executor. + +G. (1) Except as otherwise specifically provided herein and except as provided in Paragraph G(2) of this Article, my Executor shall allocate receipts and disbursements in accordance with sound trust accounting principles and shall have discretion to allocate receipts and disbursements when the treatment is uncertain under applicable laws or generally accepted accounting principles in the judgment of my Executor. + +(2) Except as otherwise specifically provided in this Will, my Executor shall not treat any part of the principal amount of the proceeds of sale of any asset of my estate as income distributable to or for the benefit of any beneficiary entitled to distributions of income; provided, however, that my Executor shall treat a portion of any proceeds of sale of any financial instrument originally issued or acquired at a discount equal to the amount which (a) has previously been characterized as ordinary income for income tax purposes or (b) will be characterized as ordinary income for income tax purposes in the year of such sale, as income for trust accounting purposes. + +FIFTH: Where a party to any proceeding with respect to my estate has the same interest as a person under a disability, it shall not be necessary to serve legal process on the person under a disability. + +SIXTH: If any beneficiary under the Trust shall in any way directly or indirectly (a) contest or object to the probate of my Will or to the validity of any disposition or provision of my Will or of the Trust or (b) institute or prosecute, or be in any way directly or indirectly instrumental in the institution or prosecution of, any action, proceeding, contest, objection or claim for the purpose of setting aside or invalidating my Will or the Trust or any disposition herein or therein or provision hereof + +or thereof, then I direct that (a) any and all provisions in the Trust for such beneficiary and his issue in any degree shall be null and void and (b) my estate, whether passing under my Will or the Trust or pursuant to the laws of intestacy, shall be disposed of as if such beneficiary and his issue in any degree had all failed to survive me. + +SEVENTH: A. As used herein: + +(1) The term "Executor" of a person's estate means all persons or entities who occupy the office of executor, administrator, personal representative, or ancillary administrator while such persons or entities occupy such office, whether one or more persons or entities occupy such office at the same time or times, and includes any successor or successors to that office. The term "Trustee" means all persons or entities who occupy the office of Trustee under the Trust Agreement while such persons or entities occupy such office, whether one or more persons or entities occupy the office of Trustee at the same time or times, and includes any successor Trustee or Trustees. A reference to a person's estate or probate estate means that person's estate which is subject to probate administration. A reference to a person's Will means such person's Last Will and Testament and any Codicil or Codicils thereto. + +(2) The term "IRC section" means a section of the Internal Revenue Code of 1986, as amended, or the corresponding provision of any successor Internal Revenue law, as in effect as of the date of my death. + +(3) A reference to any tax also includes any interest or penalties thereon. A reference to a person's "Gross Estate" means such person's gross estate as finally determined for purposes of computing such person's federal estate tax. + +(4) Whenever the singular number is used, the same shall include the plural, and the masculine gender shall include the feminine and neuter genders. + +B. (1) The Federal and state transfer taxes which my Executor shall be obligated to pay pursuant to Paragraph C of Article FIRST shall consist of all Federal and state estate, inheritance, succession, and similar taxes (including any Federal or state generation-skipping transfer tax) imposed upon my probate estate or by reason of my death in respect to all assets which pass under this Will or the Trust Agreement. Subject to Paragraph B(2) of this Article, all Federal estate taxes with respect to assets not passing under this Will or the Trust Agreement (such assets are referred to as the "Apportionment Assets") and any applicable state estate taxes with respect to the Apportionment Assets shall be apportioned among all persons interested in the Apportionment Assets. My Executor shall make reasonable efforts to collect all Federal estate taxes and state estate, inheritance, succession and similar taxes allocable to the Apportionment Assets from the recipients of the Apportionment Assets. Without changing the apportionment of taxes in this Paragraph B(1), my Executor has discretion, but is not required, to pay all or part of such taxes allocable to the Apportionment Assets. To the extent my Executor pays such taxes allocable to the Apportionment Assets, my Executor shall seek reimbursement for such taxes from the recipients of the Apportionment Assets. My Executor shall not be personally liable for any of such taxes if my Executor is unable, with reasonable efforts, to collect payment (or reimbursement) from any recipient of any Apportionment Assets for any or all of such taxes allocable to such assets. + +(2) My Executor has discretion to direct the Trustee of the Trust Agreement to pay all or any portion of the taxes which my Executor is directed or obligated to pay pursuant to Paragraph B of Article FIRST and this Paragraph B pursuant to a written direction delivered to the Trustee under the Trust Agreement. Any taxes which my Executor directs the Trustee + +under the Trust Agreement to pay shall be allocated and paid from the trusts under the Trust Agreement as provided under the Trust Agreement. + +C. Except as otherwise specifically provided in this Will, a bequest or devise to an individual who does not survive me shall lapse notwithstanding any law to the contrary. + +D. To the extent that the distribution to the Trustee under the Trust Agreement pursuant to Article SECOND shall not be effective, I give all the rest of my property, real and personal, wherever situated, after the payments and distributions provided in Article FIRST, to the person or persons named as Trustee or Trustees under the Trust Agreement, be to held in trust under this Will in accordance with the provisions comprising the Trust Agreement at the time of my death, which provisions are incorporated in this Will by reference. + +IN WITNESS WHEREOF, I have duly executed this Will the 18th day of November, 2014. + +![]()The foregoing written instrument was on the date thereof, signed, published and declared by the Testator therein named as the Testator's Will in the presence of us and of each of us, who, at the Testator's request, in the Testator's presence and in the presence of each other, have subscribed our names as witnesses thereto. + +![]()![]()We, JEFFREY E. EPSTEIN, GEORGE DE JONGH and, JEANNE BRENHAN the Testator and the witnesses, respectively, whose names are signed to the foregoing instrument, having been sworn, declared to the undersigned officer that the Testator, in the presence of the witnesses, signed the instrument as his Will, that he signed, and that each of the witnesses, in the presence of the Testator and in the presence of each other, signed the Will as a witness. + +![]() + +## TERRITORY OF THE UNITED STATES VIRGIN ISLANDS ) + +)ss: DIVISION OF ST. THOMAS AND ST. JOHN ) + +Subscribed and sworn to before me by JEFFREY E. EPSTEIN, the Testator, who is personally known to me or who has produced as identification, and by Cent c, rF i s—,. ..1.4 , a witness who is personally known to me or who has produced as identification, and 1-4MI,IrP•sia-i,gt...ipt.i Witockitra witness who is personally known to me or who has produced as identification, on November la, 2014. + +Sworn to before me this '8 16 day of November, 20 I 4. + +rr----------' 57 c liT Notary Public + +Erika A. 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EPSTEIN + +• I, JEFFREY E. EPSTEIN, of Liitle St. James Island, St. Thomas, United States Virgin Islands, do make, publish and declare this to be my Will hereby revoking all prior Wills and Codicils made by me. + +FIRST: A. I direct my Executor to pay from my estate all expenses of my last illness, my funeral and burial expenses, the administration expenses of my estate and all of my debts duly proven and allowed against my estate. + +B. I direct my Executor to pay from my estate, as compensation to each Executor for serving as Executor hereunder, the sum of Two Hundred Fifty Thousand Dollars (\$250,000) to each Executor upon the completion of probate of my estate. No Executor shall receive any other compensation for serving as Executor hereunder; provided, however, that my Executor shall be reimbursed from my estate for all reasonable costs, expenses, charges, and liabilities incurred or paid in respect thereto, including fees and expenses of counsel or any other agents hired by my Executor, and my Executor shall not be liable therefor individually. + +C. I direct my Executor to pay from my estate the federal and state transfer taxes described in Paragraph B(1) of Article SEVENTH. + +D. I direct my Executor to pay fromry estate all expenses of storing, insuring, packing, shipping and delivering my tangible personal property in accordance with Article SECOND. + +SECOND: I give all of my property, real and personal, wherever situated, after the payments and distributions provided in Article FIRST, to the then acting Trustees of The Jeffrey E. Epstein 2013 Trust (the "Trust") created under that certain Trust Agreement (the "Trust Agreement") dated September 16, 2013, as the same may be amended from time to time, to be held in accordance with the provisions comprising the Trust Agrecmeni at the time of my death. + +• THIRD: A. I appoint DARREN K. INDYKE, JOSEPH PAGANO and JAMES E. . STALEY to be the Executors of this WM. If any one or more of my Executors fails to qualify or ceases to act, I appoint DAVID MITCHELL as successor Executor. I authorize the last acting Executor to designate his successor as Executor. + +• B. If my estate must be administered in whole or in part in any jurisdiction other than the state or territory of my domicile at the date of my death and if my Executor is unable or unwilling to serve in such jurisdiction, then 1 appoint the successor Executor of my estate designated in Paragraph A of Article THIRD provided that he is able add willing to serve in such jurisdiction. If no Executor or successor Executor is able and willing to serve in such jurisdiction, my Executor shall designate a successor Executor to serve in such jurisdiction. Such designation shall be made by written instrument delivered to such successor Executor. + +C. No bond or other security shall be required of any Executor in any jurisdiction. + +D. Any Executor may resign in the manner provided for by the governing statutes of the state or territory having jurisdiction of the administration of my estate or, in the absence of such statutory guidance, by filing a written notice of resignation with the Court having jurisdiction of the administration of my estate. My Executor who resigns shall not be entitled to any compensation hereunder for any services rendered as Executor prior to his resignation. + +E. My Executor shall not be accountable or responsible to any person interested in my estate for the manner in which my Executor in good faith exercises or declines to exercise any discretionary authority or power of my Executor. My Executor shall not be liable for any loss or depreciation in value occasioned by reason of any negligence, error or mistake of judgment in entering into any transaction, in making any sale or investment, in continuing to hold any property or by reason of any action or omission, whether by my Executor or any other fiduciary, unless my Executor has acted in bad faith. In the absence of proof by affirmative evidence to the contrary, each Executor shall be deemed to have acted within the scope of my Executor's authority, to have exercised reasonable care, diligence and prudence and to have acted impartially as to all interested persons. An Executor shall not be liable fof the acts or defaults of another Executor. + +FOURTH: The following provisions shall apply to my estate and to my Executor, except as is otherwise specifically provided in this Will: + +A. My Executor has the entire care and custody of all assets of my estate. My Executor has the power to do everything my Executor in good faith deems advisable without necessity of any judicial authorization or approval, even though but for this power it would not be authorized or appropriate for fiduciaries under any statutory or other rule of law. My Executor shall exercise my Executor's best judgment and discretion for what my Executor believes to be in the best interests of the beneficiaries hereunder. If more than two Executors are empowered to participate in the decision to exercise or not exercise any fiduciary power granted by this Will or by law, a majority of such Executors shall be empowered to make such decision. + +B. Except as otherwise provided herein, my Executor shall have the power: + +(1) to enter upon and take possession of the assets of my estate and collect the income and profits from such assets, and to invest and reinvest such assets in real, personal or mixed assets (including the common trust funds of a corporate fiduciary) or in undivided interests therein without being limited by any present or future investment laws; + +(2) to retain all or any part of the. assets of my estate (without regard to the proportion that any one asset or class of assets may bear to the whole) in the form in which such assets were received or acquired by my Executor; + +(3) to sell or dispose of, exchange, transfer, invest or loan all or any part of the assets of my estate which may, at any time, be held by my Executor for such sums or -upon such terms as to payment, security or otherwise as my Executor determines, either by public or private transactions; + +(4) to buy and sell options, warrants, puts, calls or other rights to purchase or sell (collectively "options") relating to any security or securities, regardless of whether such security or securities are then held by my Executor, and whether such options are purchased or sold on a national securities exchange, and to exercise with respect to such options all powers which an individual owner thereof could exercise, including; without limitation, the right to allow the same to expire', + +(5) with respect to oil, natural gas, minerals, and all other natural resources and rights to and interests therein (together with all equipment pertaining thereto) including, without limiting the generality of the foregoing, oil and gas royalties, leases, or other oil and gas interests of any character, whether owned in fee, as lessee, lessor, licensee, concessionaire or otherwise, or alone or jointly with others as partner, joint tenant, or joint venture in any other noncorporate manner, (a) to make oil, gas and mineral leases or subleases; (b) to pay delay rentals, lease bonuses, royalties, overriding royalties, taxes, assessments, and all other charges; (c) to sell, lease, exchange, mortgage, pledge or otherwise hypothecate any or all of such rights and interests; (d) to surrender or abandon, with or without consideration, any or all of such rights and interests; (e) to make farm-out, pooling, and unitization agreements; (f) to make reservations or impose conditions on the transfer of any such rights or interests; (g) to employ the most advantageous business form in which properly to exploit such rights and interests, whether as corporations, partnerships, limited partnerships, mining partnerships, joint ventures, co-tenancies, or otherwise exploit any and all such rights and interests; (h) to produce, process, sell or exchange all products recovered through the exploitation of such rights and interests, and to enter into contracts and agreements for or in respect of the installation or operation of absorption, reprocessing or other processing plants; (i) to carry any or all such interests in the name or names of a nominee or nominees; (j) to delegate, to the extent permitted by law, any or all of the powers set forth herein to the operator of such property; and (k) to employ personnel, rent office space, buy or lease office equipment, contract and pay for geological surveys and studies, procure appraisals, and generally to conduct and engage in any and all activities incident to the foregoing powers, with full power to borrow and pledge in order to finance such activities; together with the power to allocate between principal and income any net proceeds received as consideration, whether as royalties or otherwise, for the permanent severance from lands of oil, natural gas, minerals, and all other natural resources; + +(6) to hold all or any part of the assets of my estate in cash or in bank accounts without the necessity of investing the same; + +(7) to improve, repair, partition, plat or subdivide all or any part of the assets of my estate; + +(8) to litigate, defend, compromise, settle, abandon or submit to arbitration on such terms and conditions as my Executor determines, to propose or accept a compromise with respect to any claims in favor of or against my estate or the assets of my estate; + +(9) to loan or borrow money in such amounts and upon such terms and conditions as my Executor determines, assume such obligations or give such guarantees as my Executor determines, for the purpose of the acquisition, improvement, protection, retention or preservation of the assets of my estate, or for the welfare of the beneficiaries of my estate; + +(10) to carry on for as long and in such manner as my Executor determines any business enterprise in which I owned any interest at my death, either individually, or as a partner, joint venture, stockholder or trust beneficiary; to sell such business enterprise as an ongoing business; to consolidate, merge, encumber, dissolve, liquidate or undertake any other extraordinary corporate transaction relating to such business enterprise; + +(11) to vote in person or by proxy any and all stock or securities and to become a party to any voting trusts, reorganization, consolidation or other capital or debt readjustment of any corporation, association, partnership, limited liability partnership, limited liability company or individual with respect to stocks, securities or debts held by my estate; + +(12) except as provided in paragraphs B(19) and B(20) of this Article FOURTH, to enter into any good faith transactions with my Executor individually or with any corporation, partnership or other entity in which my Executor has an ownership interest; + +/ 7 + +> (13) to lease, mortgage, pledge, grant a security interest in or otherwise encumber all or any part of the assets of my estate for any term of years whether or not beyond the duration of my estate (including, without limitation, any such action for the benefit of any of the beneficiaries of my estate); + +> (14) to abandon any property of 'my estate, real or personal, which my Executor may deem worthless or not of sufficient value to warrant keeping or protecting; to abstain from the payment of taxes, water rents or assessments and to forego making repairs, maintaining or keeping up any such property; and to permit such property to be lost by tax sale or other proceedings or to convey any such property for a nominal consideration or without consideration so as to prevent the imposition of any liability by reason of the continued ownership thereof; + +> (15) to elect the mode of distribution of the proceeds payable to my estate from any profit-sharing plan, pension plan, employee benefit plan, individual retirement plan, insurance contract or annuity contract pursuant to the tents of such plan; + +> (16) to allocate, in my Executors discretion, any adjustment to basis provided to my estate under the provisions of Federal and State law with respect to property. comprising my estate, without any obligation to make a compensatory adjustment among the beneficiaries. hereunder on account of such allocation; + +> (17) to conduct any audit, assessment or investigation with respect to any asset of my estate regarding compliance with any law or regulation having as its object protection of public health, natural resources or the environment ("Environmental Laws"); to pay from the assets of inv estate to remedy any failure to comply with any Environmental Law (even to the exhaustion of all of the assets of my estate); and, as may be required in my Executor's judgment by any Environmental Law, to notify any governmental authority of any past, present or future non-compliance with any Environmental Law; and + +> (18) to sell to the Trustee under the Trust Agreement any stocks, bonds, securities, real or personal property or other assets or borrow from the Trustee under the Trust Agreement even though the same person or persons occupy the office of the Executor of my estate and the Trustee under the Trust Agreement. + +> (19) No executor shall directly or indirectly buy or sell any property.for the estate from or to himself, or from or to his relative, employer, employee, partner, or other business associate. + +> (20) No executor shall lend estate funds to himself, or to his relative, employer, employee, partner, or other business associate. + +C. Except as otherwise provided herein, my Executor shall have the power: + +(1) to employ agents, attorneys-at-law, consultants, investment advisers (to whom my Executor has discretion to delegate my Executor's investment authority and responsibility), other executors and other fiduciaries in the administration of my Executor's duties; to delegate to such persons, or to one or more of my Executors, the custody, control or management of any part of my estate as . my Executor determines and to pay for such services from the assets of my estate, without obtaining judicial authorization or approval; + +(2) to delegate, in whole or in part, to any person or persons the authority and power to (1) sign checks, drafts or orders for the payment 'or withdrawal of funds, securities and other assets from any bank, brokerage, custody or other account in which funds, securities or other assets of my estate shall be deposited, (b) endorse for sale, transfer or delivery, or sell, transfer or deliver, or + +purchase or otherwise acquire, any and all property, stocks, stock warrants, stock rights, options, bonds or other securities whatsoever, (c) gain arrres to any safe deposit box or boxes in which my assets or assets of my estate may be located or which may be in the name of my Executor and remove part or all of the contents of any such safe deposit box or boxes and release and surrender the same, and (d) take any other action that my Executor may have the power to take with respect to my estate and the property thereof; no person or corporation acting in reliance on any such delegation shall be charged with notice of any revocation or change of such delegation unless such person or corporation receives actual notice thereof; + +(3) to pay any property distributable to abeneficiary under alegal disability, without liability to my Executor, by paying such property (a) to such beneficiary, (b) for the use of such beneficiary, (c) to alegal representative of such beneficiary appointed by a court or if none, to a relative for the use of such beneficiary, or (d) to a custodian for such beneficiary designated by my Executor; + +(4) to distribute to any of the beneficiaries of my estate in kind or in cash, or partly in kind and partly in cash, and to allocate different kinds or disproportionate shares of assets or undivided interests in assets among all of such beneficiaries; + +(5) to have evidence of ownership of any security maintained in the records of a Federal Reserve Bank under the Federal Reserve Book Entry System; to deposit • funds in any bank or trust company; to carry in the name of my Executor or the nominee or nominees of my Executor and with or without designation of fiduciary capacity, or to hold in bearer form, securities or other property requiring or permitting of registration; and to cause any securities to be held by a depository corporation of which an Executor is a member or by an agent under asafekeeping contract; provided, however, that the books and records of my Executor shall at all times show that such investments are part of my estate; + +(6) to renounce and disclaim, in whole or in part, and in. accordance with applicable law, any assets, interests, rights or powers (including any power of appointment) which are payable to (or exercisable by) me or my estate, which are includible in my estate or Gross Estate or over which I have any right, title, interest or power; and + +(7) to make, execute and deliver any and all such instruments in writing as shall be necessary or proper to carry out any power, right, duty or obligation of my Executor or any disposition whatsoever of my estate or any asset of my estate and to exercise any and all other powers incidental or necessary to carry out or to fulfill the terms, provisions and purposes of my estate. + +D. In connection with any insurance policy or annuity on the life ar an Executor which is included in my estate, such Executor shall not participate in the decision to exercise or not exercise any fiduciary power in connection with any incidents of ownership for such policy or annuity, including, without limitation, any decision to continue, assign, terminate or convert such policy or annuity or to name the 5eneficiary of such policy or annuity. + +E. An Executor hereunder may by a written notice delivered to the other Executor (or Executors) decline to participate in the decision to exercise or not exercise any fiduciary power granted by this Will or by law. + +F. If an Executor is not empowered (because of a conflict of interest, declination to act or otherwise) to participate in the decision to exercise or not exercise any fiduciary power granted by this Will or by law, then the remaining Executor or Executors shall be empowered to make such derision. If no Exechtor is empowered to participate in such decision, then the successor Executor of my estate designated in Paragraph A of Article THIRD and able and willing to act shall be empowered to make such decision. If no Executor or successor Executor is empowered to participate in such decision, my Executor may designate a successor Executor to serve as Executor of my estate who shall be empowered to make such decision but shall have no other power or authority of my Executor. Such designation shall be by written notice delivered to such successor Executor. + +G. (1) Except as otherwise specifically provided herein and except as provided in Paragraph G(2) of this Article, my Executor shall allocate receipts and disbursements in accordance with sound trust accounting principles and shall have discretion to allocate receipts and disbursements ' when the treatment is uncertain under applicable laws or generally accepted accounting principles in the judgment of my Executor. + +(2) Except as othenvise specifically provided in this . • Will, my Executor shall not treat any part of the principal amount of the proceeds of sale of any asset of my estate es income distributable to or for the benefit of any beneficiary entitled to distributions of income; provided, however, that my Executor shall treat a portion of any proceeds of sale of any financial instrument originally issued or acquired at adiscount equal to the amount which (a) has previously been characterized as ordinary income for income tax purposes or (b) will be characterized as ordinary income for income tax purposes in the year of such sale, as income for trust accounting purposes. + +. FIFTH: Where aparty to any proceeding with respect to my estate has the same interest as aperson under adisability, it shall not be necessary to serve legal process on the person under adisability. + +SIXTH: If any beneficiary under the Trust shall in any way directly or indirectly (a) contest or object to the probate of my Will or to the validity of any disposition or provision of my Will or of the Trust or (b) institute or prosecute, or be in any way directly or indirectly instrumental in the institution or ' • prosecution of, any action, proceeding, contest, objection or claim for the purpose of setting aside or invalidating my Will or the Trust or any disposition therein or provision thereof, then I direct that (a) any and all provisions in the Trust for such beneficiary and his issue in any degree shall be null and void and (b) my estate, whether passing under my Will or the Trust or pursuant to the laws of intestacy, shall be disposed of as if such beneficiary and his issue in any degree had all failed to survive me. + +SEVENTH: A. M used herein: + +The term "Executor" of aperson's estate means all persons or entities who occupy the office of executor, administrator, personal representative, or ancillary administrator while such persons or entities occupy such office, whether one or more persons or entities occupy such office at the same time or times, and includes any successor or successors to that office. The term "Trustee" means all persons or entities who occupy the office of Trustee under the Trust Agreement while such persons or entities occupy such office, whether one or more persons or entities occupy the office of Trustee at the same time or times, and includes .any successor Trustee or Trustees. A reference to aperson's estate or probate estate means that person's estate which is subject to probate administration. A reference to aperson's Will means such person's Last Will and Testament and any Codicil or Codicils thereto. + +(2). The term "IRC section" means asection of the Internal Revenue Code of 1986, as amended, or the corresponding provision of any successor Internal Revenue law, as in effect as of the date of my death. + +(1). • A. reference to any tax also includes any interest or penalties-thereon. A reference to aperson's "Gross Estate" means such person's gross estate as finally determined for purposes of computing such person's federal estate tax. + +(4) Whenever the singular number is used, the same shall include theplural, and the masculine gender shall include the feminine and neuter genders. + +B. (1) The federal and state transfer taxes which my Executor shall be obligated to pay pursuant to Paragraph C of Article FIRST shall consist of all federal and state estate, inheritance, succession, and similar taxes (including any federal or state. generation-skipping transfer tax) • imposed upon my probate estate or by reason of my death in rospect to all assets which pass under this Will or the Trust Agreement. Subject' to Paragraph B(2) of this Article, all federal estate taxes with respect to assets not passing + +under this Will or the Trust Agreement (such assets are referred to as the "Apportionment Assets") and any applicable state estate taxes with respect to the Apportionment Assets shall be apportioned among all persons interested in the Apportionment Assets. My Executor shall make reasonable efforts to collect all federal estate taxes and state estate, inheritance, succession and similar taxes allocable to the Apportionment Assets from the recipients of the Apportionment Assets. Without changing the apportionment of taxes in this Paragraph B(I), my Executor has discretion, but is not required, to pay all or part of such taxes allocable to the Apportionment Assets. To the extent my Executor. pays such taxes allocable to the Apportionment Assets, my Executor shall seek reimbursement for such taxes from the recipients of the Apportionment Assets. My Executor shall not be personally liable for any of such taxes if my Executor is unable, with reasonable efforts, to collect payment (or reimbursement) from any recipient of any Apportionment Assets for any or all of such taxes allocable to such assets. + +(2) My Executor has discretion to direct the Trustee of. the Trust Agreement to pay all or any portion of the taxes which my Executor is directed or obligated to pay pursuant to Paragraph B of Article FIRST and this Paragraph B pursuant to a written direction delivered to the Trustee under the Trust Agreement. My taxes which my Executor directs the Trustee under the Trust Agreement to pay shall be allocated and paid from the trusts under the Trust Agreement as provided under the Trust Agreement. + +C. Except as otherwise specifically provided in this Will, a bequest or devise to an individual who does not survive me shall lapse notwithstanding any law to the contrary.. + +D. To the extent that the distribution to the Trustee under the Trust Agreement pursuant to Article SECOND shall not be effective, I give all the rest of my property, real and personal, wherever situated, after the payments and distributions provided in Article FIRST, to the person or persons named as Trustee or Trustees under the Trust Agreement, be to held in trust under this Will in accordance with the provisions comprising the Trust Agreement at the time of my death, which provisions are incorporated in this Will by reference. + +IN WITNESS WHEREOF, I have duly executed this Wilt the 16° day of September, 2 + +JE + +The foregoing written instrument was on the date thereof, signed, published and declared by the Testator therein named as the Testator's Will in the presence of us and of each of us. who, at the Testator's request, in the Testator's presence and in the presence of each • other, have subscribed our names as witnesses thereto. + +S eAse\_\_ residing at + +residing at + +![](_page_6_Picture_9.jpeg) + +We, JEFFREY E. EPSTEIN, CRULE DE JONGH and, JEANNE BRONNAN the Testator and the witnesses, respectively, whose names are signed to the foregoing instrument, having been sworn, declared to the undersigned officer that the Testator, in the presence of the witnesses, signed the instrument as his Will, that he signed, and that each of the witnesses, in the presence of the Testator and in the presence of each other, signed the Will as a witness. + +![]()![]()![]()TERRITORY OF THE UNITED STATES VIRGIN ISLANDS ) + +DIVISION OF ST. THOMAS AND ST. JOHN + +)ss: +) + +Subscribed and sworn to before me by JEFFREY E. 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EPSTEIN, of Little St. James Island, United States Virgin Islands, declare this to be my last will and testament. + +FIRST + +I hereby revoke all my prior wills and codicils. + +SECOND + +I give all my property to the Trustees of The Jeffrey E. Epstein 2001 Trust One created pursuant to an agreement dated November 8, 2001, by JEFFREY E. EPSTEIN, as Grantor, and JEFFREY E. EPSTEIN and JEFFREY A. SCHANTZ, as Trustees, to be added to the principal thereof and disposed of as provided thereunder. + +THIRD + +![]()![]()(c) Any reference in this will to my Executors shall include additional and successor Executors. + +(d) No one acting hereunder as Executor shall be required to (i) furnish any bond, undertaking or other security in any jurisdiction, (ii) file periodic reports in or to any court or (iii) give notice of appointment as Trustee to any court. Each Trustee acting hereunder is specifically relieved from any and all of the duties which + +would otherwise be placed upon him by Chapter 59 of Title 15 of the Virgin Islands Code. + +(e) Each Executor acting hereunder shall be entitled to receive the sum of One Hundred Thousand Dollars (\$100,000) as compensation for such services. + +#### FOURTH + +Unless the context otherwise requires, the use in this will of the masculine and feminine shall be interchangeable, and the use of the singular and plural shall be interchangeable. + +#### FIFTH + +In extension and not in limitation of the powers and authority which my Executors would otherwise have pursuant to law or pursuant to the other provisions of this will, I direct that they have the following discretionary powers: + +(a) To retain for as long a period of time as they may consider advisable or proper any property of any kind which may at any time be in their hands. + +(b) To sell at public or private sale or to exchange any property which Imay own at the time of my death or which may at any time be in their hands, without application to court, on any terms they may consider advisable or proper, including terms involving an extension of credit for any period of time and with or without security. + +(c) To invest in or otherwise acquire any property, real or personal, of any kind, without limitation, without being bound by any provision of law restricting investments by executors, including but not limited to common and preferred stocks, secured and unsecured obligations, mutual and common funds, other securities, mortgages, and interests and options in any of the foregoing. + +(d) To acquire and retain property without regard to any principles of diversification. + +(e) To permit funds to remain uninvested, and to retain for an unlimited period of time and to acquire and retain property which is not productive of income. + +(f) To acquire, exercise, sell or abandon conversion, subscription and other rights and options, and to grant options for any period of time. + +(g) To hold securities in the names of nominees or in such form as to pass by delivery. + +![]()(h) To pay any gift or bequest in whole or in part at any time after my death, either before or after the expiration of any period authorized or provided by law for the payment of same and without deducting any discount or interest from a gift or bequest paid prior to such time or paying interest on a gift or bequest paid after such time. + +(i) To employ attorneys, accountants, investment advisers, security analysts, brokers, agents, clerks, bookkeepers, stenographers and assistants, and to pay on a regular basis the fair and reasonable value of their services, and in connection with this power an Executor who is an attorney, an accountant or a broker or any firm of attorneys, accountants or brokers of which an Executor is a partner or employee may be retained on behalf of my estate and compensated for services rendered. + +(j) To borrow money for any purpose, including, but not limited to, the payment of taxes, and to pledge or mortgage property as security for money borrowed. + +(k) To lend money or other property to any person, corporation, partnership, trust or other entity, including a beneficiary hereunder even if such beneficiary is an Executor, this power to include the power to lend, without interest, income to or for the benefit of principal and principal to or for the benefit of income. + +(l) To pay any gift or bequest and to distribute income or principal in cash or in kind or partly in each. Such payments and distributions may be made to any legatee or beneficiary with property that is like or different from property used to pay any other gift or bequest or make any other distribution to any other legatee or beneficiary. The value of any property distributed in kind shall not be reduced to reflect any expenses or taxes that may be incurred by the recipient in or as a result of a disposition of such property. The decision of my Executors with respect to the property selected to pay any gift or bequest or make any distribution shall be conclusive and no recipient shall have the right to object thereto. + +(m) To determine, in case of reasonable doubt on their part, whether any property coming into their hands constitutes income or principal, and whether any payment or expenditure made by them shall be charged to income or to principal. + +(n) To operate, repair, alter and improve any real property which they may hold or in which they may hold an interest or participation; to erect or demolish buildings thereon; to enter into leases for such real property or any part thereof or any interest or participation therein for any period of time; to mortgage such real property or any part thereof or any interest or participation therein for any period of time; to grant options with respect to such real property, mortgages and leases or any interest or participation therein for any period of time; to perform, modify, waive provisions of, + +![]()![]()(q) To become or continue to be an officer, director or employee of any corporation, stock of which may be owned by my estate and as such officer, director or employee to receive a salary, bonus or other compensation in reasonable amount for services rendered to said corporation. + +(r) To determine whether to claim any deduction available to me or my estate on estate tax or on income tax returns in such manner as they may deem advisable and without making any adjustment between income and principal or among beneficiaries on account of any such determination. + +![]()(t) To transfer any property which they may at any time hold to any jurisdiction which they may deem advisable. + +(u) My Executors shall continue to have all the powers herein vested in them until the final distribution of all property in their hands. + +### SIXTH + +If any beneficiary under The Jeffrey E. Epstein 2001 Trust One ("the trust") shall in any way directly or indirectly (a) contest or object to the probate of my will or to the validity of any disposition or provision of my will or of the trust or (b) institute or prosecute, or be in any way directly or indirectly instrumental in the institution or prosecution of, any action, proceeding, contest, objection or claim for the + +purpose of setting aside or invalidating my will or the trust or any disposition therein or provision thereof, then I direct that (a) any and all provisions in the trust for such beneficiary and his issue in any degree shall be null and void and (b) my estate, whether passing under my will or the trust or pursuant to the laws of intestacy, shall be disposed of as if such beneficiary and his issue in any degree had all failed to survive me. + +IN WITNESS WHEREOF, I have hereunto subscribed my name and affixed my seal to this my Last Will and Testament, consisting of 8 typewritten pages, on all of which I signed my name for greater security and identification, at St. Thomas, U.S. Virgin Islands on the 11th day of December, 2001. + +![]()SIGNED, SEALED, PUBLISHED and DECLARED by JEFFREY E. EPSTEIN, as and for his Last Will and Testament in our presence; and we thereupon, at his request and in his presence, and in the presence of each other, have hereunto subscribed our names as attesting witnesses and our respective places of residence on the day of its execution. + +![]()![]()SUBSCRIBED AND SWORN TO before me by the said JEFFREY E. EPSTEIN, +Testator, and Cecile R. de Jongh, Jeanne Brennan and +Daphne Blyden, witnesses, the 11th day of December, 2001. + +Before me, the undersigned authority, on this day personally appeared JEFFREY E. EPSTEIN, Testator, and Cecile R. de Jongh, Jeanne Brennan and Daphne Blyden, respectively, whose names are subscribed to the foregoing instrument in their respective capacities, and all of said persons being by me duly sworn, the said Testator declared to me and to the said witnesses, in my presence, that the said instrument is his LAST WILL AND TESTAMENT and that he has willingly made and executed it as his free act and deed for the purposes therein expressed; and that the said witnesses, each on his oath, stated to me in the presence and hearing of said Testator that the said Testator had declared to them that the said instrument is his LAST WILL AND TESTAMENT, and that he executed the same as such and wanted each of them to sign it as a witness; and upon their oaths, each witness further stated that they did sign the same as witnesses in the presence of the said Testator and at his request; and that said Testator was at the time eighteen years of age or over and of sound mind; and that each of said witnesses was then at least eighteen years of age. + +![]()![]()![]()![]()SUBSCRIBED AND SWORN TO before me by the said JEFFREY E. EPSTEIN, +Testator, and Cecile R. de Jongh, Jeanne Brennan and +Daphne Blyden, witnesses, the 11th day of December, 2001. + +![]()Barbara Mignon Weatherly +Notary Commission No. LNP-027-00 +Commission Expires November 21, 2004 + +# FIRST CODICIL + +to + +LAST WILL AND TESTAMENT + +of + +JEFFREY E. EPSTEIN + +I, JEFFREY E. EPSTEIN, of Little St. James Island, United States Virgin Islands, having made my last will and testament dated December 11, 2001, declare this to be a first codicil thereto. + +# FIRST + +I hereby delete Article THIRD of my will and substitute in its place the following new Article THIRD: + +"(a) I appoint HENRY JARECKI and JAMES CAYNE as Executors of this will. If either HENRY JARECKI or JAMES CAYNE fails to qualify or ceases for any reason to act as Executor, I hereby designate PAUL HOFFMAN as successor Executor to act in his place. + +(b) Any reference in this will to my Executors shall include successor Executors. + +(c) No one acting as Executor shall be required to (i) furnish any bond, undertaking or other security in any jurisdiction, (ii) file periodic reports in or to any court or (iii) give notice of appointment as Trustee to any court. Each Trustee acting hereunder is specifically relieved from any and all of the duties which would otherwise be placed upon him by Chapter 59 of Title 15 of the Virgin Islands Code. + +(d) Each Executor acting hereunder shall be entitled to receive the sum of One Hundred Thousand Dollars (\$100,000) as compensation for such services." + +#### SECOND + +In all other respects I ratify and republish my said last will and testament. + +IN WITNESS WHEREOF, I have hereunto subscribed my name and affixed my seal to this my first codicil to my Last Will and Testament, consisting of t —typewritten pages, on all of which I signed my name for greater security and identification, at + +U.S. Virgin Islands on the 2-1 day of , 2003. + +(L.S.) JEF + +SIGNED, SEALED, PUBLISHED and DECLARED by JEFFREY E. EPSTEIN, as and for afirst codicil to his Last Will and Testament in our presence; and we thereupon, at his request and in his presence, and in the presence of each other, have hereunto subscribed our names as attesting witnesses and our respective places of residence on the day of its execution. + +MALI Act WieladL-TegnA r/3 IR O/2.N1 + +![](_page_10_Picture_7.jpeg) + +SUBSCRIBED AND SWORN TO before me by the said JEFFREY E. EPSTEIN, Testator, and DAPHNE WALLACE, Jeanne Brennan and JERMAINE A. RUAN, witnesses, the 27th day of June, 2003. + +Before me, the undersigned authority, on this day personally appeared JEFFREY E. EPSTEIN, Testator, and DAPHNE WALLACE, JERMAINE A. RUAN and Jeanne Brennan, respectively, whose names are subscribed to the foregoing instrument in their respective capacities, and all of said persons being by me duly sworn, the said Testator declared to me and to the said witnesses, in my presence, that the said instrument is a first codicil to his LAST WILL AND TESTAMENT and that he has willingly made and executed it as his free act and deed for the purposes therein expressed; and that the said witnesses, each on his oath, stated to me in the presence and hearing of said Testator that the said Testator had declared to them that the said instrument is a first codicil to his LAST WILL AND TESTAMENT, and that he executed the same as such and wanted each of them to sign it as a witness; and upon their oaths, each witness further stated that they did sign the same as witnesses in the presence of the said Testator and at his request; and that said Testator was at the time eighteen years of age or over and of sound mind; and that each of said witnesses was then at least eighteen years of age. + +![]()![]()![]()SUBSCRIBED AND SWORN TO before me by the said JEFFREY E. +EPSTEIN, Testator, and Daphne Wallace, Termaine A. Ruan, +and Jeanne Brennan, witnesses, the 27th day of June, 2003. + +Barbara Mignon Weatherly +Notary Public + +Barbara Mignon Weatherly +Notary Commission No. LNP-027-00 +Commission Expires November 21, 2004 + +I, JEFFREY E. EPSTEIN, of Little St. James Island, United States Virgin Islands, having made my last will and testament dated December 11, 2001 and a first codicil thereto dated June 27, 2003, declare this to be a second codicil thereto. + +FIRST + +I hereby delete paragraph (a) of Article THIRD of my will and substitute in its place the following new paragraph (a) of Article THIRD: + +"I appoint HENRY JARECKI, JAMES CAYNE and LAWRENCE NEWMAN as Executors of this will. If HENRY JARECKI, JAMES CAYNE or LAWRENCE NEWMAN fails to qualify or ceases for any reason to act as Executor, I hereby designate PAUL HOFFMAN as successor Executor to act in his place." + +SECOND + +In all other respects I ratify and republish my said last will and testament and the first codicil thereto. + +IN WITNESS WHEREOF, I have hereunto subscribed my name to this my second codicil to my Last Will and Testament on the 3rd day of December, 2004. + +SIGNED, SEALED, PUBLISHED and DECLARED by JEFFREY E. EPSTEIN, as and for a second codicil to his Last Will and Testament in our presence; and we thereupon, at his request and in his presence, and in the presence of each other, have hereunto subscribed our names as attesting witnesses and our respective places of residence on the day of its execution. + +![]()![](_page_14_Picture_13.jpeg) + +Lawrence Newman + +\_\_\_\_\_ + +\_\_\_\_\_ + +\_\_\_\_\_ + +SUBSCRIBED AND SWORN TO before me by the said JEFFREY E. EPSTEIN, Testator, and DAREN K. INDYKE and LAWRENCE NEWMAN and \_\_\_\_\_, witnesses, the 3rd day of December, 2004. + +![]()LAUREN J. KWINTNER +Notary Public, State of New York +No. 02KW6016686 +Qualified in New York County +Commission Expires November 30, 20 06 + +Before me, the undersigned authority, on this day personally appeared JEFFREY E. EPSTEIN, Testator, and DARREN K. INDYKE and LAWRENCE NEWMAN and \_\_\_\_\_, respectively, whose names are subscribed to the foregoing instrument in their respective capacities, and all of said persons being by me duly sworn, the said Testator declared to me and to the said witnesses, in my presence, that the said instrument is a second codicil to his Last Will and Testament and that he has willingly made and executed it as his free act and deed for the purposes therein expressed; and that the said witnesses, each on his oath, stated to me in the presence and hearing of said Testator that the said Testator had declared to them that the said instrument is a second codicil to his Last Will and Testament, and that he executed the same as such and wanted each of them to sign it as a witness; and upon their oaths, each witness further stated that they did sign the same as witnesses in the presence of the said Testator and at his request; and that said Testator was at the time eighteen years of age or over and of sound mind; and that each of said witnesses was then at least eighteen years of age. + +![]()SUBSCRIBED AND SWORN TO before me by the said JEFFREY E. EPSTEIN, Testator, and DARREN K. INDYKE and LAWRENCE NEWMAN and \_\_\_\_\_, witnesses, the 3rd day of December, 2004. + +![]()LAUREN J. KWINTNER +Notary Public, State of New York +No. 02KW6016686 +Qualified in New York County. +Commission Expires November 30, 2018 + +I, JEFFREY E. EPSTEIN, of Little St. James Island, United States Virgin Islands, having made my last will and testament dated December 11, 2001, a first codicil thereto dated June 27, 2003, and a second codicil thereto dated December 3, 2004, declare this to be a third codicil thereto. + +#### FIRST + +I hereby delete paragraph (a) of Article THIRD of my will and substitute in its place the following new paragraph (a) of Article THIRD: + +"I appoint HENRY JARECKI, JAMES CAYNE and. LAWRENCE NEWMAN as Executors of this will. If HENRY JARECKI, JAMES CAYNE or LAWRENCE NEWMAN fails to qualify or ceases for any reason to act as Executor, I hereby designate DARREN K. INDYKE as successor Executor to act in his place." + +#### SECOND + +I hereby delete paragraph (d) of Article THIRD of my will and substitute in its place the following new paragraph (d) of Article THIRD: + +"(d) Each Executor acting hereunder shall be entitled to receive the sum of Two Hundred Fifty Thousand Dollars (\$250,000) as compensation for such services." + +THIRD + +In all other respects I ratify and republish my said last will and testament and the first codicil and second codicils thereto. + +IN WITNESS WHEREOF, I have hereunto subscribed my name to this my third codicil to my Last Will and Testament on the 16th day of December , 2004. + +![]()SIGNED, SEALED, PUBLISHED and DECLARED by JEFFREY E. EPSTEIN, as and for a third codicil to his Last Will and Testament in our presence; and we thereupon, at his request and in his presence, and in the presence of each other, have hereunto subscribed our names as attesting witnesses and our respective places of residence on the day of its execution. + +![]()![](_page_17_Picture_183.jpeg) + +Before me, the undersigned authority, on this day personally appeared JEFFREY E. EPSTEIN, Testator, DARREN K. INDYKE and LAWRENCE NEWMAN, respectively, whose names are subscribed to the foregoing instrument in their respective capacities, and all of said persons being by me duly sworn, the said Testator declared to me and to the said witnesses, in my presence, that the said instrument is a third codicil to his Last Will and Testament and that he has willingly made and executed it as his free act and deed for the purposes therein expressed; and that the said witnesses, each on his oath, stated to me in the presence and hearing of said Testator that the said Testator had declared to them that the said instrument is a third codicil to his Last Will and Testament, and that he executed the same as such and wanted each of them to sign it as a witness; and upon their oaths, each witness further stated that they did sign the same as witnesses in the presence of the said Testator and at his request; and that said Testator was at the time eighteen years of age or over and of sound mind; and that each of said witnesses was then at least eighteen years of age. + +![]()![]()![]()SUBSCRIBED AND SWORN TO before me by the said JEFFREY E. EPSTEIN, Testator, and Darren K. Indyke and Lawrence Newman, witnesses, the 16 day of December, 2004. + +![]()LAUREN J. KWINTNER +Notary Public, State of New York +No. 02KW6016686 +Qualified in New York County +Commission Expires November 30, 20 e.6 + +Third Codicil to + +![](_page_19_Picture_14.jpeg) + +~~((( amd )))~~ + +![](_page_19_Picture_16.jpeg) + +~~((( aF )))~~ + +JEFFREY E. EPSTEIN + +LAWRENCE NEWMAN, ESQ. + +1633 BROADWAY • 46TH FLOOR + +NEW YORK, NY 10019-6708 + +TELEPHONE + +![](_page_19_Picture_23.jpeg) + +I, JEFFREY E. EPSTEIN, of Little St. James Island, United States Virgin Islands, having made my last will and testament dated December I I, 2001, a first codicil thereto dated June 27, 2003, a second codicil thereto dated December 3, 2004, a third codicil thereto dated December 16, 2004, and a fourth codicil thereto dated September 5, 2007, declare this to be a fifth codicil thereto. + +# FIRST + +I hereby delete paragraphs (b) (c) and (d) of Article THIRD of my will and substitute in its place the following new paragraphs (b) (c) and (d) of Article THIRD: + +"(b) Any reference in this will to my Executors shall include additional and successor Executors. + +(c) No one acting hereunder as Executor shall be required to (i) furnish any bond, undertaking or other security in any jurisdiction, (ii) file periodic reports in or to any court or (iii) give notice of appointment as Trustee to any court. Each Trustee acting hereunder is specifically relieved from any and all of the duties which would otherwise be placed upon him by Chapter 59 of Title 15 of the Virgin Islands Code. + +(d) Each Executor acting hereunder shall be entitled to receive the sum of Five Hundred Thousand Dollars (\$500,000) as compensation for such services.” + +SECOND + +In all other respects I ratify and republish my said last will and testament and the first codicil, second, third and fourth codicils thereto. + +IN WITNESS WHEREOF, I have hereunto subscribed my name to this my fifth codicil to my Last Will and Testament on the 20th day of Sept., 2007. + +![]()SIGNED, SEALED, PUBLISHED and DECLARED by JEFFREY E. EPSTEIN, as and for a fifth codicil to his Last Will and Testament in our presence; and we thereupon, at his request and in his presence, and in the presence of each other, have hereunto subscribed our names as attesting witnesses and our respective places of residence on the day of its execution. + +![]()![]()\_\_\_\_\_ + +![](_page_21_Picture_86.jpeg) + +\_\_\_\_\_ + +SUBSCRIBED AND SWORN TO before me by the said JEFFREY E. EPSTEIN, Testator, and DARREN K. INDYKE and LAWRENCE NEWMAN, witnesses, the 20th day of September, 2007. + +![]()Notary Public + +LAUREN J. KWINTNER +Notary Public, State of New York +No. 02KW6016686 +Qualified in New York County +Commission Expires November 30, 20 10 + +STATE OF NEW YORK +COUNTY OF NEW YORK + +Before me, the undersigned authority, on this day personally appeared JEFFREY E. EPSTEIN, Testator, DARREN K. INDYKE and LAWRENCE NEWMAN, respectively, whose names are subscribed to the foregoing instrument in their respective capacities, and all of said persons being by me duly sworn, the said Testator declared to me and to the said witnesses, in my presence, that the said instrument is a fourth codicil to his Last Will and Testament and that he has willingly made and executed it as his free act and deed for the purposes therein expressed; and that the said witnesses, each on his oath, stated to me in the presence and hearing of said Testator that the said Testator had declared to them that the said instrument is a fourth codicil to his Last Will and Testament, and that he executed the same as such and wanted each of them to sign it as a witness; and upon their oaths, each witness further stated that they did sign the same as witnesses in the presence of the said Testator and at his request; and that said Testator was at the time eighteen years of age or over and of sound mind; and that each of said witnesses was then at least eighteen years of age. + +![]()![]()SUBSCRIBED AND SWORN TO before me by the said JEFFREY E. EPSTEIN, Testator, and DARREN K. INDYKE and LAWRENCE NEWMAN, witnesses, the 20th day of September, 2007. + +![]()LAUREN J. 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/dev/null +++ b/marker2/ds9/EFTA00089546/_page_21_Picture_86.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:5a915f474edddf7abaec5b4b58e0f44c63ded218c34d6560a25de77e6c346662 +size 6041 diff --git a/marker2/ds9/EFTA00089570/EFTA00089570.md b/marker2/ds9/EFTA00089570/EFTA00089570.md new file mode 100644 index 0000000000000000000000000000000000000000..8e7bc4d5d4dd26bf8207616cd2c1dccad6e77e6d --- /dev/null +++ b/marker2/ds9/EFTA00089570/EFTA00089570.md @@ -0,0 +1,238 @@ +From: ' )" cti To: "McGorty, Glen" •cl k's Cc: "I >, "Giffuni, Danielle" Subject: RE: Meeting with Date: Wed, 22 Jul 2020 22:08:16 +0000 + +We received the calendar invite, thanks, and we'll talk with you then. + +From: Sent: Wednesday, July 22, 2020 17:30 To: Cc: > Subject: RE: Meeting with Giffuni, Danielle + +Yes, that works. We will send a calendar invite with a dial-in. + +Thanks, Glen + +Glen G. McGorty I Crowell & Moring LLP + +Mana in Partner. New York Office + +wvAv.crowell.corn + +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, July 22, 2020 4:51 PM To: McGorty, Glen Cc: Danielle c Subject: RE: Meeting with C ; Giffuni, + +External Email + +Glen, + +No problem. Would tomorrow at 2:00 p.m. work for you? Or if not, we should be pretty flexible, if you want to suggest an alternate time. + +Sent: Wednesday, July 22, 2020 09:53 + +To: + +Cc: ‹ ; >; Giffuni, Danielle + +Subject: RE: Meeting with + +Sorry for the delay. We've spoken to =. Let us know when might be a good time for a call over the next couple days. + +Best, Glen + +Glen G. McGorty I Crowell & Moring LLP + +Mane in Partner. New York Office + +wvAv.crowell.com + +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 for 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, July 16, 2020 2:32 PM + +To: McGorty, Glen < + +Cc: Zelenko, Daniel Giffuni, Danielle >; + +Subject: RE: Meeting with + +## External Email + +Glen, + +Thanks again for following up with us on this issue previously, and we wanted to circle back to take you up on the offer to convey some additional information to your client to see if it causes him to recall anything additional. If you could please advise Mr. of the following additional information? And then we can have a call similar to our last one to check in. + +The individual whose photo we sent is named is an employee of the U.S. Customs and Border Protection agency and worked in Saint Thomas for a number of years, and may have had a friendship with Jeffrey Epstein during that time. In particular has been to Epstein's home in the Virgin Islands and has accompanied Epstein on boat, helicopter, and/or plane trips. + +Mr. was listed as a contact in phone, and =may have introduced one or more individuals to at a bar or other location in the Virgin Islands. + +Please let us know when you've had an opportunity to provide this additional information? And we hope you're well and look forward to being in touch. + +Sent: Monday, June 22, 2020 14:27 + +To: [REDACTED] <[REDACTED]> + +Cc: Zelenko, Daniel <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] + +<[REDACTED]>; Giffuni, Danielle <[REDACTED]> + +Subject: RE: Meeting with [REDACTED] + +[REDACTED] - + +Would you all be available for a call on Wednesday morning? I think we could do any time before noon. + +We will let you know if Mr. [REDACTED] recognizes the individual in the photo. + +Best, +Glen + +**Glen G. McGorty | Crowell & Moring LLP** + +Managing Partner, New York Office + +[REDACTED] +[REDACTED] +[REDACTED] + +**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](mailto: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: [REDACTED] <[REDACTED]> + +Sent: Monday, June 22, 2020 12:49 PM + +To: McGorty, Glen <[REDACTED]> + +Cc: Zelenko, Daniel <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] + +[REDACTED] <[REDACTED]> + +Subject: RE: Meeting with [REDACTED] + +[External Email](#) + +Glen, + +It was indeed quite a weekend, but we continue to do our work as always, and the kind words are appreciated. + +Thanks also for getting back to us, and we're available for a call this week if that would be helpful, and/or if you want to let us know in the first instance about the photo in particular, we can also just go from there. Let us know, and we're around. + +thanks, + +[REDACTED] + +--- + +From: McGorty, Glen <[REDACTED]> + +Belated thanks, We will circle up with Mr. and maybe we can have a call early this coming week. + +Crazy times in the Office these days — I hope you are all doing okay. I was on a number of e-mail threads since last night and there are many efforts afoot from generations of alums to publicly support the Office as an institution and all it stands for (and to express profound disappointment over the recent developments). Hang in there. + +Glen G. McGorty I Crowell & Moring LLP + +Mane in Partner. New York Office + +www.croweecom + +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: Friday, June 19, 2020 3:07 PM + +To: McGorty, Glen < + +Cc: Zelenko, Daniel >; + +Subject: FW: Meeting with + +External Email + +Glen, + +Per my previous email, please see the below. + +thanks, + +From: + +Sent: Wednesday, June 17, 2020 18:29 + +To: Donnie Murrell + +Cc: >; < + +Subject: RE: Meeting with + +Donnie, + +It's been a while since we've been in touch, and obviously our world changed substantially very shortly after the below email exchange from August 9. But we wanted to reach back out because we were wondering if you would be willing to ask Mr. a couple specific, relatively narrow questions relating to an ongoing investigation. Ordinarily we would ask ourselves, in the context of the discussion we had planned to have—and still hope to schedule, once health and safety permits—but given all of the current circumstances, we'd like to make the request through you. + +The initial question is whether Mr. recognizes the individual in the attached photo, and if so, generally how he knows the individual. And if Mr. does know the individual, we may ask you to please convey limited follow-up questions, or to schedule a brief call. If it would be at all useful to discuss this request, please let us know; if that is helpful we can chat at your convenience. + +Thank you, and hope this finds you well. + +Assistant U.S. Attorney Southern District of New York + +From: 'c => + +Sent: Friday, August 09, 2019 15:20 + +To: Donnie Murrell < M> + +Cc: + +Subject: RE: Meeting with + +Donnie, + +Our schedule is a bit up in the air right now, but we are tentatively looking at dates during the week of the 19th. We will let you know as soon as our plans firm up, and thanks for being flexible. + +Best, + +From: Donnie Murrell + +Sent: Friday, August 9, 2019 11:19 AM + +To: + +Subject: Meeting with + +Ms. I.: + +I lave you firmed up the date/s you will be down here? + +L.D. MURRELL, P.A. + +Donald "Donnie" Murrell, Jr. + +Board Certified Criminal Trial Lawyer \ No newline at end of file diff --git a/marker2/ds9/EFTA00089570/EFTA00089570.metadata.json b/marker2/ds9/EFTA00089570/EFTA00089570.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..37b4b7c68a66259e186817cbce533b7154cb923c --- /dev/null +++ b/marker2/ds9/EFTA00089570/EFTA00089570.metadata.json @@ -0,0 +1,229 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089570.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 5, + "chars": 7889, + "elapsed_seconds": 9.02, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "COVID-19 Questions or Concerns? 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They request that this letter that would state in short that they are a victim of Jeffrey Epstein's as identified by the FBI. Their hopes was to use this to assist them in applying for the victim compensation fund. They originally requested 302's of the interviews which obviously will not be providing during an active investigation. As me and discussed earlier today this could be a little tricky because the generic letter would typically use states something to the effect of "XXXXX has been identified by the FBI as a victim of a federal crime by Jeffrey Epstein". As we know not all of the girls we interviewed were necessarily victims of a federal crime but still we would like to do our best in appropriately assisting everyone who has been negatively effected by Jeffrey Epstein. + +=suggested we jump on a phone call sometime next week to hash this out before returning to = and with an answer on how we will proceed. What's everyone's availability next week? We already have one for 4:30 on Tuesday...how about doing a call that same day but earlier in the afternoon? I'm free all day. + +Thanks, + +NYPD / FBI + +Child Exploitation Human Trafficking Task Force + +Office: + +Cell: + +Fax: \ No newline at end of file diff --git a/marker2/ds9/EFTA00089575/EFTA00089575.metadata.json b/marker2/ds9/EFTA00089575/EFTA00089575.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..ee3c664dbf5c93ef36bfa55d7a166b9cb7e106c0 --- /dev/null +++ b/marker2/ds9/EFTA00089575/EFTA00089575.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089575.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1466, + "elapsed_seconds": 0.75, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 51 + ], + [ + "Line", + 25 + ], + [ + "Text", + 15 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089575" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089576/EFTA00089576.md b/marker2/ds9/EFTA00089576/EFTA00089576.md new file mode 100644 index 0000000000000000000000000000000000000000..406eba305b4835cf92d3edb1658ace2b4420dee7 --- /dev/null +++ b/marker2/ds9/EFTA00089576/EFTA00089576.md @@ -0,0 +1,567 @@ +To + +![](_page_0_Picture_2.jpeg) + +0 + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +Date: Sat, 05 Sep 2020 13:08:50 +0000 + +Attachments: KCG\_Appendix\_3-20\_13\_penultimate.docx; KCG\_TCR\_3-20-13-penultimate\_draft.pdf; KCG\_TCR\_3-20-13-penultimate\_draft.docx; KCG\_Appendix\_3-20\_13\_penultimate.pdf + +Ms Strauss, Mr Berger et al, + +Your prosecution of Mr Kamensky while obstructing an investigation of Little Dick Handler/JEF et al in the massive and very much ongoing SEC facilitated criminal activity with regards to Knight/KCG/VIRT:NITE and the primary role of Little Dick Handler/JEF is itself criminal obstruction. In fact, the grossly corrupt SEC et al have been in possession of this exculpatory evidence in my claims since 2013. The courts will see this exculpatory evidence. Proceeding with your prosecution of Mr Kamensky is a KNOWN fraud on the courts. Exposing the irrefutable evidence in my claims :the record Janey: brings down some very powerful people. INCLUDING people at the SEC. In short, the SEC criminally obstructed an investigation of my claims into the criminal activity of Little Dick Handler/JEF for 7 years now. Mr Handler/ JEF should have been prosecuted by the same entities now prosecuting Mr Kamensky LONG ago. + +Cheers! + +Christopher J Dilorio + +Whistleblower + +![](_page_0_Picture_11.jpeg) + +From: Chris Dilorio + +Sent: Tuesday. June 23.2020 9:48 AM + +![](_page_0_Picture_14.jpeg) + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +Ms Norberg, + +I am in receipt of the SEC OWB correspondence allowing me more time to respond to the preliminary denial of my award application for the Oppenheimer 2015 covered action. This e mail was the last 1 I sent to your office related to my appeal. It will serve as the basis of my appeal. Including the attachments of my 2013 TCR submitted with Berger Montague to the SEC. I will also forward correspondence from 2012 and following detailing my extensive correspondence with Robin Traxler at FINRA as well as Sean McKessy in the OWB. Even though, I have previously forwarded your office as well as the SEC IG office the exact same corroborating evidence. My response to you will be lengthy and detailed. However, given that it took your office FIVE YEARS to send me a preliminary denial notice, that is understandable and in fact a result of YOUR lengthy delay in notifying me. ALL of my response pertains to the denial appeal at hand. + +In 2011, I filed my first Whistleblower complaint with the SEC. Detailing a massive fraud on the public directly implicating dozens of entities. The center of my claims: Knight/KCG/VIRT: collectively NITE and the Swiss banking giant UBS:UBSS. By far, NITE was and still is today the largest MM/executing BD in the OTCM space. I was shocked to find the Swiss banking Giant UBSS was trading many of the same stocks as NITE and to the extent they were. This came on the heels of the FINRA UBSS Reg SHO complaint where the extent of the UBSS activity "threatened to undermine the integrity of our markets" while the SEC analysis of this activity was simply a case of "sloppy record keeping". My experience as an Institutional Sales trader: executing multi million share equity trades for the largest institutions in the world like Fidelity and Putnam. In addition, as a Research Sales person: analyzing financial statements and making investment recommendations formed the basis of my expertise. In fact, the SEC OWB has paid out awards for information just like mine. In August of 2011, I informed the SEC that NITE was insolvent having reported just \$105 mil in working capital at June 30, 2011. AND, for the resaons cited in my TCR detailing massive accounting fraud as a direct result of illegal naked shorting/self clearing/reverse splits/cusip changes etc. The SEC had a choice: investigate these extremely serious allegations and shut down this massive fraud on the public OR cover up their failure and allow this massive fraud on the public to continue. Unfortunately for the American public the SEC is mandated to protect, the SEC chose the latter. As a direct result, ALL of the activity detailed by me in this TCR and other TCR's filed with the SEC as well as 9 years of additional correspondence with the SEC, this is very much an ongoing, massive scheme. One that the SEC actively facilitates. Countless losses have been incurred as a result. NITE as I detailed is in a constant state of insolvency. The SEC has time and again intentionally misled the investing public that there is no abusive naked shorting. NITE is still in business TODAY. + +The core business at NITE is and always has been: abusive naked shorting OTCM shells to facilitate money laundering. Not DMM, FCM, reverse mortgages, or even HFT. This illegal business is EXTREMELY profitable and virtually riskless. AND, both the SEC and FINRA know this. In 2016, FINRA brought a Rule 204 complaint against NITE. The fine was pathetic and not meant to be a deterrent. This is WHY the OTCM exists. But it's not JUST OTCM as my AQR TCR filed with the SEC clearly proves: NASDAQ Blank check shells as well. I have also filed + +separate TCR's related to NewLead and FreeSeas: 2 massive money laundering shells which began on NASDAQ,de listed to the OTCM. NONE of the activity detailed in the Opco/Gibraltar complaint takes place without a willing executing BD/MM who ultimately turns worthless certs into real money. That #1 trader is NITE. As you read in my Knight TCR CGFIA is at the heart and, because it was based in Colorado, became a template of sorts for my extensive research. See Ms Norberg, unlike the SEC "investigators" on the Opco/Gibraltar complaint, I've actually seen first hand the CGFIA "world HQ" as well as the rented Littleton home of CGFIA CEO Guyer. I've done extensive research on Properties claimed to be owned and M&A transactions done for the sole purpose of cert printing and distribution (Aurelio AMNP) where the ultimate acquisition amounted to a distributor of Ukrainian folk music. I've also done extensive research on domestic and foreign financial institutions claiming to "invest" in these scam companies like Josh Sason/Hanover/Magna also cited in my 2013 Berger/Knight TCR linked. So, as I detailed to Ms Traxler, I followed Guyer to Neuchatel Switzerland and his previous endeavor: Antelope Technologies also with an office in Highlands Ranch CO. Where I discovered a connection to Swiss/German individuals/entities that were also related to another OTCM shell in the OpCo/Gibraltar complaint as well as my Knight TCR: AppTech. Offices in the Woodlands TX and Boca Raton. AND very much up and running today. SHOCKING. The SEC OpCo/Gibraltar complaint is based on the FINRA complaint. That is absolutely irrefutable. As the Gibraltar complaint alleges just 1 OTCM shell and just amillion shares while Commissioners Stein and Aguilar referenced BILLIONS of shares in their OpCo waiver dissent. Who executed those BILLIONS of shares? Was OpCo even a MM? If I ask a question it's typically a rhetorical: I know the answer. The SEC knows the answer also. The SEC OpCo complaint does not mention the executing BD/MM. The SEC complaint doesn't mention Sason/Hanover/Magna either. The SEC complaint makes no mention of illegal naked shorting which is clearly evident in the CGFIA 10Q referenced below. THIS IS MY INFORMATION. So, why aren't NITE, Hanover/Magna and UBSS implicated in the SEC OpCo/Gibraltar complaint? What my TCR clearly and irrefutably proves: NITE was engaged in illegal activity both BEFORE and AFTER the SEC et al orchestrated August 1 2012 "trading glitch". So, the SEC bailed out a KNOWN criminal entity. Unfortunately for the investing public, the SEC has doubled downed on facilitating this illegal activity into 2020. The "glitch". Knight was insolvent in August 2011. 1 told the SEC this. The "glitch" proved my allegations. Key point in my TCR: NITE inadvertently sent 4000 worthless securities to JPM to secure an emergency bridge financing as collateral. These were open, naked short fails that could not be covered/closed due to a cusip change (SEC/FINRA approved rev split) booked as an "asset"(receivable) due to self clearing: MASSIVE accounting fraud. Ironically, the "glitch" proved my allegations: despite claiming to have a "highly liquid balance sheet" NITE had to raise the entire amount of the "glitch". AND the ultimate "financing" was not collateral based. Rather a 50% discounted convert when the stock had already been crushed to \$3 OR \$1.50. ALL of the financing participants knew the NITE balance sheet was complete fraud. NITE also committed securities fraud in pledging those 4000 worthless securities as collateral to JPM: SCOTUS Rubin: pledging collateral to secure financing is an offer to sell. JPM looked the other way. As did the SEC. Further, I submitted my amended TCR with Berger in March 2013, In August of 2013, FINRA brought a penny stock AML complaint against OpCo. Sale of unregistered penny stocks. WHO ultimately executed the trades? 2008-2010. In July 2013, the "glitch" financing Gen Atlantic/Getco reverse merger with Knight to form KCG closed. The new CEO of KCG was Dan Coleman who ran Equities at UBSS during their Reg Sho and cross border activity. For UBSS, the DOJ (Acosta Downing et al) dropped their DPA in 2010. My claims: the FINRA OpCo/Gibraltar complaint clearly implicates UBSS criminal activity AFTER the DoJ dropped its UBSS x border DPA. This is what the SEC is protecting in the OpCo/Gibraltar complaint: NITE/UBSS/Hanover/Magna illegal activity. + +Also in my Knight/Berger 2013 TCR: IMDS. A multi year money laundering shell kept up and running by the SEC. Also NITE,UBSS, and Hanover Magna. In addition to other entities like JMJ, Southridge, and Alpha Capital Anstalt. Alpha Capital Anstalt is very much in business today as a result of SEC obstruction while the SEC recently brought a complaint against JMJ for activity like that in IMDS even AFTER he was barred by FINRA. In IMDS, the SEC allowed 2 barred individuals (CEO/CFO) to do an offering that created 37 BILLION shares of IMDS at .0001 with Chinese Nationals before revoking the IMDS registration. What do you do with 37 billion shares of IMDS at .0001 when there are no bids below that? NOTHING. The stock never traded. The SEC orchestrated a NITE/UBSS/Hanover/Magna/JMJ/Alpha etc MASSIVE naked shorting to facilitate money laundering scheme bailout so that the MASSIVE naked short position didn't need to be covered in the open market as is mandated by Rule 204. Thus insuring profits and not MASSIVE losses for NITE and UBSS. + +I also filed separate TCR's for NewLead and FreeSeas. 2 "Greek shipping" money laundering shells started on NASDAQ and delisted to OTCM. NITE top trader in BOTH. Hanover/Magna in both. I contacted the KY Div of Mines and notified the SEC that these "transactions" were complete fraud. The SEC Feb 2019 complaint against Hanover/Magna is my information: Bogus obligations, assigned, converted to worthless certs. Then dumped on the public and converted to REAL money by the executing BD/MM:NITE. Who generates illegal trading profits by abusive naked shorting. Very symbiotic relationship. 1 of the Hanover/Magna entities was Gibraltar/Hanover. + +Somehow omitted from the SEC OpCo/Gibraltar complaint. In NewLead, then SEC White and Ceresney firm Debevoise did a "fairness opinion" of a Russian Nickel wire transaction where the NewLead CEO had back dated documents. That has been expunged from SEC reviewed filings. FreeSeas: a structured tax evasion/money laundering shell. Also involved Credit Suisse and Deutsche Bank. Both Debevoise clients. Both involved in the tens of billions Russian Mirror trade scheme. In addition to Hanover/Magna a Milken related entity Crede: Run by Milken/Drexel/Obstruction of justice/Parking: Terren Peizer and his felon partner Michael Wachs. This led me to Net Element NETE. Peizer again. This time with more AML red flags than be counted. Well known to the SEC through TWO of my separate TCR's. CEO is Oleg Firer. Firer former money laundering shell Acies shut down by the SEC while NETE was left up and running. Acies very much up and running also in MA. In NETE: NASDAQ. AQR Blank check shell. SEC allowed 2 offerings so that NETE could keep its NASDAQ listing. 1 was with entity Esousa: felon Wachs ex wife. 2nd was with Cobblestone: felon Wachs sister. I told the SEC. They still approved the offerings. I discovered AQR money laundering blank check shell activity doing research on NITE and Hanover/Magna. A top traded NITE OTCM shell was Cereplast. Another AQR blank check shell. + +Hanover/Magna/NITE/ and Alpha Capital Anstalt. Alpha is Liechtenstein based and controlled by Martin Schlaff: Austria/Israel. AlsolMDS (w/Schlaff controlled Balmore) and the Frost/Honing/Stetson et al complaint. Schlaff also LH Financial/Wolfson/Sulphco and Bawag: Sedona/Scan Graphics: Refco: Naked shorting. NITE is Refco on steroids. Cereplast ended in bankruptcy. + +NETE claims to be a "payment processor". BILLIONS in transactions processed. Never break even let alone profitable. Balance sheet complete fraud. AML red Flags: Firer is Grenada Amb to Russia living in Miami, Apockinas/Grinshpun/Antonov/RakisheviTrump/Kushner/SBNY/CardWorks/Merrick Bank/ESCt/Cohen etc etc etc money laundering/transaction laundering BILLIONS shell. Kept up and running for years since filing my NETE/AQR SEC TCR's. ALL of my allegations proved accurate in 2020 when NETE received Cares Act taxpayer money then announcing it was "unlocking the value in its misunderstood payment processing business" by doing a reverse merger with a CA electric car company started by a former musician. The payment processing business to be "sold" and the new company (Mullen) will own 80-90%. All made possible by SEC obstruction and ACTIVELY facilitating illegal activity. Another AQR blank check shell is Astra/Phunware. More Greek shippers related to massive swindler Economou originally intended to do an "energy logistics company" acquisition and somehow settled on "mobile app developer" Austin DC Phunware. PHUN CEO is well known to the SEC with shells going back 15 years. I alerted the DoJ and SEC that PHUN was a money laundering shell. In addition to the "genius quant" AQR, AIPAC: Gerber/Hudson Bay, Nordlicht: Ari Glass/Boothbay, 1MDB: Khazanah Nasional, Global Crown/Rani Jarkas/EFG/BSI/Optima/Max Fang. AG Barr 1MDB waivers: Kirkland also AQR. Broidy: Trump: 1MDB money laundering. PHUN also received Cares Act money. AND PHUN is Trump/Kushner/Parscale campaign mobile App. PHUN should have also been shut down long ago. AQR too. OTHER AQR blank check shells: CIS/Delta/Urban Tea, Ability/Cambridge, Hunter Maritime, and MI Acquisition/Priority Tech Holdings. Ability/Cambridge: Israeli cellular intercept/surveillance. Israel sent employees to jail. In the US it was "securities fraud". The SEC Ability/Cambridge complaint was handled by Ansu Banerjee in the SECLA office. Milken/Mogilevich/BoNY money laundering entity Sinex: Debasish Banerjee. WHY did SECLA have jurisdiction over ABILF/Cambridge? Result: ABILF is very much up and running today. I believe this is the PHUN/Trump/Kushner/Parscale mobile app technology. + +Hunter Maritime:HUNTF: Never consummated an acquisition. Just cert printing/dumping. Also involved: Milken family office: Silver Rock. MI/Priority:PRTH. CEO Tom Priore: well known fraudster to the SEC. Also transaction/money laundering like NETE. Also involved: Hanover/Magna. + +ALL AQR money laundering shells up and running today thanks to the SEC. Only recently did the SEC revoke CGFIA and NewLead. well after going dark and the massive fraud on the public had already been perpetrated. In NewLead, FreeSeas, etc etc etc a common tool used is reverse splits to perpetuate and facilitate illegal activity. SEC/FINRA approved. The result is the massive accounting fraud at NITE. WHEN not IF there is an open naked + +short fail when a rev split takes place, a new CUSIP/security is issued. Trades in the old cusip/security cease. This creates a structural liability. The fail/short can NOT be closed. Like covering a short in AAPL with MSFT. Because NITE is self clearing it books a prop naked short as a receivable. An asset. But, because NITE won't or CAN'T deliver, massive accounting fraud. Literally a liability booked as an asset. This is how "glitches" are born. + +But the SEC facilitated fraud doesn't end there. The definition of a failed trade: 1 that hasn't settled. The SEC/DTCC issue new securities where trades in the old haven't settled yet AND not authorized by the issuer. Settlement: buyer brings cash/seller brings securities. The DTCC simply makes journal entries. But there are still "IOU's" in the system. The SEC authorized the DTCC to create a shadow clear,non guaranteed, ILLEGAL (clearly + +contrary to 34' Act "prompt and accurate settlement) Obligation Warehouse so criminals like NITE et al can circumvent close out REQUIREMENS of Rule 204. The OW is just what it sounds like. Per my Knight TCR, DTCC suspends services (Chill/Lock) and trades are deemed "ex clearing". In a FOIA request made with POGO,Berger and I asked the SEC fails data on dozens of NITE/UBSS top traded stocks like CGFIA,APCX and IMDS. The SEC + +response: see our website. The SEC fails data is for DTCC cleared trades only. The SEC knows exactly the level of fails sitting in the OW. They don't disclose. Intentionally misleading the public there is no naked shorting. In 1Q2020, the receivable at NITE/VIRT increased \$1.2 BILLION sequentially. Up almost 90%. AND the tangible book value is grossly insolvent. When it comes down to it, there really isn't ANYTHING in the receivable that NITE can convert into cash for its own use. There are prior commitments on those "assets": SETTLEMENT of transactions. Because the SEC has never shut down this activity, NITE is in a constant state of insolvency. Other examples of SEC attempts to cover up NITE illegal activity so that it can continue include: + +Cerberus/Feinberg/VIRT bidding on NITE post "glitch". Wasn't their turn. First, Gen Atlantic needed to monetize its GETCO "investment". The HFT business at GETCO was in a death spiral when the rev merger took place. So what was the attraction to NITE? The business that had absolutely ZERO overlap/synergies: OTCM. As low tech as it gets. Literally a trader sitting in a chair. As I have asked the SEC on hundreds of occasions over the years: what would happen to NITE trading profits if their OTCM share volumes went to ZERO? Cerberus is Feinberg: Gruntal/Milken. Also bailed out Bawag:Refco, HSH, and Deutsche Bank (\$50 bil Bad Bank to Goldman). Another Milken/NITE connection is Rich Handler: Jefferies. Also a Milken/Drexel protege. Milken was Gruntal: + +Feinberg,SAC,lcahn, Sater etc. Gruntal was "sold" to Ladenburg. Controlled by Vector/NewValley:Icahn/Lorber/Elliman etc. And, was sold to multi billionaire Frost. Who, according to the SEC risked it all trying to "make" a few million when he, Honig, Stetson, Alpha et al were really LAUNDERING. Milken also Whiterock ,D H Blair (Morty Davis) and AR Baron (Bressman/D H Blair) which was the precursor to Bear Stearns collapse . So, Milken and his merry crew of flunkies are really at the nexus of JUNK. They own Trump and his White House (Trump casino junk) and they own the SEC. It was Milken, Leon Black, Handler, Moelis, + +Virtue: Drexel that caused the S&L taxpayer bailout stuffing them with junk like Trump's. It is no coincidence that these same flunkies are also the largest CLO originators/managers. CLO's: Junk on steroids. AGAIN Bailed out by taxpayers in Cares Act HY. There also connections to Epstein. Treasury Sec Mnuchin and Black: + +HY/Junk/S&L's and Epstein. Black: Money laundering shell ESWW kept up and running by the SEC was/is an Epstein money laundering vehicle: JUNK IS JUNK. + +THIS EXPLAINS the Handler/Jefferies/Milken repeated bailouts of NITE. It also explains the SEC criminal obstruction. + +SEC Chair Clayton is also directly linked to this criminal obstruction. His firm Sullivan Cromwell and Jared Fishman are ACTIVELY facilitating this massive fraud on the public. Clayton did not disclose these conflicts in his disclosures. Sull Crom/Fishman have advised Knight/KCG/VIRT and several transactions designed to facilitate + +this ongoing and ongoing fraud on the public. Many of the same players involved in the "glitch" were involved in the VIRT acquisition of KCG in July 2017. In addition to Sull Crom/Fishman and Handler/Jefferies: JPM and Goldman. The SEC facilitated fraud in the NITE/VIRT transaction is egregious illegal activity. The transaction NEVER should have happened. KCG was an SEC reporting company until the deal closed on July 31 2017. Despite this FACT, VIRT CEO Cifo refused to "publish" KCG 2Q2017 financials. I estimate Cifu/Coleman/Handler/GS/JPM wrote down more than \$4 billion in open naked short fails: "leverage". The SEC let him. Meaning: "assets" used to determine the take out/ tangible book of KCG was complete fraud. VIRT grossly OVER paid for insolvent KCG. + +Prior to the NITE/VIRT transaction closing in July 2017, NITE would report its trading stats monthly. Including OTCM share volumes. Cifu stopped this post merger. The SEC let him. In fact, you will find NO reference to NITE/VIRT OTCM share volumes in any SEC reviewed filing, sell side research or investor presentation. A well orchestrated fraud on the public. Omissions to Intentionally mislead the public as to the true representation of the NITE/VIRT business model. These share volumes are also at the center of my 2013 Berger TCR. There are no affirmative disclosures in any SEC filings to this day as to the AML risks posed in trading these OTCM and other shells. In a 2014 letter to the SEC, I detailed the first 2 months of NITE OTCM share volumes. When the 1Q2014 10O was filed, these volumes were confirmed: An ASTRONOMICAL increase sequentially as well as year over year. These share volumes/my letter/TCR SHOULD have triggered an immediate SEC investigation. It did not. This portion of the KCG 2O201410O was expunged as well as 3Q2014 OTCM share volumes. I have detailed this to the SEC/OWB/Enforcement/IG. In the months leading up to the NITE/VIRT closing in July 2017, KCG put out monthly trade stat pr's showing KCG trading more volume than the overall market. Also indicative of naked shorting. Those pr's were also expunged. I also including electronic forms to the SEC OWB/Enforcement/IG. The SEC has essentially outsourced the ENTIRE OTCM market to the Broker Dealer SRO FINRA. Including: management of the OTCM share volume website fka OtcBB.com. Today, there is very little transparency into trading activity by MM as a result. Also: ISSUER corporate actions: rev splits, Short interest reporting: an absolute farce given there is still no CAT. AND BD compliance with the BSA. Per my TCR: WHY did NITE and UBSS trade Billions of shares of CGFIA and IMDS AFTER a Chill or Lock was placed (ex clear/OW)? CLEAR AML red flags. Because they had an open naked short position. Why not pull a market? Because they had an open naked short position. SAR's? WHEN? BEFORE OR AFTER THEY TRADED BILLIONS OF SHARES? There were no SAR's either. NITE can not outsource its compliance responsibilities to 3rd parties (like OpCo) when executing trades as MM. In 2015 at a SIFMA conference, Ceresney was "shocked" by the number of BD's under his supervision filing 1 or ZERO SAR's. NITE SHOULD have been investigated for egregious BSA violations long ago based on my TCR. Knight/KCG/VIRT:NITE is and always has been a criminal enterprise. Spitzer Russian/US mob bust: "worthless paper". Ashton Tech became VIE became Optimark became Knight/Trimark NITE literally "made by the mob". The SEC has known this for years. ALL of the "worthless paper" shells were SEC reporting companies. Today, Trump PA Campaign Mgr David Urban sits on the NITE BoD. AND is also on the BoD of his very own money laundering shell: Canadian/Pakastani/pot/COVID: FSD Parma: HUGE. Trump advisers/campaign staff Bannon and Parscale also involved in OTCM money laundering shells.Parscale Cloudcommerce fka Roaming Messenger also receiving taxpayer Cares Act money. Madoff: more money laundering than Ponzi. HOW THE HELL did the SEC let that scam go on for as long as it did? Criminal obstruction. The former SEC IG Kotz actually investigated his "bosses" at the SEC unlike current IG Hoecker. Years of SEC obstruction. Bullshit "investigations" into "running ahead" meant to distract. Similar to the SEC "glitch" "market access complaint" where former SEC "glitch" Enforcement Dir Khuzami/Kirkland(Barr) also rep'd NITE. Can't make this up. The center of IG Kotz scathing failure of the SEC in Madoff: SEC NY and Mr John McCarthy who ended up being Knight/KCG Chief Counsel. As I said: can't make this up. And, as we know Madoff started his career in NASDAQ penny stocks exactly like the l's in the Spitzer/Mob complaint. OTCM: This is WHY the OTCM exists: abusive naked shorting publicly traded shells to facilitate money laundering. CEO Cromwell Coulson CHAIRED the FINRA market Regulation Cmte. Say it with me: Can't make this shit up: CMTSU. A founding OTCM Board member is former NITE trader Andrew Wimpfheimer:CMTSU. This is a very well orchestrated and ongoing fraud on the public. Russian mirror trades: no SEC OR DOJ investigation + +HOW? According to stories: activity peaked in 2H2014. Coinciding with NITE astronomical OTCM 1Q2014 share volume increase. In additional to money laundering penny stock shells, the OTCM is also home to many ADR's. Including Russian ADR's cited in the NYDFS/DBTCA/mirror trade complaint. Little/no disclosures. Also in my TCR: P&D is just a tool used to facilitate the fraud and NOT a stand alone fraud. The SEC intentionally stops short of thorough investigations into much bigger frauds. The same way it has the public believe the "penny stock trading fairies" convert worthless certs to real money. NO! willing executing BD's and MM's like NITE do that. Less than a year after filing my Knight TCR with Berger, FINRA (not the SEC) brought the BBH AML complaint. This was my information. Swiss banks, foreign/domestic institutions, executing BD's/MM's/ penny stock shells: \$850 mil in proceeds. Did BBH implicate NITE and other entities in my claims? WHY are all of the entities in the complaint UN NAMED? In the interest of transparency for the investing public? In 2019, I also filed an award application for the UBS x border/AML complaint. This is BLATANTLY my information. SEC/FINRA/ AND the SEC. I filed an IRS TCR based on my SEC TCR attached. In April 2016, 2 IRS CI Agents: VIKAS Arora and Nathan Sarnacki flew to Denver from Chicago to meet with me. I believe they were blown away. Then came the UBS complaint. As a follow up to our meeting, they wanted to know WHO at the SEC I shared my information with. I told them. That was the last I heard from them although I continued to send them my information. To the SEC IG Carl Hoecker: In 2015 I parted ways with Berger as I was convinced the SEC was using my information in an unethical/illegal manner to both bring and obstruct complaints. Berger was not willing to file an IG complaint. After parting ways, I almost immediately did just that. Prior to retaining Berger I had filed an award application for the UBS Reg Sho complaint. In my submission and my correspondence with Mckessy/OWB I made the claim based on OWB permissible rules to "open a new line of inquiry". One that would link the trading activity detailed in my ultimate TCR by NITE and UBSS. That link: Abusive naked shorting publicly traded shells and money laundering. My application was denied and there was no investigation into this link. The SEC had just bailed out a "known criminal enterprise":NITE "glitch" was not a forthcoming admission. Neither was the blatantly and knowingly false pretext for the DOJ dropping its UBSS x border DPA because "UBSS was in full compliance" in 2010. So, rather than open a new line of inquiry, the SEC chose to obstruct. + +I made clear to Hoecker the egregious conflicts by Khuzami,White and Ceresney with clients UBS,JPM,CS, and DB. Hoecker claims to have conducted a "thorough" investigation of my very serious allegations and found nothing. Despite MJW waivers received to "investigate" her Swiss bank client CS. Then in 2019, Hoecker arrogantly told me I could file a FOIA request on his findings. Then, came 2019 and absolutely nothing had changed. NITE was still trading billions of shares of OTCM shells like ELTZ. There were still no risk disclosures. Cifu refused to publish KCG 2Q2017 financials, Hanover/Magna/AQR/Alpha/IMDS etc etc etc were still up and running . I filed ANOTHER complaint with IG Hoecker. Despite the fact that Hoecker himself wroth the IG handbook on "thorough investigations" mandating complainant interviews, I have never been interviewed by Hoecker. In addition, the IG Hoecker is mandated to inform Congress as to serious allegations like mine. He did not. In doing so, obstructed Congress from executing its oversight of the SEC/OWB. And despite hundreds of offers to fly to SEC HQ to have the best and brightest at the SEC rip apart my allegations 1 by 1 I have never been taken up on my offer. Why is that? The SEC OWB has gone to great lengths in other cases to explain the OWB process etc to whistleblowers. I have never been told "no thanks" for my information. In fact, McKessy has solicited MORE information from me after submitting my Berger TCR. In Madoff, an intern could have verified/shut down in weeks NOT years. No contra parties. Only a well orchestrated obstruction by SECNY/McCarthy et al kept it up and running. As I have also repeatedly told the SEC: My claims could be verified in weeks also. NITE has a P&L for every stock they trade. These, aggregated, are basis for quarterly trading profits. These P&L's, combined with OW data, and balance sheet data will validate ALL of my claims. I've offered my service to do exactly that. 2 weeks max. Afterall, proprietary trading strategies are NOT proprietary if they're illegal. For the reasons I have listed in this summary, NITE/VIRT is on the SEC "do not investigate list". And yes, there most definitely is such a thing. Especially when it comes to illegal activity facilitated by the SEC. So, the SEC denial of my OpCo award claim which was 5 years in the making is just another example of my very serious allegations: The SEC solicits and uses whistleblower information like mine to both bring and obstruct + +complaints. Unethical. Illegal. To deny my award application because the "investigators" didn't see my information is further affirmation of my allegations. They saw it. They used it. They denied my compensation for it. Again Ms Norberg, I will forward my 2012 etc emails with Robin Traxler at FINRA as well as McKessy as further evidence that my Award application denial should be overturned. Further affirmation from 2 dissenting SEC Commissioners and the judge in the Gibraltar case makes this denial both egregious and bizarre. Bizarre ONLY if you believe that there is no SEC obstruction that is. BTW, crazy stuff going on with the firing of Mr Berman/Clayton nomination to take his place/Rabbitt to DoJ/Carpenito replacing Audrey Strauss/Trump/Barr don't you think? The SEC needs some fixers. Wonder why. + +I'm cc'ing some our mutual friends on this email Jane. The last overt act of this massive ongoing, SEC facilitated conspiracy has not occurred yet. + +Cheers! + +Christopher J Dilorio + +Wistleblower + +From: Chris Dilorio ‹ > + +Sent: Wednesda June 10 2020 2:30 PM + +T + +Su ject: Fw: Forma appea or preliminary enia covere action 15-016/ Knight Capital TCR & Appendix + +Mr Roach, + +The SEC is irrefutably using my information in unethical and illegal manner. My information is being used to BOTH Bring complaints AND obstruct/protect investigations into entities detailed in my various TCR's. Denying me rightful compensation. This is the latest example + +Chris + +From: Chris Dilorio ‹ > + +Sent: Monday. May 18. 2020 10:36 AM + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +As straightforward as it gets: + +The SEC OWB dragged its feet for 5 years in issuing its preliminary denial notice. + +The SEC knows this is my information. The SEC committed fraud on the court in Gibraltar. The judge corrected them. The SEC was omitting information that implicated NITE, UBSS and customers like Sason/Hanover/Magna. The SEC was obstructing a thorough investigation of my claims. The naked shorting cited in the CGFIA 10O in 2013 PROVES my allegations. The SEC's "targeted investigation" stops short of a full accounting. The SEC Gibraltar complaint does NOT explain the totality of the Oppenheimer complaint. The SEC Gibralter complaint cites 1 OTCM shell and less than 1 million shares traded by Opco. 2 dissenting Opco waiver SEC Commissioners proved that also citing "BILLIONS" of shares in their dissent. The SEC/Opco AML complaint was based on the FINRA complaint and my information. The SEC OWB concocted a completely fabricated reason for denying my + +Award: "The SEC investigators involved never saw claimants information". The responsibility to distribute Whistleblower information within the SEC is the exclusive and explicit responsibility of the OWB. As a result, the massive fraud taking place continued well into 2020. The 1Q2020 10O proves this. + +The SEC IG Hoecker is guilty of violating specific IG requirements in keeping Congress informed of serious matters like mine. The SEC IG Hoecker has never interviewed me despite my filing 2 separate complaints with his office. The SEC IG Hoecker is guilty of criminal obstruction. SEC Chair Clayton and Co Enforcement Peikin worked at Sullivan Cromwell with Jared Fishman. Fishman has played a key role in the SEC facilitated criminal obstruction. Peikin and Clayton should have recused themselves from ANY pending NITE/VIRT matter before the SEC: My information. Clayton and Peikin should have recused themselves from the SEC facilitated KCG/VIRT merger. My information, including the Opco AML complaint SHOULD have stopped the merger from ever happening. 2 former SEC Commissioners agree with that analysis. The SEC is actively facilitating a massive ,ongoing fraud on the American people they are mandated to protect. NITE/VIRT is a criminal entity. The SEC MUST invoke emergency powers and halt trading in VIRT IMMEDIATELY. + +In short Mr Arp, the criminal activity actively perpetrated by the SEC OWB/IG must be referred to law enforcement as well as Congress. Separate but related: SEC facilitated criminal activity and my claims. The criminality is a matter for law enforcement. My pending matters with the SEC have no bearing on a criminal investigation OR a GAO investigation. + +You are incorrect in your analysis. + +I Urge the IG Integrity Board to have SEC IG Hoecker refute my claims point by point. + +I will be on a plane tomorrow so he can do it in person. + +Cheers! + +Christopher.' Dilorio + +Whistleblower + +From: Chris Dilorio < + +Sent: Tuesday, May 12, 2020 8:54 AM + +To: + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +Almost immediately I filed a formal appeal to the SEC OWB fabricated denial of my award application. In this appeal I show irrefutable proof of my allegations: The SEC OWB used/ is using my information to both bring complaints AND obstruct complaints while denying me compensation. In short: My information exposes an ongoing, massive in scope, SEC facilitated fraud on the American people. Rather than shut it down, the SEC has chosen to cover up so that the illegal activity can continue. It does in 2020 + +Chris + +From: Chris Dilorio < + +Sent: Monda , Ma 11, 2020 7:16 PM + +From: Chris Dilorio + +Sent: Wednesday. Aoril 29 2020 8:03 AM + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +The SMOKING GUN in my allegations: + +Naked shorting in CGFIA (My TCR/FINRA complaint) by "un named third party BD" in 2013. Well known to the SEC. This is why there was no investigation into the ENTIRETY of the FINRA trading activity. The SEC issued waivers to Opco within days of its AML complaint. WHO was the SEC protecting? WHO were the customers and executing BD's/MM's in the Opco complaint? ALSO well known to the SEC: + +MY INFORMATION. 5 years to get a preliminary denial: statute of limitations. BUT the last overt act of this ongoing conspiracy has not yet occurred. + +Chris + +From: Chris Dilorio < + +Cant- 1A/adnacrinu Anril 10 .3m3n 7.56 AM + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +Still more evidence of a well orchestrated scheme to cover up and obstruct a FULL SEC investigation into Opco/Gibraltar/NITE/UBSS trading activity in billions of shares of OTCM money laundering shells. The SEC used my information to bring AND obstruct complaints. + +The 2 SEC Commissioners dissent in granting Oppenheimer waivers after this egregious activity https://www.sec.gov/news/statement/dissenting-statement-oppenheimer-inc.html + +### SEC.gov I Dissenting Statement In the Matter of Oppenheimer & Co., Inc. + +Dissenting Statement In the Matter of Oppenheimer & Co., Inc., by Commissioner Luis A. Aguilar and Commissioner Kara M. Stein, February 4, 2015 + +www.sec.gov + +In fact, the SEC waivers came within days of their complaint. Here, these 2 Commissioners cite Oppenheimer trading "BILLIONS of shares of penny stocks". Clearly, they were not JUST referencing the SEC Gibraltar complaint. WHO was the SEC protecting with its complaint then waivers? + +Indicate by check mark whether the registrant (1) has filed all reports required to be filed by Section 13 or 15(d) of the Securities Exchange Act of 1934 during the preceding 12 months (or for such shorter period that the registrant was required to file such reports), and (2) has been subject to such filing requirements for the past 90 days. + +www.sec.gov + +pg 27 + +"Our stock is subject to a "Global Lock" imposed by the Depository Trust and Clearing Corporation (DTCC)" "On September 24, 2013, we were notified that the DTCC would be placing a 'Global Lock" on the Company's Class A stock as a result of actions by a third-party broker dealer. On November 11 2013, DTCC imposed the "Global Lock". Since less than 0.02% of the Company's Class A common stock shares were held within DTCC, Management chose to not undertake the expense of challenging the Global Lock. Nevertheless, shares that are held in street name (CEDE & CO), will not be able to be withdrawn from DTCC without further action." + +Of Course, I have hard copies if you prefer. + +ex clearing: The illegal SEC/DTCC Obligation Warehouse. + +This is CLEAR,IREEFUTABLE,INCONTROVETIBLE evidence of naked shorting by executing BD's in CGFIA. This activity took place per my Knight/UBSS TCR submitted to the SEC. So, WHY did the SEC obstruct an investigation into the ENTIRETY of the trading activity in the FINRA (and FINCEN) complaints? WHO were the executing BD's/MM's? WHO were the customers? + +The veracity of my information is also irrefutable and incontrovertible. + +Game. Set. Match. The SEC is a grossly corrupt, criminal enterprise facilitating illegal activity detailed by me so that this activity can continue. It does in 2020. The SEC solicits then uses Whistleblower information (MINE) to bring complaints AND obstruct other illegal activity while denying proper compensation to whistleblowers (ME). The SEC KNEW who the "third party BD" was in the CGFIA filing long before it filed its Opco complaint in 2015. It had my TCR in its possession in March 2013. So why did it take 5 years for the SEC to issue its preliminary + +denial? I would remind the SEC that this is very much an ONGOING conspiracy on the part of the SEC et al. IN FURTHERANCE OF THE CONSPIRACY + +Cheers! + +Christopher Dilorio + +Whistleblower + +From: Chris Dilorio + +Sent: Tuesday, April 28, 2020 7:24 AM + +Per my extensive SEC TCR's: Josh Sason/Emanuel/Abitebol/Hanover/Magna extensive overlap with NITE/VIRT (and AQR) money laundering shells. + +The SEC Sason/Magna/NewLead Feb 2019 complaint: also my information + +https://www.sec.gov/litigation/complaints/2019/comp24403.pdf + +### Marc P Berger SECURITIES AND EXCHANGE COMMISSION Brookfield Place 200 Vesey Street, Suite 400 New York, NY 10281-1022 SOUTHERN DISTRICT OF NEW YORK JOSHUA SASON, MARC MANUEL, + +3 S. In addition, Pallas acted as an underwriter for a primary offering of NewLead stock, which NewLead attempted to disguise as an asset sale transaction. + +gov + +https://www.sec.gov/Archives/edgar/data/ 1322587/000114420413065095/v361773 scl3g.htin + +### www.sec.gov + +(i) Sole power to vote or to direct the vote . The information required by Item 4(c)(i) is set forth in Row S of the cover page for each Reporting Person hereto and is incorporated by reference for each such Reporting Person. + +www.sec.gov + +MG Partners Ltd: Abitebol + +But not in the complaint: MAGNA GIBRALTAR INVESTMENTS LLC: also Abitebol + +As with Opco/GIBRALTAR, who is the SEC protecting? + +AND, per my extensive correspondence with the SEC re my TCR's: The SEC is ALSO grossly under estimating the criminal activity in NITE/Magna/NewLead + +SEC: Criminals bailing out/actively facilitating criminals/criminal activity. + +soliciting/using whistleblower information in unethical/illegal manner to bring complaints/obstruct complaints/deny whistleblower rightful compensation. + +Cheers! + +Christopher.' Dilorio + +Whistleblower + +From: Chris Dilorio + +Sen • Tuesday\_Aorit28\_2020 6.43 AM + +More evidence of SEC fraud on the court in Gibraltar. + +It is CLEAR that the Opco AML Covered Action 2015-016 was NOT ENTIRELY based on the SEC Gibraltar Action. The SEC Gibraltar action covered trading activity in just 1 OTCM Money laundering shell: Magnum d'Or where Opco traded less than 1 million shares. CLEARLY the SEC Opco complaint was based on the trading activity in the FINRA Opco AML complaint: my information. However, the SEC Opco complaint even stops short of a thorough investigation of the ENTIRETY of the FINRA trading activity. WHY? WHY didn't the SEC Opco/Gibraltar complaint go into trading activity in the FINRA AML OTCM shells through 2014 as FINCEN did? WHY did the SEC omit MATERIAL information to the court in Gibraltar causing a "significant under estimating" of criminal activity? The SEC knows who the accounts were. The SEC knows who the executing BD's/MM's were. The SEC committed a fraud on the court in Gibraltar. + +Gibraltar was ROLLING OUT NEW OTCM services into the end of 2011. + +https://www.prcom/press-release/355246 + +# Gibraltar Global Securities Now Offering Offshore Brokerage Accounts - PR.com + +Nassau, Bahamas, The, September 22, 2011 --0-- Gibraltar Global Securities is now offering offshore brokerage accounts in addition to their broad array of financial services.Gibraltar Global ... + +www.pr.com + +https://www.pr.com/press-release/355247 + +# GGSI Bahamas is Now Offering Pink Sheet Clearance + +Offshore Broker Adds to Buying and Selling Services + +www.pr.com + +https://www.prcom/press-release/369649 + +# GGSI Bahamas Provides State-of-the-Art Security for OTC PINK Transactions and Communication + +GGSI (Gibraltar Global Securities Inc.) has just announced the release of their latest security measures designed to protect their client's personal data, and to secure electronic communication. + +www.pr.com + +The SEC KNEW the Gibraltar/Opco trading activity went well beyond 2011 YET cut off its investigation at "well into 2010". Thus, KNOWINGLY omitting material information in Gibraltar: FRAUD ON THE COURT. + +Confirming my allegations of SEC criminal activity in handling my information. WHY? to protect NITE and UBSS. 2 criminal entities bailed out by the SEC. + +Now, the SEC is using the completely fabricated reason for denying my award claim for covered action 2015- 016: "The investigators never saw the claimants information". + +WHEN the explicit and exclusive responsibility to distribute whistleblower information within the SEC falls on the OWB itself. + +More criminal activity. + +Criminals bailing out criminals while denying Whistleblowers due process and compensation. + +Cheers! + +Christopher Dilorio + +Whistleblower + +From: Chris Dilorio + +Se + +To + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +From: Chris Dilorio < + +Sent: Friday, April 24, 2020 8:18 AM + +Subject: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +I am in receipt of the SEC preliminary denial of my award claim for the Oppenheimer AML covered action 2015- 016 + +This is my formal appeal of the SEC preliminary determination. + +My award application was based on this very simple FACT: + +The SEC (and FINCEN) Oppenheimer AML actions were based on the FINRA Oppenheimer AML action + +FINRA + +https://www.finra.org/sites/default/files/fda documents/2009018668801 FDA KMX39652.pdf + +### of - FINRA + +which isFINRA a party, to the entry of findings and violations consistent with the allegations of the (asComplaint sanctions amended andby the Offer of Settlement), to the imposition of the set forth andbelow, understands fully that this Order will become part ofRespondent's permanent disciplinary andrecord may anybe considered in future actions brought by FINRA. BACKGROUND ... + +www.finra.org + +The SEC + +https://www.sec.gov/litigation/admin/2015/33-9711.pdf + +Before the . SECURITIES AND EXCHANGE COMMISSION . SECURITIES ACT OF 1933 . Release No. 9711 / January 27, 2015 . SECURITIES EXCHANGE ACT O F 1934 . Release No. 74141 / January 27, 2015 . ACCOUNTING AND AUDITING ENFORCEMENT . Release No. 3621 / January 27, 2015 . ADMINISTRATIVE PROCEEDING . File No. 3 -16361 . In the Matter of + +www.sec.gov + +#### FINCEN + +https://www.fincen.govinews/news-releases/fincen-fines-oppenheimer-co-inc-20-million-continued-antimoney-laundering + +# FinCEN Fines Oppenheimer & Co. Inc. \$20 Million for Continued Anti— Money Laundering Shortfalls I FinCEN.gov + +Washington, D.C. — The Financial Crimes Enforcement Network (FinCEN), working closely with the U.S. Securities and Exchange Commission (SEC), assessed a \$20 million civil money penalty today against Oppenheimer & Co., Inc., for willfully violating the Bank Secrecy Act (BSA). Oppenheimer, a securities broker-dealer in New York, admitted that it failed to establish and implement an adequate ... + +www.fincen.gov + +In the summer of 2012, I had extensive correspondence with Robin Traxler at FINRA where I also cc'd Sean McKessy then SEC OWB Chief. The CURRENT OWB Chief and the SEC IG are in possession of this correspondence. My correspondence dealt with 2 penny stock shells cited in my Knight Capital TCR submitted by Berger Montague in March 2013 attached here: Colorado Goldfields and AppTech. Both shells were NITE and UBSS top traded OTCM shells in 2010-2013. These 2 shells were cited by FINRA in their Oppenheimer AML complaint. Again, the SEC and FINCEN Oppenheimer AML complaints were based on this FINRA complaint. In fact, per the FINRA Opco complaint above, customer "TC" was dumping worthless AppTech (APCX) certificates well into mid 2010. DIRECTLY overlapping with the NITE/UBSS APCX trading activity cited in my Berger 2013 TCR attached and discussed by me with Robin Traxler at FINRA. HOW is it possible that the SEC OWB didn't share my information with SEC investigators? Current SEC OWB Chief Norberg was previously an assistant to then OWB Chief McKessy. + +WHO ultimately executed the trades cited in the FINRA Opco complaint? + +Further, the SEC Gibraltar Securities complaint raises more questions than answers as well. + +https://www.sec.gov/litigation/complaints/2013/comp22683.pdf + +# UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK SECURITIES AND EXCHANGE COMMISSION, 13 Civ. GffiRALTAR GLOBAL SECURITIES, COMPLAINT NATURE OF THE ACTION - SEC.gov + +12. David Della Sciucca, Jr., age 27, is a resident of Fort Lauderdale, Florida. In . the Magnum d'Or complaint, the Commission charged Della Sciucca with acting as a nominee + +vAyw.secgov + +The SEC Gibraltar Securities complaint references only 1 OTCM money laundering shell: Magnum d'Or. The complaint specifically states that Oppenheimer sold just 969,822 shares. Again, no mention of executing BD/MM. + +The SEC Oppenheimer AML cites Gibraltar trading activity also. + +The share amounts in the SEC complaint grossly under estimate that in the FINRA complaint. WHY? + +The judge in the Gibraltar case said "the SEC's requested amount CLEARLY UNDERESTIMATES the defendants illgotten gains...." + +http://www.tribune242.com/news/2016/jan/13/bahamian-broker-25m-sanction/ + +# Bahamian broker in \$25m sanction I The Tribune + +A former Bahamian broker/dealer and its principal have been hit with a combined \$24.484 million in financial sanctions by a US court, which found that their "ill gotten gains" were likely ... + +www.tribune242.com + +WHY didn't the SEC go after ALL of the sellers in the FINRA Opco AML complaint? WHY did the SEC "strip out" \$46 million from the Gibraltar ill gotten gains claiming the customers were "UNKNOWN"? WHO is the SEC protecting? WHO were the executing BD's/MM's in the FINRA Opco CGFIA and APCX trades? They certainly know who the customers were. Is customer "JK" Justin Keener/JMJ also in my March 2013 TCR attached? While the SEC Opco AML was based on the FINRA Opco AML, it stopped short of a thorough investigation of NITE and UBSS. In fact, the trading activity of NITE/VIRT and UBSS in the FINRA complaint: my information SHOULD have triggered an immediate investigation of NITE and UBSS. It did not. Did the SEC commit fraud on the court in its OMISSION of material information? + +The timing of the SEC's preliminary determination and the reasoning for the denial ALSO raises more questions than answers. + +My Award application for the Oppenheimer AML SEC complaint was 5 years ago. That's FIVE years ago. So, WHY NOW am I so blessed by the SEC with a preliminary judgement? + +The SEC basis for denying my Award claim for covered action 2015-016: + +"Investigative staff responsible for the covered action NEVER RECEIVED ANY INFORMATION FROM THE CLAIMANT OR had any communication with the claimant" + +First, the SEC OWB denied my Award application because The investigators in the complaint never received my information. Has the SEC OWB re written the investigative protocol in this denial? How am I or ANY whistleblower supposed to know WHO the investigators are in a particular case WHEN according to the SEC: ALL investigations are done in a confidential manner???? + +WHAT DOES THE SEC DO WITH WHISTLEBLOWER TIPS EXACTLY? Do they share whistleblower information with ENFORCEMENT as is mandated? HOW would ANY whistleblower know WHO to share information with at the SEC? Isn't that the job of the SEC OWB? + +Second, the fact that no one at the SEC contacted me DOES NOT mean the SEC didn't use my information. This is a completely bogus argument. It certainly would NOT be the first time the SEC used my information now would it Jane? + +In fact, it is NOT the responsibility of the whistleblower to get his/her information to the right Enforcement personnel. That responsibility EXPLICITLY falls on the SEC OWB. So, is the SEC OWB admitting gross negligence in handling my information? After the monumental failure in the Madoff Ponzi/ money laundering SEC facilitated scam on the public the then SEC IG made specific recommendations to the SEC with regards to the proper handling/vetting of Tips and Complaints. + +https://www.sec.gov/files/468.pdf + +# Review and Analysis of OCIE Examinations of Bernard L. Madoff Investment Securities, LLC + +Review and Analysis of ODE Examinations of Bernard L. Madoff Investment Securities, LLC Executive Summary Background. On June 25, 2009, the Securities and Exchange Commission's + +VA.:W.sec cloy + +AGAIN: The responsibility to properly vet Whistleblower information and get the information into the right hands at the SEC falls EXPLICITLY and EXCLUSIVELY with the SEC OWB itself and is NOT the responsibility of the whistleblower. Further, according to the previous SEC IG in the monumental Madoff failure: the responsibility to contact those supplying Tips and Complaints ALSO falls explicitly and exclusively with the SEC OWB and not the whistleblower. Using these excuses as the basis of denial of Award is completely contrary to SEC MANDATED protocols and procedures. + +Is the SEC OWB admitting it doesn't comply with those recommendations? Recall: the monumental SEC Madoff failure was NOT the fault of Whistleblowers either. OR is the SEC OWB scrambling for a 5 years in the waiting preliminary determination? + +So, after 5 years of waiting for a preliminary determination for my award claim, this is what the SEC best and brightest come up with? + +My Denial of Award for covered action 2015-016 was completely made up on the fly. + +The SEC OWB has applied completely fabricated "rules" to issue this denial. Further affirmation of ALL of my allegations. + +Also by SEC admission, the SEC allowed these 2 penny stock shells to remain a clear and present risk to the investing public. Were CGFIA and APCX ONLY money laundering shells for Oppenheimer in 2008-2010 and then suddenly they were no longer money laundering shells when NITE and UBSS traded billions of shares of both shells 2010-2013? + +WHY did it take until September 2018 before the SEC finally revoked the CGFIA registration? + +https://www.sec.govicgi-bin/browse-edgar?company.Garpa&owner=exclude&action=getcompany + +So, WHY was there no SEC investigation of NITE and UBSS trading activity in money laundering shells APCX and CGFIA? The SEC et al facilitated NITE "glitch" took place in August 2012. This SEC/Jefferies/JPM/BX/GS/SEC Chair Clayton Sullivan Cromwell colleague Jared Fishman et al bailout coincides directly with NITE trading activity in 2 SEC/FINFtA/FINCEN acknowledged money laundering shells. AND the "bailout" penny stock esque reverse merger between Getco and Knight didn't close until July 2013. HOW could the SEC conduct a COMPLETE and thorough investigation into the FINRA Opco AML complaint WITHOUT implicating NITE when NITE was CLEARLY trading billions of shares of OTCM money laundering shells BEFORE and coinciding with the SEC et al facilitated "glitch" bailout? For UBSS, the DOJ dropped its cross border AML DPA complaint in 2010. UBSS was trading money laundering shells well after the DOJ claimed UBSS was in compliance with the cross border DPA. To be clear: BOTH NITE and UBSS knew CGFIA and APCX were money laundering shells when they traded billions of shares of each 2010-2013. Is that FACT disputed by the SEC? The SEC OBSTRUCTED a thorough investigation into the ENTIRETY of trading activity of NITE and UBSS in CGFIA and APCX: MY CLAIMS. Josh Sason/Hanover/ Magna knew CGFIA was a money laundering shell also + +https://www.sec.gov/Archives/edgar/data/1344394/000114420413041432/0001144204-13-041432-index.htm + +ALSO in my claims: Joshua Sason/Hanover Magna. CGFIA. Also my NewLead TCR1426518350699 and FreeSeas TCR1440274395191 separate but related TCR's where NITE was a top trader in both and BOTH TCR's were filed well in advance (years prior) to the Sason/Hanover/Magna February 2019 complaint. Here's one thing the SEC has been consistent about: The SEC ignores the role of executing BD's and MM's in these scams. WHY? Because NITE is the #1 OTCM shell trader. As far as the SEC is concerned Penny stock trading fairies convert worthless certificates into real money. NOI Executing BD's/MM's like NITE do. Did Oppenheimer sell this order flow to NITE? Who ultimately converted these worthless certificates to real money? As the number 1 OTCM money laundering shell trader it is statistically improbable the NITE has never been the focus of an SEC AML complaint. Per my TCR: what does the NITE Compliance Department do exactly? How many SAR's has NITE filed in the last 10 years? In a 2015 SIFMA speech then SEC Enforcement Director Ceresney was "SHOCKED" by the number of BD's filing 1 or ZERO SAR's. That was just 5 years ago. WHEN would NITE file a SAR releted to the billions of shares of OTCM money laundering shells it trades like CGFIA and APCX: BEFORE or AFTER it trades those BILLIONS of shares?Does NITE pull markets and alert regulators OR continue to trade billions of shares of OTCM money laundering shells in the face of GLARING AML red flags? In fact, in December 2019 the top traded NITE/VIRT OTCM money laundering shell was ELTZ + +https://www.sec.gov/cgi-bin/browse-edgar? + +action=getcompany&CIK=0001607281&ownerrexclude&count=40&hidefilings=0 + +The SEC knows the people/entities in ELTZ well + +https://www.sec.gov/litigation/admin/34-46993.htm + +# Strata Coal Company and Terrence A. Tecco: Admin. Proc. Rel. No. 34- 46993 / December 13, 2002 + +Strata Coal Company ("Strata" or "the company") is a non-reporting Nevada shell corporation based in Frisco, Texas. Strata's shares are quoted on the Pink Sheets under the symbol SCOC. Until September 2002, the company was known as WesPac Technologies, at which time it changed its name to Strata. 2. Tecco is the sole officer, director, and ... + +www.sec.gov + +# SEC.gov I SEC Charges Broker-Dealer and Transfer Agent in Microcap Shell Factory Fraud + +The Securities and Exchange Commission today announced charges against a broker-dealer, a transfer agent, and three individuals for their roles in the creation of over a dozen undisclosed "blank check" companies from 2009 to 2014. + +vii.vw.sec gov + +Doesn't the NITE/VIRT compliance Department have internet service in Jersey City? As a DIRECT result of the SEC obstructing a complete and thorough investigation into the ENTIRETY of trading activity in APCX and CGFIA, the top NITE/VIRT traded OTCM money laundering shell in December 2019 was AML red flags galore ELTZ. Illegal activity ACTIVELY facilitated by the SEC. The examples cited in this e mail are not exhaustive. + +And, for it's part AppTech is up and running again/still + +https://www.sec.gov/cgi-bin/browse-edgar?company=Apptech&owner=exclude&action=getcompany + +Unfortunately, AppTech is still up and running as a direct result of the aforementioned SEC " CLEARLY under estimating" otherwise known as CLEARLY OBSTRUCTING. + +In conclusion, The SEC solicits information from whistleblowers like me. The SEC uses whistleblower information to bring actions and then doesn't compensate whistleblowers for their information. + +OR + +The SEC uses whistleblower information to protect criminality perpetrated on the investing public so that this criminal activity can continue. BOTH are gross dereliction of the stated and MANDATED SEC Whistleblower statutes. To blame a whistleblower for the SEC's EXPLICIT and EXCLUSIVE responsibility to properly vet and distribute whistleblower information within the SEC as an excuse to deny Awards is also criminal activity. The SEC: criminals using whistleblower information to protect other criminals AND deny whistleblower rightful compensation for their information. + +I appeal the SEC preliminary determination and wish to file ANOTHER complaint with the SEC IG. + +Cheers! + +Christopher J Dilorio + +Janey, + +how long have you been in possession of my Knight Capital TCR? Almost 7 years to the day. How many follow up e mails have I sent the SEC since then? + +For 7 fucking years, the SEC has known about JMJ/Keener. I told them + +https://www.sec.gov/litigation/complaints/2020/comp-pr2020-72.pdf + +## IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORIDA SECURITIES AND EXCHANGE COMMISSION No. COMPLAINT SUMMARY - sec.gov + +5. Justin W. Keener, age 45, resides in San Juan, Puerto Rico.During the Relevant Period, Keener was a resident of Miami Beach, Florida. Keener registered the name "JMJ Financial" as a fictitious name in Florida in 2008 and used it to conduct the business described + +w.sec.gov + +In February 2019, the SEC brought an action against Joshua Sason/NewLead + +I told the SEC about Magna/ Sason ALSO in my 2013 TCR. + +https://www.sec.gov/litigation/litreleases/2019/Ir24403.htm + +Joshua Sason, et al. (Release No. LR-24403; Feb. 15, 2019) + +Washington, D.C., February 15, 2019 - The Securities and Exchange Commission today announced charges against four individuals and related businesses for their roles in two microcap frauds and unlawful securities offerings. + +vo.vw.sec.gov + +AND, I filed separate but related NewLead and FreeSeas TCR's in 2015 + +Then there's the UBS AML complaint. + +ALSO my claims. For which I sent 10 (TEN) separate Award applications from a commercial fax machine in + +April/May 2019. AND I have YET to receive even a preliminary determination from the OWB/Norberg + +IG, I see your "investigation" into my very very serious accusations of Obstruction related to my information was thorough. In short, the SEC has and still is ripping me off. + +Janey, be a hun and update my TCR's/Awards cited in this e mail. + +And Ms Welshhans, a couple of questions for you: + +1) Have you read the FINRA WTFC Keener complaint? Fictitious notes Ring a bell? + +Same MO as Sason/Magna/NewLead/FreeSeas etc etc etc + +2) WHO executed the Keener OTCM trades in your complaint? Penny stock trading fairies? + +YES, NITE was a top trader in BOTH FreeSeas and NewLead + +The core business at NITE/VIRT is and ALWAYS has been: abusive naked shorting OTCM (and other) shells to facilitate money laundering. + +In short Ms Welshhans, NITE/VIRT converts these worthless certs into real money. NONE of + +JMJ/Sason/IBC/Ironridge/Asher etc etc etc activity takes place without a willing,corrupt, criminal, executing BD/MM like NITE/VIRT, CDEL etc + +Finally, The Keener SEC complaint is FURTHER evidence that FINRA has NO business enforcing US securities LAWS. When FINRA "invited" Keener to a disciplinary hearing almost 7 years ago, Keener told them to "fuck off". FINRA bar meant nothing the last 7 years. EXCEPT JMJ/Keener/NITE ripping off more investors. + +Obviously the SEC has/is using my information. I expect to be compensated. + +Mr Peirce, + +Congratulations on your nomination as SEC Commissioner. I have read your paper on FINRA lack of accountability. I believe the SEC has abdicated its responsibility to enforce Broker Dealer compliance with the BSA to FINRA BECAUSE it is not accountable. The SEC has not initiated a single stand alone AML complaint. The Brown Brothers Harriman AML complaint IS my claim. ALL of the entities in the complaint are un named WHY? My SEC and IRS Whistleblower complaints explain why. + +Hello, My name is Chris Dilorio. I have filed extensive SEC and IRS Whistleblower complaints alleging a direct link between penny stock money laundering, domestic and foreign entities, Swiss Banks, and executing brokers like KCG and UBS. I can provide overwhelming evidence of SEC obstruction. Please read the FINRA Brown Brothers Harriman AML complaint. This is my claim. All of the entities in the complaint are un named. Why? The SEC is not only obstructing an investigation, they are aiding and abetting the activity. These are not far flung theories. The UBS Whistleblower Birkenfeld and his attorney sent 52,000 accounts to the SEC and DOJ. The DOJ at the influence of President Obama and Hillary Clinton entered into the UBS DPA based on just 4400. What is so egregious is the activity continues un abated today. + +Start with the so calledAugust 2012 Knight/KCG trading "glitch". Initial reports say the NYSE was breaking the trades. WHY did they stop. Former KCG CEO Joyce said he had a very frank discussion with then SEC Chair Schapiro where the SEC wanted to send a very strong message to market participants. Why not just continue to break the trades and hit KCG with a hefty fine? That would not create the conditions to grant KCG exception after exception to do their emergency funding which transferred 74% of the company to "glitch" funding participants and ultimate reverse merger partner GETCO. AND, despite claiming to having a "highly liquid balance sheet" KCG had to raise the entire amount of the loss. + +A very significant and public event was cited in a WSJ article where immediately following the "glitch"KCG inadvertently sent 4000 worthless securities to JPM in an attempt to secure a tri party financing where JPM guaranteed the loan. This is discussed in my attached TCR's and also the topic in a March 2014 letter I sent to the SEC. In the end, the emergency funding was NOT collateral based. The participants knew exactly what a fraud the KCG balance sheet was. After the stock was decimated to \$3, the deal was a convertible with a conversion price at a 50% discount or \$1.50/ share. + +There is much more, but this is a good start. + +Recently, KCG did a modified Dutch auction where they "sold" an asset (HotSpot) to an entity both KCG and GETCO were a major shareholder (BATS) KCG CEO Coleman called it a "highly competitive process". + +Virtually all of the proceeds went to buy back stock from "glitch" financing participants. The purchase price was \$14/share. The stock had never traded there and hasn't since. Reports say 82 million shares were tendered at or BELOW \$14. But they chose to repurchase 23 million shares AT \$1477999 I have overwhelming evidence that supports my allegations that the SEC is engaging in criminal obstruction to protect KCG. + +I) Current KCG Dan Coleman ran Equities at UBS during the massive REG Sho violations as well as the cross border activity detailed by Whistleblower Birkenfeld. White and Ceresney represented UBS prior to joining the SEC + +2) At June 30 2011 KCG/Knight reported just 105 million in working capital with hundreds of millions in worthless securities sitting on its balance sheet. KCG was insolvent + +3) The SEC orchestrated the emergency funding for KCG following the so called Aug 2012 trading "glitch" + +4) Read FINRA AML complaints against Brown Brothers Harriman. This is my claim. It links penny stock money laundering to executing brokers like KCG, domestic and foreign entities, and Swiss banks. ALL of the entities in the complaint are un named. WHY? + +5) The FINRA World Trade Financial AML complaint discusses several entities cited in my claims. The customer the complaint focuses on is Justin Keener. Still very much in business. The red flags cited by FINRA were cited in my claims as well. Yet still no investigation. + +6) in July 2015 I contacted Kevin Goodman Dir OCIE for Broker Dealrsat the SEC. He had never seen my information. The IG OCIE Madoff report mandated the OCIE to vet information. McKessy and Ceresney never sent my info to him + +7) I'm sure you are familiar with the Manning v Merrill,KCG,UBS et al litigation. The SEC does not want an investigation into my claims while the litigation is pending. + +8) My claims detail ex clearing trading activity by KCG and UBS. despite the glaring red flags in doing so. Ex clearing s the Obligation Warehouse. A NON GUARANTEED SERVICE set up by the SEC and DTCC to allow firms like KCG to circumvent close out requirements of Rule 204. Clearly contrary to the intent of the SEC authorization in Sec I7a of the 1934 Act to create a system of prompt and timely settlement and to remove impediments there of. + +In short, I told the SEC KCG was insolvent in 2011. Rather than investigate and prosecute, they chose to obstruct. The activity in my TCR's pre dates the "glitch". An investigation would show the SEC bailed out a criminal enterprise. Because of the obstruction, the activity continues today unabated in stocks like STBV,VELA,NEWL,FREE, and dozens more. 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b/marker2/ds9/EFTA00089598/EFTA00089598.md @@ -0,0 +1,65 @@ +From: ' (USANYS)" <1 + +To: (USANYS)" + +Subject: Re: Report + +Date: Thu, 10 Sep 2020 20:47:25 +0000 + +Otherwise we have to produce the draft. Which we may have to produce regardless. + +Sent from my iPhone + +On Sep 10, 2020, at 4:20 PM, (USANYS) > wrote: + +Think we should push for this? + +Sent: TillaMber 10, 2020 10:31 AM + +From: OIG) 1 M> + +To: (USANYS) (USANYS) + +Subject: Fwd: Report + +GM + +Please see below. If you have any issues obtaining report directly, as instructed, please let me know and I will have HQ make request. Thx, + +Sent from my iPhone + +Begin forwarded message: + +From: + +Date: September 10, 2020 at 10:07:42 AM EDT + +To: "Dan Omar D. CMG " + +Cc: + +Subject: Re: Report + +We would be more comfortable with a formal request directly from an AUSA. You are welcome to share my contact information with anyone who asks you about this. + +Thanks, + +>» OIG)" < > 9/9/2020 5:25 PM >» + +Hi + +Thank you for your response. Yes, AUSAs from the SDNY are requesting report in relation to the prosecution of COs charged in case. + +Sent from my iPhone + +On Sep 9, 2020, at 5:05 PM, > wrote: + +Hi there, + +I am the Senior Deputy Assistant Director of the Reentry Services Division over at BOP. I received word from my staff that you were seeking a copy of a report on inmate Epstein. They shared you intended to distribute the report to AUSAs. Can you give me a little more information about this request? I have copied the Deputy General Counsel as well. + +Thank you, + +Senior Deputy Assistant Director Reentry Services Division Federal Bureau of Prisons + +Washington, DC 20534 Office: Fax: \ No newline at end of file diff --git a/marker2/ds9/EFTA00089598/EFTA00089598.metadata.json b/marker2/ds9/EFTA00089598/EFTA00089598.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..fa301c0c768a3484431d6617a9702b63f75fa957 --- /dev/null +++ b/marker2/ds9/EFTA00089598/EFTA00089598.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089598.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 1562, + "elapsed_seconds": 1.29, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 67 + ], + [ + "Line", + 32 + ], + [ + "Text", + 26 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 33 + ], + [ + "Line", + 17 + ], + [ + "Text", + 8 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089598" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089600/EFTA00089600.md b/marker2/ds9/EFTA00089600/EFTA00089600.md new file mode 100644 index 0000000000000000000000000000000000000000..8e44ea533a9243ea97a53879d8c2ec7251494930 --- /dev/null +++ b/marker2/ds9/EFTA00089600/EFTA00089600.md @@ -0,0 +1,75 @@ +To + +Cc + +Subject: RE: Fwd (TEL) Prosecutors in Ghislaine Maxwell Case Ask for Halt to Civil Proceed + +Date: Sat, 12 Sep 2020 00:18:12 +0000 + +Attachments: 2020.09.04\_Govemment\_letter\_in\_support\_of stay.pdf + +The letter was publicly filed on the docket in the civil case, per Judge Freeman's order. The version from ECF is attached. + +From: (USANYS) [Contractor) + +Sent: n a , e • tem r 11, 2020 3:11 PM + +To: + +(USANYS) + +(USANYS) + +Cc: (USANYS) + +Subject: FW: Fwd (TEL) Prosecutors in Ghislaine Maxwell Case Ask for Halt to Civil Proceed + +Here's the Telegraph story that quotes from the letter. + +From: + +Sent: Friday, September 11, 2020 3:06 PM + +To: + +Subject: w L rosecutors m 'same axwe ase s or a t toCivil Procee + +This is the Telegraph story... + +Prosecutors in Ghislaine Maxwell Case Ask for Halt to Civil Proceedings Against British Heiress 2020-09-11 18:16:21.827 GMT + +By Josie Ensor + +(Telegraph) -- Federal prosecutors pursuing child sex trafficking charges against Ghislaine Maxwell say their case would be jeopardised if a separate civil lawsuit against the heiress was allowed to continue, in an extraordinary appeal to the judge. + +Prosecutors from the Southern District of New York (SDNY) have argued that there is a "factual overlap between the civil and criminal cases" and there was "significant risk" that proceeding with the civil suit jeopardises the criminal prosecution against Ms Maxwell. + +The civil suit, filed earlier this year under the pseudonym Jane Doe, contains allegations that are substantially similar to those in the criminal indictment against Ms Maxwell, who allegedly groomed three minor girls to be abused by Epstein in the mid-1990s. + +Ms Maxwell, 58, who is being detained in a federal prison in Brooklyn until her trial next year, has pleaded not guilty to the charges and has denied the allegations in the civil suit. + +The woman, now 40, alleges that she was first approached at age 13 by Epstein and Ms Maxwell in 1994 at a summer camp in Michigan and that a months-long grooming process by the pair continued after she returned home to Florida. + +She claims she was then subjected to years of sexual abuse. + +"Witnesses may be forced to testify about any efforts to assist the criminal investigation and prosecution, and may thereby expose facts about the investigation ... and could potentially expose witnesses and/or their families to harassment," states the SDNY's letter filed on Thursday. + +"Moreover, permitting any discovery to proceed in this lawsuit would enable Maxwell to seek a preview of trial testimony in the criminal case, and would afford her with a broader array of discovery than she is entitled to in the criminal case." + +By advocating for a stay in the civil case, the government finds itself, in this instance, aligned with Ms Maxwell and the co-executors of Epstein's estate, who have been arguing that the case should be placed on hold while criminal investigation remains open. + +The disgraced late financier left behind an estate worth an estimated \$577(£450m) million after he was found dead in his prison cell five weeks after his arrest on July 6, 2019 on multiple sex-trafficking charges. + +A number of his victims are suing the estate, arguing they should be compensated for the abuse they suffered. + +Robert Glassman, a lawyer representing Jane Doe, wrote in a letter to the court that his client "is best served by pressing forward with her claims not waiting even longer for justice. + +"A stay of the civil proceedings would provide what defendant Maxwell has sought for years - concealing her heinous acts from public view," he said. + +A court in Manhattan is also due to hear oral argu ' the civil defamation case filed against Ms Maxwell by a victim of Epstein's, in the decision over whether to unsea sensitive evidence. + +-0- Sep/11/2020 18:16 GMT + +To view this story in Bloomberg click here: + +https:/Thlinks.bloomberg.corn/news/stories/QGIAR93HBS3K \ No newline at end of file diff --git a/marker2/ds9/EFTA00089600/EFTA00089600.metadata.json b/marker2/ds9/EFTA00089600/EFTA00089600.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..622d42c2bac381400d0dc3e92fa0a8c92ba3bc5f --- /dev/null +++ b/marker2/ds9/EFTA00089600/EFTA00089600.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089600.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 3914, + "elapsed_seconds": 1.22, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 76 + ], + [ + "Line", + 36 + ], + [ + "Text", + 25 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 73 + ], + [ + "Line", + 37 + ], + [ + "Text", + 14 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089600" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089602/EFTA00089602.md b/marker2/ds9/EFTA00089602/EFTA00089602.md new file mode 100644 index 0000000000000000000000000000000000000000..d1f6765cd779ab0ce2bbb434cb39c30b5efc5e9d --- /dev/null +++ b/marker2/ds9/EFTA00089602/EFTA00089602.md @@ -0,0 +1,19 @@ +## FEDERAL. BUREAU OF INVESTIGATION + +![](_page_0_Picture_4.jpeg) + +Datcoremm Y...121/2020 + +On or about January 8, 2020, writer contacted , date of birth at . The purpose of the call was to ascertain availability in scheduling an in-person interview. was willing to meet in person to be interviewed. While on the call, provided the following information: + +advised that she did not know JEFFREY EPSTEIN and GHISLAINE MAXWELL all that well. and her daughter, went to EPSTEIN's home; was in his home one time. At a later date, EPSTEIN told that he wanted to move to New York with he and MAXWELL. told them. no. EPSTEIN and MAXWELL loved art and wanted to help . They lied to advised she did not know what happened with her daughter because she was working. + +advised that when she found out what had happened to her daughter, she called and asked her how come she did not tell her. advised that cried on the phone to her. son contacted her and asked her how she did not know what was going on. + +advised that EPSTEIN and MAXWELL were evil. stated MAXWELL is "evil, evil as can be". felt that MAXWELL was worse than EPSTEIN because MAXWELL appealed to her as a mother. advised that EPSTEIN and MAXWELL destroyed her life. + +UNCLASSIFIED//FOUO + +Investigation on 01 / 08/2020 at New York, New York, Untted States (Phone) + +This document contains neither recommendations nor conclusions or the FBI. 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Present for the interview was Assistant United States Attorney , FBI Special Agent NYPD Detective , Swedish Police Detective Inspector and Swedish Police Detective Inspector . After being advised of the identities of the above listed individuals and the nature of the interview, provided the following information: + +only met JEFFREY EPSTEIN twice. EPSTEIN wanted daughter herein referred to as ) to move in with him and a lady name- does not talk to about the case as she cries and becomes upset. says she cannot talk about it. feels like a bad mother because she wondered how she couldn't have noticed what was happening. + +They lived on the island of Palm Beach and was very close to her father. When was 9 years old she and her father raised millions for charity. + +EPSTEIN was present at and he was a godfather figure. said she could sue because they knew what was going on. EPSTEIN was with GHISLAINE MAXWELL. MAXWELL told that she would pay for scholarship at After 2 years EPSTEIN and MAXWELL were stubborn and kept asking but she didn't know at that point that they were already seeing at + +Around 1995-1996 MAXWELL contacted asked about MAXWELL. told that MAXWELL lived with EPSTEIN. MAXWELL called at her job. worked at an art gallery in Palm Beach. knew that EPSTEIN lived near her in Palm Beach and he sup orted the arts. knew that MAXWELL and EPSTEIN would fly together to MAXWELL told that she wanted to take under her wing and have + +Inwsugammon 02/05/2323 g Stockho1m, Sweden (1n Per5on) + +This document contains neither recommendations nor conclusions or the FBI. It is the property of the FIB and is loaned to your agency; it and its contents are not to be distributed outside your agency. + +Continuation of FD-302 of ( U ) Interview of ,on 02/05/2020 m g, 2 of 6 + +her move in with her and EPSTEIN. told MAXWELL no. + +After a while, told that she has a hard life and is asking how could she pay for school. says that she does not trust MAXWELL and EPSTEIN. asked to meet them. and either went together to EPSTEIN's house or was already there. The housekeeper let in and she met MAXWELL, then she met EPSTEIN. EPSTEIN was wearing pajama pants and a T-shirt. EPSTEIN told that he and MAXWELL had seen at saying she was beautiful and talented and she needed to go to JUILLIARD. EPSTEIN said that he was a board member at JUILLIARD. told them no, that she wanted to stay in Palm Beach. then left. + +Sometime later EPSTEIN T-shirt. EPSTEIN told • him take with him showed up at art gallery in pajamas and a that she was talented and asked if she would let to New York. + +told that school in Palm Beach. • school do not like kill herself. Eventually an apartment near the stock market/ Wall Street. New York. EPSTEIN told to tell to go home spending too much money and she did not have a job. At her future is in New York and refused to go to a teacher told that all the kids in The teacher told that wanted to moved to New York with and they found went to school in because she was this time did not know that still had contact with EPSTEIN and MAXWELL. + +used to go to EPSTEIN's Palm Beach house. They would send a car to pick her up. would show which would make feel comfortable. Maybe once a week or every other week a car would pick her up to bring to EPSTEIN's house. Around 1995-1996 started to go to EPSTEIN's house. was about 15 years old. pictures of other girls there + +attended for about three summers. told that MAXWELL and EPSTEIN used to visit her at would tell that famous people would go to EPSTEIN's house. heard that a prince and DONALD TRUMP visited EPSTEIN's house and this made think that if they are there then how could EPSTEIN be a criminal. + +has six children and loves them as they are her life. thinks that MAXWELL is to blame. In reference to MAXWELL, stated, "She is a + +Continuation of FD-302 of (U) Interview of on 02/05/2020 mg, 3 of 6 + +wolf. She picks the girls." When was in EPSTEIN's house, MAXWELL told her to look at all the pictures of famous people. MAXWELL told , "I can be a big sister" as she pat on the head. On one instance, over the phone, MAXWELL told that she would take care of was working hard and could not take care of her. because + +Police in West Palm Beach were very good to + +would tell about the nice parties that EPSTEIN and MAXWELL would host. would call to the house and a housekeeper would answer the phone. The housekeeper would tell her that everything was ok. would then call women and people felt was MAXWELL called back to say everything was OK. There were always other at the house, even if there was not a party going on. safe because of this. Approximately three to four times, to ask if could come over because they were having a party. MAXWELL would say something "mother-like" to "she's a daughter to us...we like to take care of her". A driver come to pick up. He was an older man and very polite. possibly be in his BO's now. , saying, would always He might + +On a few occasions, MAXWELL called the home at night asking if could come over the next day. Once, MAXWELL called at the art gallery. EPSTEIN visited at the art gallery only once. + +When asked if ever traveled with MAXWELL and EPSTEIN, stated yes...One weekend while in New York they traveled together to New Mexico. is not sure if traveled with them from Palm Beach. + +MAXWELL called one evening Mexico. told MAXWELL that another occasion, MAXWELL called it makes her angry presently. fly. Prior to moving to New York, and asked if could go to New had school and could not go. On on a weekend. trusted MAXWELL so does not think had a passport to went to New York with twice for a weekend to look for an apartment. Once they moved to New York, was not sure if traveled with them as never told her. + +When living in Palm Beach, MAXWELL asked if asked her if could go with them to New Mexico. got a job after moving to New York working for the in Los Angeles. visited in Los Angeles, and then moved back to New York. + +Continuation of FD-302 of ( U ) Interview of on 02/05/2020 mg, 4 of 6 + +MAXWELL called and told her they would like to come with them to New York to live with them and go to JUILLIARD. went to everyday and told her that she wanted to go to New York. hated Palm Beach, knowing that no one liked her and wanted to kill herself. + +About seven years ago, while living in New York, a British journalist knocked on door. refused to talk. The journalist then continued to contact her over the phone. asked him to stop calling. decided to move back to Sweden to get away. + +stated she moved to New York from West Palm Beach in the summer of 1997, before school started. was in school at this time. She was student of the year and a very good normal student. She was not done with high school yet when they moved to New York. finished high school while in New York at + +recalled going to Phoenix, Arizona for two weeks and asked to come with her from New York but did not want to go. wanted to get a job so took photos and sent them out. Then received a call fro flew back to New York from Phoenix to pick up then they flew out to Los Angeles together. + +lath birthday was in Los Angeles and she was already working for started this job right after she finished at + +did not remember if had any travel from West Palm Beach with EPSTEIN and MAXWELL when she was 16 years old. was asked if it was possible if this ever happened to which she responded she was not sure but it maybe happened only once. + +During the fall of 1996, was still in West Palm Beach living with . During the spring of 1997 was not sure where she was. When was 16-17 years old, she and lived in New York. + +A few weeks before school started, and moved to New York in the summer when was 16 years old. was 17 years old when she starte + +Continuation of FD-302 of ( U ) Interview of a 02/05/2020 mg, 5 of 6 + +at her house in West Palm Beach. MAXWELL asked if could fly with them to New Mexico. told her no. was then upset about this and cried. + +The second call received from MAXWELL occurred while was at her house in West Palm Beach. MAXWELL asked if could go to New Mexico with them and told her no. Again, was upset and cried about it a lot. told that all of her friends were going so decided to give in and told her she could go. ended up traveling with EPSTEIN and MAXWELL. The driver picked up from her house in West Palm Beach and brought her to EPSTEIN's house in the morning. They then flew together to New Mexico on his plane from West Palm Beach. recalled asking the driver if this was safe and he said, "Don't worry, madam". + +told that they flew on EPSTEIN's jet. She was 15 years old at the time. They stayed there for a weekend, about three days. never talked to MAXWELL about this trip. did not get along with MAXWELL at first, as MAXWELL was very snobby. was in school in West Palm Beach when she flew with them to New Mexico. When returned from New Mexico she told that she had fun, met famous people, there was a big party and her friends were there. + +recalled calling to talk to the principal to ask about EPSTEIN. She spoke with a receptionist who said they knew him. They said, "He is our guardian...He is trustworthy around the kids and there is no need to worry.". told that the first summer she was at EPSTEIN was buying all the kids ice cream. + +had no memory of sleeping at EPSTEIN's West Palm Beach house. She only recalled hanging out there. EPSTEIN and MAXWELL would call the house phone if they ever called. If was working then would answer the phone. + +trusted that these situations would be OK. told to trust her and that everything was OK. would ask her if anything happened and would say "no mother". trusted it because EPSTEIN was surrounded by so many good and famous people. + +Continuation of FD-302 of ( U ) Interview of on 02/05/2020 mg, 6 of 6 + +MAXWELL. didn't tell about them. lived at apartment JEAN- was at at the time. When they moved to New York, became depressed but did not talk to about why. + +When moved to New York, she called EPSTEIN's office and spoke with his lawyer. She told him to tell EPSTEIN not to contact anymore. did not tell she did this. 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2020-10- 19 Discovety\_Letter\_Draft\_vl.docx + +Hi team, + +Attached is a draft letter in response to Chris's October 13, 2020 letter (his letter is attached here for your convenience). + +Since you are both much closer to the discovery and the investigation, please feel free to edit as much as you would like. + +Thanks, + +Assistant United States Attorney + +United States Attorney's Office + +Southern District of New York + +New York, New York 10007 + +Tel: \ No newline at end of file diff --git a/marker2/ds9/EFTA00089609/EFTA00089609.metadata.json b/marker2/ds9/EFTA00089609/EFTA00089609.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..1dc7b910eeae0cfd3adc159fb2ae9299f3410d88 --- /dev/null +++ b/marker2/ds9/EFTA00089609/EFTA00089609.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089609.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 651, + "elapsed_seconds": 0.74, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 33 + ], + [ + "Text", + 16 + ], + [ + "Line", + 16 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089609" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089610/EFTA00089610.md b/marker2/ds9/EFTA00089610/EFTA00089610.md new file mode 100644 index 0000000000000000000000000000000000000000..1e6eb28a98f686fce284d8063f0b22021982a4a6 --- /dev/null +++ b/marker2/ds9/EFTA00089610/EFTA00089610.md @@ -0,0 +1,111 @@ +October 13, 2020 + +## BY EMAIL + +, Esq. Esq. Esq. United States Attorney's Office Southern District of New York New York, NY 10007 + +Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +Dear + +We write on behalf of our client, Ghislaine Maxwell, to set forth requests for discovery and Brady material. Based on our review of the government's productions of August 5, 2019, August 13, 2019, and August 21, 2020, we make the following requests for discovery, inspection, and copying, in accordance with the guarantees of the Fourth, Fifth, and Sixth Amendments, Rule 16 of the Federal Rules of Criminal Procedure, the Federal Rules of Evidence, and such other laws and rules as may be applicable. We are still reviewing these productions, as well as the government's most recent production of October 2, 2020, and reserve the right to supplement these requests as necessary. + +- 1. We request any oral, written, or recorded statements made by Ms. Maxwell, aside from the statements made in prior civil case proceedings that you produced on August 13, 2020 and the statements made at the time of arrest, which you produced on August 21, 2020. Fed. R. Crim. P. 16(a)(1)(A), (B). +- 2. We request that the government disclose and identify any statements of alleged coconspirators that it intends to introduce at trial. +- 3. We request any prior criminal records of Ms. Maxwell. Fed R. Crim. P. 16(aX 1)(D). +- 4. We request any books, papers, documents, data, photographs, tangible objects, buildings or places, or copies or portions of any of these items. Fed R. Crim. P. 16(a)( I )(E). + +- a. Based on our review of the discovery, it does not appear that any documents or tangible objects were obtained from Ms. Maxwell through a search warrant or a search incident to arrest. Please confirm this. +- b. We will schedule a time in the near future to inspect the originals of photographs and any other evidence (including documents and tangible objects) that have already been disclosed. +- 5. We request the results or reports of any physical or mental examination and of any scientific test or experiment. Fed R. Crim. P. 16(a)(1)(F). +- 6. We request a written summary of any testimony that the government intends to introduce at trial under Federal Rules of Evidence 702, 703 or 705, which summary must describe the witness's opinions, the bases and reasons for those opinions, and the witness's qualifications. Fed R. Crim. P. 16(a)(1)(G). +- 7. We request that the government disclose the identities of the individuals identified in the indictment as Minor Victims 1-3. +- 8. We request that the government disclose the complete birthdays of the individuals identified in the indictment as Minor Victims 1-3. +- 9. We request all written and oral communications concerning the negotiations relating to the Non-Prosecution Agreement ("NPA") signed by Jeffrey Epstein on September 24, 2007. Such communications include: + - a. All communications between the government including, but not limited to, attorneys and staff at the U.S. Attorney's Office for the Southern District of Florida, the United States Attorney's Office for Southern District of New York, the Department of Justice, state prosecutor's offices, the FBI, and any other federal and state investigative agencies — and Mr. Epstein's attorneys. + - b. All communications between and among any government employees including, but not limited to, attorneys and staff at the U.S. Attorney's Office for the Southern District of Florida, the United States Attorney's Office for Southern District of New York, the Department of Justice, state prosecutor's offices, the FBI, and any other federal and state investigative agencies. + - c. Unredacted copies of all emails and other correspondence between the government and Mr. Epstein's attorneys concerning the negotiation of the NPA, which you previously produced on August 13, 2020. See, e.g., SDNY GM 00134069 et seq. + +October 13, 2020 + +Page 3 + +- 10. We request that the government produce a complete copy of the diary, only seven pages of which were produced by the government on August 21, 2020. See SDNY GM 00165982-00162988.i +- II. We request a complete, unredacted copy of the FBI 302 produced by the government on August 13, 2020, bearing Bates numbers SDNY\_GM\_00114982-00114993. +- 12. We request that the government produce all versions and drafts of the book/memoir "The Billionaires Playboy Club" produced by the government on August 13, 2020, and identify the dates of each version/draft. See, e.g., SDNY\_GM\_00117607-608, 00117626-635, 00117637-640, 00117726-727, 00117761-762, 00117836-837 (sample list). +- 13. We request the following documents and materials related to the individuals identified in the indictment as Minor Victims 1-3 and for any other witness who has alleged that Ms. Maxwell engaged in or facilitated improper sexual conduct at any time up to the present: + - a. All diaries, notes, journals, e-mails, text messages, letters, or other writings by these individuals, including but not limited to, all written communications between these individuals and Mr. Epstein or Ms. Maxwell; + - b. All travel and immigration records, as well as copies of any passports and travel documents; + - c. All school records or other educational records; + - d. All phone records; + - e. All photographs; + - f. All financial records, including all records reflecting any payments or money transfers from Mr. Epstein or his associated businesses to these individuals or their family members or their counsel; + - g. All police reports or complaints to law enforcement authorities filed by these individuals; + - h. Any submissions to the Epstein Victims' Compensation Program made by any of these individuals; + - i. All communications between or among these individuals, or between these individuals and counsel for any other such individual, including but not limited to, emails, text messages, social media posts, and other correspondence; + - j. All public statements made by these individuals concerning Mr. Epstein or Ms. Maxwell; + - k. Any record or report of any physical, medical, mental, or psychological examination of these individuals; + +1 We also make this request, as well as Requests 11.16, pursuant to the government's Brady obligations. + +- I. Any record, report or other document reflecting the use or abuse of alcohol or any legal or illegal drug, including marijuana; +- m. All written and oral communications between the government and the attorneys for these individuals — including , but not limited to, Bradley Edwards, David Boies, Sigrid McCawley, Peter Skinner, Stanley Pottinger, Paul Cassell, Spencer Kuvin, and Jack Scarola (the "Attorneys") — concerning or relating to Mr. Epstein and/or Ms. Maxwell. +- 14. We request all written and oral communications and other documents concerning any meetings between the Attorneys and prosecutors and staff from the United States Attorney's Office for the Southern District of New York ("SDNY") concerning Jeffrey Epstein and/or Ghislaine Maxwell. + - a. This request includes all communications and documents related to any meetings that took place in or about 2016 in which certain of the Attorneys met with SDNY prosecutors to ask SDNY to initiate a criminal investigation into Mr. Epstein and Ms. Maxwell. See New York Daily News, "Manhattan Federal Prosecutors Declined to Pursue Jeffrey Epstein and Ghislaine Maxwell Case in 2016: Sources" (Oct. 13, 2020), https://www.nvdailvnews.com/new-vork/nyjeffrey-epstein-maxwell-case-20201013-jmzh17zdrzdgrbbs7yc6bfnszustorv.html ; see also Bradley J. Edwards, Relentless Pursuit: My Fight for the Victims of Jeffrey Epstein, at 281. + - b. This request also includes all communications and documents related to any meetings between any of the Attorneys and SDNY prosecutors and staff concerning or relating to Mr. Epstein and/or Ms. Maxwell that took place in or about 2018, when the government asserts that it began the SDNY investigation into this case (see Dkt. 63), or at any time thereafter. +- 15. We request the complete FBI's case file regarding the investigation of for obstruction of justice, referenced in the government's production cover letter of August 21, 2020. +- 16. We request copies of the "82-page pros memo and 53-page indictment" drafted as part of the investigation conducted by the Southern District of Florida. See SDNY GM 00131226. +- 17. We request all e-mails, text messages, letters, or other written communications to or from Ms. Maxwell. +- 18. We request all medical records or reports concerning Mr. Epstein. + +- 19. We request all subpoenas and voluntary request for production of documents issued in connection with or related to this case, and all evidence obtained by the government by subpoena or from voluntary production (to the extent it has not already been produced), including information to identify where and how the evidence was obtained. +- 20. We request that the government disclose and identify any evidence it intends to introduce under Federal Rule of Evidence 404(b) or as background of the conspiracies charged in the Indictment. +- 21. We request information about the composition of the grand jury that indicted this case, including a list of grand jurors, their attendance dates, the reasons for any absence, and whether attendance was in person or virtual. +- 22. We request that the government disclose whether any persons were present during grand jury proceedings other than the grand jurors, witnesses under examination, court reporters, and attorneys from the United States Department of Justice. + +Consistent with the requirements of Brady v. Menyland, 373 U.S. 83 (1963) and Kyles v. Whitley, 514 U.S. 419, 438 (1995), as well as your own professional obligations, we request that the government conduct an affirmative search for, locate, identify, and produce, all documents, books, papers, photographs, scientific tests or experiments, tangible objects, written or recorded statements, grand jury transcripts and oral statements, reports, memoranda, names, and addresses or persons or other evidence or information favorable to the defense as to either guilt or punishment, or tends to affect the weight or credibility of the evidence to be presented against Ms. Maxwell, or which will lead to evidence favorable to or exculpatory of Ms. Maxwell, including but not limited to information which is within the possession, custody, or control of the government. Impeachment evidence, as well as exculpatory evidence, falls within Brady's definition of evidence favorable to the accused. See United States v. Bagley, 473 U.S. 667 (1985); United States v. Agars, 427 U.S. 97 (1976). We also make the following specific Brady requests: + +- I. Exculpatory Evidence: We request all such evidence requested above and evidence known to the government which tends to exculpate Ms. Maxwell of the offense alleged, including exculpatory statements. This request includes, but is not limited to: + - a. Any statements or written communications made by any witness who has alleged that she was sexually abused or assaulted by Mr. Epstein, but has not alleged that Ms. Maxwell participated in, was involved in, or facilitated the alleged sexual abuse. These include, but are not limited, to, all diaries, notes, journals, e-mails, text messages, letters, or other writings by these individuals. + - b. Any evidence suggesting that Ms. Maxwell was not involved in or aware of the conduct alleged in the indictment. + +- c. Any evidence concerning witnesses who have contacted the government or law enforcement authorities about alleged sexual abuse by Mr. Epstein or Ms. Maxwell who were determined not to be credible. +- d. Any evidence suggesting that any witness who has alleged that she was sexually abused or assaulted by Mr. Epstein, with or without the involvement of Ms. Maxwell, was not a minor at the time the alleged sexual abuse took place. +- e. All investigative efforts to verify any information provided by any and all witnesses, where such efforts were negative. +- f. All discussions with any witness, including law enforcement, that reveal Brady information. +- 2. Favorable Statements and Witnesses: We request that the government produce any witness statements favorable to Ms. Maxwell, and identify the names of any witnesses who have information favorable to Ms. Maxwell. This includes any witness who the government does not intend to call at trial, but who made a favorable statement concerning Ms. Maxwell. +- 3. Evidence of Criminal Investigation of Any Government Witness: We request any evidence that any prospective witness is under investigation by federal, state or local authorities for any criminal conduct. This includes their entire criminal record (both arrests and convictions, whether adult or juvenile) and probation reports, supervised release, pre-sentence reports, violation reports, intelligence reports and all supplementals. +- 4. Evidence of Misconduct of Government Agents: We request information about any allegation of misconduct of any government agents or attorneys involved in any investigation into Mr. Epstein and Ms. Maxwell. +- 5. Impeachment Evidence: We request any evidence that may be used to impeach a prospective government witness. This request includes, but is not limited to: + - a. Any evidence that any prospective government witness has engaged in any criminal act, whether or not resulting in a conviction, and whether any witness has made a statement favorable to Ms. Maxwell. + - b. Any information tending to establish that the witness is or was a user of any drug or alcohol and any other information which tends to discredit the witness's ability to perceive, recollect and/or narrate events. + +- c. Any information concerning any government witnesses' history of emotional disorders and psychiatric or psychological counseling, which may bear on a witness's ability to perceive or relate events accurately and truthfully. +- d. Any evidence suggesting that any witness who has alleged that she was sexually abused or assaulted by Mr. Epstein, with or without the involvement of Ms. Maxwell, had a financial motive or incentive to accuse Mr. Epstein or Ms. Maxwell. +- 6. Giglio Information: Pursuant to Giglio v. United States, 405 U.S. 150 (1972), we request dates and descriptions of any and all considerations or promises (express or implied) of consideration given during the course of the investigation by any law enforcement officials to or on behalf of any witness the government intends to call at trial, or any such consideration or promises expected by any such witness in the future. This includes but is not limited to the following: + - a. Rewards, monetary or otherwise; + - b. Employment; + - c. Protection and relocation; + - d. The rejection, dismissal, immunization from prosecution or reduction of any federal, state or local offenses charged in the past or present or that might be charged in the future; + - e. Reduction of sentence, improvement of custody status or leniency at sentencing by making the witnesses' cooperation known to the prosecution, Court, probation or parole officer, or other federal, state or local agency or jurisdiction; + - f. Other incidents of cooperation. +- 7. Evidence of Bias or Motive to Lie: We request any evidence that any prospective government witness is biased or prejudiced against Ms. Maxwell or has a motive to falsify or distort his or her testimony. Pennsylvania v. Ritchie, 480 U.S. 39 (1987); United States v. Strifler, 851 F.2d 1197 (9th Cir. 1988). +- 8. Contradictory Statements: We request all prior contradictory statements of any prospective government witness. Giles v. Maryland, 386 U.S. 66 (1967). +- 9. Statements Relevant to the Defense: We request disclosure of any statement that may be "relevant to any possible defense or contention" that Ms. Maxwell might assert. +- 10. We request any other materials or documents not otherwise accounted for in other requests herein that arguably reflect the (i) motivation of any government witness to cooperate with the prosecution team, (ii) the competency or credibility of the witness, or (iii) the witness's bias or hostility against Mr. Epstein or Ms. Maxwell. + +October 13, 2020 + +Page 8 + +Please note that under both Federal Rule of Criminal Procedure 16(c) and Brady, the duty to disclose is a continuing one, and you must disclose promptly any additional discovery evidence, information, or material of which you or any member of the prosecution team become aware. + +In the event that you are unable or unwilling to provide the information and documents requested in this letter, please advise us by October 21, 2020, so that we may file any necessary motions with the Court. + +Thank you in advance for your attention to these matters. + +Sincerely, + +Is/ Christian Everdell Christian R. Everdell COHEN & GRESSER LLP New York, New York 10022 + +cc: Mark S. Cohen, Esq. Jeff Pagliuca, Esq. Laura Menninger, Esq. Bobbi C. 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Received 03/02/2017 + +From Myspace, CO... +(Name of Contributor/Interviewee) + +(Address) + +(City and State) + +By \_\_\_\_\_ + +To Be Returned Yes No + +Receipt Given Yes No + +Grand Jury Material - Disseminate Only Pursuant to Rule 6 (e) + +Federal Rules of Criminal Procedure + + Yes No + +Federal Taxpayer Information (FTI) + + Yes No + +Title: + +Reference: + +(Communication Enclosing Material) + +Description: Original notes re interview of + +1) MARO COPY & COREM SUBPOENA RETURN + +RESULTS FOR MYSPACE IN THE + +[REDACTED] + +**ITEMS (S)** + +**CANNOT** + +**BE** + +**SCANNED** + +DESCRIPTION + +--- + +CD + +MySpAcs.com + +SUBPOENA + +60688973 + +65737918 + +65732979 + +172831 + +3/E-MA- +108062- +IA + +![](_page_2_Picture_14.jpeg) + +**CD-R** +recordable discs + +![](_page_2_Picture_16.jpeg) + +![](_page_2_Picture_17.jpeg) + +![](_page_3_Picture_0.jpeg) + +March 1, 2007 + +Via Fax And Via UPS + +ATTN: SA FBI West Palm Beach Florida West Palm Beach, FL 33401 + +Re: MySpace.com subpoena results for User IDs 60688973, 65739018, 65739759, and 172831. + +Dear SA + +Enclosed are the results for the subpoena sent to MySpace.com. + +All time stamps are Pacific Standard Time. + +Please let us know if you have any questions. + +Thank you, + +Ceiting Lu + +NMI + +![](_page_4_Picture_23.jpeg) + +## Subscription Information Report + +--- + +**User ID:** + +**First Name:** + +**Last Name:** + +**Country:** + +**City:** + +**Postal Code:** + +**Region:** + +**Email Address:** + +**User Name:** + +**Signup IP Address:** + +**Signup Date:** + +**Delete Date:** + +![](_page_4_Picture_37.jpeg) + +US + +Lox + +33411 + +FLORIDA + +![](_page_4_Picture_42.jpeg) + +Mar 5 2006 9:49PM + +N/A + +![](_page_5_Picture_8.jpeg) + +## IP Activity Report + +| User ID | Login Date | IP Address | +|------------|---------------------------|------------| +| [REDACTED] | Mar 5 2006 9:49:02:580 PM | [REDACTED] | + +![](_page_6_Picture_0.jpeg) + +# jjmyspace® Subscription Information Report + +a place for Mends + +### User ID: + +First Name: + +Last Name: + +Country: + +City: + +Postal Code: + +Region: + +Email Address: + +User Name: + +Signup IP Address: + +Signup Date: + +Delete Date: + +:No Value Was Entered> + +WEST PALM BEACH + +33411 + +Florida + +Mar 26 2006 12:45AM + +Nth + +![](_page_7_Picture_0.jpeg) + +### myspace® IP Activity Report + +![](_page_7_Picture_5.jpeg) + +![]()![]()![](_page_9_Picture_0.jpeg) + +![](_page_9_Picture_3.jpeg) + +![](_page_10_Picture_0.jpeg) + +# famyspace® Subscription Information Report 'a a place for friends + +User ID: First Name: Last Name: Country: City: Postal Code: Region: Email Address: User Name: SIgnup IP Address: SIgnup Date: Delete Date: US Oct 15 2003 5:23PM N/A + +![](_page_11_Picture_0.jpeg) + +# j myspac69 IP Activity Report + +![](_page_11_Picture_3.jpeg) + +a place for friends + +![](_page_12_Picture_5.jpeg) + +![](_page_13_Picture_0.jpeg) + +j + +![](_page_13_Picture_3.jpeg) + +![](_page_14_Picture_0.jpeg) + +i + +![](_page_14_Picture_3.jpeg) + +![](_page_15_Picture_5.jpeg) + +## IP Activity Report + +![](_page_15_Picture_7.jpeg) + +![](_page_16_Picture_0.jpeg) + +![](_page_16_Picture_3.jpeg) + +![](_page_17_Picture_6.jpeg) + +![](_page_18_Picture_6.jpeg) + +![](_page_19_Picture_0.jpeg) + +j + +![](_page_19_Picture_3.jpeg) + +![](_page_20_Picture_0.jpeg) + +![](_page_20_Picture_2.jpeg) + +![](_page_21_Picture_6.jpeg) + +![](_page_22_Picture_0.jpeg) + +### myspace® IP Activity Report + +![](_page_22_Picture_3.jpeg) + +![](_page_23_Picture_6.jpeg) + +![](_page_24_Picture_6.jpeg) + +![](_page_25_Picture_0.jpeg) + +![](_page_25_Picture_3.jpeg) + +![](_page_26_Picture_6.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00089618/EFTA00089618.metadata.json b/marker2/ds9/EFTA00089618/EFTA00089618.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..12a4ca10df0cfb04a705cbec94f973b4647deb11 --- /dev/null +++ b/marker2/ds9/EFTA00089618/EFTA00089618.metadata.json 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sha256:bff9cd24f46a29a3cf6edf39c333768815cf64f65d4ac8447fcd0603263c6dd2 +size 1508 diff --git a/marker2/ds9/EFTA00089618/_page_9_Picture_3.jpeg b/marker2/ds9/EFTA00089618/_page_9_Picture_3.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..b8b341fbe5a9053acdfc1708b22973ceb5c29440 --- /dev/null +++ b/marker2/ds9/EFTA00089618/_page_9_Picture_3.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:47fd4e8882609227d482cef06abe911586e5180df8d058bb776ce9ce0433178c +size 10610 diff --git a/marker2/ds9/EFTA00089645/EFTA00089645.md b/marker2/ds9/EFTA00089645/EFTA00089645.md new file mode 100644 index 0000000000000000000000000000000000000000..2a5c5234f744903c5ce8d5def19d04c5c5112de7 --- /dev/null +++ b/marker2/ds9/EFTA00089645/EFTA00089645.md @@ -0,0 +1,178 @@ +From To Cc + +Subject: RE: GM -- search warrant returns + +Date: Tue, 20 Oct 2020 21:34:24 +0000 + +Inline-Inn ages: image001.jpg + +Yes, my view is that these would be responsive to 2, 3, 4, 5, and 6. And confirmed that these have been deduped. + +I'm going to go through and do a few more spot checks to try to weed out any more false hits. My hope is that we can clarify the empty attachments with tomorrow and then ask.o start bates stamping the remaining responsive documents for production tomorrow. + +Please let me know if you'd like to discuss anything else in the meantime. + +From: Se + +To Cc + +Subject: RE: GM -- search warrant retu + +Thanks, this is helpful. It seems like th nd jeevacation hits (which had two of the highest hit rates in the STR) would be responsive to #6 (and possibly #2, 3, 4, or 5) — is that right? And have these documents been de-duped? • + +- 1. Evidence concerning the identity or location of the owner(s) or user(s) of the Subject Devices. +- 2. Evi identity or location of co-conspirators of JEFFREY EPSTEDI. includin ' and GHISLAD/E MAXWELL] +- 3. Evidence concernm2 conununications to. from. by. andfor among co-conspirators of JEFFREY EPSTEK includin and GHISLAEST MAXWELL +- 4. Any documents or communications with or regarding victims or potential victims of the Subject Offenses. +- 5. Documents or records reflecting payments to victims andlor co-conspirators including but not limited to bank and financial records. spreadsheets. ledgers. account listings. check and wire records. and documents reflecting cash withdrawals. +- 6. Documents or records reflecting travel plans or arrangements for victims or potential victims of the Subject Offenses. or co-conspirators in those Subject Offenses. including + +Given that the warrant authorizes seizing data from a more than 20-year period, and given the extent to which Epstein traveled, having this many responsive documents does not seem crazy to me. Particularly if you've already tried to weed out the spam, and spot-checked the responsive documents for each search term to make sure it wasn't pulling in false hits. + +From + +Sent: Tuesda October 20 2020 3:58 PM + +To Cc + +Subject: RE: GM -- search warrant returns Sure, the warrant is attached. + +Cc Subj • • -- search warrar ns el. + +Thanks Let's see what says about the attachments. Do you mind sending the rider for the warrant that we wou e seizing these materials pursuant to? + +From + +Sent: + +To Cc + +Subject: RE: -- arch warrant returns + +Update from + +There are 128,175 email attachments attached to emails with search term hits that are empty filesMeview of the emails to which these empty files attached suggests that the FBI only provided us with partial files for these emails. + +Unclear whether those partial files are all that the FBI was a tract from the devices, or whether the FBI left out parts of these files when producing them to us. I have asked for a call tomorrow morning to discuss. + +In the meantime, that still leaves us with a very large number of documents hitting on the search terms. Here is a breakdown of the file types: + +- 1,087,903 are emails (majority featuring Epstein as sender or recipient) +- 323,179 are email attachments (128,175 of which are empty files as discussed above) +- The remaining 36,619 are a mix of non-email files with no association with emails, such as Word, PDF, PowerPoint, and Excel files. + +From + +Sent: Tuesday, October 20, 2020 8:26 AM + +To: Cc: + +Subject: RE: GM — search warrant returns + +I tend to agree that if we really do have hundreds of thousands of emails between Epstein and =I talking about the logistics of travel or meetings with women, we have a good faith basis to tag those as responsive. To the extent defense counsel (or we) want(s) to run search terms within those hundreds of thousands of emails focused on particular names or time periods, they are free to do so, and we may well want to do so. + +Also agree on drilling down on the attachment issue. Sorry for the issue with which is really annoying. Please let us know what you learn from him when he's back tomorrow. + +From: + +Sent: Tuesda October 20 2020 8:14 AM + +To: + +u • ject: — searc warrant returns + +I can ask about the attachments=is out today, so I cannot ask CART until tomorrow. + +On Oct 20, 2020, at 7:28 AM wrote: + +Thanks those certainly do sound like they would be responsive. But I can imagine improper) attachments being something the defense will certainly complain about- can we go back to CART or o ask them to figure out what happened and whether there is a way to fix it, or we just have to live with that (for instance, maybe the attachments were deleted or partially overwritten). + +On Oct 19, 2020, at 11:47 PM, wrote: + +Following up on this, I've done a spot check of a couple hundred of these hits, and the vast majority are emails with Epstein as a sender or recipient. A small number were spam emails, though I did not see any repeat emails from spam senders. The majority were emails discussing logistics, such as travel, phone calls, and meetings, including the travel + +plans of individuals with female names. Most of these logistics emails are witt here are also emails about paying for school for people with female names, renovations to Epstein's properties, Epstein's finances, and miscellaneous emails about people with female names (e.g., discussing the physical appearance of various females, Epstein asking to have a threesome, modelling photos). + +One thing I noticed is that most of the attachments to emails did not appear to have been successfully extracted. Most were just blank pages when I clicked through them. So one way to narrow the responsive category would be just to take the documents with hits and not the entire family of documents along with them. + +From Sent: Monda October 19 2020 10:37 PM + +To C + +Subject: RE: GM — search warrant rel. I'm struggling to think of a way to limit or "jeevaction" more because: + +- ast name. Because she was Epstein's primary secretary who handled the travel logistics for Epstein, his employees, and the victims who traveled. So it makes sense that her last name has so many hits. Those will include essentially all of the day-to-day communications regarding Epstein's schedule and travel. +- The term "jeevacation" is the phrase Epstein used for the majority of his email addresses (e.g., jeevacation@gmail.com, jeevacation@yahoo.com. etc.). So it's unsurprising that this phrase is the highest hit. I suspect that number reflects the majority of Epstein's emails. We ran that search term because we do not know all of the email addresses Epstein used, and we suspected that there were more domains with "jeevacation" email accounts than we knew about. + +We've already run search terms to cut out spam, though we can certainly try to find more. + +From Se + +To Cc + +Subject: RE: GM — search warrant returns Thanks, this is a helpful start. I would recommend we think about how we can perhaps narrow or focus our search terms a bit, perhaps through combinations/connectors or other means, particularly for common names/words that are likely to generate a significant number of hits. For example, "David" turns up nearly 40,000 hits, and "flight" or "flights" turns up over 100 to pick a few. + +Also, curious as to wh urns up 450,000 hits and "jeevacation" (which I'm not familiar with but assume you all are?) turns up 750,000. Those two alone seem to account for the overwhelming majority of documents we've identified, so if there's a way to focus those two in particular, that might be a big help. + +One thing you might want to do is just review a couple hundred random hits, if you haven't already, to get a bit of a flavor for what we're turning up, as that may help inform our efforts to focus the search. I think we may also have the technology to weed out spam and potentially duplicates, if we haven't already, but defer to others with more experience in those areas.... + +From: Se • • + +To: Cc: + +Subject: RE: GM — search warrant returns The STR report is attached, in case that's useful. + +From Sent: Monda October 19 2 • + +To: Cc: + +Subject. • M sears warrant returns Thanks, Taking these one by one: + +- We designated certain email accounts responsive, per our discussion, at that yielded 90,000 emails. The balance of the 1.4 million emails/documents comes from search terms. +- The database contains all kinds of documents—word, PDF, and excel. I haven't seen any texts, and it's mainly the kinds of things you'd expect to be saved on someone's computer. +- I C ' ve numbers by search term, but will check on that and circle back. We sent a list of terms toM nd asked him to execute, so I'm not sure about the breakdown. +- Yes, Maxwell is a search term and her email account has been designated responsive. + +From: Sent: Monday, October 19, 2020 8:37 PM + +To, + +Subjecil • • l M -- search warrant returns + +Thanks Couple of follow up questions on this, and happy to set up a call if that's easier. + +First, am I understanding correctly that we ran all of our search terms and came up with 90,000 responsive emails and 1.31 million other responsive documents? Or is the 90,000 figure just mail account? + +Second, and related, with respect to the non-email documents, whatever their volume, do you have a sense of what kinds of documents we're talking about? Word documents, texts, excel spreadsheets, some combination thereof? + +Third, do you know how many documents hit on each term? If we came up with 1 million hits on the names of the victims, that's one thing, but if we came up with a million hits on the word "flight" or "passenger" we might want to think about whether to narrow the terms a bit. + +Also, I presume we ran Maxwell's name as one of the co-conspirators and ran any email account of hers we identified as one of the email accounts? + +As noted, happy to jump on a call tomorrow if that's easier. + +Thanks, + +From + +Sent: on a cto er • + +To: + +Cc: + +• — earch warrant returns + +We've run our responsiveness search terms for the search warrant returns, and they yield a total of 1.4 million documents. As a breakdown, 90,000 of those items are emails we designated responsive by account (for example, The remaining documents are hits on our search terms, which included the first and last names of every victim and suspected co-conspirators, as well as specific keywords (e.g., passenger, flight). The total database is 1.6 million documents. + +1.4 million documents is obviously a substantial portion of the 1.6 million document database. Given our prior discussions, our understanding is that the office is okay with us designating all of these documents responsive, but please let us know if you'd like us to take a different approach. + +Thanks, + +Assistant United States Attorney + +Southern District of New York + +One Saint Andrew's Plaza + +007 \ No newline at end of file diff --git a/marker2/ds9/EFTA00089645/EFTA00089645.metadata.json b/marker2/ds9/EFTA00089645/EFTA00089645.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..d910e0b169b993458535d80c574e265b5d308b9a --- /dev/null +++ b/marker2/ds9/EFTA00089645/EFTA00089645.metadata.json @@ -0,0 +1,176 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089645.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 4, + "chars": 10759, + "elapsed_seconds": 1.59, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 92 + ], + [ + "Line", + 47 + ], + [ + "Text", + 18 + ], + [ + "ListItem", + 6 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 95 + ], + [ + "Line", + 48 + ], + [ + "Text", + 26 + ], + [ + "ListItem", + 3 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 111 + ], + [ + "Line", + 51 + ], + [ + "Text", + 17 + ], + [ + "ListItem", + 2 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 3, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 85 + ], + [ + "Line", + 42 + ], + [ + "Text", + 23 + ], + [ + "ListItem", + 4 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089645" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089649/EFTA00089649.md b/marker2/ds9/EFTA00089649/EFTA00089649.md new file mode 100644 index 0000000000000000000000000000000000000000..323dabc6eb94aac8a40572e6e3a9ad12bd12eb6a --- /dev/null +++ b/marker2/ds9/EFTA00089649/EFTA00089649.md @@ -0,0 +1,223 @@ +From: ' "cl To: " riMi l=1.>, " (USANYS)" Cc: ' >, " (USANYS)" + +Subject: RE: GM -- search warrant returns + +Date: Wed, 21 Oct 2020 15:04:27 +0000 + +Inline-Images: image001.jpg + +My inclination is to mark all empty attachments as non-responsive. Unless anyone disagrees, I'll go ahead and tag all empty attachments as non-responsive in Relativity. + +From: (USANYS) Sent: Wednesday, October 21, 2020 10:27 AM To: (USANYS) Cc: ) Subject: RE: GM -- search warrant returns (USANYS) + +We didn't, but that could also be a function of the stellar defense lawyers in the GEP case. My understanding is that the email will show the attachments ("i.e., "Attachment 1" "Attachment 2") but then when they click through the responsive documents, there just won't be a "Attachment 2" if that's the one that was missing. The reason we didn't "seize" them was that without any content, they weren't responsive to the warrant, which would be my concern with seizing them here. You could also ask Chris whether there's a way to substitute "blank attachment" or some sort of filler page for the missing attachments so that it's clear to the defense what happened. + +From: (USANYS) Sent: Wednesday, October 21, 2020 10:22 AM To: (USANYS) Cc: Subject: RE: GM -- search warrant returns (USANYS) + +Just out of curiosity, did that result in a million questions from defense counsel about where the attachments were? I don't feel strongly about this at all, the only issue to flag is that if we tag them as responsive, we can then tell defense counsel that for any attachment that is blank, what that means is the FBI was unable to extract the attachment, so what they have is what we have. Alternatively we could mark all the blank pages as non-responsive and, if true, tell defense counsel that for any email lacking an attachment, the reason is the FBI was unable to extract one. Whichever you think will be more likely to stave off lots of follow up questions from defense counsel. + +From: (USANYS) Sent: Wednesday, October 21, 2020 10:19 AM To: Cc: ) Subject: RE: GM -- search warrant returns (USANYS) (USANYS) + +We ran into this issue in GEP and marked them non-responsive. + +From: Sent: Wednesday, October 21, 2020 10:15 AM To: (USANYS) (USANYS) + +I just spoke with Flatley about the partial emails and empty attachments. He explained that for those files, because of the platform Epstein was using to check some of his emails, the FBI's technology was not able to extract the full emails and attachments. So what we see on Relativity is what the FBI has as well. + +Given that answer, do we want to mass mark the empty attachments as non-responsive? Or should we include the empty attachment files as related to the responsive partial emails? + +From: (USANYS) + +Sent: Tuesday, October 20, 2020 6:04 PM + +To: (USANYS) < + +Cc: (USANYS) + +Subject: RE: GM -- search warrant returns + +Great, this all makes sense to me. + +From: + +Sent: Tuesday, October 20, 2020 5:34 PM + +To: (USANYS) < (USANYS) + +Cc: ) (USANYS) + +Subject: RE: GM -- search warrant returns + +Yes, my view is that these would be responsive to 2, 3, 4, 5, and 6. And confirmed that these have been deduped. + +I'm going to go through and do a few more spot checks to try to weed out any more false hits. My hope is that we can clarify the empty attachments with Flatley tomorrow and then ask PAE to start bates stamping the remaining responsive documents for production tomorrow. + +Please let me know if you'd like to discuss anything else in the meantime. + +From: (USANYS) + +Sent: Tuesday, October 20, 2020 4:51 PM + +To: (USANYS) < + +Cc: (USANYS) + +Subject: RE: GM -- search warrant returns + +Thanks, this is helpful. It seems like the= and jeevacation hits (which had two of the highest hit rates in the STR) would be responsive to #6 (and possibly #2, 3, 4, or 5) — is that right? And have these documents been de-duped? + +2. Evi • identity or location of co-conspirators of JEFFREY EPSTEDI. including and GHISLAINE MAXWELL] + +3. Evidence COIKeflaill to. from. by. anclior among CO-CODSIXIMOTS of JEFFREY EPSTEIN. including and GHISLAINE MAXWELL + +4. Any documents or communications with or regarding victims or potential victims of the Subject Offenses. + +5. Documents or records reflecting payments to victims andlor co-conspirators including but not limited to bank and financial records. spreadsheets. ledgers. account listings. check and wire records. and documents reflecting cash withdrawals. + +6. Documents or records reflecting travel plans or arrangements for victims or potential victims of the Subject Offenses. or co-conspirators in those Subject Offenses. including + +Given that the warrant authorizes seizing data from a more than 20-year period, and given the extent to which Epstein traveled, having this many responsive documents does not seem crazy to me. Particularly if you've already tried to weed out the spam, and spot-checked the responsive documents for each search term to make sure it wasn't pulling in false hits. + +From: + +Sent: Tuesday, October 20, 2020 3:58 PM + +To: (USANYS) (USANYS) + +Cc: ) c )'; (USANYS) < + +Subject: RE: GM -- search warrant returns + +Sure, the warrant is attached. + +From: (USANYS) + +Sent: Tuesday, October 20, 2020 3:52 PM + +To: (USANYS) + +Cc: (USANYS) c + +Subject: RE: GM -- search warrant returns + +Thanks Let's see what Flatley says about the attachments. Do you mind sending the rider for the warrant that we would be seizing these materials pursuant to? + +From: + +Sent: Tuesday, October 20, 2020 2:12 PM + +To: (USANYS) (USANYS) + +Cc: ) c >; (USANYS) + +Subject: RE: GM -- search warrant returns + +Update from + +There are 128,175 email attachments attached to emails with search term hits that are empty files. review of the emails to which these empty files attached suggests that the FBI only provided us with partial files for these emails. Unclear whether those partial files are all that the FBI was able to extract from the devices, or whether the FBI left out parts of these files when producing them to us. I have asked Flatley for a call tomorrow morning to discuss. + +- 1,087,903 are emails (majority featuring Epstein as sender or recipient) +- 323,179 are email attachments (128,175 of which are empty files as discussed above) +- The remaining 36,619 are a mix of non-email files with no association with emails, such as Word, PDF, PowerPoint, and Excel files. + +From: (USANYS) + +Sent: Tuesday, October 20, 2020 8:26 AM + +To: >; (USANYS) + +Cc: (USANYS) + +Subject: RE: GM -- search warrant returns + +I tend to agree that if we really do have hundreds of thousands of emails between Epstein and =I talking about the logistics of travel or meetings with women, we have a good faith basis to tag those as responsive. To the extent defense counsel (or we) want(s) to run search terms within those hundreds of thousands of emails focused on particular names or time periods, they are free to do so, and we may well want to do so. + +Also agree on drilling down on the attachment issue. Sorry for the issue with Flatley, which is really annoying. Please let us know what you learn from him when he's back tomorrow. + +From: + +Sent: Tuesday, October 20, 2020 8:14 AM + +To: (USANYS) + +Cc: (USANYS) + +(USANYS) + +Subject: Re: GM -- search warrant returns + +I can ask about the attachments. is out today, so I cannot ask CART until tomorrow. + +On Oct 20, 2020, at 7:28 AM, (USANYS) C wrote: + +Thanks Those certainly do sound like they would be responsive. But I can imagine improperly extracted attachments being something the defense will certainly complain about- can we go back to CART or to ask them to figure out what happened and whether there is a way to fix it, or we just have to live with that (for instance, maybe the attachments were deleted or partially overwritten). + +On Oct 19, 2020, at 11:47 PM, ) , > wrote: + +Following up on this, I've done a spot check of a couple hundred of these hits, and the vast majority are emails with Epstein as a sender or recipient. A small number were spam emails, though I did not see any repeat emails from spam senders. The majority were emails discussing logistics, such as travel, phone calls, and meetings, including the travel plans of individuals with female names. Most of these logistics emails are with =. There are also emails about paying for school for people with female names, renovations to Epstein's properties, Epstein's finances, and miscellaneous emails about people with female names (e.g., discussing the physical appearance of various females, Epstein asking to have a threesome, modelling photos). + +Most were just blank pages when I clicked through them. So one way to narrow the responsive category would be just to take the documents with hits and not the entire family of documents along with them. + +From: Sent: Monday, October 19, 2020 10:37 PM To: (USANYS) (USANYS) Cc: (USANYS) Subject: RE: GM -- search warrant returns + +I'm struggling to think of a way to limit '=' or "jeevaction" more because: + +- is last name. Because she was Epstein's primary secretary who handled the travel logistics for Epstein, his employees, and the victims who traveled. So it makes sense that her last name has so many hits. Those will include essentially all of the day-to-day communications regarding Epstein's schedule and travel. +- The term "jeevacation" is the phrase Epstein used for the majority of his email addresses (e.g., jeevacation@gmail.com jeevacation@yahoo.com etc.). So it's unsurprising that this phrase is the highest hit. I suspect that number reflects the majority of Epstein's emails. We ran that search term because we do not know all of the email addresses Epstein used, and we suspected that there were more domains with "jeevacation" email accounts than we knew about. + +We've already run search terms to cut out spam, though we can certainly try to find more. + +From: (USANYS) Sent: Monday, October 19, 2020 9:21 PM To: ) Cc: Subject: RE: GM -- search warrant returns (USANYS) (USANYS) C + +Thanks, this is a helpful start. I would recommend we think about how we can perhaps narrow or focus our search terms a bit, perhaps through combinations/connectors or other means, particularly for common names/words that are likely to generate a significant number of hits. For example, "David" turns up nearly 40,000 hits, and "flight" or "flights" turns up over 100,000 just to pick a few. + +Also, curious as to why' " turns up 450,000 hits and "jeevacation" (which I'm not familiar with but assume you all are?) turns up 750,000. Those two alone seem to account for the overwhelming majority of documents we've identified, so if there's a way to focus those two in particular, that might be a big help. + +One thing you might want to do is just review a couple hundred random hits, if you haven't already, to get a bit of a flavor for what we're turning up, as that may help inform our efforts to focus the search. I think we may also have the technology to weed out spam and potentially duplicates, if we haven't already, but defer to others with more experience in those areas.... + +From: Sent: Monday, October 19, 2020 8:51 PM To: (USANYS) (USANYS) Cc: (USANYS) Subject: RE: GM -- search warrant returns + +The STR report is attached, in case that's useful. + +From: Sent: Monday, October 19, 2020 8:44 PM To: (USANYS) Cc: (USANYS) (USANYS) Subject: RE: GM -- search warrant returns + +Thanks, M. Taking these one by one: + +- We designated certain email accounts responsive, per our discussion, at that yielded 90,000 emails. The balance of the 1.4 million emails/documents comes from search terms. +- The database contains all kinds of documents—word, PDF, and excel. I haven't seen any texts, and it's mainly the kinds of things you'd expect to be saved on someone's computer. +- I don't have numbers by search term, but will check on that and circle back. We sent a list of terms to and asked him to execute, so I'm not sure about the breakdown. +- Yes, Maxwell is a search term and her email account has been designated responsive. + +From: (USANYS) + +Sent: Monday, October 19, 2020 8:37 PM + +To: (USANYS) Cc: (USANYS) Subject: RE: GM -- search warrant returns + +Thanks, Couple of follow up questions on this, and happy to set up a call if that's easier. + +First, am I understanding correctly that we ran all of our search terms and came up with 90,000 responsive emails and 1.31 million other responsive documents? Or is the 90,000 figure just email account? + +Second, and related, with respect to the non-email documents, whatever their volume, do you have a sense of what kinds of documents we're talking about? Word documents, texts, excel spreadsheets, some combination thereof? + +Third, do you know how many documents hit on each term? If we came up with 1 million hits on the names of the victims, that's one thing, but if we came up with a million hits on the word "flight" or "passenger" we might want to think about whether to narrow the terms a bit. + +Also, I presume we ran Maxwell's name as one of the co-conspirators and ran any email account of hers we identified as one of the email accounts? + +As noted, happy to jump on a call tomorrow if that's easier. + +Thanks, + +From: + +Sent: Monday, October 19, 2020 8:14 PM + +To: (USANYS) (USANYS) Cc: (USANYS) Subject: GM — search warrant returns + +We've run our responsiveness search terms for the search warrant returns, and they yield a total of 1.4 million documents. As a breakdown, 90,000 of those items are emails we designated responsive by account (for example, . The remaining documents are hits on our search terms, which included the first and last names of every victim and suspected co-conspirators, as well as specific keywords (e.g., passenger, flight). The total database is 1.6 million documents. + +1.4 million documents is obviously a substantial portion of the 1.6 million document database. Given our prior discussions, our understanding is that the office is okay with us designating all of these documents responsive, but please let us know if you'd like us to take a different approach. + +Thanks, + +Assistant United States Attorney Southern District of New York One Saint Andrew's Plaza New York, NY 10007 \ No newline at end of file diff --git a/marker2/ds9/EFTA00089649/EFTA00089649.metadata.json b/marker2/ds9/EFTA00089649/EFTA00089649.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..fc27cbeb5068fb465f4f112b26e4f29428093bbf --- /dev/null +++ b/marker2/ds9/EFTA00089649/EFTA00089649.metadata.json @@ -0,0 +1,258 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089649.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 7, + "chars": 14064, + "elapsed_seconds": 1.84, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 96 + ], + [ + "Line", + 45 + ], + [ + "Text", + 12 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 66 + ], + [ + "Line", + 33 + ], + [ + "Text", + 24 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 99 + ], + [ + "Line", + 47 + ], + [ + "Text", + 27 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 3, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 83 + ], + [ + "Line", + 42 + ], + [ + "Text", + 20 + ], + [ + "ListItem", + 3 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 4, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 93 + ], + [ + "Line", + 44 + ], + [ + "Text", + 10 + ], + [ + "ListItem", + 2 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 5, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 83 + ], + [ + "Line", + 41 + ], + [ + "Text", + 16 + ], + [ + "ListItem", + 4 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 6, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 17 + ], + [ + "Line", + 9 + ], + [ + "Text", + 6 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089649" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089656/EFTA00089656.md b/marker2/ds9/EFTA00089656/EFTA00089656.md new file mode 100644 index 0000000000000000000000000000000000000000..96c0ec7cc615ffae8fd41ee2e781ed39a28e1f20 --- /dev/null +++ b/marker2/ds9/EFTA00089656/EFTA00089656.md @@ -0,0 +1,31 @@ +To: + +Subject: RE: Relativity + +Date: Tue, 27 Oct 2020 00:21:32 +0000 + +No problem. I went through these, and none of this is Rule 16 material in my view. I think we should review these for 3600 disclosures, as we'll want to turn over the majority of this, which consists of text messages, meeting notes, and meeting reports. The other materials in here are charts of victim contact information and print outs of articles about Jeffrey Epstein. + +From + +Sent: Monda October 26 2020 5:53 PM + +To + +Su •Jed: • : •e ativity + +Thanks so much. If you have time to review the documents we just received from the GA USAO, that would be terrific. They are all saved here: \\ Usa.doj.gov \ cloud \ NYS \ StAndrews \ Shared \ USvEpstein-2018R01618 \ Investigation \ Materials from GA USAO + +From: + +Sent: Monday, October 26, 2020 5:27 PM + +To: + +Subject: Relativity + +Hi team, + +I'm done with my last batch, which means we should be done with the Relativity review of the FOIA dots—so those should be ready to go out, wheneve .ets through the current queue. What doc review project should we be turning to next? + +Assistant United States Attorney Southern District of New York One Saint Andrew's Plaza 07 \ No newline at end of file diff --git a/marker2/ds9/EFTA00089656/EFTA00089656.metadata.json b/marker2/ds9/EFTA00089656/EFTA00089656.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..da694cf893c6e203c14a2a16e52490c3fc79351d --- /dev/null +++ b/marker2/ds9/EFTA00089656/EFTA00089656.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089656.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1179, + "elapsed_seconds": 0.83, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 57 + ], + [ + "Line", + 28 + ], + [ + "Text", + 17 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089656" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089657/EFTA00089657.md b/marker2/ds9/EFTA00089657/EFTA00089657.md new file mode 100644 index 0000000000000000000000000000000000000000..8a326556f6b2759c2540ffe39e3a77a539954974 --- /dev/null +++ b/marker2/ds9/EFTA00089657/EFTA00089657.md @@ -0,0 +1,127 @@ +To: ' < + +Subject: RE: Grand Jury Materials for Federal Investigation + +Date: Mon, 26 Oct 2020 22:40:49 +0000 + +Apologies, I was tied up in court and on calls all day. I will give you a call tomorrow. + +Thank you, + +Assistant United States Attorney Southern District of New York + +New York, NY 10007 + +From: + +Sent: Monday, October 26, 2020 4:23 PM + +To: + +Subject: RE: Grand Jury Materials for Federal Investigation + +Please give me a call when you get a chance so we can discuss transfer of documents. Thank you, + +From: + +Sent: Friday, October 23, 2020 5:51 PM + +To: + +Cc: + +Subject: RE: Grand Jury Materials for Federal Investigation + +Note: This email was sent from a source external to Palm Beach County. Links or attachments should not be accessed unless expected from a trusted source. + +Good evening, + +Attached please find a signed unsealing order. + +Assistant United States Attorney Southern District of New York New York, NY 10007 + +From: Sent: Thursday, October 15, 2020 9:28 PM To: ' Cc Subject: RE: Grand Jury Materials for Federal Investigation + +Thank you very much. I will send you the unsealing order as soon as it is signed. + +From: Sent: Thursday, October 15, 2020 9:25 PM To: Cc: Subject: Re: Grand Jury Materials for Federal Investigation + +Case No. 50-2006-CF-009454 AXX in 15th Judicial Circuit ,Palm Beach County, Florida. + +On Oct 15, 2020, at 4:59 PM, wrote: + +Note: This email was sent from a source external to Palm Beach County. Links or attachments should not be accessed unless expected from a trusted source. + +His + +Following up on my original email to s below, we would be very grateful for any guidance regarding how we might obtain copies of the grand jury materials related to Jeffrey Epstein. We are happy to have a call to discuss if that would be useful. + +Thank you, + +Assistant United States Attorney Southern District of New York New York, NY 10007 + +From: C + +Sent: Thursday, October 15, 2020 4:49 PM + +To: + +Cc: + +Subject: RE: Grand Jury Materials for Federal Investigation + +Hi + +I'm not exactly the right person to ask — I handle communications for the office. However, I can connect you with the person who can walk you through the process here: our Chief Operating Officer for Courts and Legal Records and our Acting General Counsel. + +I've copied her on this email so you have her contact information. + +Thank you, + +Chief Communications Officer + +Executive + +Clerk & Comptroller Palm Beach County Serving the Citizens of Palm Beach County 301 N. Olive Ave., 9th Floor West Palm Beach, FL 33401 Direct + +www.mypalmbeachclerk.com [protect2.fireeye.com] + +Tell us how we're doing at www.mypalmbeachclerk.com/survey [protect2.fireeye.con].l + +imaue00 I rotectl firceve coin + +twitter.com )rotect2.fireeve coin )rotect2.fireeye.com] + +ima e001 rotectl firceve coin + +facehook.com roteet2.firceve.com protect2.fireeye.com] + +ima 0001 > rower> firceye com + +Please be advised that Florida has a broad public records law, and all correspondence to me may be subject to disclosure. Under Florida public records laws email addresses are public records. If you do not want your email address released in response to a public records request, do not send electronic mail to this entity. Instead, contact this office by phone or in writing. + +From: [mailto:l + +Sent: Thursday, October 15, 2020 4:25 PM + +To: + +Cc: .; (USANYS) + +Subject: Grand Jury Materials for Federal Investigation + +\*\*\*\*\*\* Note: This email was sent from a source external to Palm Beach County. Links or attachments should not be accessed unless expected from a trusted source. \*\*\*\*\*\* + +The Office of the State Attorney for the 15th Judicial Circuit provided me with your contact information and suggested you may be able to assist my office with a request for records. Together with my colleagues AUSA and AUSA (both cc'd), I am one of the federal prosecutors handling the ongoing investigation regarding Jeffrey Epstein and prosecution of Ghislaine Maxwell. + +We understand that evidence, including witness testimony, relevant to our investigation may have been presented to a grand jury in your courthouse in connection with the prosecution of Jeffrey Epstein. How might our office obtain a copy of any transcripts, records, and related materials from those grand jury presentations? When seeking such items from state courts in New York, we regularly obtain unsealing orders from a federal judge in our district. Would such an order suffice for your court, or are there other procedures you would like us to follow? + +We are happy to have a phone call to discuss this request if that would be useful. I can be reached by email or at the phone number below. + +Thank you very much for your assistance. + +Best, + +Assistant United States Attorney Southern District of New York + +New York, NY 10007 \ No newline at end of file diff --git a/marker2/ds9/EFTA00089657/EFTA00089657.metadata.json b/marker2/ds9/EFTA00089657/EFTA00089657.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..01a456f6b1d3674c382a9b8f455b1df6e91d86e1 --- /dev/null +++ b/marker2/ds9/EFTA00089657/EFTA00089657.metadata.json @@ -0,0 +1,144 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089657.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 4, + "chars": 4755, + "elapsed_seconds": 1.46, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 49 + ], + [ + "Text", + 28 + ], + [ + "Line", + 25 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 55 + ], + [ + "Line", + 27 + ], + [ + "Text", + 11 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 89 + ], + [ + "Line", + 42 + ], + [ + "Text", + 28 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 3, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 37 + ], + [ + "Line", + 18 + ], + [ + "Text", + 12 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089657" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089661/EFTA00089661.md b/marker2/ds9/EFTA00089661/EFTA00089661.md new file mode 100644 index 0000000000000000000000000000000000000000..0ac21627aa9b04386481350df2ae42476677a494 --- /dev/null +++ b/marker2/ds9/EFTA00089661/EFTA00089661.md @@ -0,0 +1,42 @@ +From: To: Cc: Subject: Re Date: Tue, 27 Oct 2020 21:18:13 +0000 Igo " Ii(USANYS)" M> " FBI)" + +Just met withed his We could not find a good phone number for him but he does not live that far from the city so we knocked on his door. His daughter advised us that his English is not good and she would translate for him. I told him we would just like to speak to him about his former employer over video conference. They acknowledged that the knew I was referring to Epstein. She told us he is currently represented by Aitan Gohlman and they prefer all communications go through him. Do you guys wanna take it from here? + +On Oct 27, 2020, at 13:14, wrote: + +I should add: if he prefers to meet in person and you want to do a field interview without us in the first instance, that's fine. Thanks. + +Sent from my iPhone + +On Oct 27, 2020, at 12:38 PM, wrote: + +Also, if he's willing to come into our office would you guys be ok with doing that or do you still prefer Webex? + +Detective NYPD / FBI Child Exploitation Human Trafficking Task Force Office: Cell: Fax: + +From: Sent: Tuesday, October 27, 2020 12:30 PM To: I c . (NY) (FBI) < Cc: (USANYS) Subject: Re: + +He currently lives on I can reach out and see if he's willing to chat with us. Would you like to provide us with a subpoena for him? + +Detective NYPD / FBI Child Exploitation Human Trafficking Task Force Office: + +**From:** [REDACTED] <[REDACTED]> +**Sent:** Wednesday, October 21, 2020 8:53 PM +**To:** [REDACTED]. (NY) (FBI) <[REDACTED]>; [REDACTED] <[REDACTED]> +**Cc:** [REDACTED] <[REDACTED]>; [REDACTED] (USANYS) +<[REDACTED]> +**Subject:** [REDACTED] + +[REDACTED], + +What do you think of reaching out to [REDACTED] for an interview? Happy to discuss next time we speak—can you check to see if he is in the area? + +Thanks, + +[REDACTED] + +[REDACTED] +Assistant United States Attorney +Southern District of New York + +[REDACTED] \ No newline at end of file diff --git a/marker2/ds9/EFTA00089661/EFTA00089661.metadata.json b/marker2/ds9/EFTA00089661/EFTA00089661.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..aa83fdb08e16fd9cab990775a6e6fc28435b9a51 --- /dev/null +++ b/marker2/ds9/EFTA00089661/EFTA00089661.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089661.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 1882, + "elapsed_seconds": 3.08, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 83 + ], + [ + "Line", + 39 + ], + [ + "Text", + 11 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 27 + ], + [ + "Text", + 22 + ], + [ + "Line", + 14 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089661" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089663/EFTA00089663.md b/marker2/ds9/EFTA00089663/EFTA00089663.md new file mode 100644 index 0000000000000000000000000000000000000000..6e162317c308608c747748d5ffcec9bf2285ad8f --- /dev/null +++ b/marker2/ds9/EFTA00089663/EFTA00089663.md @@ -0,0 +1,98 @@ +# UNITED STATES DISTRICT COURT + +for the Southern District of New York + +In the Matter of the Search of (Briefly describe the property to be searched or identiry, the person by name and address) 3 electronic devices seized on July 11, 2019 from 9 East 71st Street, New York, NY Case No. + +## SEARCH AND SEIZURE WARRANT + +To: Any authorized law enforcement officer + +An application by a federal law enforcement officer or an attorney for the government requests the search of the following person or property located in the Southern District of New York (identify thethe person or describe the properry,to be searched and give its location): + +See Attachment A + +The person or property to be searched, described above, is believed to conceal (identify the person or describe the property to be seized): + +See Attachment A + +The search and seizure are related to violation(s) of (insert statutory citations): + +18 U.S.C. 1591; 18 U.S.C. 2422; 18 USC 2423; 18 U.S.C. 371 + +I find that the affidavit(s), or any recorded testimony, establish probable cause to search and seize the person or property. + +YOU ARE COMMANDED to execute this warrant on or before November 10, 2020 + +(not to exceed 14 days) + +in the daytime 6:00 a.m. to 10 p.m. O at any time in the day or night as I find reasonable cause has been established. + +Unless delayed notice is authorized below, you must give a copy of the warrant and a receipt for the property taken to the person from whom, or from whose premises, the property was taken, or leave the copy and receipt at the place where the property was taken. + +The officer executing this warrant, or an officer present during the execution of the warrant, must prepare an inventory as required by law and promptly return this warrant and inventory to the Clerk of the Court. + +Upon its return, this warrant and inventory should be filed under seal by the Clerk of the Court. + +USMJ Initials + +O I find that immediate notification may have an adverse result listed in 18 U.S.C. § 2705 (except for delay of trial), and authorize the officer executing this warrant to delay notice to the person who, or whose property, will be searched or seized (check the appropriate box) Ofor 30 days (not to exceed 30). + +°until, the facts justi ing, the later specific date of + +Date and time issued: October 27, 2020 / 7:20 pm + +to c signature + +#### Return + +Case No.: Date and time warrant executed: Copy of warrant and inventory left with: + +Inventory made in the presence of : + +Inventory of the property taken and name of any person(s) seized: + +#### Certification + +I declare under penalty to the Court. of perjury that this inventory is correct and was returned along with the original warrant + +Date: + +Executing officer's signature + +Printed name and title + +#### Attachment A + +### I. Devices Subject to Search and Seizure + +The devices that are the subject of this search and seizure warrant (the "Subject Devices") are described as follows: + +The Subject Devices were recovered from a search of JEFFREY EPSTEIN's private residence located at 9 East 71st Street, New York, New York, which took place on July 11, 2019. The Subject Devices are particularly described as follows: + +- a. A "Seagate Path 100" hard drive, which was seized from inside a book shelf cabinet in an oval study on the first floor of the New York Residence, and which has been assigned internal FBI barcode number E6433822 ("Corrected Subject Device-32"); +- b. A "Seagate Path 100" hard drive, which was seized from inside a book shelf cabinet in an oval study on the first floor of the New York Residence, and which has been assigned internal FBI barcode number E6433824 ("Corrected Subject Device-33"); and +- c. A "Seagate Path 100" hard drive, which was seized from inside a book shelf cabinet in an oval study on the first floor of the New York Residence, and which has been assigned internal FBI barcode number E6433821 ("Corrected Subject Device-34"). + +## II. Review of ESI on the Subject Devices + +Law enforcement personnel (who may include, in addition to law enforcement officers and agents, attorneys for the government, attorney support staff, agency personnel assisting the government in this investigation, and outside technical experts under government control) are authorized to review the ESI contained on the Subject Device for evidence, fruits, and instrumentalities of violations of Title 18, United States Code, Sections 1591 (sex trafficking of minors), 2422 (transportation of minors), 2423 (enticement to travel), and 371 (conspiracy to commit sex trafficking, transportation of minors, and enticement to travel) (the "Subject Offenses"), for the period 1994 through August 8, 2019, described as follows: + +- 1. Evidence concerning the identity or location of the owner(s) or user(s) of the Subject Devices. +- 2. Evidence concerning the identity or location of co-conspirators of JEFFREY EPSTEIN, including and GHISLAINE MAXWELL. +- 3. Evidence concerning communications to, from, by, and/or among co-conspirators of JEFFREY EPSTEIN, including' and GHISLAINE MAXWELL. +- 4. Any documents or communications with or regarding victims or potential victims of the Subject Offenses. + +5. Documents or records reflecting payments to victims and/or co-conspirators including but not limited to bank and financial records, spreadsheets, ledgers, account listings, check and wire records, and documents reflecting cash withdrawals. + +6. Documents or records reflecting travel plans or arrangements for victims or potential victims of the Subject Offenses, or co-conspirators in those Subject Offenses, including but not limited to itineraries, tickets, receipts, flight manifests, passport or identification information, and related records. + +7. Any photographs of victims or potential victims of the Subject Offenses. + +8. Any nude, partially nude, or sexually suggestive photographs of individuals who appear to be teenage girls, or younger. + +9. Records or other items that evidence ownership, control, or use of, or access to devices, storage media, and related electronic equipment used to access, transmit, or store information relating to the Subject Offenses, including, but not limited to, sales receipts, warranties, bills for Internet access, handwritten notes, registry entries, configuration files, saved usernames and passwords, user profiles, e-mail contacts, and photographs. + +10. Any child erotica, defined as suggestive visual depictions of nude minors that do not constitute child pornography as defined by 18 U.S.C. § 2256(8). + +If the Government determines that any of the Subject Devices is no longer necessary to retrieve and preserve the data on the device, and that any of the Subject Devices is not subject to seizure pursuant to Federal Rule of Criminal Procedure 41(c), the Government will return any such Subject Device, upon request. \ No newline at end of file diff --git a/marker2/ds9/EFTA00089663/EFTA00089663.metadata.json b/marker2/ds9/EFTA00089663/EFTA00089663.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..665e18f2f641d658c30aab8aa72d3e2f2671c91e --- /dev/null +++ b/marker2/ds9/EFTA00089663/EFTA00089663.metadata.json @@ -0,0 +1,334 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089663.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 4, + "chars": 6824, + "elapsed_seconds": 1.39, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 170.13600000000002, + 65.1243896484375 + ], + [ + 443.9737854003906, + 65.1243896484375 + ], + [ + 443.9737854003906, + 87.427734375 + ], + [ + 170.13600000000002, + 87.427734375 + ] + ] + }, + { + "title": "SEARCH AND SEIZURE WARRANT", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 194.61599999999999, + 223.56000000000003 + ], + [ + 417.59759521484375, + 223.56000000000003 + ], + [ + 417.59759521484375, + 239.36248779296875 + ], + [ + 194.61599999999999, + 239.36248779296875 + ] + ] + }, + { + "title": "Return", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 286.41600000000005, + 55.89000000000001 + ], + [ + 325.2778625488281, + 55.89000000000001 + ], + [ + 325.2778625488281, + 68.72406005859375 + ], + [ + 286.41600000000005, + 68.72406005859375 + ] + ] + }, + { + "title": "Certification", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 273.564, + 519.21 + ], + [ + 338.31561279296875, + 519.21 + ], + [ + 338.31561279296875, + 532.9740600585938 + ], + [ + 273.564, + 532.9740600585938 + ] + ] + }, + { + "title": "Attachment A", + "heading_level": null, + "page_id": 2, + "polygon": [ + [ + 267.44399999999996, + 72.08999999999999 + ], + [ + 346.0738525390625, + 72.08999999999999 + ], + [ + 346.0738525390625, + 86.103515625 + ], + [ + 267.44399999999996, + 86.103515625 + ] + ] + }, + { + "title": "I. 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AUSA + +Date: Wed, 28 Oct 2020 23:18:13 +0000 + +Embedded: FW:\_Email\_2\_of 2:\_Sigmed\_warrant\_for 3\_devices\_(EPSTEINLAUS).msg + +Sender: + +Subject!...aMllign warrant 13 devices (EPSTEIN; AUSA\_) + +Message-Id: + + + +Recipient: \ No newline at end of file diff --git a/marker2/ds9/EFTA00089668/EFTA00089668.metadata.json b/marker2/ds9/EFTA00089668/EFTA00089668.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..1c90f79d25881ae83c27659c7157b50b5ae2de83 --- /dev/null +++ b/marker2/ds9/EFTA00089668/EFTA00089668.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089668.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 449, + "elapsed_seconds": 0.64, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 23 + ], + [ + "Text", + 13 + ], + [ + "Line", + 12 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089668" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089669/EFTA00089669.md b/marker2/ds9/EFTA00089669/EFTA00089669.md new file mode 100644 index 0000000000000000000000000000000000000000..ae562dda90d773118985600e90ae5f093f9bb453 --- /dev/null +++ b/marker2/ds9/EFTA00089669/EFTA00089669.md @@ -0,0 +1,13 @@ +To: Criminal Case O s NYSD >, "Arraignment NYSD" II + +Subject: FW: Email 2 of 2: Signed warrant for 3 devices (EPSTEIN; AUSA =I) + +Date: Wed, 28 Oct 2020 23:17:56 +0000 + +Attachments: 2020.10.27\_Unsigned\_Warrant\_for\_3\_Drives\_from\_NY\_Residencefflattened).pdf + +From: Sent: Tuesda , October 27, 2020 7:25 PM + +To: Subject: Email 2 of 2: Signed warrant for 3 devices (EPSTEIN; AUSA l) + +Sent from my mobile device \ No newline at end of file diff --git a/marker2/ds9/EFTA00089669/EFTA00089669.metadata.json b/marker2/ds9/EFTA00089669/EFTA00089669.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..f61b88fd5c487a5f05d570c337b401e5fcbf4935 --- /dev/null +++ b/marker2/ds9/EFTA00089669/EFTA00089669.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089669.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 412, + "elapsed_seconds": 0.48, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 24 + ], + [ + "Line", + 12 + ], + [ + "Text", + 9 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089669" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089670/EFTA00089670.md b/marker2/ds9/EFTA00089670/EFTA00089670.md new file mode 100644 index 0000000000000000000000000000000000000000..3aae6b3650a89f4d64df270b9b91d30039597902 --- /dev/null +++ b/marker2/ds9/EFTA00089670/EFTA00089670.md @@ -0,0 +1,139 @@ +From: BOBBI C STERNHEIM + +To:'1 < + +Subject: Re: Ghislaine Maxwell (02879-509) + +Date: Mon, 02 Nov 2020 19:21:00 +0000 + +Thank you. + +BOBBI C. STERNHEIM, ESQ. Law Offices of Bobbi C. Stemheim 33 West 19th Street - 4th Floor New York, NY 10011 + +Main: 212-243-1100 Cell: 917-912-9698 Fax: 888-587-4737 bcstemheim@mac.com + +"Covid-19 Notice: The %Vest 19th Street office is currently closed but we continue to work remotely. + +Please use email or fax, instead of regular mail, for all correspondence during this time. + +We continue to work regular business hours throughout this situation. + +Thank you for your consideration. Our best wishes for your good health and well being. + +This message and any attached documents contain information from the Law Offices of Bobbi C. Stemheim + +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 Nov 2, 2020, at 11:05 AM, > wrote: + +Bobbi, + +This morning, I spoke with MDC legal counsel regarding the concerns you raised. MDC legal counsel conveyed the following: + +- Within the last approximately 48 hours, MDC staff has conducted temperature checks in Ms. Maxwell's cell, all of which revealed that the temperature in Ms. Maxwell's cell was between 71 and 74 degrees. MDC legal counsel noted that the target temperature for the MDC during this season is 68 degrees. MDC staff also gave Ms. Maxwell an extra blanket, so she now has three blankets in her isolation cell. +- MDC staff physically entered Ms. Maxwell's cell and did not observe any smell or moisture. The unit team leader physically felt the papers in Ms. Maxwell's cell and observed that they felt normal and in no way damaged by moisture. +- MDC staff will ensure that Ms. Maxwell is able to bring a cup and a snack with her into her isolation cell. + +Assistant United States Attorney Southern District of New York I St. Andrew's Plaza + +From: BOBBI C STERNHEIM + +Sent: Sunday, November 1, 2020 1:50 PM + +To: Cc: aa; Subject: Re: Ghislaine Maxwell (02879-509) (USANYS) + +Thank you. Please keep me informed. Best-Bobbi + +BOBBI C. STERNHEIM, ESQ. Law Offices of Bobbi C. Sternheim 33 West 19th Street - 4th Floor New York, NY 10011 + +Main: 212-243-1100 Cell: 917-912-9698 Fax: 888-587-4737 + +bcsternheim@mac.com + +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 notO, the sender immediately by reply e-mail and then delete this message. Thank you. + +On Nov I, 2020, at 1:03 PM, > wrote: + +Thank you for reaching out regarding these concerns. I am forwarding your email to MDC legal counsel and will follow up to look into these issues. Please do not hesitate to reach out if any other concerns arise, and I will let you know when I have an update regarding the conditions in Ms. Maxwell's isolation cell. + +Best, + +[REDACTED] +[REDACTED] +Assistant United States Attorney +Southern District of New York +1 St. Andrew's Plaza +New York, NY 10007 +[REDACTED] +[REDACTED] + +--- + +**From:** BOBBI C STERNHEIM <[bcsternheim@mac.com](mailto:bcsternheim@mac.com)> + +**Sent:** Sunday, November 1, 2020 12:41 PM + +**To:** [REDACTED] <[REDACTED]> + +**Cc:** [REDACTED] <[REDACTED]>; [REDACTED] (USANYS) <[REDACTED]> + +**Subject:** Ghislaine Maxwell (02879-509) + +Good afternoon- + +I write to request immediate assistance for Ghislaine Maxwell. + +There are many conditions and restrictions placed upon her at the MDC that are of great complaint, but of immediate concern are conditions within Ms. Maxwell's isolation cell. + +The combination of cold, moisture, and sewage stench have made confinement in her cell unhealthy, unbearable, and utterly unreasonable. + +Her request for an extra blanket has been denied. + +Her request for use of her day mug for water has been denied. + +(She's been told to cup her hands to drink water from the faucet.) + +Her request to keep a snack in her cell has been denied. + +The moisture accumulating in her cell risks her health and the security of her legal work. + +You have known me and my reputation among your colleagues and the court. + +Trust me when I way that in my 35 years of federal criminal practice, having represented individuals charged and convicted of terrorism and capital murder, housed in MCC's 10South and FCI Florence-ADMAX (facilities I have visited), I have never witnessed such inappropriate and outlandish treatment of a non-violent pretrial detainee held on risk of flight. The mistreatment of Ghislaine Maxwell reflects negatively on your Office, the Court, and the BOP. The Government as a whole can and needs to do better. + +For today, we seek the bare minimum - a change of cell to a location that is safe from the cold, moisture, and stench, and an extra blanket to keep her warm. The rest will be left for another day. + +Please assist. + +Thank you- +Bobbi + +BOBBI C. STERNHEIM, ESQ. Law Offices of Bobbi C. Sternheim 33 West 19th Street - 4th Floor New York, NY 10011 + +Main: 212-243-1100 Cell: 917-912-9698 Fax: 888-587-4737 bcstemheim@mac.com + +••Covid-19 Notice: The \Vest 19th Street office is currently closed but we continue to work remotely. + +Please use email or fax, instead of regular mail, for all correspondence during this time. + +We continue to work regular business hours throughout this situation. + +Thank you for your consideration. Our best wishes for your good health and well being. + +This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim + +that may be confidential and/or privileged. + +If you are not the intended recipient, you may not read, copy, distribute, or use this information. + +If you have received this transmission in error, please notify the sender immediately by reply e-mail and then delete this message. 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I just uploaded them to USAfx for [♦to **download.** + +**From:** + +**Sent: Tuesday, July 7, 2020 5:25 PM** + +**To:** + +**Cc:** + +**Subject: FW: SDNY Investigation** + +**Hi** + +**In a moment, I'll forward you two emails with subpoena returns from UBS. Could you please unzip the files (password below), save them in the Epstein shared, update the subpoena tracker, and reach out t o provide him with a copy?** + +**Thanks!** + +**From:** + +**Sent: Tuesday, July 7, 2020 5:22 PM** + +**To:** + +**Subject: RE: SDNY Investigation** + +**You're welcome. The password for all is Max\_0707. Winzip directions are attached and 7-zip.org is also useful for opening files.** + +From: [REDACTED] + +Sent: Tuesday, July 7, 2020 4:17 PM + +To: [REDACTED] + +Cc: [REDACTED] + +Subject: [External] RE: SDNY Investigation + +[REDACTED] + +Received, and thanks very much. + +Best, + +[REDACTED] + +From: [REDACTED] + +Sent: Tuesday, July 7, 2020 5:13 PM + +To: [REDACTED] + +Cc: [REDACTED] + +Subject: SDNY Investigation + +[REDACTED] + +[REDACTED] + +Paralegal – Authorized Officer + +[REDACTED] + +[REDACTED] + +[REDACTED] + +![](_page_1_Picture_72.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00089674/EFTA00089674.metadata.json b/marker2/ds9/EFTA00089674/EFTA00089674.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..3b7334ffda1d2c8b3b8de45393854539a30e9907 --- /dev/null +++ b/marker2/ds9/EFTA00089674/EFTA00089674.metadata.json @@ -0,0 +1,90 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089674.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 1334, + "elapsed_seconds": 3.67, + "image_assets": [ + "_page_1_Picture_72.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 59 + ], + [ + "Line", + 29 + ], + [ + "Text", + 25 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 29 + ], + [ + "Text", + 27 + ], + [ + "Line", + 14 + ], + [ + "Picture", + 2 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089674" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089674/_page_1_Picture_72.jpeg b/marker2/ds9/EFTA00089674/_page_1_Picture_72.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..1bf8cd24f024c401e76f58fafec1d93101ad0ffe --- /dev/null +++ b/marker2/ds9/EFTA00089674/_page_1_Picture_72.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:431483b7399ce888f8eb207fce3fe7e2cde20a73a0238db8a5363475bf8c9d52 +size 2697 diff --git a/marker2/ds9/EFTA00089676/EFTA00089676.md b/marker2/ds9/EFTA00089676/EFTA00089676.md new file mode 100644 index 0000000000000000000000000000000000000000..8b0fe3d4dd74e4a2275e63fcd6e09e57e4dce5cb --- /dev/null +++ b/marker2/ds9/EFTA00089676/EFTA00089676.md @@ -0,0 +1,31 @@ +To: ' + +Subject: RE: Maxwell + +Date: Mon, 06 Jul 2020 13:45:41 +0000 + +Thanks very much, If you have an AJN tips, I'm sure we'd be all ears! + +From: + +Sent: Monday, July 6, 2020 8:38 AM + +To: + +Subject: FW: Maxwell + +Belated congratulations, and my condolences on the wheel out. Good luck going forward. I hope AJN loves your case as much as everyone else does. + +From: + +Sent: Thursday, July 2, 2020 10:43 AM + +To: + +Subject: Maxwell + +PCU — Please join me in congratulatinv on the arrest this morning of Ghislaine Maxwell. spoke a bit about the case on our call on Tuesday and the truly remarkable job the team has done in bringing it. I won't repeat all of that, buy you should know, as you read press coverage today that already is making it seem like these charges were inevitable, that they were anything but, and that they are instead the result of an extraordinary amount of work and perseverance and creativity by in building a case based on conduct that I'm pretty sure is older than all of our paralegals. + +Audrey will be holding a press conference at 12, and while it is sadly not possible for all of us to be there to join her given current conditions, I hope we can all take a moment to remotely congratulate the team on a terrific accomplishment in bringing an extremely important case against a woman very worthy of criminal prosecution. + +• \ No newline at end of file diff --git a/marker2/ds9/EFTA00089676/EFTA00089676.metadata.json b/marker2/ds9/EFTA00089676/EFTA00089676.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..fb8212fce6d151e575cb575dd9500e6ac8792993 --- /dev/null +++ b/marker2/ds9/EFTA00089676/EFTA00089676.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089676.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1343, + "elapsed_seconds": 0.81, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 53 + ], + [ + "Line", + 26 + ], + [ + "Text", + 17 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089676" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089677/EFTA00089677.md b/marker2/ds9/EFTA00089677/EFTA00089677.md new file mode 100644 index 0000000000000000000000000000000000000000..1673b8da0b4865007a301f8184d8d48b573d0e05 --- /dev/null +++ b/marker2/ds9/EFTA00089677/EFTA00089677.md @@ -0,0 +1,531 @@ +# U.S. District Court District of New Hampshire (Concord) CRIMINAL DOCKET FOR CASE #: 1:20-mi-00132-AJ All Defendants + +Case title: USA v. Maxwell Date Filed: 07/02/2020 + +Assigned to: Magistrate Judge Andrea K. Johnstone + +#### Defendant (1) + +Ghislaine Maxwell + +#### Pending Counts Disposition + +18 U.S.C. 371 CONSPIRACY TO ENTICE MINORS TO TRAVEL TO ENGAGE IN ILLEGAL SEX ACTS (1) + +18 U.S.C. 2422 and 2 ENTICEMENT OF A MINOR TO TRAVEL TO ENGAGE IN ILLEGAL SEX ACTS (2) + +18 U.S.C. 371 CONSPIRACY TO TRANSPORT MINORS WITH INTENT TO ENGAGE IN CRIMINAL SEXUAL ACTIVITY (3) + +18 U.S.C. 2423(a) and 2 TRANSPORTATION OF A MINOR WITH INTENT TO ENGAGE IN CRIMINAL SEXUAL ACTIVITY (4) + +PERJURY (5-6) + +#### Highest Offense Level (Opening) + +Felony + +#### Terminated Counts Disposition + +None + +#### Highest Offense Level (Terminated) + +# enMplainIS + +None + +#### Disposition + +# Plaintiff + +USA represented by + +US Attorney's Office (NH) James C Cleveland Federal Bldg 53 Pleasant St, 4th FIr 3301 + +Email: LEAD ATTORNEY ATTORNEY TO BE NOTICED Designation: Assistant US Attorney + +| Date Filed | # Page | Docket Text | +|------------|--------|--------------------------------------------------------------------------------| +| 07/02/2020 | | Arrest (Removal) of Ghislaine Maxwell.(kad) (Entered: 07/02/2020) | +| 07/02/2020 | 1 | COPY of Warrant and Indictment from Southern District of New York (White | +| 07/02/2020 | | NOTICE OF HEARING as to Ghislaine Maxwell. Removal Hearing via Video | +| 07/02/2020 | 2 | Public Access Findings as to Ghislaine Maxwell. So Ordered by Magistrate Judge | +| 07/02/2010 | | Minute Entry for proceedings held before Magistrate Judge Andrea K. Johnstone: | +| | | hearing to be held in rosecuting district. (Court Reporter: Susan Batemmiliwt | +| 0- 02 2020 | ; | COMMITMENT TO ANOTHER DISTRICT as to Ghislaine Maxwell. | + +# UNITED STATES DISTRICT COURT + +for the + +Southern District of New York + +United States of America + +v. + +Ghislaine Maxwell + +Defendant + +To: Any authorized law enforcement officer + +20 CR 330 ) ) INL Nio + +) ) ) ) + +# ARREST WARRANT + +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: + +W Indictment O Superseding Indictment O Information O Superseding Information O Complaint O Probation Violation Petition O Supervised Release Violation Petition O Violation Notice O 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 ofa minor) Title 18, United States Code, Section 1623 (perjury) + +Date: 06/29/2020 + +City and state: White Plains, NY + +Issuing officer's signature + +• + +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 + +UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +x UNITED STATES OF AMERICA GHISLAINE MAXWELL, Defendant. SEALED INDICTMENT 20 Cr. + +20 Cr. 330 + +#### COUNT ONE (Conspiracy to Entice Minors to Travel to Engage in Illegal Sex Acts) + +The Grand Jury charges: + +#### OVERVIEW + +1. The charges set forth herein stem from the role of GHISLAINE MAXWELL, the defendant, in the sexual exploitation and abuse of multiple minor girls by Jeffrey Epstein. In particular, from at least in or about 1994, up to and including at least in or about 1997, MAXWELL assisted, facilitated, and contributed to Jeffrey Epstein's abuse of minor girls by, among other things, helping Epstein to recruit, groom, and ultimately abuse victims known to MAXWELL and Epstein to be under the age of 18. The victims were as young as 14 years old when they were groomed and abused by MAXWELL and Epstein, both of whom knew that certain victims were in fact under the age of 18. + +2. As a part and in furtherance of their scheme to abuse minor victims, GHISLAINE MAXWELL, the defendant, and Jeffrey Epstein enticed and caused minor victims to travel to + +Epstein's residences in different states, which MAXWELL knew and intended would result in their grooming for and subjection to sexual abuse. Moreover, in an effort to conceal her crimes, MAXWELL repeatedly lied when questioned about her conduct, including in relation to some of the minor victims described herein, when providing testimony under oath in 2016. + +# FACTUAL BACKGROUND + +3. During the time periods charged in this Indictment, GHISLAINE MAXWELL, the defendant, had a personal and professional relationship with Jeffrey Epstein and was among his closest associates. In particular, between in or about 1994 and in or about 1997, MAXWELL was in an intimate relationship with Epstein and also was paid by Epstein to manage his various properties. Over the course of their relationship, MAXWELL and Epstein were photographed together on multiple occasions, including in the below image: + +![](_page_4_Picture_4.jpeg) + +4. Beginning in at least 1994, GHISLAINE MAXWELL, the defendant, enticed and groomed multiple minor girls to engage in sex acts with Jeffrey Epstein, through a variety of means and methods, including but not limited to the following: + +a. MAXWELL first attempted to befriend some of Epstein's minor victims prior to their abuse, including by asking the victims about their lives, their schools, and their families. MAXWELL and Epstein would spend time building friendships with minor victims by, for example, taking minor victims to the movies or shopping. Some of these outings would involve MAXWELL and Epstein spending time together with aminor victim, while some would involve MAXWELL or Epstein spending time alone with aminor victim. + +b. Having developed a rapport with a victim, MAXWELL would try to normalize sexual abuse for aminor victim by, among other things, discussing sexual topics, undressing in front of the victim, being present when aminor victim was undressed, and/or being present for sex acts involving the minor victim and Epstein. + +c. MAXWELL'S presence during minor victims' interactions with Epstein, including interactions where the minor victim was undressed or that involved sex acts with Epstein, helped put the victims at ease because an adult woman was present. For example, in some instances, MAXWELL would + +massage Epstein in front of a minor victim. In other instances, MAXWELL encouraged minor victims to provide massages to Epstein, including sexualized massages during which a minor victim would be fully or partially nude. Many of those massages resulted in Epstein sexually abusing the minor victims. + +d. In addition, Epstein offered to help some minor victims by paying for travel and/or educational opportunities, and MAXWELL encouraged certain victims to accept Epstein's assistance. As a result, victims were made to feel indebted and believed that MAXWELL and Epstein were trying to help them. + +e. Through this process, MAXWELL and Epstein enticed victims to engage in sexual activity with Epstein. In some instances, MAXWELL was present for and participated in the sexual abuse of minor victims. Some such incidents occurred in the context of massages, which developed into sexual encounters. + +5. GHISLAINE MAXWELL, the defendant, facilitated Jeffrey Epstein's access to minor victims knowing that he had a sexual preference for underage girls and that he intended to engage in sexual activity with those victims. Epstein's resulting abuse of minor victims included, among other things, touching a victim's breast, touching a victim's genitals, placing a sex toy such as a vibrator on a victim's genitals, + +directing a victim to touch Epstein while he masturbated, and directing a victim to touch Epstein's genitals. + +#### MAXWELL AND EPSTEIN'S VICTIMS + +6. Between approximately in or about 1994 and in or about 1997, GHISLAINE MAXWELL, the defendant, facilitated Jeffrey Epstein's access to minor victims by, among other things, inducing and enticing, and aiding and abetting the inducement and enticement of, multiple minor victims. Victims were groomed and/or abused at multiple locations, including the following: + +a. A a multi-story private residence on the Upper East Side of Manhattan, New York owned by Epstein (the •New York Residence"), which is depicted in the following photograph: + +![](_page_7_Picture_5.jpeg) + +b. An estate in Palm Beach, Florida owned by Epstein (the "Palm Beach Residence"), which is depicted in the following photograph: + +![](_page_8_Picture_2.jpeg) + +c. A ranch in Santa Fe, New Mexico owned by Epstein (the "New Mexico Residence"), which is depicted in the following photograph: + +![](_page_8_Picture_4.jpeg) + +England. + +d. MAXWELL's personal residence in London, + +7. Among the victims induced or enticed by GHISLAINE MAXWELL, the defendant, were minor victims identified herein as Minor Victim-1, Minor Victim-2, and Minor Victim-3. In particular, and during time periods relevant to this Indictment, MAXWELL engaged in the following acts, among others, with respect to minor victims: + +a. MAXWELL met Minor Victim-1 when Minor Victim-1 was approximately 14 years old. MAXWELL subsequently interacted with Minor Victim-1 on multiple occasions at Epstein's residences, knowing that Minor Victim-1 was under the age of 18 at the time. During these interactions, which took place between approximately 1994 and 1997, MAXWELL groomed Minor Victim-1 to engage in sexual acts with Epstein through multiple means. First, MAXWELL and Epstein attempted to befriend Minor Victim-1, taking her to the movies and on shopping trips. MAXWELL also asked Minor Victim-1 about school, her classes, her family, and other aspects of her life. MAXWELL then sought to normalize inappropriate and abusive conduct by, among other things, undressing in front of Minor Victim-1 and being present when Minor Victim-1 undressed in front of Epstein. Within the first year after MAXWELL and Epstein met Minor Victim-1, Epstein began sexually abusing Minor Victim-1. MAXWELL was present for + +and involved in some of this abuse. In particular, MAXWELL involved Minor Victim-1 in group sexualized massages of Epstein. During those group sexualized massages, MAXWELL and/or Minor Victim-1 would engage in sex acts with Epstein. Epstein and MAXWELL both encouraged Minor Victim-1 to travel to Epstein's residences in both New York and Florida. As a result, Minor Victim-1 was sexually abused by Epstein in both New York and Florida. Minor Victim-1 was enticed to travel across state lines for the purpose of sexual encounters with Epstein, and MAXWELL was aware that Epstein engaged in sexual activity with Minor Victim-1 after Minor-Victim-1 traveled to Epstein's properties, including in the context of asexualized massage. + +b. MAXWELL interacted with Minor Victim-2 on at least one occasion in or about 1996 at Epstein's residence in New Mexico when Minor Victim-2 was under the age of 18. Minor Victim-2 had flown into New Mexico from out of state at Epstein's invitation for the purpose of being groomed for and/or subjected to acts of sexual abuse. MAXWELL knew that Minor Victim-2 was under the age of 18 at the time. While in New Mexico, MAXWELL and Epstein took Minor Victim-2 to amovie and MAXWELL took Minor Victim-2 shopping. MAXWELL also discussed Minor Victim-2's school, classes, and family with Minor Victim-2. In New Mexico, MAXWELL began her efforts to groom Minor Victim-2 for abuse by Epstein by, among other things, providing + +an unsolicited massage to Minor Victim-2, during which Minor Victim-2 was topless. MAXWELL also encouraged Minor Victim-2 to massage Epstein. + +c. MAXWELL groomed and befriended Minor Victim-3 in London, England between approximately 1994 and 1995, including during a period of time in which MAXWELL knew that Minor Victim-3 was under the age of 18. Among other things, MAXWELL discussed Minor Victim-3's life and family with Minor Victim-3. MAXWELL introduced Minor Victim-3 to Epstein and arranged for multiple interactions between Minor Victim-3 and Epstein. During those interactions, MAXWELL encouraged Minor Victim-3 to massage Epstein, knowing that Epstein would engage in sex acts with Minor Victim-3 during those massages. Minor Victim-3 provided Epstein with the requested massages, and during those massages, Epstein sexually abused Minor Victim-3. MAXWELL was aware that Epstein engaged in sexual activity with Minor Victim-3 on multiple occasions, including at times when Minor Victim-3 was under the age of 18, including in the context of asexualized massage. + +#### MAXWELL'S EFFORTS TO CONCEAL HER CONDUCT + +8. In or around 2016, in the context of a deposition as part of civil litigation, GHISLAINE MAXWELL, the defendant, repeatedly provided false and perjurious statements, under oath, regarding, among other subjects, her role in facilitating the + +abuse of minor victims by Jeffrey Epstein, including some of the specific events and acts of abuse detailed above. + +#### STATUTORY ALLEGATIONS + +9. From at least in or about 1994, up to and including in or about 1997, in the Southern District of New York and elsewhere, GHISLAINE MAXWELL, the defendant, Jeffrey Epstein, and others known and unknown, willfully and knowingly did combine, conspire, confederate, and agree together and with each other to commit an offense against the United States, to wit, enticement, in violation of Title 18, United States Code, Section 2422. + +10. It was a part and object of the conspiracy that GHISLAINE MAXWELL, the defendant, Jeffrey Epstein, and others known and unknown, would and did knowingly persuade, induce, entice, and coerce one and more individuals to travel in interstate and foreign commerce, to engage in sexual activity for which a person can be charged with a criminal offense, in violation of Title 18, United States Code, Section 2422. + +# Overt Acts + +11. In furtherance of the conspiracy and to effect the illegal object thereof, the following overt acts, among others, were committed in the Southern District of New York and elsewhere: + +a. Between in or about 1994 and in or about 1997, when Minor Victim-1 was under the age of 18, MAXWELL participated in multiple group sexual encounters with Epstein and Minor Victim-1 in New York and Florida. + +b. In or about 1996, when Minor Victim-1 was under the age of 18, Minor Victim-1 was enticed to travel from Florida to New York for purposes of sexually abusing her at the New York Residence, in violation of New York Penal Law, Section 130.55. + +c. In or about 1996, when Minor Victim-2 was under the age of 18, MAXWELL provided Minor Victim-2 with an unsolicited massage in New Mexico, during which Minor Victim-2 was topless. + +d. Between in or about 1994 and in or about 1995, when Minor Victim-3 was under the age of 18, MAXWELL encouraged Minor Victim-3 to provide massages to Epstein in London, England, knowing that Epstein intended to sexually abuse Minor Victim-3 during those massages. + +(Title 18, United States Code, Section 371.) + +#### COUNT TWO + +#### (Enticement of a Minor to Travel to Engage in Illegal Sex Acts) + +The Grand Jury further charges: + +12. The allegations contained in paragraphs 1 through 8 of this Indictment are repeated and realleged as if fully set forth within. + +13. From at least in or about 1994, up to and including in or about 1997, in the Southern District of New York and elsewhere, GHISLAINE MAXWELL, the defendant, knowingly did persuade, induce, entice, and coerce an individual to travel in interstate and foreign commerce to engage in sexual activity for which a person can be charged with a criminal offense, and attempted to do the same, and aided and abetted the same, to wit, MAXWELL persuaded, induced, enticed, and coerced Minor Victim-1 to travel from Florida to New York, New York on multiple occasions with the intention that Minor Victim-1 would engage in one or more sex acts with Jeffrey Epstein, in violation of New York Penal Law, Section 130.55. + +(Title 18, United States Code, Sections 2422 and 2.) + +#### COUNT THREE (Conspiracy to Transport Minors with Intent to Engage in Criminal Sexual Activity) + +The Grand Jury further charges: + +14. The allegations contained in paragraphs 1 through 8 of this Indictment are repeated and realleged as if fully set forth within. + +15. From at least in or about 1994, up to and including in or about 1997, in the Southern District of New York and elsewhere, GHISLAINE MAXWELL, the defendant, Jeffrey Epstein, and others known and unknown, willfully and knowingly did combine, conspire, confederate, and agree together and with each other to commit an offense against the United States, to + +wit, transportation of minors, in violation of Title 18, United States Code, Section 2423(a). + +16. It was a part and object of the conspiracy that GHISLAINE MAXWELL, the defendant, Jeffrey Epstein, and others known and unknown, would and did, knowingly transport an individual who had not attained the age of 18 in interstate and foreign commerce, with intent that the individual engage in sexual activity for which a person can be charged with a criminal offense, in violation of Title 18, United States Code, Section 2423(a). + +# Overt Acts + +17. In furtherance of the conspiracy and to effect the illegal object thereof, the following overt acts, among others, were committed in the Southern District of New York and elsewhere: + +- a. Between in or about 1994 and in or about 1997, when Minor Victim-1 was under the age of 18, MAXWELL participated in multiple group sexual encounters with EPSTEIN and Minor Victim-1 in New York and Florida. +- b. In or about 1996, when Minor Victim-1 was under the age of 18, Minor Victim-1 was enticed to travel from Florida to New York for purposes of sexually abusing her at the + +New York Residence, in violation of New York Penal Law, Section 130.55. + +c. In or about 1996, when Minor Victim-2 was under the age of 18, MAXWELL provided Minor Victim-2 with an unsolicited massage in New Mexico, during which Minor Victim-2 was topless. + +d. Between in or about 1994 and in or about 1995, when Minor Victim-3 was under the age of 18, MAXWELL encouraged Minor Victim-3 to provide massages to Epstein in London, England, knowing that Epstein intended to sexually abuse Minor Victim-3 during those massages. + +(Title 18, United States Code, Section 371.) + +#### COUNT FOUR (Transportation of aMinor with Intent to Engage in Criminal Sexual Activity) + +The Grand Jury further charges: + +18. The allegations contained in paragraphs 1 through 8 of this Indictment are repeated and realleged as if fully set forth within. + +19. From at least in or about 1994, up to and including in or about 1997, in the Southern District of New York and elsewhere, GHISLAINE MAXWELL, the defendant, knowingly did transport an individual who had not attained the age of 18 in interstate and foreign commerce, with the intent that the individual engage in sexual activity for which a person can be charged with acriminal offense, and attempted to do so, and + +aided and abetted the same, to wit, MAXWELL arranged for Minor Victim-1 to be transported from Florida to New York, New York on multiple occasions with the intention that Minor Victim-1 would engage in one or more sex acts with Jeffrey Epstein, in violation of New York Penal Law, Section 130.55. + +(Title 18, United States Code, Sections 2423(a) and 2.) + +#### COUNT FIVE (Perjury) + +The Grand Jury further charges: + +20. The allegations contained in paragraphs 1 through 8 of this Indictment are repeated and realleged as if fully set forth within. + +21. On or about April 22, 2016, in the Southern District of New York, GHISLAINE MAXWELL, the defendant, having taken an oath to testify truthfully in a deposition in connection with acase then pending before the United States District Court for the Southern District of New York under docket number 15 Civ. 7344, knowingly made false material declarations, to wit, MAXWELL gave the following underlined false testimony: + +> Q. Did Jeffrey Epstein have ascheme to recruit underage girls for sexual massages? If you know. + +A. I don't know what you're talking about. + +Q. List all the people under the age of 18 that you interacted with at any of Jeffrey's properties? + +A. I'm not aware of anybody that I interacted with, other than obviously [the plaintiff) who was 17 at this point. + +(Title 18, United States Code, Section 1623.) + +### COUNT SIX (Perjury) + +The Grand Jury further charges: + +22. The allegations contained in paragraphs 1 through 8 of this Indictment are repeated and realleged as if fully set forth within. + +23. On or about July 22, 2016, in the Southern District of New York, GHISLAINE MAXWELL, the defendant, having taken an oath to testify truthfully in a deposition in connection with a case then pending before the United States District Court for the Southern District of New York under docket number 15 Civ. 7344, knowingly made false material declarations, to wit, MAXWELL gave the following underlined false testimony: + +> Were you aware of the presence of sex toys or devices used in sexual activities in Mr. Epstein's Palm Beach house? + +A: No, not that I recall. . . . + +Q. Do you know whether Mr. Epstein possessed sex toys or devices used in sexual activities? + +A. No. + +Q. Other than yourself and the blond and brunette that you have identified as having been involved in three-way sexual activities, with whom did Mr. Epstein have sexual activities? + +A. I wasn't aware that he was having sexual activities with anyone when I was with him other than myself. + +Q. I want to be sure that I'm clear. Is it your testimony that in the 1990s and 2000s, you were not aware that Mr. Epstein was having sexual activities with anyone other than yourself and the blond and brunette on those few occasions when they were involved with you? + +A. That is my testimony, that is correct. + +• • • + +Q. Is it your testimony that you've never given anybody a massage? + +A. I have not given anyone a massage. + +Q• You never gave Mr. Epstein a massage, is that your testimony? + +A. That is my testimony. + +Q. You never gave (Minor Victim-2] a massage is your testimony? + +A. I never gave (Minor Victim-2] a massage. + +(Title 18, United States Code, Section 1623.) + +cE/Ilsm Itr- AUDREY S RAUSS Acting nited States Attorney Form No. USA-33s-274 (Ed. 9-25-58) + +#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +#### UNITED STATES OF AMERICA + +v. + +GHISLAINE MAXWELL, + +Defendant. + +#### INDICTMENT + +(18 U.S.C. §§ 371, 1623, 2422, 2423(a), and 2) + +AUDREY STRAUSS + +Acting United States Attorney + +if! + +Foreperson + +#### UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE + +United States of America + +v. + +Ghislaine Maxwell + +Case No. 20-mj-132-AJ-1 + +#### Public Access Findings + +### I. Background + +This hearing is taking place during the public health emergency caused by the COVID-19 outbreak. All parties to this proceeding, including the court, are appearing remotely via video. In light of the anticipated volume of public and media interest and the operational/capacity limitations of videoconference technology, public and media access to the proceeding will be via telephonic conference. The court's protocols for this hearing are laid out in Standing Order 20-7 (Mar. 23, 2020).1 The court finds that conducting this hearing via video — under the unique circumstances presented by the COVID-19 pandemic — is the best way to ensure the safety of the litigants, court personnel, and the public at large. All findings made in the court's prior standing orders are + +2 Standing Order 20-7 was extended to August 1, 2020 by Standing Order 20-21 (June 17, 2020). + +incorporated herein. See Standing Orders 20-5 (Mar. 20, 2020) and 20-21 (June 17, 2020).2 + +The hearing held today will be an initial appearance and removal hearing for defendant Ghislaine Maxwell. Today's hearing has been noticed as a video hearing. In the event defendant consents to proceed, the court makes the findings below. + +Before convening this video/telephone hearing, the court carefully considered the defendant's Sixth Amendment right to public court proceedings and the public's and press's First Amendment rights to in-person access to such proceedings. See Bucci v. United States, 662 F.3d 18. 22 (1st Cir. 2011) (citing Waller v. Georgia 467 U.S. 39. 48 (1984)); Press-Enter. Co. v. Superior Court of California, Riverside Cty., 464 U.S 501. 509 la (1984). This Order details my findings. + +# II. Partial Rather Than Total Closure + +The court first finds that this video hearing constitutes a partial, rather than total, closure of these proceedings. The court so finds because the goals of public access will still be achieved: this proceeding is not being held in secret and the public, including members of the press, maintains the + +2 All the court's Standing Orders regarding the COVID-19 outbreak can be found here: http://www.nhd.uscourts.gov/courtresponse-coronavirus-disease-covid-19. + +opportunity to access this proceeding in real time. See Richmond Newspapers, Inc. v. Virginia 448 U.S. 555. 593-97 (1980) (Brennan, J., concurring) (discussing the functions of public access to court proceedings, including ensuring that procedural rights are respected and that justice is afforded equally, maintaining public confidence in the administration of justice, promoting accurate fact-finding, and enabling the public to act as a check on judicial power); see also Bucci, kka F.ld at 27 (discussing benefits of openness in criminal proceedings). Under the extraordinary circumstances presented by the continuing C0VID-19 pandemic, the court finds this partial closure is necessary. + +# III. Findings in Support of Necessity for this Partial Closure + +A. First, the court finds that protecting the health and safety of the public and the parties to this proceeding from the spread of COVID-19 is a substantial interest that would be jeopardized and prejudiced if the court did not impose this partial closure. + +Since the first announced case in New Hampshire on March 2, 2020, the state has reported 5,802 confirmed cases of C0VID-19.3 So far, 373 deaths have been attributed to the disease in this + +3 C0VID-19, N.H. Dep't of Health and Human Servs., https://www.nh.gov/covidl9/ (last visited 12:00 p.m. July 2, 2020); Explore the Data: Tracking C0VID-19 in New Hampshire, N.H. Pub. Radio, https://www.nhpr.org/post/updated-trackingcovid-19-cases-and-testing-new-hampshire#stream/0 (last visited 12:00 p.m. July 2, 2020). + +state. Further, in New Hampshire approximately 3,475 people are being monitored for signs of C0VID-19 infection, over 120,307 total tests have been reported (both positive and negative test results), and community-based transmission has been confirmed." Nationally, the number of confirmed cases has grown to over 2,797,737, with 130,984 cases resulting in death.5 + +Given the contagious nature of the virus and the exponential growth in cases, C0VID-19 presents an enormous danger to the health and safety of the public, including the litigants, security, and court personnel involved in this proceeding. The court's interest in preventing the spread of C0VID-19 and preserving the health of all hearing participants, including the public, is a weighty and substantial interest that would likely be prejudiced if the court were not to impose this partial closure. See United States v. Smith 426 F 3d 567. 572- 2a (2d Cir. 2005) (finding that U.S. Marshal's policy after September 11th of requiring unknown visitors to court to produce photo identification constituted partial closure of courtroom + +4 C0VID-19, N.H. Dep't of Health and Human Servs., https://www.nh.gov/covidl9/ (last visited 12:00 p.m. July 2, 2020); Explore the Data: Tracking C0VID-19 in New Hampshire, N.H. Pub. Radio, https://www.nhpr.org/post/updated-trackingcovid-19-cases-and-testing-new-hampshire#stream/0 (last visited 12:00 p.m. July 2, 2020). + +5 Real Clear Politics, https://www.realclearpolitics.com/ (last visited 12:45 p.m. July 2, 2020). + +that was justified by substantial interest of promoting security and preventing terrorism). + +B. Second, the court finds that this partial closure of court proceedings is narrowly tailored to protect public health and safety and is less restrictive than the court's current in-court hearing protocols. + +Allowing the public to access these proceedings through telephone conference allows a large number (up to 500) of members of the public to access the proceedings while, at the same time, protecting the health of all involved by limiting the potential exposure of the public, parties, and court staff to COVID-19. + +Importantly, the court finds that, in light of the court's current restrictions on the number of people permitted in the courtroom, providing public telephonic access is less restrictive than holding an in-person hearing which only a limited number of people can attend. Further, via telephone, even individuals who would have otherwise been prohibited from entering the courthouse — for example, people who have tested positive for COVID-19 — now have access (even though virtual) to the proceedings. See Standing Order 20-9 (Mar. 20, 2020) (prohibiting certain individuals from entering the courthouse, including people diagnosed with or exposed to someone diagnosed with COVID-19). Providing the public access to this proceeding via telephone is the least restrictive means of protecting the + +substantial interest of public health and safety. See United States v. Alimehmeti, 284 F. Cupp. 'id 477. 490 (S.D.N.Y. 2018) (granting partial closure of courtroom to protect identity of undercover agents: courtroom was closed to public during undercover agents' testimony but audio of testimony was livestreamed into different courtroom during partial closure and transcripts of testimony were made available to public promptly). + +### C. Third, the court has considered reasonable alternatives to this partial closure. + +The court has considered alternatives to this partial closure and finds they are neither reasonable nor feasible under the circumstances of the COVID-19 pandemic and this case, particularly the necessity that this hearing be conducted promptly. + +# IV. Conclusion + +In sum, the court finds that in this case a partial closure of court proceedings is necessary in that today's hearing will be conducted by video and telephone conference. This partial closure is justified by the substantial interest of protecting public health and safety from the spread of COVID-19 and is narrowly tailored to protect that interest. The public maintains the opportunity to access these proceedings in full by telephone. + +SO ORDERED. + +![]()Andrea K. Johnstone +United States Magistrate Judge + +July 2, 2020 + +cc: Counsel of record + +#### UNITED STATES DISTRICT COURT DISTRICT OF NEW HAMPSHIRE + +United States + +v. + +Ghislaine Maxwell + +Case No. 20-mj-I32-01-AJ + +Charging District Case No. 20 CR 330 + +# COMMITMENT TO ANOTHER DISTRICT + +The defendant has been charged by way of with a violation of , alleged to have been committed in the Southern District of New York. + +Brief Description of Charge(s): + +18 U.S.C. 371 CONSPIRACY TO ENTICE MINORS TO TRAVEL TO ENGAGE IN ILLEGAL SEX ACTS + +18 U.S.C. 2422 and 2 ENTICEMENT OF A MINOR TO TRAVEL TO ENGAGE IN ILLEGAL SEX ACTS + +18 U.S.C. 371 CONSPIRACY TO TRANSPORT MINORS WITH INTENT TO ENGAGE IN CRIMINAL SEXUAL ACTIVITY + +18 U.S.C. 2423(a) and 2 TRANSPORTATION OF A MINOR WITH INTENT TO ENGAGE IN CRIMINAL SEXUAL ACTIVITY + +PERJURY + +# CURRENT BOND STATUS: + +Bail fixed S and conditions were not met. Government moved for detention and defendant detained after hearing in District of Arrest. Government moved for detention and defendant detained pending detention hearing in District of Offense. El Other (specify): + +REPRESENTATION: Lawrence Vogelman, Esq. + +INTERPRETER REOUIRED: No + +The United States marshal must transport the defendant, together with a copy of this order, to the charging district and deliver the defendant to the United States marshal for that district, or to another officer authorized to receive the defendant. The marshal or officer in the charging district should immediately notify the United States attorney and the clerk of court for that district of the defendant's arrival so that further proceedings may be promptly scheduled. The clerk of this district must promptly transmit the papers and any bail to the charging district. + +SO ORDERED. + +July 2, 2020 + +LGucuat, 11:71ervehl-e- + +Andrea K. Johnstone United States Magistrate Judge + +| RETURN | | | +|-------------------------------------------------------|-----------------------|--------------------------| +| THIS COMMITMENT WAS RECEIVED AND EXECUTED AS FOLLOWS: | | | +| DATE COMMITMENT ORDER RECEIVED | PLACE OF COMMITMENT | DATE DEFENDANT COMMITTED | +| DATE | UNITED STATES MARSHAL | (BY) DEPUTY MARSHAL | + +MIME-Version:1.0 From:ecf\_bounce@nhd.uscourts.gov To:nef@nhd.uscourts.gov Bcc: --Case Participants: --Non Case Participants: US Marshal I US --No Notice Sent: Probation (caseview.ecf@usdoj.gov, cfcriminal@usdoj.gov, usanh.ecfdocket@usdoj.gov) (nhpdb\_cmecf@nhp.uscourts.gov) + +Message-Id:2213049@nhd.uscourts.gov Subject:Activity in Case 1:20-mj-00132-AJ USA v. Maxwell Notice of Hearing Content—Type: text/html + +### U.S. District Court + +# District of New Hampshire + +#### Notice of Electronic Filing + +The following transaction was entered on 7/2/2020 at 12:09 PM EDT and filed on 7/2/2020 + +Case Name: USA v. Maxwell Case Number: 1.20-m.-00132—AJ Filer: + +Document Number: No document attached + +#### Docket Text: + +NOTICE OF HEARING as to Ghislaine Maxwell. Removal Hearing via Video Conference set for 7/2/2020 03:30 PM before Magistrate Judge Andrea K. Johnstone. (kad) + +1:20-mj-00132—A,l—1 Notice has been electronically mailed to: + +n bsp 8mbsp CaseView.ECF@usdoj.gov, , USANH.ECFCriminal@usdoj.gov, USANH.ECFDocket@usdoj.gov + +1:20-n1j-00132—Ai—I Notice, to the extent appropriate, must be delivered conventionally to: + +MIME-Version:1.0 From:ecf\_bounce@nhd.uscourts.gov To:nefenhd.uscourts.gov Bcc: --Case Participants: --Non Case Participants: --No Notice Sent: caseview.ecf@usdoj.gov, usan .ecfcriminal@usdoj.gov, usanh.ecfdocket@usdoj.gov) + +Message-Id:2213529@nhd.uscourts.gov Subject:Activity in Case 1:20-mj-00132-AJ USA v. Maxwell Removal Hearing Content—Type: text/html + +#### U.S. District Court + +#### District of New Hampshire + +# Notice of Electronic Filing + +The following transaction was entered on 7/6/2020 at 9:45 AM EDT and filed on 7/2/2020 + +Case Name: USA v. Maxwell Case Number: .20—mj-00 i12—A Filer: Document Number: No document attached + +#### Docket Text: + +Minute Entry for proceedings held before Magistrate Judge Andrea K. Johnstone: REMOVAL HEARING as to Ghislaine Maxwell held on 7/2/2020. The court found the defendant knowingly and voluntarily waived and in-court hearing. Defendant: advised of rights and charges, waived identity hearing. Detention hearin to secuting district. (Court Reporter: Su n B m n Govt Atty: (Defts Atty: Lawrence Vogelman) (USP: (Total Hearing Time: 1 mm.) (kacl) + +1:20-n1j-00132—A.1-1 Notice has been electronically mailed to: + +    . CaseView.ECF@usdoj.gov, . • rinutial@usdoj.gov, USANH.ECFDocket@usdoj.gov + +1:20-n1j-00132—A.1-1 Notice, to the extent appropriate; must be delivered conventionally to: + +MIME-Version:1.0 From:ecf\_bounce@nhd.uscourts.gov To:nef@nhd.uscourts.gov Bee: --Case Participants: --Non Case Participants: --No Notice Sent: Message-Id:2212948@nhd.uscourts.gov Subject:Activity in Case 20-132 Sealed v. Sealed (Redacted Notice) Content—Type: text/html + +NOTE: This docket entry (or case) is sealed, no entail notices have been sent. + +# U.S. District Court + +### District of New Hampshire + +# Notice of Electronic Filing + +The following transaction was entered on 7t2/2020 at 9:45 AM EDT and filed on 7/2/2020 + +Case Name: USA v. Maxwell Case Number: I :20—mj-00132—AJ \*SEALED\* Filer: Document Number: No document attached Docket Text: Arrest (Removal) of Ghislaine Maxwell.(kad) + +1:20—mj-00132—AJ \*SEALED\*-1 No electronic public notice will be sent because the casefentry is sealed. \ No newline at end of file diff --git a/marker2/ds9/EFTA00089677/EFTA00089677.metadata.json b/marker2/ds9/EFTA00089677/EFTA00089677.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..35a8b3729c39c86186992780eb05f43bc108b6ec --- /dev/null +++ b/marker2/ds9/EFTA00089677/EFTA00089677.metadata.json @@ -0,0 +1,2492 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089677.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 33, + "chars": 36841, + 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NATHAN, District Judge: + +An arraignment, initial conference, and bail hearing in this matter is hereby scheduled to occur as a remote video/teleconference using an intemet platform on July 14, 2020 at 1 p.m. In advance of the conference, Chambers will email counsel with further information on how to access the video conference. + +To optimize the quality of the video feed, only the Court, the Defendant, defense counsel, and counsel for the Government will appear by video for the proceeding; all others may access the audio of the public proceeding by telephone. Due to the limited capacity of the intemet platform system, only one attorney per party may participate by video. Co-counsel, members of the press, and the public may access the audio feed of the proceeding by calling a dial-in number, which the Court will provide in advance of the proceeding by subsequent order. + +Given the high degree of public interest in this case, a video feed of the remote proceeding will be available for viewing in the Jury Assembly Room located at the Daniel Patrick Moynihan Courthouse, 500 Pearl Street, New York, NY. Due to social distancing requirements, seating will be extremely limited; when capacity is reached no additional persons will be admitted. Per the S.D.N.Y. COVID-19 Courthouse Entry Program, anyone who appears at any S.D.N.Y. courthouse must complete a questionnaire on the date of the proceeding prior to arriving at the courthouse. All visitors must also have their temperature taken when they arrive at the courthouse. Please see the instructions, attached. Completing the questionnaire ahead of time will save time and effort upon entry. 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. Face coverings that cover the nose and mouth must be worn at all times. 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. + +As discussed in the Court's previous order, defense counsel shall, if possible, discuss the Waiver of Right to be Present at Criminal Proceeding with the Defendant prior to the proceeding. See Dkt. No. 7. If the Defendant consents, and is able to sign the form (either personally or, in accordance with Standing Order 20-MC-174 of March 27, 2020, by defense counsel), defense counsel shall file the executed form at least 24 hours prior to the proceeding. In the event the Defendant consents, but counsel is unable to obtain or affix the Defendant's signature on the form, the Court will conduct an inquiry at the outset of the proceeding to determine whether it is appropriate for the Court to add the Defendant's signature to the form. + +Pursuant to 18 U.S.C. § 3771(c)(1), the Government must "make their best efforts to see that crime victims are notified of, and accorded, the rights" provided to them in that section. This includes "[t]he right to reasonable, accurate, and timely notice of any public court proceeding ... involving the crime or of any release . . . of the accused" and "[t]he right to be reasonably heard at any public proceeding in the district court involving release." Id. § 3771(a)(2), (4). The Court will inquire with the Government as to the extent of those efforts. So that appropriate logistical arrangements can be made, the Government shall inform the Court by + +email within 24 hours in advance of the proceeding if any alleged victim wishes to be heard on the question of detention pending trial. + +Finally, the time between the Defendant's arrest and July 6, 2020 is excluded under the Speedy Trial Act due to the delay involved in transferring the Defendant from another district. *See* 18 U.S.C. § 3161(h)(1)(F). And the Court further excludes time under the Speedy Trial Act from today through July 14, 2020. Due to the logistical issues involved in conducting a remote proceeding, the Court finds "that the ends of justice served by [this exclusion] outweigh the best interest of the public and the defendant in a speedy trial." 18 U.S.C. § 3161(h)(7)(A). The exclusion is also supported by the need for the parties to discuss a potential protective order, which will facilitate the timely production of discovery in a manner protective of the rights of third parties. *See* Dkt. No. 5. + +SO ORDERED. + +Dated: July 7, 2020 +New York, New York + +![]() + +--- + +ALISON J. NATHAN +United States District Judge + +All members of the public, including attorneys, appearing at a Southern District of New York courthouse must complete a questionnaire and have their temperature taken before being allowed entry into that courthouse. + +On the day you are due to arrive at the courthouse, click on the following weblink, or scan the following QR code with a mobile device camera to begin the enrollment process. Follow the instructions and fill out the questionnaire. If your answers meet the requirements for entry, you will be sent a QR code to be used at the SDNY entry device at the courthouse entrance. + +https://app.certify.me/SDNYPublic + +![](_page_3_Picture_3.jpeg) + +Note: If you do not have a momre pnone or moone pnone numoer, you must complete the questionnaire and temperature screening at an entry device at the courthouse. \ No newline at end of file diff --git a/marker2/ds9/EFTA00089710/EFTA00089710.metadata.json b/marker2/ds9/EFTA00089710/EFTA00089710.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..399b97b7a6b5ccb427397f2266cd0ef2a3305cea --- /dev/null +++ b/marker2/ds9/EFTA00089710/EFTA00089710.metadata.json @@ -0,0 +1,186 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089710.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 4, + "chars": 5468, + "elapsed_seconds": 4.66, + "image_assets": [ + "_page_3_Picture_3.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 71.28 + ], + [ + 281.41961669921875, + 71.28 + ], + [ + 281.41961669921875, + 99.603515625 + ], + [ + 68.544, + 99.603515625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 63 + ], + [ + "Line", + 31 + ], + [ + "Text", + 10 + ], + [ + "PageHeader", + 1 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 45 + ], + [ + "Line", + 23 + ], + [ + "Text", + 3 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 33 + ], + [ + "Line", + 17 + ], + [ + "Text", + 10 + ], + [ + "Caption", + 2 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 3, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 38 + ], + [ + "Line", + 18 + ], + [ + "Text", + 4 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089710" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089710/_page_3_Picture_3.jpeg b/marker2/ds9/EFTA00089710/_page_3_Picture_3.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..5010b06e0bc5dbd5ccaeaf7261e4174a93050387 --- /dev/null +++ b/marker2/ds9/EFTA00089710/_page_3_Picture_3.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:4ecf7cd062f8e936c2b4cce84ef2b1a59d3d6177b75a906f0a4eb332299192e1 +size 27479 diff --git a/marker2/ds9/EFTA00089714/EFTA00089714.md b/marker2/ds9/EFTA00089714/EFTA00089714.md new file mode 100644 index 0000000000000000000000000000000000000000..7d80629c88be9a010797d6a52017dbef985e18df --- /dev/null +++ b/marker2/ds9/EFTA00089714/EFTA00089714.md @@ -0,0 +1,37 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +United States of America, + +—v— + +Ghislaine Maxwell, + +Defendant. + +![](_page_0_Picture_6.jpeg) + +20-CR-330 (AJN) + +ORDER + +ALISON J. NATHAN, District Judge: + +As noted in its previous order, the Court will hold an in-person pretrial conference on November 1, 2021 at 11:00 a.m. Dkt. No. 330. The conference will take place in Courtroom 518 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 any members of the Defendant's family. Dkt. No. 344. Two pool reporters will be permitted in the courtroom proper. + +In order to comply with the District's COVID-19 protocols, the public will be able to access the proceeding in overflow Courtrooms 110, 506, 619, 905, and 906 of the Thurgood Marshall U.S. Courthouse. These overflow rooms will have live video and audio feeds of the proceeding. The use of any electronic devices during the proceeding in the overflow rooms is strictly prohibited. + +The Court anticipates seating capacity in the overflow rooms for at least 100 members of the public. If capacity is reached, no additional persons will be admitted. 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 . + +SO ORDERED. + +Dated: October 28, 2021 +New York, New York + +![]() + +--- + +ALISON J. NATHAN +United States District Judge \ No newline at end of file diff --git a/marker2/ds9/EFTA00089714/EFTA00089714.metadata.json b/marker2/ds9/EFTA00089714/EFTA00089714.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..2220dad2e9b2c85113cd118062e77a3a13900100 --- /dev/null +++ b/marker2/ds9/EFTA00089714/EFTA00089714.metadata.json @@ -0,0 +1,130 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089714.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2299, + "elapsed_seconds": 3.97, + "image_assets": [ + "_page_0_Picture_6.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 72.08999999999999 + ], + [ + 281.419189453125, + 72.08999999999999 + ], + [ + 281.419189453125, + 99.7330322265625 + ], + [ + 68.544, + 99.7330322265625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 67 + ], + [ + "Line", + 33 + ], + [ + "Text", + 10 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "SectionHeader", + 1 + ], + [ + "Picture", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 29 + ], + [ + "Line", + 15 + ], + [ + "Text", + 8 + ], + [ + "PageFooter", + 4 + ], + [ + "PageHeader", + 2 + ], + [ + "Caption", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089714" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089714/_page_0_Picture_6.jpeg b/marker2/ds9/EFTA00089714/_page_0_Picture_6.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..f966c892b2a81827aa4f747607d0977deca5dea8 --- /dev/null +++ b/marker2/ds9/EFTA00089714/_page_0_Picture_6.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:963a6283591272fa07e11451658fadc68a79d754782b6a672cdf58783762d4f2 +size 12435 diff --git a/marker2/ds9/EFTA00089716/EFTA00089716.md b/marker2/ds9/EFTA00089716/EFTA00089716.md new file mode 100644 index 0000000000000000000000000000000000000000..65c0bda08148b40c318e78fedb1599366bb723cf --- /dev/null +++ b/marker2/ds9/EFTA00089716/EFTA00089716.md @@ -0,0 +1,86 @@ +![](_page_0_Picture_153.jpeg) + +Florida Office + +Bradley J. Edwards \*01 +Seth M. Lehrman \*+ +Brittany N. Henderson \*0 +Matthew D. Weissing \*1 + +425 North Andrews Avenue +Suite 2 +Fort Lauderdale, FL 33301 + +Telephone (954)524-2820 +Fax (954)524-2822 + +New York Office +J. Stanley Pottinger † + +† Admitted in California +◊ Admitted in District of Columbia +\* Admitted in Florida +† Admitted in New York +† Board Certified Civil Trial Lawyer + +October 21, 2020 + +## FOIA PRIVACY EXEMPTION + +### VIA E-MAIL AND FEDEX + +The Honorable Geoffrey S. Berman +United States Attorney for the +Southern District of New York + +[REDACTED] +Assistant United States Attorney +86 Chambers Street, Third Floor +New York, New York 10007 +[REDACTED] + +**Re: Request for Tangible and Documentary Evidence (Touhy Request)** +[REDACTED], SDNY Case No. 1:19-cv-07771 +**Victim:** [REDACTED] + +Dear [REDACTED] + +In follow up to our previous communications, please accept this as our formal written request for documentary and tangible evidence currently in the in the possession, custody, and control of the Department of Justice by way of the Southern District of New York relating to the sexual abuse of one of Jeffrey Epstein's many victims, [REDACTED].1 See United States ex rel. *Touhy v. Ragen*, 340 U.S. 462 (1951). We make this written request pursuant to the *Touhy* regulations codified as 28 C.F.R. § 16.21 et seq. Should you find there to be any deficiencies within this request, please notify us and we will do what is necessary to correct any such shortcomings. + +[REDACTED] +[REDACTED] + +1 To protect her anonymity, our client, [REDACTED] has elected to proceed as a [REDACTED] As such, we have referred to her herein using the pseudonym under which she has filed her lawsuit. + +![](_page_1_Picture_1.jpeg) + +We specifically seek copies of the following documents that we believe are currently in the possession of the Government: + +- I) Photographs of +- 2) Videos of +- 3) Any and all correspondence between Jeffrey Epstein, his agents, employees, medical providers, or attorneys and +- 4) Any and all records of purchases of gifts or anything of value purchased for or sent to +- 5) Any and all records showing that a letter or package was sent via U.S. Mail, UPS, FedEx, or by any other means of shipping from Jeffrey Epstein, his agents, or his employees to +- 6) Any and all records of payments made to medical providers on behalf of +- 7) Any and all records of payments made to attorneys on behalf of +- 8) Any and all records of payments made to accountants on behalf of +- 9) Any and all documents referencing residing at +- 10) Any and all documents including true name; +- 11) Any and all lists including true name; and +- 12) Any and all other documentary materials relating in any way to a + +Pursuant to the Touhy regulations set forth by the Department of Justice, the Deputy or Associate Attorney General assesses the following considerations in determining whether disclosure is warranted: + +(a)(1) Whether such disclosure is appropriate under the rules of procedure governing the case or mater in which the demand arose; + +(a)(2) Whether disclosure is appropriate under the relevant substantive law of privilege. This request satisfies both of these considerations. As explained previously, the requested non-privileged documentary evidence directly concerns the allegations in civil case. + +Due to the establishment of the Epstein Victim Compensation Program that is currently underway, seeks this information on an expedited basis in order to properly and completely present her claim for consideration, and if necessary, to continue to proceed by way of formal litigation. The requested information is within the scope of ordinary practice and does not seek disclosure of information prohibited by statute or regulation. Furthermore, this request does not seek information that is classified or that would reveal the source or identity of any informant. To that effect, specifically does not request any investigatory records compiled for law enforcement purposes that would interfere with ongoing law enforcement proceedings. simply requests information in the Government's possession that will assist in the prosecution of her claims and ultimately, aid in her ability to finally obtain the 'ustice that she deserves. To the extent that the requested materials can be made available to on an expedited basis, it would be greatly appreciated. + +Please contact us at your earliest convenience to discuss the identity of in more detail, at which time we are fully prepared to answer any questions that you may have. + +Very truly yours, + +EDWARDS POTTINGER LLC + +Bradley Edwards Brittany Henderson \ No newline at end of file diff --git a/marker2/ds9/EFTA00089716/EFTA00089716.metadata.json b/marker2/ds9/EFTA00089716/EFTA00089716.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..1dab3520d1a92eb3d4c8acfbb3eb2b35deaa2f4f --- /dev/null +++ b/marker2/ds9/EFTA00089716/EFTA00089716.metadata.json @@ -0,0 +1,200 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089716.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 4715, + "elapsed_seconds": 6.85, + "image_assets": [ + "_page_0_Picture_153.jpeg", + "_page_1_Picture_1.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "FOIA PRIVACY EXEMPTION", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 192.168, + 238.95 + ], + [ + 416.15999999999997, + 238.95 + ], + [ + 416.15999999999997, + 253.53000000000003 + ], + [ + 192.168, + 253.53000000000003 + ] + ] + }, + { + "title": "VIA E-MAIL AND FEDEX", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 269.73 + ], + [ + 215.42399999999998, + 269.73 + ], + [ + 215.42399999999998, + 283.5 + ], + [ + 68.544, + 283.5 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 90 + ], + [ + "Line", + 44 + ], + [ + "Text", + 27 + ], + [ + "SectionHeader", + 4 + ], + [ + "Picture", + 2 + ], + [ + "Footnote", + 2 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 61 + ], + [ + "Line", + 31 + ], + [ + "ListItem", + 12 + ], + [ + "Text", + 5 + ], + [ + "PageHeader", + 1 + ], + [ + "Picture", + 1 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 31 + ], + [ + "Line", + 16 + ], + [ + "Text", + 5 + ], + [ + "PageHeader", + 1 + ], + [ + "Caption", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089716" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089716/_page_0_Picture_153.jpeg b/marker2/ds9/EFTA00089716/_page_0_Picture_153.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..a51e07e3ea8b07ea2bb9c5f082312ad64292e90d --- /dev/null +++ b/marker2/ds9/EFTA00089716/_page_0_Picture_153.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:2d4661781cb73862bacd8ca13a3f241a885b37a92277892ca1945cbe2061c721 +size 9052 diff --git a/marker2/ds9/EFTA00089716/_page_1_Picture_1.jpeg b/marker2/ds9/EFTA00089716/_page_1_Picture_1.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..77afb4d177ef02a789183cee03095c699a8a029c --- /dev/null +++ b/marker2/ds9/EFTA00089716/_page_1_Picture_1.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:abcea8d741aa6d25c6c18e90cb15e794f9b8fcd444f9c9389e9490f42470e451 +size 12878 diff --git a/marker2/ds9/EFTA00089719/EFTA00089719.md b/marker2/ds9/EFTA00089719/EFTA00089719.md new file mode 100644 index 0000000000000000000000000000000000000000..2b7595b6ebc67953c4c9a22aba082f506087172e --- /dev/null +++ b/marker2/ds9/EFTA00089719/EFTA00089719.md @@ -0,0 +1,67 @@ +![](_page_0_Picture_0.jpeg) + +Florida Office + +Bradley J. Edwards \*0f Seth M. Lehrman 't Brittany N. Henderson \*0 Matthew D. Weissing \*I + +EDWARDS POTTINGER LLC + +425 North Andrews Avenue Suite 2 Fort Lauderdale, FL 33301 + +Telephone (954)524-2820 Fax (950524-2822 + +October 21, 2020 + +## FOIA PRIVACY EXEMPTION + +## VIA E-MAIL AND FEDEX + +The Honorable Geoffrey S. Berman United States Attorney for the Southern District of New York + +Assistant United States Attorney 86 Chambers Street, Third Floor New York, New York 10007 + +Dear + +New York Office J. Stanley Porringer + +j Admitted in California 0 Admitted in District of Columbia • Admitted m Florida t Admitted in New York board Certified Civil Trial ilWyCl + +Re: Re uest for Tangible and Documentary Evidence (Touhy Request) et al., SDNY Case No. 1:19-cv-07772 + +In follow up to our previous communications, please accept this as our formal written request for documentary and tangible evidence currently in the in the possession, custody, and control of the Department of Justice by way of the Southern District of New York relating to the sexual abuse of one of Jeffrey Epstein's many victims,[ See United States ex rel. Touhy v. Rages, 340 U.S. 462 (1951). We make this written request pursuant to the Touhy regulations codified as 28 C.F.R. § 16.21 et seq. Should you find there to be any deficiencies within this request, please notify us and we will do what is necessary to correct any such shortcomings. + +' To protect her anonymity, our clients has elected to proceed as a we have referred to her herein using the pseudonym under which she has filed her lawsuit. As such, + +![](_page_1_Picture_1.jpeg) + +We specifically seek copies of the following documents that we believe are currently in the possession of the Government: + +- I) Photographs of +- 2) Videos of +- 3) Any and all correspondence between Jeffrey Epstein, his agents, employees, medical providers, or attorneys and +- 4) Any and all records of purchases of gifts or anything of value purchased for or sent to +- 5) Any and all records showing that a letter or package was sent via U.S. Mail, UPS, FedEx, or by any other means of shipping from Jeffrey Epstein, his agents, or his employees to +- 6) Any and all records of payments made to medical providers on behalf of +- 7) Any and all records of payments made to attorneys on behalf of +- 8) Any and all records of payments made to accountants on behalf of +- 9) Any and all documents referencing residing a +- 10) Any and all documents including +- 11) Any and all lists including +- 12) Any and all other documentary materials relating in any way to true name; true name; and +- • + +Pursuant to the Touhy regulations set forth by the Department of Justice, the Deputy or Associate Attorney General assesses the following considerations in determining whether disclosure is warranted: + +(a)(1) Whether such disclosure is appropriate under the rules of procedure governing the case or mater in which the demand arose; (a)(2) Whether disclosure is appropriate under the relevant substantive law of privilege. This request satisfies both of these considerations. As explained previously, the requested non-privileged documentary evidence directly concerns the allegations in civil case. + +Due to the establishment of the Epstein Victim Compensation Program that is currently underway, seeks this information on an expedited basis in order to properly and completely present her claim for consideration, and if necessary, to continue to proceed by way of formal + +litigation. The requested information is within the scope of ordinary practice and does not seek disclosure of information prohibited by statute or regulation. Furthermore, this request does not seek information that is classified or that would reveal the source or identity of any informant. To that effect, specifically does not request any investigatory records compiled for law enforcement purposes that would interfere with ongoing law enforcement proceedings. simply requests information in the Government's possession that will assist in the prosecution of her claims and ultimately, aid in her ability to finally obtain the \*ustice that she deserves. To the extent that the requested materials can be made available to on an expedited basis, it would be greatly appreciated. + +Please contact us at your earliest convenience to discuss the identity of in more detail, at which time we are fully prepared to answer any questions that you may have. + +Very truly yours, + +EDWARDS POTTINGER LLC + +Bradley Edwards Brittany Henderson \ No newline at end of file diff --git a/marker2/ds9/EFTA00089719/EFTA00089719.metadata.json b/marker2/ds9/EFTA00089719/EFTA00089719.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..7a17e8a5e8d62fe290b3fcae26a30bce56c7b3f3 --- /dev/null +++ b/marker2/ds9/EFTA00089719/EFTA00089719.metadata.json @@ -0,0 +1,196 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089719.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 4542, + "elapsed_seconds": 1.01, + "image_assets": [ + "_page_0_Picture_0.jpeg", + "_page_1_Picture_1.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "FOIA PRIVACY EXEMPTION", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 192.78000000000003, + 238.95 + ], + [ + 419.9288330078125, + 238.95 + ], + [ + 419.9288330078125, + 257.2598876953125 + ], + [ + 192.78000000000003, + 257.2598876953125 + ] + ] + }, + { + "title": "VIA E-MAIL AND FEDEX", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 269.73 + ], + [ + 217.50064086914062, + 269.73 + ], + [ + 217.50064086914062, + 284.8535461425781 + ], + [ + 68.544, + 284.8535461425781 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 92 + ], + [ + "Line", + 44 + ], + [ + "Text", + 14 + ], + [ + "SectionHeader", + 2 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 65 + ], + [ + "Line", + 33 + ], + [ + "ListItem", + 13 + ], + [ + "Text", + 4 + ], + [ + "ListGroup", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 33 + ], + [ + "Line", + 17 + ], + [ + "Text", + 5 + ], + [ + "PageHeader", + 1 + ], + [ + "Caption", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089719" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089719/_page_0_Picture_0.jpeg b/marker2/ds9/EFTA00089719/_page_0_Picture_0.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..e3cfb073c292735b73101c4569dafc9467041ac5 --- /dev/null +++ b/marker2/ds9/EFTA00089719/_page_0_Picture_0.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:9c3ffc5b20f49a13baf12142d7b5847766e086f69f390400f6e19efbe92ed4bb +size 3768 diff --git a/marker2/ds9/EFTA00089719/_page_1_Picture_1.jpeg b/marker2/ds9/EFTA00089719/_page_1_Picture_1.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..96d6ea4c47687007464243425e4736ee9adc2691 --- /dev/null +++ b/marker2/ds9/EFTA00089719/_page_1_Picture_1.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:3a9cbaaadd6924903c947796c4be6b6272935ce4e2a4a00e9b04cffe746b2d0f +size 13592 diff --git a/marker2/ds9/EFTA00089722/EFTA00089722.md b/marker2/ds9/EFTA00089722/EFTA00089722.md new file mode 100644 index 0000000000000000000000000000000000000000..52b70b9d00aa2e79363219562cc5e059c06bcf04 --- /dev/null +++ b/marker2/ds9/EFTA00089722/EFTA00089722.md @@ -0,0 +1,67 @@ +![](_page_0_Picture_0.jpeg) + +Florida Office + +Bradley J. Edwards "Of Seth M. Lehrman "t Brittany N. Henderson "0 Matthew D. Weissing "I + +EDWARDS POTTINGER LLC + +425 North Andrews Avenue Suite 2 Fort Lauderdale, FL 33301 + +Telephone (954)524-2820 Fax (954)524-2822 + +October 21, 2020 + +## FOIA PRIVACY EXEMPTION + +## VIA E-MAIL AND FEDEX + +The Honorable Geoffrey S. Berman United States Attorney for the Southern District of New York + +Assistant United States Attorney 86 Chambers Street, Third Floor New York, New York 10007 + +Dear + +New York Office J. Stanley Pottinger + +j Admitted in California 0 Admitted in District of Columbia • Admitted m Florida t Admitted in New York I Heard Certified Civil Trial IMF.' + +Re: Re uest for Tangible and Documentary Evidence (Touhy Request) et al., SDNY Case No. 1:19-cv-07773 + +In follow up to our previous communications, please accept this as our formal written request for documentary and tangible evidence currently in the in the possession, custody, and control of the Department of Justice by way of the Southern District of New York relating to the sexual abuse of one of Jeffrey Epstein's many victims, See United States ex rel. Touhy v. Rages, 340 U.S. 462 (1951). We make this written request pursuant to the Touhy regulations codified as 28 C.F.R. § 16.21 et seq. Should you find there to be any deficiencies within this request, please notify us and we will do what is necessary to correct any such shortcomings. + +&#x27; To protect her anonymity, our client has elected to proceed as a have referred to her herein using the pseudonym under which she has filed her lawsuit. As such, we + +![](_page_1_Picture_1.jpeg) + +We specifically seek copies of the following documents that we believe are currently in the possession of the Government: + +- I) Photographs of +- 2) Videos of +- 3) Any and all correspondence between Jeffrey Epstein, his agents, employees, medical providers, or attorneys and +- 4) Any and all records of purchases of gifts or anything of value purchased for or sent to +- 5) Any and all records of donations made to the Martha Graham Dance Company or Ballet Academy East on behalf of +- 6) Any and all records showing that a letter or package was sent via U.S. Mail, UPS, FedEx, or by any other means of shipping from Jeffrey Epstein, his agents, or his employees to +- 7) Any and all records of payments made to medical providers on behalf of +- 8) Any and all records of payments made to accountants on behalf of +- 9) Any and all documents including true name; +- 10) Any and all lists including true name; and +- 11) Any and all other documentary materials relating in any way to + +Pursuant to the Touhy regulations set forth by the Department of Justice, the Deputy or Associate Attorney General assesses the following considerations in determining whether disclosure is warranted: + +(a)(1) Whether such disclosure is appropriate under the rules of procedure governing the case or mater in which the demand arose; + +(a)(2) Whether disclosure is appropriate under the relevant substantive law of privilege. This request satisfies both of these considerations. As explained previously, the requested non-privileged documentary evidence directly concerns the allegations in civil case. + +Due to the establishment of the Epstein Victim Compensation Program that is currently underway, seeks this information on an expedited basis in order to properly and completely present her claim for consideration, and if necessary, to continue to proceed by way of formal litigation. The requested information is within the scope of ordinary practice and does not seek disclosure of + +information prohibited by statute or regulation. Furthermore, this request does not seek information that is classified or that would reveal the source or identity of any informant. To that effect, specifically does not request any investigatory records compiled for law enforcement purposes that would interfere with ongoing law enforcement proceedings. simply requests information in the Government's possession that will assist in the prosecution of her claims and ultimately, aid in her ability to finally obtain the 'ustice that she deserves. To the extent that the requested materials can be made available to on an expedited basis, it would be greatly appreciated. + +Please contact us at your earliest convenience to discuss the identity of in more detail, at which time we are fully prepared to answer any questions that you may have. + +Very truly yours, + +EDWARDS POTTINGER LLC + +Bradley Edwards Brittany Henderson \ No newline at end of file diff --git a/marker2/ds9/EFTA00089722/EFTA00089722.metadata.json b/marker2/ds9/EFTA00089722/EFTA00089722.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..927d302778bcd7855ad62a6d444680be5c11c760 --- /dev/null +++ b/marker2/ds9/EFTA00089722/EFTA00089722.metadata.json @@ -0,0 +1,200 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089722.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 4546, + "elapsed_seconds": 1.04, + "image_assets": [ + "_page_0_Picture_0.jpeg", + "_page_1_Picture_1.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "FOIA PRIVACY EXEMPTION", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 192.168, + 238.95 + ], + [ + 419.9288330078125, + 238.95 + ], + [ + 419.9288330078125, + 257.2598876953125 + ], + [ + 192.168, + 257.2598876953125 + ] + ] + }, + { + "title": "VIA E-MAIL AND FEDEX", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 269.73 + ], + [ + 217.50064086914062, + 269.73 + ], + [ + 217.50064086914062, + 284.8535461425781 + ], + [ + 68.544, + 284.8535461425781 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 92 + ], + [ + "Line", + 44 + ], + [ + "Text", + 13 + ], + [ + "SectionHeader", + 2 + ], + [ + "Picture", + 1 + ], + [ + "Footnote", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 61 + ], + [ + "Line", + 31 + ], + [ + "ListItem", + 11 + ], + [ + "Text", + 5 + ], + [ + "PageHeader", + 1 + ], + [ + "Picture", + 1 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 31 + ], + [ + "Line", + 16 + ], + [ + "Text", + 5 + ], + [ + "PageHeader", + 1 + ], + [ + "Caption", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089722" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089722/_page_0_Picture_0.jpeg b/marker2/ds9/EFTA00089722/_page_0_Picture_0.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..7c82d24501d19299f7d968076664a4da9fd15f6b --- /dev/null +++ b/marker2/ds9/EFTA00089722/_page_0_Picture_0.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:6fc56c2478f4f2880c39aeb2d77e8a4ee873e4cc6b7005f6d1a1526097bd8ff3 +size 3640 diff --git a/marker2/ds9/EFTA00089722/_page_1_Picture_1.jpeg b/marker2/ds9/EFTA00089722/_page_1_Picture_1.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..b7ae806b098b7450a0583d387222ee75eb5216ef --- /dev/null +++ b/marker2/ds9/EFTA00089722/_page_1_Picture_1.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:ab04481e385facfff12e66391b2f4b906c6c8dc4da557826c5a308a730dc4aa8 +size 13205 diff --git a/marker2/ds9/EFTA00089725/EFTA00089725.md b/marker2/ds9/EFTA00089725/EFTA00089725.md new file mode 100644 index 0000000000000000000000000000000000000000..d7c4039948f16dda2481b2a6f9d66d2b597a8750 --- /dev/null +++ b/marker2/ds9/EFTA00089725/EFTA00089725.md @@ -0,0 +1,57 @@ +![](_page_0_Picture_0.jpeg) + +Florida Office + +Bradley J. Edwards "Of Seth M. Lehrman "t Brittany N. Henderson "0 Matthew D. Weissing "I + +EDWARDS POTTINGER LLC + +425 North Andrews Avenue Suite 2 Fort Lauderdale, FL 33301 + +Telephone (954)524-2820 Fax (954)524-2822 + +October 21, 2020 FOIA PRIVACY EXEMPTION + +## VIA E-MAIL AND FEDEX + +The Honorable Geoffrey S. Berman United States Attorney for the Southern District of New York + +Assistant United States Attorney 86 Chambers Street, Third Floor New York, New York 10007 + +Dear + +New York Office J. Stanley Pottinger + +j Admitted in California 0 Admitted in District of Columbia • Admitted m Florida t Admitted in New York I liKard Certified Civil Trial l.av,)rr + +Re: Request for Tangible and Documentary Evidence (Touhy Request) + +In follow up to our previous communications, please accept this as our formal written request for documentary and tangible evidence currently in the in the possession, custody, and control of the Department of Justice by way of the Southern District of New York relating to the sexual abuse of one of Jeffrey Epstein's many victims, See United States ex rel. Touhy v. Ragen, 340 U.S. 462 (1951). We make this written request pursuant to the Touhy regulations codified as 28 C.F.R. § 16.21 et seq. Should you find there to be any deficiencies within this request, please notify us and we will do what is necessary to correct any such shortcomings. + +' To rotect her anonymity, our client As such, we have referred to her herein as has elected to proceed as a We specifically seek copies of the following documents that we believe are currently in the possession of the Government: + +- I) Photographs of +- 2) Videos of +- 3) Any and all correspondence between Jeffrey Epstein, his agents, employees, medical providers, or attorneys and -; +- 4) Any and all records of purchases of gifts or anything of value purchased for or sent to +- 5) Any and all records showing that a letter or package was sent via U.S. Mail, UPS, FedEx, or by any other means of shipping from Jeffrey Epstein, his agents, or his employees to +- 6) Any and all records of payments made to medical providers on behalf of +- 7) Any and all documents including 's true name; +- 8) Any and all lists including s true name; and +- 9) Any and all other documentary materials relating in any way to + +Pursuant to the Touhy regulations set forth by the Department of Justice, the Deputy or Associate Attorney General assesses the following considerations in determining whether disclosure is warranted: + +(a)( I ) Whether such disclosure is appropriate under the rules of procedure governing the case or mater in which the demand arose; + +(a)(2) Whether disclosure is appropriate under the relevant substantive law of privilege. This request satisfies both of these considerations. As explained previously, the re uested non-privileged documentary evidence directly concerns the allegations in civil case. + +Due to the establishment of the Epstein Victim Compensation Program that is currently underway, seeks this information in order to properly submit her claim for consideration, and if necessary, to proceed by way of formal litigation. The requested information is within the scope of ordinary practice and does not seek disclosure of information prohibited by statute or regulation. Furthermore, this request does not seek information that is classified or that would reveal the source or identity of any informant. To that effect, specifically does not request any investigatory records compiled for law enforcement purposes that would interfere with ongoing law enforcement proceedings. simply requests information in the Government's possession that will assist in the prosecution of her claims and ultimately, aid in her ability to finally obtain the \*ustice that she deserves. To the extent that the requested materials can be made available to on an expedited basis, it would be greatly appreciated. + +Please contact us at your earliest convenience to discuss the identity of in more detail, at which time we are fully prepared to answer any questions that you may have. + +Very truly yours, + +EDWARDS POTTINGER LLC + +Bradley Edwards Brittany Henderson \ No newline at end of file diff --git a/marker2/ds9/EFTA00089725/EFTA00089725.metadata.json b/marker2/ds9/EFTA00089725/EFTA00089725.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..c61b696d294602999953d42dfa1f5ee987896cb4 --- /dev/null +++ b/marker2/ds9/EFTA00089725/EFTA00089725.metadata.json @@ -0,0 +1,168 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089725.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 4181, + "elapsed_seconds": 1.2, + "image_assets": [ + "_page_0_Picture_0.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "VIA E-MAIL AND FEDEX", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 255.96000000000004 + ], + [ + 217.50064086914062, + 255.96000000000004 + ], + [ + 217.50064086914062, + 271.353515625 + ], + [ + 68.544, + 271.353515625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 89 + ], + [ + "Line", + 44 + ], + [ + "Text", + 14 + ], + [ + "Picture", + 1 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 69 + ], + [ + "Line", + 35 + ], + [ + "ListItem", + 9 + ], + [ + "Text", + 5 + ], + [ + "PageHeader", + 1 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 15 + ], + [ + "Line", + 8 + ], + [ + "Text", + 4 + ], + [ + "PageHeader", + 1 + ], + [ + "Caption", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089725" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089725/_page_0_Picture_0.jpeg b/marker2/ds9/EFTA00089725/_page_0_Picture_0.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..1b6f6adfda6cce6dda811e8d3663f6846bcba019 --- /dev/null +++ b/marker2/ds9/EFTA00089725/_page_0_Picture_0.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:515faaabb5a516f7fa2cbe4c62ae6fb18519b5c97804543fbb8da22a0ba92529 +size 3880 diff --git a/marker2/ds9/EFTA00089728/EFTA00089728.md b/marker2/ds9/EFTA00089728/EFTA00089728.md new file mode 100644 index 0000000000000000000000000000000000000000..d5a4fffb5a1ef1c5e70ddcceac01b90bf8cb96c8 --- /dev/null +++ b/marker2/ds9/EFTA00089728/EFTA00089728.md @@ -0,0 +1,63 @@ +Florida Office + +Bradley J. Edwards \*0f Seth M. Lehrman "t Brittany N. Henderson \*0 Matthew D. Weissing \*I + +![](_page_0_Picture_0.jpeg) + +EDWARDS POTTINGER LLC + +425 North Andrews Avenue Suite 2 Fort Lauderdale, FL 33301 + +Telephone (954)524-2820 Fax (954)524-2822 + +October 21, 2020 FOIA PRIVACY EXEMPTION + +## VIA E-MAIL AND FEDEX + +The Honorable Geoffrey S. Berman United States Attorney for the Southern District of New York + +Assistant United States Attorney 86 Chambers Street, Third Floor New York, New York 10007 + +Dear + +New York Office J. Stanley Pottinger + +j Admitted in California 0 Admitted in District of Columbia • Admitted m Florida j Admitted in New York I HOAR] Certified Civil Trial lawFr + +Re: Request for Tangible and Documentary Evidence (Touhy Request) + +In follow up to our previous communications, please accept this as our formal written request for documentary and tangible evidence currently in the in the possession, custody, and control of the Department of Justice by way of the Southern District of New York relating to the sexual abuse of one of Jeffrey Epstein's many victims' See United States ex rel. Touhy v. Rage::, 340 U.S. 462 (1951). We make this written request pursuant to the Touhy regulations codified as 28 C.F.R. § 16.21 et seq. Should you find there to be any deficiencies within this request, please notify us and we will do what is necessary to correct any such shortcomings. + +' To protect her anonymity, our client, have referred to her herein as has elected to proceed as a . As such, we + +![](_page_1_Picture_1.jpeg) + +We specifically seek copies of the following documents that we believe are currently in the possession of the Government: + +- I) Photographs of +- 2) Videos of +- 3) Any and all correspondence between Jeffrey Epstein, his agents, employees, medical providers, or attorneys and +- 4) Any and all records of purchases of gifts or anything of value purchased for or sent to +- 5) Any and all records showing that a letter or package was sent via U.S. Mail, UPS, FedEx, or by any other means of shipping from Jeffrey Epstein, his agents, or his employees to +- 6) Any and all records of payments made to medical providers on behalf of +- 7) Any and all documents including true name; +- 8) Any and all lists including true name; and +- 9) Any and all other documentary materials relating in any way to + +Pursuant to the Touhy regulations set forth by the Department of Justice, the Deputy or Associate Attorney General assesses the following considerations in determining whether disclosure is warranted: + +(a)(1) Whether such disclosure is appropriate under the rules of procedure governing the case or mater in which the demand arose; (a)(2) Whether disclosure is appropriate under the relevant substantive law of privilege. This request satisfies both of these considerations. As explained previously, the requested non-privileged documentary evidence directly concerns the allegations in civil case. + +Due to the establishment of the Epstein Victim Compensation Program that is currently underway, seeks this information in order to properly submit her claim for consideration, and if necessary, to proceed by way of formal litigation. The requested information is within the scope of ordinary practice and does not seek disclosure of information prohibited by statute or regulation. Furthermore, this request does not seek information that is classified or that would reveal the source or identity of any informant. To that effect, specifically does not request any investigatory records compiled for law enforcement purposes that would interfere with ongoing law enforcement proceedings. simply requests information in the Government's possession that will assist in the prosecution of her claims and ultimately, aid in her ability to + +finally obtain the that she deserves. To the extent that the requested materials can be made available to on an expedited basis, it would be greatly appreciated. + +Please contact us at your earliest convenience to discuss the identity of in more detail, at which time we are fully prepared to answer any questions that you may have. + +Very truly yours, + +EDWARDS POTTINGER LLC + +aa + +Bradley Edwards Brittany Henderson \ No newline at end of file diff --git a/marker2/ds9/EFTA00089728/EFTA00089728.metadata.json b/marker2/ds9/EFTA00089728/EFTA00089728.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..793067229e94525cf405d28058922d13c455d3fb --- /dev/null +++ b/marker2/ds9/EFTA00089728/EFTA00089728.metadata.json @@ -0,0 +1,173 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089728.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 4200, + "elapsed_seconds": 0.96, + "image_assets": [ + "_page_0_Picture_0.jpeg", + "_page_1_Picture_1.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "VIA E-MAIL AND FEDEX", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 255.96000000000004 + ], + [ + 217.50064086914062, + 255.96000000000004 + ], + [ + 217.50064086914062, + 271.353515625 + ], + [ + 68.544, + 271.353515625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 88 + ], + [ + "Line", + 44 + ], + [ + "Text", + 14 + ], + [ + "Picture", + 1 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 65 + ], + [ + "Line", + 33 + ], + [ + "ListItem", + 9 + ], + [ + "Text", + 4 + ], + [ + "ListGroup", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 23 + ], + [ + "Line", + 11 + ], + [ + "Text", + 5 + ], + [ + "PageHeader", + 1 + ], + [ + "Caption", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089728" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089728/_page_0_Picture_0.jpeg b/marker2/ds9/EFTA00089728/_page_0_Picture_0.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..1f327f01a596c45e3aed9af3bf01c70eb31c4ca2 --- /dev/null +++ b/marker2/ds9/EFTA00089728/_page_0_Picture_0.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:ec11c60f79b8089c2d4feb7355f93529d8cc7758cbe76346380c7844a07dd223 +size 3877 diff --git a/marker2/ds9/EFTA00089728/_page_1_Picture_1.jpeg b/marker2/ds9/EFTA00089728/_page_1_Picture_1.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..5cda2fadad0b6f63bde01ea5d707965cc773be3f --- /dev/null +++ b/marker2/ds9/EFTA00089728/_page_1_Picture_1.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:01f519f53ccd638b392e4b1019b64ce4eeae4593316fbf983fc24b991d9fb94e +size 12855 diff --git a/marker2/ds9/EFTA00089731/EFTA00089731.md b/marker2/ds9/EFTA00089731/EFTA00089731.md new file mode 100644 index 0000000000000000000000000000000000000000..0800c62f8739a7dc6e5ea1107ea5ed45a5f1af83 --- /dev/null +++ b/marker2/ds9/EFTA00089731/EFTA00089731.md @@ -0,0 +1,56 @@ +![](_page_0_Picture_0.jpeg) + +Florida Office + +Bradley J. Edwards \*Of Seth M. Lehrman 't Brittany N. Henderson \*0 Matthew D. Weissing \*I + +EDWARDS POTTINGER LLC + +425 North Andrews Avenue Suite 2 Fort Lauderdale, FL 33301 + +Telephone (954)524-2820 Fax (954)524-2822 + +October 21, 2020 FOIA PRIVACY EXEMPTION + +## VIA E-MAIL AND FEDEX + +The Honorable Geoffrey S. Berman United States Attorney for the Southern District of New York + +Assistant United States Attorney 86 Chambers Street, Third Floor New York, New York 10007 + +Dear + +New York Office J. Stanley Pottinger + +j Admitted in California 0 Admitted in District of Columbia • Admitted m Florida t Admitted in New York Hoard Certified Civet Trial lawFr + +Re: Request for Tangible and Documentary Evidence (Touhy Request) et al., SDNY Case No. 1:19-cv-07625 + +In follow up to our previous communications, please accept this as our formal written request for documentary and tangible evidence currently in the in the possession, custody, and control of the Department of Justice by way of the Southern District of New York relating to the sexual abuse of one of Jeffrey Epstein's many victims,. I See United States ex rel. Touhy v. Ragen, 340 U.S. 462 (1951). We make this written request pursuant to the Touhy regulations codified as 28 C.F.R. § 16.21 et seq. Should you find there to be any deficiencies within this request, please notify us and we will do what is necessary to correct any such shortcomings. + +U + +&#x27; To protect her anonymity, our client has elected to proceed as a II. As such, we have referred to her herein using the pseudonym under which she has filed her lawsuit. + +We specifically seek copies of the following documents that we believe are currently in the possession of the Government: + +- I) Photographs of.; +- 2) Videos of M; +- 3) Any and all correspondence between Jeffrey Epstein, his agents, or his employees, and +- 4) Any and all documents including true name; +- 5) Any and all lists including true name; and +- 6) Any and all other documentary materials relating in any way to E. + +Pursuant to the Touhy regulations set forth by the Department of Justice, the Deputy or Associate Attorney General assesses the following considerations in determining whether disclosure is warranted: + +(a)( I) Whether such disclosure is appropriate under the rules of procedure governing the case or mater in which the demand arose; + +(a)(2) Whether disclosure is appropriate under the relevant substantive law of privilege. This request satisfies both of these considerations. As explained previously, the requested non-privileged documentary evidence directly concerns the allegations in civil case. + +Due to the establishment of the Epstein Victim Compensation Program that is currently underway, seeks this information on an expedited basis in order to properly and completely present her claim for consideration, and if necessary, to continue to proceed by way of formal litigation. The requested information is within the scope of ordinary practice and does not seek disclosure of information prohibited by statute or regulation. Furthermore, this request does not seek information that is classified or that would reveal the source or identity of any informant. To that effect, El specifically does not request any investigatory records compiled for law enforcement purposes that would interfere with ongoing law enforcement proceedings. simply requests information in the Government's possession that will assist in the prosecution of her claims and ultimately, aid in her ability to finally obtain thej2stice that she deserves. To the extent that the requested materials can be made available to on an expedited basis, it would be greatly appreciated. + +Please contact us at your earliest convenience to discuss the identity of. in more detail, at which time we are fully prepared to answer any questions that you may have. + +Very truly yours, EDWARDS POTTINGER LLC + +Bradley Edwards Brittany Henderson \ No newline at end of file diff --git a/marker2/ds9/EFTA00089731/EFTA00089731.metadata.json b/marker2/ds9/EFTA00089731/EFTA00089731.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..0cb4637dc52ce8fa0097779d0f44b1b41407a0b3 --- /dev/null +++ b/marker2/ds9/EFTA00089731/EFTA00089731.metadata.json @@ -0,0 +1,134 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089731.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 3972, + "elapsed_seconds": 0.96, + "image_assets": [ + "_page_0_Picture_0.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "VIA E-MAIL AND FEDEX", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 255.96000000000004 + ], + [ + 217.50064086914062, + 255.96000000000004 + ], + [ + 217.50064086914062, + 271.353515625 + ], + [ + 68.544, + 271.353515625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 92 + ], + [ + "Line", + 44 + ], + [ + "Text", + 14 + ], + [ + "Picture", + 1 + ], + [ + "SectionHeader", + 1 + ], + [ + "Footnote", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 73 + ], + [ + "Line", + 37 + ], + [ + "Text", + 8 + ], + [ + "ListItem", + 6 + ], + [ + "PageHeader", + 1 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089731" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089731/_page_0_Picture_0.jpeg b/marker2/ds9/EFTA00089731/_page_0_Picture_0.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..e5b706b9f56fc960576d2d48f3d10442908702f5 --- /dev/null +++ b/marker2/ds9/EFTA00089731/_page_0_Picture_0.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:964ffa4c723efd06b1d5ca074421baf6fc71b255a22af40c4a4367a18a9eec06 +size 3645 diff --git a/marker2/ds9/EFTA00089733/EFTA00089733.md b/marker2/ds9/EFTA00089733/EFTA00089733.md new file mode 100644 index 0000000000000000000000000000000000000000..da1be39752cf1ada8176916b06fa9f4ed88195b2 --- /dev/null +++ b/marker2/ds9/EFTA00089733/EFTA00089733.md @@ -0,0 +1,47 @@ +To: + +Subject: RE: US v. Epstein (SW database) + +Date: Wed, 04 Nov 2020 18:07:59 +0000 + +Inline-Images: image001.png + +Thank you. + +From: + +Sent: Wednesday, November 4, 2020 12:13 PM + +To + +Subject: RE: US v. Epstein (SW database) + +If everything goes according to plan and there are no issues the estimate from the vendor is that the large production should be completed and copied to a drive by November 19th . Please note that this does not include the Florida documents which the vendor is working on right now. + +From + +Se + +Thank you very muc At this point, can the vendor give us an estimate of (1) when all seven parts will finish bates stamping, and (2) when all seven parts will be saved on the drive? + +From + +Sent: e nes a ovem er : + +To: + +u je : v. ps ein a a ase + +Hello, + +The vendor had to break up the production into seven parts. As of right now the vendor has finished parts 1— 3 and is about to start on the stamping of documents for part 4. The vendor has exported part one to the hard drive and is currently working on exporting part to two the hard drive right now. Part three just finished about 10 minutes ago and the export has not started yet. You can review the productions by going to the following searches: + +Q SDNY\_PROD015 - PART 02 + +Q SDNY\_PROD015 - PART 03 + +If there are any questions please let me know. + +Thank you. + +![](_page_1_Picture_5.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00089733/EFTA00089733.metadata.json b/marker2/ds9/EFTA00089733/EFTA00089733.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..85fd795b22e575532b79352b007365d60bf26754 --- /dev/null +++ b/marker2/ds9/EFTA00089733/EFTA00089733.metadata.json @@ -0,0 +1,90 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089733.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 1363, + "elapsed_seconds": 1.04, + "image_assets": [ + "_page_1_Picture_5.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 55 + ], + [ + "Line", + 27 + ], + [ + "Text", + 21 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 13 + ], + [ + "Line", + 6 + ], + [ + "Text", + 5 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089733" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089733/_page_1_Picture_5.jpeg b/marker2/ds9/EFTA00089733/_page_1_Picture_5.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..c8a743127f34b7dddfb5f47dc4af2acf06ccd34b --- /dev/null +++ b/marker2/ds9/EFTA00089733/_page_1_Picture_5.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:4a8678132b65b72903491e22e33068eafe1e0d285c58778c81323156997100a5 +size 1575 diff --git a/marker2/ds9/EFTA00089735/EFTA00089735.md b/marker2/ds9/EFTA00089735/EFTA00089735.md new file mode 100644 index 0000000000000000000000000000000000000000..a10ed905a5c9d8ed1309dc13fcd7122140ab5a04 --- /dev/null +++ b/marker2/ds9/EFTA00089735/EFTA00089735.md @@ -0,0 +1,109 @@ +To: + +Cc: + +Subject: RE: Expert Witness + +Date: Wed, 04 Nov 2020 21:13:41 +0000 + +Importance: Normal + +Hi M, I have asked Dr. Cooper for a date/time next week. Do you prefer after 5pm? + +Jan + +Jan Johnson + +Legal & Conference Coordinator + +Dev A. + +cell: + +Original Message + +From: + +Sent: Wednesday, November 4, 2020 2:28pm + +To: + +Cc: + +Subjec xper i ness + +Hi Jan, + +Just following up on this — would it be possible to schedule a call with Dr. Cooper? + +Thanks very much, + +From: + +Sent: Wednesda October 28, 2020 6:58 PM + +To + +Cc: + +Subject: RE: Expert Witness + +Hi Jan, + +Thank you, that's the correct date — apologies for the typo. It is generally not our practice to provide an expert with information about the case, as we are not seeking an expert opinion on a specific set of facts. Instead, we are interested in calling an expert to explain certain specific terms and concepts relating to child victims of sexual abuse, which we understand is an area within Dr. Cooper's expertise. + +Thanks, + +From• + +Sent: Wednesday, October 28, 2020 2:24 PM + +To: + +Cc: + +Subject: RE: Expert Witness + +Good afternoon + +This case is scheduled for trial on July 12, 2021? If so, would you be able to give me a brief summary for Dr.Cooper to review? Once she has a chance to review it, I will be happy to schedule a conference call between you. + +Thanks for your kind consideration. + +**Jan Johnson** + +Legal & Conference Coordinator + +Developmental & Forensic Pediatrics, P.A. + +cell: [REDACTED] + +-----Original Message----- + +From: [REDACTED] + +Sent: Wednesday, October 28, 2020 1:24pm + +To: "[REDACTED]" + +Cc: [REDACTED] + +Subject: Expert Witness + +Good afternoon, + +My colleagues, [REDACTED] and [REDACTED], and I are the prosecutors in the case of *United States v. Ghislaine Maxwell*, which is scheduled to go to trial on July 12, 2020 in the Southern District of New York. We are reaching out because we would be interested in speaking with Dr. Cooper about potentially testifying at trial. Would it be possible to schedule a call with Dr. Cooper to discuss? + +Thanks very much, + +[REDACTED] + +Assistant United States Attorney + +Southern District of New York + +One Saint Andrew's Plaza + +New York, NY 10007 + +[REDACTED] \ No newline at end of file diff --git a/marker2/ds9/EFTA00089735/EFTA00089735.metadata.json b/marker2/ds9/EFTA00089735/EFTA00089735.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..247fde16ef614cc578190f9be9b9cde20b1da674 --- /dev/null +++ b/marker2/ds9/EFTA00089735/EFTA00089735.metadata.json @@ -0,0 +1,76 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089735.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2167, + "elapsed_seconds": 5.12, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 90 + ], + [ + "Line", + 44 + ], + [ + "Text", + 37 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 42 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089735" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089737/EFTA00089737.md b/marker2/ds9/EFTA00089737/EFTA00089737.md new file mode 100644 index 0000000000000000000000000000000000000000..8d47d40ae8a127413921c32397c18c249c0bbfca --- /dev/null +++ b/marker2/ds9/EFTA00089737/EFTA00089737.md @@ -0,0 +1,33 @@ +![](_page_0_Picture_0.jpeg) + +United States Attorney Southern District of New York + +## BY ECF + +The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse + +May 20, 2021 + +Re: United States v. Ohislaine Maxwell, 20 Cr. 330 (AJN) + +Dear Judge Nathan: + +The Government respectfully submits this letter in response to the Court's Order dated May 17, 2021, which directed the Government to confer with defense counsel and submit proposed redactions to Exhibit C to the defendant's memorandum in support of her supplemental pre-trial motions. (Dkt. No. 284). + +The Government seeks redactions that are narrowly tailored to protect the privacy interests of victims and third parties referenced in the document. These proposed redactions are consistent with the three-part test articulated by the Second Circuit in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006). Today the Government is submitting to the Court by email its proposed redactions to Exhibit C, which the Government respectfully requests be filed under seal. + +The Government has conferred with defense counsel in accordance with the Order. 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Mollo Building One Saint Andrew's Plaza New York, New York 10007 + +May 21, 2021 + +## BY ELECTRONIC MAIL + +Christian Everdell, Esq. Mark Cohen, Esq. Cohen & Gresser LLP + +111.111.2 + +Laura Menninger, Esq. Jeffrey Pagliuca, Esq. Haddon, Morgan and Foreman, P.C. + +enver, + +Bobbi Stemheim, Esq. Law Offices of Bobbi C. Stemheim + +New York, NY 10007 + +Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) + +Dear Counsel: + +Today we are producing the materials listed in the below index. These discovery materials are stamped with control numbers SDNY\_GM\_02753432 through SDNY\_GM\_02753551 and SDNY GM SUPP 00219450 through SDNY\_GM\_SUPP\_00219451. + +Please note that both this letter and the enclosed materials are governed by the July 31, 2020 Protective Order in this case. This letter is itself designated as "confidential," because it includes information regarding records designated as "confidential" under the Protective Order. An index of the materials contained in this production is below: + +| Bates Start | Bates End | Summary Description | Confidential | +|------------------|------------------|------------------------|--------------| +| SDNY_GM_02753432 | SDNY GM 02753528 | Interlochen records | Confidential | +| SDNY_GM_02753529 | SDNY_GM_02753529 | Native "carved" images | | + +| SDNY_GM_02753530 | SDNY_GM_02753530 | Native "carved" images | +|------------------|------------------|------------------------| +| SDNY GM 02753531 | SDNY GM 02753531 | Native "carved" images | +| SDNY_GM_02753532 | SDNY_GM_02753532 | Native "carved" images | +| SDNY_GM_02753533 | SDNY_GM_02753533 | Native "carved" images | +| SDNY_GM_02753534 | SDNY_GM_02753534 | Native "carved" images | +| SDNY_GM_02753535 | SDNY_GM_02753535 | Native "carved" images | +| SDNY_GM_02753536 | SDNY_GM_02753536 | Native "carved" images | +| SDNY_GM_02753537 | SDNY_GM_02753537 | Native "carved" images | +| SDNY_GM_02753538 | SDNY_GM_02753538 | Native "carved" images | +| SDNY_GM_02753539 | SDNY_GM_02753539 | Native "carved" images | +| SDNY_GM_02753540 | SDNY_GM_02753540 | Native "carved" images | +| SDNY GM 02753541 | SDNY GM 02753541 | Native "carved" images | +| SDNY_GM_02753542 | SDNY_GM_02753542 | Native "carved" images | + +| | | format for device NYCO24351 | +|-----------------------------|-----------------------------|--------------------------------------------------------------------------------------------| +| SDNY_GM_02753543 | SDNY_GM_02753543 | Native "carved" images Confidential previously produced in PDF format for device NYCO24363 | +| SDNY GM 02753544 | SDNY_GM_02753544 | Native "carved" images Confidential previously produced in PDF format for device NYCO24368 | +| SDNY_GM_02753545 | SDNY_GM_02753545 | Native "carved" images Confidential previously produced in PDF format for device NYCO24370 | +| SDNY_GM_02753546 | SDNY_GM_02753546 | Native "carved" images Confidential previously produced in PDF format for device NYCO24372 | +| SDNY_GM_02753547 | SDNY_GM_02753547 | Native "carved" images Confidential previously produced in PDF format for device NYCO24384 | +| SDNY_GM_02753548 | SDNY_GM_02753548 | Native "carved" images Confidential previously produced in PDF format for device NYCO24386 | +| SDNY_GM_02753549 | SDNY_GM_02753549 | Native "carved" images Confidential previously produced in PDF format for device NYCO24388 | +| SDNY_GM_02753550 | SDNY_GM_02753550 | Native "carved" images Confidential previously produced in PDF format for device NYCO24392 | +| SDNY_GM_02753551 | SDNY_GM_02753551 | Native "carved" images Confidential previously produced in PDF format for device NYCO27910 | +| SDNY _ GM _ SUPP _ 00219450 | SDNY _ GM _ SUPP _ 00219450 | Image from device Confidential NYCO24329 | +| SDNY _ GM _ SUPP _ 00219451 | SDNY _ GM _ SUPP _ 00219451 | Image from device Confidential NYCO24366 | + +The Government recognizes that its discovery obligations are ongoing and will promptly produce any additional discoverable material of which it becomes aware. Please do not hesitate to reach out if you have any difficulty accessing these materials. + +Very truly yours, + +AUDREY STRAUSS +United States Attorney + +by: + +![]()Assistant United States Attorneys + +![]() \ No newline at end of file diff --git a/marker2/ds9/EFTA00089739/EFTA00089739.metadata.json b/marker2/ds9/EFTA00089739/EFTA00089739.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..ea1a2020fa7e120e4036aa3fe898436417ec423d --- /dev/null +++ b/marker2/ds9/EFTA00089739/EFTA00089739.metadata.json @@ -0,0 +1,217 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089739.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 4, + "chars": 4696, + "elapsed_seconds": 2.9, + "image_assets": [ + "_page_0_Picture_0.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "U.S. Department of Justice", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 319.464, + 25.11 + ], + [ + 463.635986328125, + 25.11 + ], + [ + 463.635986328125, + 40.5 + ], + [ + 319.464, + 40.5 + ] + ] + }, + { + "title": "BY ELECTRONIC MAIL", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 168.48 + ], + [ + 211.11807250976562, + 168.48 + ], + [ + 211.11807250976562, + 182.853515625 + ], + [ + 68.544, + 182.853515625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 75 + ], + [ + "Line", + 37 + ], + [ + "Text", + 13 + ], + [ + "SectionHeader", + 2 + ], + [ + "Picture", + 1 + ], + [ + "Table", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 129 + ], + [ + "Line", + 65 + ], + [ + "PageHeader", + 1 + ], + [ + "Table", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 109 + ], + [ + "Line", + 55 + ], + [ + "PageHeader", + 1 + ], + [ + "Table", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 3, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 20 + ], + [ + "Text", + 18 + ], + [ + "Line", + 10 + ], + [ + "PageHeader", + 2 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089739" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089739/_page_0_Picture_0.jpeg b/marker2/ds9/EFTA00089739/_page_0_Picture_0.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..88e47fe2fe4113bd29a148279f43eb38062042a5 --- /dev/null +++ b/marker2/ds9/EFTA00089739/_page_0_Picture_0.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:a7bc6cc90d0d51d6bd77a66f0e0833ad450f5d79e8dee4c6316c34e63f1f5677 +size 3490 diff --git a/marker2/ds9/EFTA00089743/EFTA00089743.md b/marker2/ds9/EFTA00089743/EFTA00089743.md new file mode 100644 index 0000000000000000000000000000000000000000..05a6518eee626d0e79c5f912b6b04deb0c3e5e43 --- /dev/null +++ b/marker2/ds9/EFTA00089743/EFTA00089743.md @@ -0,0 +1,223 @@ +To: Laura Menninger , ' )" , USANYS)" + +Cc: Jeff Pagliuca , mceverdellgcohengressencomm + +e-ceverdellgcohengressencom>, "'Bobbi Sternheim (bcsternheimgmac.com)'" + +Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies) + +Date: Fri, 21 May 2021 00:21:35 +0000 + +Inline-Images: image001.png; image002.png + +Laura, + +I will pass this on to the FBI and our vendor for review. Once I have consulted with them, I will revert back to you on this issue. + +Thank you, + +From: Laura Menninger + +Sent: Thursday, May 20, 20213:28 PM + +To: mc==.>: I ‹ > (USANYS) + +Cc: Jeff Pagliuca ; 'ceverdell@cohengresser.com' ; 'Bobbi Sternheim (bcsternheim@mac.com)' + +Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies] + +Thank you for your explanation. I also have gone back to our IT department and, unfortunately, your FBI/vendor explanation is insufficient. + +- Based on our review, which has been double-checked, there are hash values in the overlay that don't match the index and visaversa. +- The snips below show an example of an entry from the overlay file you provided (with file names and MD5 Hash) which did not join to the non-nude index. We were able to find the corresponding file in the index using the file name, which in this particular instance was unique. As you can see, the MD5 hashes don't match. + +## From the overlay file + +| ProdBeg8ates File Name | MD5 Hash | +|---------------------------------------------|-----------------------------------| +| SDNY_GM_C0503260 Jeffrey VF2.psd | DA92DF87819FCCI3F38E05841)8077DFB | +| SDNY GM 00506551 LSJ librarywindow150dpilif | 58ACKBE826.591AEFD0604ABA226272D | + +## From non-nude index + +| File Name | SHA-1 | MD5 | +|-------------------------------|------------------------------------------|----------------------------------| +| 1 LJI librarywindow150dpl.tif | 043670EDF17D35EE5794EBDF094AEF63A95D4B9A | BDEB66247E99D1C9EED2BA30FB8F72D5 | + +- More importantly, if as you report you did not deduplicate the production and if the index you produced is accurate, we should be able to match files based on the combination of File Name and MD5 hash. The hash + file name combination might not be unique, but each hash+file name value in the index should have a corresponding entry in the overlay unless hash values and/or file names were modified somewhere in the process. +- As previously reported, if we require a match on the hash value and ignore file names, there are 65 production numbers that don't match the index. + +- There are more entries in SDNY011 (40,567) than entries on the non-nude index (40,536). We cannot understand the discrepancy based on your explanation. + +My earlier requests - a new copy of the non-nude index with an added column to note the production number of each file and a new index for the produced files that were not included in the prior index — still stand. + +Thank you, + +Laura + +Laura A. Menninger I Partner + +Haddon, Morgan & Foreman, P.C. + +1501. 10th Avenue I Denver, CO 80203 + ++1 303 831 7364 (Office) + +ImenningerWmillauccom + +From: + +Sent: Tuesday, May 11, 2021 9:15 PM + +To: Laura Menninger ; iceverdell@cohengresser.com' ; 'Bobbi Sternheim (Msternheim(amarcum)' 4csternheimAmacsum> + +Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies) + +Laura, + +I have consulted with the FBI and our vendor regarding the issues you raised with the overlay. Below is what I understand from them: + +- When using the overlay, you should require only a match of the hash value. +- When our vendor uses the overlay, they do not see any production numbers that do not have a match in the index. If you are still seeing outliers, please let us know which files are not matching up with the index, and our vendor will look into what that issue could be. +- The 17 files with no hash values were either incomplete files or corrupt files when they were recovered from the CDs. We produced them to you so that you would have a copy of every file on the CDs that did not have identifiable nudity. +- Any non-unique hash values are duplicate files. There were many duplicate files on the CDs. The FBI and vendor did not deduplicate the images before producing them in an effort to ensure that you had a complete set of all files recovered from the CDs. +- There are a number of files that were recovered from the CDs but are unopenable on our end. We produced them to you so that you would have a copy of every file on the CDs that did not have identifiable nudity. If you would like to check to see if any particular files are unopenable on our end, we would be happy to check. + +Given the above, the FBI and the vendor believe the overlay previously provided should be sufficient to allow you to review the metadata in this production. + +Best, + +Assistant United States Attorney + +Southern District of New York + +I St. Plaza + +New York, NY 10007 + +From: Laura Menninger + +Sent: Wednesday, April 28, 2021 1:18 PM + +To:
    : (USANYS) + +Thank you for sending the overlay. After review, it unfortunately does not appear sufficient to allow us to properly match the metadata to your production of native files. + +Based on your representations, the "Non-Nude index" located at Bates 467567 in Excel should match the Bates number native images produced at SDNY011. However: + +- The number of entries in the Non-Nude Index is less than the number of files produced. Although the overlay file has 40,567 entries (the same number of files in SDNY011), they don't match up to the Non-Nude Index. o When joining the overlay file to the index: If we require a matching value for both MD5 hash and file name, there are 24,757 entries in the overlay that do not match the index. + - **If we require a match on the hash value and ignore file names, there are 65 production numbers that don't match the index; 17 of those don't have hash values at all.** +- **The overlay has many non-unique hash values, meaning we cannot rely on hash value alone.** +- **The Non-Nude index also has many non-unique hash values.** + +**I think the only feasible resolution is for you to provide a new copy of the non-nude index with an added column to note the production number of each file. We also need a new index for the produced files that were not included in the prior index.** + +**Let me know if you will agree to produce these two new indices.** + +**Thank you, Laura** + +**Laura A. Menninger I Partner Iladdon. Morgan & Foreman, P.C. 150 1. 10th Avenue I Denver, CO 80203 +1 303 831 7364 (Office) ImenningeShinflaw.com** + +**From:** + +**Sent: Tuesday, April 27, 2021 9:35 PM** + +**To: Laura Menninger ** + +**Cc: (USANYS) <** + +**)< I>, Jeff Pagliuca ; 'Bobbi Sternheim (bcs\_ternheimrkoncsgra)' ** + +**Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies)** + +**Laura,** + +**Attached please find a metadata overlay for the production of images from the CDs recovered from Epstein's residence. This file contains the file name and the MDF Hash for each file, which corresponds with the information contained in the SDNY\_GM\_00467567 Spreadsheet. This overlay should allow your team to see which row of metadata corresponds with which Bates number in the production.** + +**Best,** + +**Assistant United States Attorney** + +**Southern District of New York** + +**I St. Plaza** + +From: Sent: Friday, April 23, 2021 1:44 PM To: Laura Menninger <]meppjOgertalhmflaw corO> Cc: (USANYS) < >; Jeff Pagliuca ipagliucaehmflaw.com>; 'ceverdell@cohengresser.comt . 'Bobbi Sternheim (bcsternheim@mac.com)' ; (CIV) Subject: RE: US v. Maxwell - 'conferral re photo and other discovery deficiencies] S>: + +Laura, + +Our vendor has explained the issue with SDNY\_GM\_00467566. That file is a temporary file without content. The file that contains the content is SONY\_GM\_00467567. + +Best, + +Assistant United States Attorney Southern District of New York 1 St. Plaza New York. NY 10007 + +From: + +Sent: Friday, April 23, 2021 12:13 PM + +To: Laura Menninger + +(USANYS) Cc: , Jeff Pagliuca ; iceverdell@cohengresser.com' . 'Bobbi Sternheim (bcsternheimPmac com ; (CIV) < > + +Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies] + +Laura, + +I am working with our team as quickly as we can to address the issues you raised in the below email. In particular: + +- I have asked our vendor to look into the issues with SDNY\_GM\_00467566. When I attempt to access that document on our Relativity database, I also receive an error message saying that the document is corrupt. I am not sure what this spreadsheet is because the only two spreadsheets that I'm aware of that correspond with the SONY\_PROD011 contained in the November 9, 2020 production are the two other Excel spreadsheets you referenced. In any event, I am looking into the issue. +- I am similarly working with our vendor to understand how to best identify for you which Bates number corresponds with the metadata in the index contained in the Excel spreadsheets. Can you please provide me with a list of the photos that you are unable to view? Once I have that list, I will check to see whether we are able to open them on our end. +- Can you be more specific in identifying photographs that you believe should have been produced but have been omitted, please? We have endeavored with the FBI to produce copies of all non-nude photographs recovered from searches of Epstein's residence to the defense, and I am not aware of any intentional omissions. +- I am discussing with the FBI your request that we produce all Highly Confidential images to you. I will respond to that request next week. + +Once we have a firm trial date, I will let you know by what date I expect to be able to provide you with a list of the Highly Confidential photographs we may introduce at trial. I am working with our paralegals to assess the list of files that your client is unable to review at the MDC. As soon as we have finished looking into those issues, I will let you know. + +Best, + +From: Laura Menninger + +Sent: Wednesday, April 21, 2021 1:42 PM + +To: ) + +Cc: (USANYS) < + +>; Jeff Pagliuca . 'ceverdell@cohengresser.com' . + +'Bobbi Sternheim (bcsternheirn(a)mac.com)' + +Subject: US v. Maxwell - [conferral re photo and other discovery deficiencies] + +I'm writing to follow-up on our discussion last Thursday regarding the photo evidence and to address a number of other critical problems with the discovery provided to date. + +Unfortunately, both in the production to defense counsel and on the hard-drive supplied by your office to our client at MDC, there are thousands, if not hundreds of thousands, of photos that are still unreadable. We have spent countless hours, and a chunk of our client's resources, trying to rectify a number of these problems ourselves, to no avail. Our ability, and our client's ability, to review all of the discovery in this case is absolutely critical and is constitutionally guaranteed. Unless you can quickly propose a solution, we believe we need to raise this with the Court. + +- We do not have a functional copy the Excel spreadsheet located at SDNY\_GM\_00467566. I have confirmed that the original spreadsheet provided to us is corrupt and the vendor and discovery provider cannot open it. +- The other two Excel spreadsheets from the production (and presumably the one we cannot open) are insufficiently detailed to tell us which photo goes with which meta-data. o The index contains multiple instances of the same "file name" with different hash values. o The index does not match any particular file with a Bates stamp. o The index does not indicate which files were withheld as "highly confidential." +- Many of the photo files that were provided in discovery (M., SDNY011) do not have a discernible reader. I cannot open them. Ms. Maxwell does not have a reader on her MDC laptop that can read them. If the government is able to view them, then we should be provided the means to view them as well. +- A number of photo files appear to be missing from the MDC laptop and are not highly confidential, based on my review of documents last week. Because we do not have a list of what was/was not produced, however, we cannot confirm. +- As you know, the 2 x "highly confidential hard-drives" in NY did not work until Thursday once an appropriate reader was added to the laptop. I did not have enough time to view all of the files. I do not have the reader that you ultimately added to that laptop. +- The discs that I attempted to view in NY (from various binders) would not load on the government laptop. I was unable to match up disks with potential files on the hard-drives. Because I did not have a functioning Excel spreadsheet, I also was not able to match any highly confidential photos from the hard-drives with the associated metadata. + +I am requesting that you produce to defense counsel replicas of the two hard-drives that you made available for review last week, subject to all of the strictures of the protective order. + +I recognize that you have designated as "highly confidential" photos that you contend contain "nude, partially-nude, or otherwise sexualized images, videos, or other depictions of individuals." Among the photos on the hard-drive that I was able to view, there were a lot of "nude" and "partially-nude" photos of adults, but I did not see anything that would qualify as child pornography under the statute. Some of the photos only showed a woman's back or shoulder. If you have reason to believe that there is child pornography + +contained on the two hard-drives, then certainly defense counsel is not asking to possess that material; you can designate it as such and we can view it at an acceptable location as occurs in any CP case. + +Otherwise, I think the burden of reviewing adult nudity only in the government's office or courthouse imposes an extraordinary cost on our client and prevents us from analyzing the metadata, having our experts review the file structures, keeps us from preparing photos for use at trial, and generally impedes our defense. + +In a similar vein, can you let me know when you are willing to disclose any photos that you intend to introduce at trial? As to any of those, I will need sufficient information and time to analyze them for foundation and admissibility purposes with an appropriate expert. + +Finally, I am attaching an incomplete list of the documents that our client still cannot read at MDC. It is a small sample, as she has had to spend hours of her "review" time communicating to our staff which files she cannot read. Also, the manner in which the discovery was provided to her (load file format) precludes her from comparing the "image" and the "native" files (they do not, for example, have clearly labeled bates-stamps). + +I would appreciate as prompt a response as you can provide so that we can address any issues with the Court on Friday. + +Thanks, Laura + +Laura A. 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Sent: Thursday, May 20, 2021 10:00 PM To: ) Cc: (USANYS) [Contractor] cl > (USANYS) \*c )'; (USANYS) [Contractor] + +Subject: RE: Status update: Maxwell discovery issue files review + +The two part upload worked, and the production is ready to be shared with defense counsel once we have their info to set them up on USAfx. I'll be online for a bit longer tonight in case they get back to us ASAP with that, otherwise I'll add them in the morning. Thank you very much for your patience, and we'll get the production sent out on a disc for Maxwell at MDC tomorrow. + +From: Sent: Thursday, May 20, 2021 8:38 PM To: (USANYS) [Contractor] Cc: (USANYS) [Contractor] < 4 (USANYS) (USANYS) [Contractor] + +Subject: RE: Status update: Maxwell discovery issue files review + +Thanks! Let me know once you've tried the split upload. Once I hear from you, I'll email defense counsel. + +From: (USANYS) (Contractor) .'z . Sent: Thursday, May 20, 2021 8:38 PM To: ) Cc: (USANYS) [Contractor] (USANYS) [Contractor] c:= > (USANYS) + +Subject: RE: Status update: Maxwell discovery issue files review + +ust had the idea to try and split the production into two smaller uploads to put on USAfx, so I'm going to try that and see if it works. Otherwise I'll put it on a disc in the morning for counsel and for Maxwell, though it might be worth noting (either just among us or to defense counsel) that if she can't view non pdf image files she will not be able to view the vast majority of this production. + +From: Sent: Thursday, May 20, 2021 8:31 PM To: (USANYS) [Contractor] Cc: (USANYS) [Contractor] < (USANYS) + +Subject: RE: Status update: Maxwell discovery issue files review + +Ok, no problem. Will you also be able to put it on a disc to send to the MDC for Maxwell, please? + +From: (USANYS) [Contractor] .cz > + +Sent: Thursday, May 20, 2021 8:30 PM + +To: ) tz > + +Cc: (USANYS) [Contractor] (USANYS) + +cfl (USANYS) [Contractor) + +Subject: RE: Status update: Maxwell discovery issue files review + +Actually, unfortunately, the production has failed to upload to USAfx, so we may just need to stick it on a disc tomorrow morning. + +From: (USANYS) [Contractor] + +Sent: Thursday, May 20, 2021 8:24 PM + +To: ) + +Cc: (USANYS) [Contractor] c > (USANYS) + +(USANYS) [Contractor) + +Subject: RE: Status update: Maxwell discovery issue files review + +Feel free to email defense counsel, the production is uploading to USAfx now. We'll just need the email addresses and cell phone numbers to make USAfx accounts for whoever they want to have access to the production (defense counsel or their litigation support people or whoever) so we can share it with them once it's uploaded. Thank you! + +From: cfl + +Sent: Thursday, May 20, 2021 8:17 PM + +To: (USANYS) [Contractor] + +Cc: (USANYS) [Contractor] > (USANYS) + +Subject: RE: Status update: Maxwell discovery issue files review + +(USANYS) [Contractor) + +Perfect, thank you! This is ready to go. Ok for me to email defense counsel with the letter and spreadsheet now? Or do you need any more time to prep the production? + +From: (USANYS) [Contractor] • + +Sent: Thursday, May 20, 2021 7:59 PM + +To: ) + +Cc: (USANYS) [Contractor] c > (USANYS) + +(USANYS) [Contractor) + +Subject: RE: Status update: Maxwell discovery issue files review + +Updated discovery letter is attached (saved here) with the spreadsheet as well for reference. Let me know if you have any additional revisions. + +To: (USANYS) [Contractor] < Cc: (USANYS) [Contractor] < (USANYS) (USANYS) [Contractor] Subject: RE: Status update: Maxwell discovery issue files review + +Perfect, thanks. Let's plan to jump on a call at 7:30. + +From: (USANYS) [Contractor] Sent: Thursday, May 20, 2021 7:15 PM To: Cc: (USANYS) [Contractor] < (USANYS) ; (USANYS) [Contractor] Subject: Re: Status update: Maxwell discovery issue files review + +I will be home in 5-10 if that's okay with you all to wait just a few min? + +Sent from my iPhone + +On May 20, 2021, at 7:13 PM, > wrote: + +That sounds good! I've reviewed what=ent. Are you all available to hop on a call now? + +From: (USANYS) [Contractor] < Sent: Thursday, May 20, 2021 6:26 PM To: Cc: (USANYS) [Contractor] < >; >; Subject: RE: Status update: Maxwell discovery issue files review (USANYS) < (USANYS) [Contractor] >; + +I think we're all around to hop on a call tonight. We were thinking it would be efficient to discuss the materials that Must sent around on the same call. Let us know if you'd like time to review those materials before hopping on the call. + +From: Sent: Thursday, May 20, 2021 6:12 PM To: (USANYS) [Contractor] < >; (USANYS) Cc: (USANYS) [Contractor] < >; Subject: RE: Status update: Maxwell discovery issue files review (USANYS) [Contractor] + +Thanks so much! Can we hop on a quick call to talk this through? Either this evening or tomorrow morning is fine. + +From: (USANYS) [Contractor] < Sent: Thursday, May 20, 2021 5:10 PM To: >; (USANYS) < >; Cc: (USANYS) [Contractor] < >; (USANYS) [Contractor] + +Hi + +Attached is the spreadsheet with each problem file that Maxwell's counsel listed and our corresponding notes. This does not include the "Images Not Exported" section as we are having sre-export those for us to double check. There is one group of files that we'd like to bring to your attention: + +In the "Corrupt" tab of the spreadsheet you'll see that there are a number of files which are labeled "Lazer Scan." These are the same files that we dealt with last August/September (linked here) which I believe we worked out to be 3D renderings and scans of Epstein's compound. and I both recall dealing with this extensively but are having trouble locating emails documenting that fact other than the attached. Happy to discuss over the phone if you'd like and determine a better way to mark them in the spreadsheet. + +Besides that, the list of files should be good to go. And we can inform counsel tonight that we are already working with the vendor to address any files we found to have any issues. + +Please let us know if you have any questions or comments on the spreadsheet. + +Thanks, + +From: + +Sent: Thursday, May 20, 2021 11:58 AM + +To: (USANYS) [Contractor] (USANYS) + +Cc: (USANYS) [Contractor] 4 ); (USANYS) [Contractor] + +Subject: RE: Status update: Maxwell discovery issue files review + +Great, thanks. I'll send an invite for 1:30. + +From: (USANYS) [Contractor] •c + +Sent: Thursday, May 20, 2021 11:54 AM + +To: (USANYS) + +Cc: (USANYS) [Contractor] 4 (USANYS) [Contractor] + +Subject: RE: Status update: Maxwell discovery issue files review + +Of course==, and I are all available from 1pm on. + +From: + +Sent: Thursday, May 20, 2021 11:53 AM + +To: (USANYS) [Contractor] c (USANYS) + +Cc: (USANYS) [Contractor] 4 (USANYS) [Contractor] + +Subject: RE: Status update: Maxwell discovery issue files review + +Thanks, + +From: (USANYS) [Contractor] + +Sent: Friday, May 14, 2021 5:58 PM + +To: (USANYS) + +Cc: (USANYS) [Contractor] (USANYS) [Contractor] + +< + +Subject: Status update: Maxwell discovery issue files review + +Hi all, + +Here is our status update for the review of discovery files that Maxwell is having various issues with, categorized by issue and whether the file was from a PAE export or something we stamped on the shared. + +- Blank files o From PAE export (29 pages/files): all but one of these files that were described as "blank" were in fact blank files; nothing more to do for these files. The one non-blank file among these (SDNY\_GM\_00218894) has no native file that was produced with it (we will look into/confirm with PAE re: whether this was intentional or an oversight), but the image produced for this Bates number should not appear "blank." o From shared drive/stamped by SDNY (308 pages/files): none of these pages were blank. They all were pages within Deutsche Bank records from Production 2. +- Corrupt files o From PAE export (501 pages/files): the initial review of these files is complete, and 290 documents were corrupt in their native produced form when we opened them. There are additionally about 160 documents of varying file types that we did not identify as corrupt but had various issues opening or viewing, which could possibly explain why she had an issue with them. We (paras) can confer more about these files early next week and let you know what we think we should do next (e.g., ask PAE to re-export them, determine whether we/she has appropriate software for viewing, etc.). The remaining pages/files among the 501 identified for review in this category are duplicates of other Bates identified as "corrupt." o From shared drive/stamped by SDNY (2152 pages/files): none of the pdf files identified by defense as "corrupt" were corrupt per our review; all files were able to be opened, and all Bates numbered pages were able to be viewed. + - However, there is a range of files (SDNY\_GM\_00169505-SDNY\_GM\_00169737 from Production 3 (SDNY\_GM\_00166191-SDNY\_GM\_00169759 (Search warrant photos))) that defense listed as "corrupt" but they seem to be weird computer/electronic system files. I cannot open these files to see what they are (many seem to be .fls files or other systems-related unknown file types), and I'm not sure if you previously identified what these files are in particular, either internally when initially producing them or to defense counsel. These files can be found here for our reference/review, and we (paras) will again touch base about these next week to determine to what extent we can help her view them (or whether they are even viewable to us). +- Missing o From PAE export: pending review of master copy discovery hard drive o From shared drive/stamped by SDNY: neither file is missing/no issues with these files +- Can't read/won't open o From PAE export: pending review of master copy discovery hard drive o From shared drive/stamped by SDNY: no issue with these files +- Not supported o From PAE export: pending review of master copy discovery hard drive o No files with this issue from shared drive/stamped by SDNY +- Images not exported + +All in all, the files identified as "blank" and "corrupt" are nearly done being reviewed, and we'll aim to get as much done as we can on the remaining categories in the next week. Let us know if you have questions based on this initial review, and we'll keep you posted as we made additional progress. + +Thanks, + +Paralegal Specialist + +U.S. Attorney's Office I SDNY + +1 Saint Andrew's Plaza + +New York, NY 10007 + +Office: + +Cell: \ No newline at end of file diff --git a/marker2/ds9/EFTA00089749/EFTA00089749.metadata.json b/marker2/ds9/EFTA00089749/EFTA00089749.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..16f454ce6c3e555f5756e134d38be944c4c9db30 --- /dev/null +++ b/marker2/ds9/EFTA00089749/EFTA00089749.metadata.json @@ -0,0 +1,222 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089749.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 6, + "chars": 10538, + "elapsed_seconds": 1.91, + "image_assets": [ + "_page_0_Picture_0.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 91 + ], + [ + "Line", + 42 + ], + [ + "Text", + 13 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 103 + ], + [ + "Line", + 46 + ], + [ + "Text", + 33 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 85 + ], + [ + "Line", + 40 + ], + [ + "Text", + 12 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 3, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 79 + ], + [ + "Line", + 35 + ], + [ + "Text", + 33 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 4, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 97 + ], + [ + "Line", + 49 + ], + [ + "Text", + 11 + ], + [ + "ListItem", + 7 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 5, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 25 + ], + [ + "Line", + 13 + ], + [ + "Text", + 11 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089749" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089749/_page_0_Picture_0.jpeg b/marker2/ds9/EFTA00089749/_page_0_Picture_0.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..b60336bd51085e262263308a3d6e10ff4111a01c --- /dev/null +++ b/marker2/ds9/EFTA00089749/_page_0_Picture_0.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:67299cc0768ce645f4d61e689b6161e1df339b34e03d482bb2861034f064758a +size 10153 diff --git a/marker2/ds9/EFTA00089755/EFTA00089755.md b/marker2/ds9/EFTA00089755/EFTA00089755.md new file mode 100644 index 0000000000000000000000000000000000000000..b4e3d4c8faf7ec0524db1bfeefacd84b2ffa00a2 --- /dev/null +++ b/marker2/ds9/EFTA00089755/EFTA00089755.md @@ -0,0 +1,191 @@ +From: To: Laura Mennin er Christian Everdell Cc: Jeff Pa , "Bobbi Stemheim ( a)" (USANYS) [Contractor]" (USANYS) [Contractor]" USANYS) [Contractor 6 a> + +Subject: RE: Discovery Issues + +Date: Fri, 21 May 2021 02:45:33 +0000 + +Attachments: 2021.05.20\_Maxwell\_Discovery\_Letter.pdf; 2021.05.20\_Supplementary\_Production\_Notes\_for\_Defense\_Counsel.xlsx + +Inline-Images: image001.jpg; image002.jpg + +Counsel, + +Today we have an additional discovery production ready to send to you. This production is small enough to produce via USAfx. Please let us know if you do not already have a USAfx account, in which case our paralegals (cc'd) can assist you in creating an account. We are also sending a CD containing this production to the MDC via FedEx. + +Attached please find a cover letter accompanying this production. As you will see in the letter, the majority of this production consists of materials we are providing in response to your requests for additional information regarding the SUPP production (referenced in the below email exchange). I am also attaching the excel spreadsheet referenced in the cover letter to assist in your review of the materials from the SUPP production. + +Please let us know if you have any further questions regarding the SUPP production or if you have any difficulty accessing the materials. + +Best, + +From: Sent: Tuesday, May 11, 2021 10:42 PM + +To: Laura Menninger .: >; Christian Everdell c >; (USANYS) Cc: Jeff Pagliuca c l); Bobbi Sternheim I 'c > Subject: RE: Discovery Issues + +Laura, + +I am working with our paralegals to look into your requests below. Our paralegals are also still working on the list of files that you provided that Ms. Maxwell has been unable to review at the MDC. As soon as we are able to provide an update on these issues, I will reach back out. + +Best, + +**From:** Laura Menninger <[REDACTED]> + +**Sent:** Friday, May 7, 2021 4:53 PM + +**To:** [REDACTED] <[REDACTED]>; Christian Everdell <[REDACTED]>; [REDACTED] + +[REDACTED] <[REDACTED]>; [REDACTED] (USANYS) <[REDACTED]> + +**Cc:** Jeff Pagliuca <[REDACTED]>; Bobbi Sternheim ([REDACTED]) <[REDACTED]> + +**Subject:** RE: Discovery Issues + +[REDACTED] - + +Also following up on your response to Chris. We have had a chance to take a look at these files again. + +For the SUPP production, many of the files were produced as PDFs, which seems as though they were converted prior to production. As I understand it (which is admittedly limited), carved or deleted files can still contain application metadata. + +We request that as to the SUPP production, you: + +1. a. Provide a list of all files that were carved or deleted; +2. b. Confirm if all those files were produced in native format or if any were converted to PDF; +3. c. If any were converted, provide additional information including the MIME type (for all), and if available from application metadata original file name, file dates, etc. This would amount to the equivalent of the index you provided for SDNY011. +4. d. In the absence of (b), confirm that no application metadata was recovered from those files which might indicate file creation/modified dates + +Please let me know if you have any questions. + +Thanks, + +Laura + +**Laura A. Menninger** | Partner +**Haddon, Morgan & Foreman, P.C.** + +[REDACTED] +[REDACTED] (Office) +[REDACTED] + +**From:** [REDACTED] <[REDACTED]> + +**Sent:** Friday, April 23, 2021 10:30 AM + +**To:** Christian Everdell <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] (USANYS) <[REDACTED]> + +**Cc:** Jeff Pagliuca <[REDACTED]>; Laura Menninger <[REDACTED]>; Bobbi Sternheim ([REDACTED]) <[REDACTED]> + +**Subject:** RE: Discovery Issues + +Chris, + +- For #3, the attachments were not recovered from the searched devices. We do not have them, which is why they were not produced. +- For #4, the electronic files recovered from Epstein's devices have the same metadata on the hard drive that was available when the FBI seized each file. For files that were carved or deleted, no metadata was recovered, so none is viewable, except for data showing when a particular file was saved to a drive by the investigative team or prepared for production. I am not aware of any additional metadata in our possession that you do not have for these files. +- For #5, those photographs were not processed by CART, which is why they do not have a CART number. They came from the CDs that your team reviewed last week. The available metadata for those photographs was produced in two excel spreadsheets with the same production — one with metadata for nude images (which were contained on one of the hard drives you reviewed last week), and one with metadata for non-nude images (which were produced in the November 9, 2020 discovery production). As I mentioned in my email to Laura earlier today, I am working with our vendor to figure out how to best convey to you which Bates numbers correspond with which rows in the spreadsheet. +- For #6: o The SDNY\_GM\_SUPP contain electronic files recovered from Epstein's devices. As noted above, those files have the same metadata on the hard drive that was available when the FBI seized each file. For files that were carved or deleted, no metadata was recovered, so none is viewable. o The videos from SDNY005 (October 20, 2020 production) were converted by a vendor from VHS and cassette tapes, so there is no metadata to provide. The Sept-Octo 2020 dates reflect when these recordings were converted by our vendor. o The SDNY011 (November 9, 2020 production) consists of images from the CDs seized from Epstein's residences, which you reviewed last week. As referenced above, those photographs were not processed by CART, which is why they do not have a CART number. As referenced above, the available metadata for those photographs was produced in two excel spreadsheets with the same production — one with metadata for nude images (which were contained on one of the hard drives you reviewed last week), and one with metadata for non-nude images (which were produced in the November 9, 2020 discovery production). As I mentioned in my email to Laura earlier today, I am working with our vendor to figure out how to best convey to you which Bates numbers correspond with which rows in the spreadsheet. + +Best, + +Assistant United States Attorney Southern District of New York + +From: + +Sent: Tuesday, March 30, 2021 11:10 PM + +To: Christian Everdell < >, + +(USANYS) + +Chris, + +That all makes sense, thanks very much. I will reach back out once I have conferred with our vendor and have answers for you on #3-#6. + +Best, + +Assistant United States Attorney Southern District of New York + +New York, NY 10007 + +From: Christian Everdell • + +Sent: Tuesday, March 30, 2021 10:58 PM + +To: (USANYS) >; + +Cc: 'Jeff Pagliuca' ,:=En; Laura Menninger A >; Bobbi Sternheim + +< + +Subject: RE: Discovery Issues + +Apologies for the late response on this. It seems like it would be better to confer after you have heard back from your vendor, since the answers to #3-#6 will depend on what the vendor says. And I believe we have now resolved #7. + +As for #1 and #2, I will call at MDC and represent to her that we have your concurrence to send the drive directly to Ms. Maxwell. If she agrees, we can add the additional productions to our drive before we send it. If she refuses, we will take it up with Judge Nathan. + +Thanks, + +Chris + +From: rmailto I + +Sent: Monday, March 29 2021 3:36 PM + +To: Christian Everdell; ); III II\_JS. ANYS I + +Cc: 'Jeff Pagliuca'; Laura Menninger; Bobbi Sternheim ) + +Subject: RE: Discovery Issues + +Chris, + +We are available for a call to discuss tomorrow between 1pm and 2pm, between 3pm and 5pm, or after 5:30pm. Please let us know if there is a time in those windows that would work on your end. In the meantime, below are some initial responses: + +- 1. Our supervisors have indicated that we are not permitted to send a drive that our IT department did not load to the MDC. As a result, we cannot provide the drive directly to the MDC. That said, I am happy to join you in asking the MDC to accept the drive from you. If the MDC still refuses, then my office would not object to an application to Judge Nathan for an order directing the MDC to accept the drive from you, though we would need to allow MDC legal counsel the opportunity to note their objections to Judge Nathan. +- 2. The MDC recently alerted us to this issue, and our paralegal converted the excel files at issue to pdfs and sent a new CD with those pdfs to the MDC. If you client still cannot view them, then we are happy to load them to a drive if you would like to provide one for us. +- 3. I have asked our vendor to look into this issue and will get back to you when I have spoken with them. +- 4. I have asked our vendor to look into this issue and will get back to you when I have spoken with them. That said, similar to the note I sent in my email regarding highly confidential images on March 16, 2021, the electronic files recovered from Epstein's devices have the same metadata on the hard drive that was available when the FBI seized each file. For files that were carved or deleted, no metadata was recovered, so none is viewable, except for data showing when a particular file was saved to a drive by the investigative team or prepared for production. +- 5. As indicated in our November 9, 2020 discovery letter, all images within Bates range SDNY\_GM\_00467566 though SDNY\_GM\_00514100 were seized during the 2019 searches of Epstein residences. These are the images from the CDs that were recovered during those searches, so they did not come from any of the electronic devices that were the subject of extractions by CART. As a result, these images would not have CART numbers. As for the metadata, I have asked our vendor to look into this issue and will get back to you when I have spoken with them. +- 6. I have asked our vendor to look into this issue and will get back to you when I have spoken with them. That said, I note again that the electronic files recovered from Epstein's devices have the same metadata on the hard drive that was available when the FBI seized each file. For files that were carved or deleted, no metadata was recovered, so none is viewable. Additionally, as indicated in our November 9, 2020 discovery letter, all images within the SDNY011 load file (Bates range SDNY\_GM\_00467566 though SDNY\_GM\_00514100) were seized during the 2019 searches of Epstein residences. These are the images from the CDs that were recovered during those searches, so they did not come from any of the electronic devices that were the subject of extractions by CART. As a result, these images would not have CART numbers. +- 7. I have asked our paralegals and vendor to look into the Bates gap and will get back to you when I have spoken to them. + +Best, + +Assistant United States Attorney Southern District of New York + +Cc: 'Jeff Pagliuca' c :, Laura Menninger c: >• Bobbi Sternheim + +Subject: Discovery Issues + +< + +and I. — + +We write to raise a few issues concerning the discovery. Below is the list of items. Please let me know if you are free for a call to discuss. + +- 1. On our last call, we asked you if we could send our client a hard drive containing the discovery that we had created (without the highly confidential items). You had said you would check to see if you could facilitate this. We have not heard back from you. Are you able to send Ms. Maxwell the hard drive? +- 2. The last two productions you sent to Ms. Maxwell on disks. As you know, she cannot read disks on her laptop and must use the prison computer. But the prison computer cannot read some of the files. We can include these files on our hard drive to send to Ms. Maxwell. Otherwise, you will need to produce them on a hard drive. Please advise which way you would like to proceed. +- 3. A number of the emails in the discovery over 109,000 were produced without their attachments (see tab 1 of the attached Excel file). Instead, the attachments appear as slip-sheets (see example attached). Please provide the missing attachments, if they exist. +- 4. A number of electronic documents over 110,000 that were extracted from one of Epstein's devices, as identified by a CART number, have metadata that indicates a "date created" or "date last modified" date in July 2020 or afterwards (see tab 2 of the attached Excel file). We request that you produce a metadata overlay with the original metadata for these files. +- 5. A number of photographs over 6500 —were produced in native format, but do not have a CART number and have "date created" and/or "date last modified" dates after July 2019 (see tab 3 of the attached Excel file). Please provide the CART number for these photographs or specify which device they came from. Also, we request that you produce a metadata overlay with the original metadata for these files. +- 6. A number of the audio/visual files over 460 have similar metadata issues (see tab 4 of the attached Excel file). These fall into the following buckets: + - a. SDNY GM SUPP: these have CART numbers, but were produced without metadata load files and have "date created" and "date last modified" dates in September-November 2020, after the date the device was seized. We request that you produce a metadata overlay with the original metadata for these files. + - b. SDNY005 (October 20 2020 production): these are a few videos from the SDFL or PBPD investigations that were produced in native form without metadata load files. They have Sept-Oct 2020 dates. We request that you produce a metadata overlay with the original metadata for these files. + - c. SDNY011 (November 9 2020 production): these were produced in native form with load files, but do not reference a CART number and have Sept 2020 dates. We request that you provide a CART number for these files or indicate their source. Also, we request that you produce a metadata overlay with the original metadata for these files. +- 7. There is a gap between 11/18 and 12/18 production numbers (SDNY\_GM\_02742044 to 2742183). Was that intentional or are we missing those documents? + +Please let us know your responses as soon as possible. + +Christian R Everdell + +COHEN & GRESSER LLP + +a I view bio + +www.cohengresser.com + +New York I Pans I Washington DC I London + +![](_page_6_Picture_8.jpeg) + +CONFIDENTIALITY NOTICE: The information contained in this e-mail may be confidential and/or ptivileged. This e-mail is intended to be reviewed initially by only the individual named above. If the reader of this e-mail is not the intended recipient or a representative of the intended recipient. you are hereby notified that any review. dissemination or copying of this e-mail or the information contained herein is prohibited. If you have received this e-mail in amt. please immediately notify the sender by telephone and permanently delete this e-mail. 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Mollo Building One Saint Andrew's Plaza New York, New York 10007 + +May 20, 2021 + +## BY ELECTRONIC MAIL + +Christian Everdell, Esq. Mark Cohen, Esq. Cohen & Gresser LLP + +Laura Menninger, Esq. Jeffrey Pagliuca, Esq. Haddon, Morgan and Foreman, P.C. + +Bobbi Stemheim, Esq. Law Offices of Bobbi C. Stemheim + +Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) + +Dear Counsel: + +Today we are producing the materials listed in the below index. These discovery materials are stamped with control numbers SDNY\_GM\_02753432 through SDNY\_GM\_02753551 and SDNY\_GM\_SUPP\_002 19450 through SDNY\_GM\_SUPP\_00219451. + +Regarding the materials stamped with control numbers SDNY\_GM\_02753529 through SDNY\_ GM \_02753551, these folders contain native image files from several devices that correspond with images previously produced to you in PDF format on November 9, 2020. The enclosed spreadsheet indicates which control numbers with "SDNY\_GM\_SUPP" prefixes correspond with these native "carved" images. The enclosed spreadsheet also details the original file names of the "carved" files that were previously produced to you in their native format, also on November 9, 2020. + +Please note that both this letter and the enclosed materials are governed by the July 31, 2020 Protective Order in this case. This letter is itself designated as "confidential," because it includes information regarding records designated as "confidential" under the Protective Order. An index of the materials contained in this production is below: + +| Bates Start | Bates End | Summary Description Confidential | +|------------------|------------------|----------------------------------| +| SDNY GM 02753432 | SDNY_GM_02753528 | Interlochen records Confidential | +| SDNY_GM_02753529 | SDNY_GM_02753529 | Native "carved" images | +| SDNY_GM_02753530 | SDNY_GM_02753530 | Native "carved" images | +| SDNY GM 02753531 | SDNY GM 02753531 | Native "carved" images | +| SDNY_GM_02753532 | SDNY_GM_02753532 | Native "carved" images | +| SDNY_GM_02753533 | SDNY_GM_02753533 | Native "carved" images | +| SDNY_GM_02753534 | SDNY_GM_02753534 | Native "carved" images | +| SDNY_GM_02753535 | SDNY_GM_02753535 | Native "carved" images | +| SDNY_GM_02753536 | SDNY_GM_02753536 | Native "carved" images | +| SDNY_GM_02753537 | SDNY_GM_02753537 | Native "carved" images | +| SDNY_GM_02753538 | SDNY_GM_02753538 | Native "carved" images | +| SDNY_GM_02753539 | SDNY_GM_02753539 | Native "carved" images | + +| SDNY_GM_02753540 | SDNY_GM_02753540 | Native "carved" images | +|------------------------|------------------------|------------------------| +| SDNY GM 02753541 | SDNY GM 02753541 | Native "carved" images | +| SDNY_GM_02753542 | SDNY_GM_02753542 | Native "carved" images | +| SDNY_GM_02753543 | SDNY_GM_02753543 | Native "carved" images | +| SDNY_GM_02753544 | SDNY_GM_02753544 | Native "carved" images | +| SDNY_GM_02753545 | SDNY_GM_02753545 | Native "carved" images | +| SDNY_GM_02753546 | SDNY_GM_02753546 | Native "carved" images | +| SDNY_GM_02753547 | SDNY_GM_02753547 | Native "carved" images | +| SDNY_GM_02753548 | SDNY_GM_02753548 | Native "carved" images | +| SDNY_GM_02753549 | SDNY_GM_02753549 | Native "carved" images | +| SDNY_GM_02753550 | SDNY_GM_02753550 | Native "carved" images | +| SDNY GM 02753551 | SDNY GM 02753551 | Native "carved" images | +| SDNY_GM_SUPP_002 19450 | SDNY_GM_SUPP_002 19450 | Image from device | + +| SDNY_GM_SUPP_00219451 | SDNY_GM_SUPP_00219451 | Image from device
    NYC024366 | Confidential | +|-----------------------|-----------------------|--------------------------------|--------------| +|-----------------------|-----------------------|--------------------------------|--------------| + +The Government recognizes that its discovery obligations are ongoing and will promptly produce any additional discoverable material of which it becomes aware. 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Maxwell - [conferral re photo and other discovery deficiencies] + +Date: Fri, 21 May 2021 16:08:12 +0000 + +Hi Laura, + +I have conferred with our vendor regarding the list of file extensions you provided. The mpg extension should be an audio file, which would be playable on VLC or Windows Media. The psb and psd extensions should be openable on PhotoShop. For the rest of the extensions, QuickView Plus may open these files. To the extent you have specific issues with particular files in our productions, we cannot provide further assistance unless you identify the specific Bates numbers at issue. + +Best, + +Assistant United States Attorney Southern District of New York I St. Plaza New York, NY 10007 + +From: Sent: Thursday, Ma 20 2021 8:19 PM + +To: 'Laura Menning Cc: (USANYS) r rnh; ejeff im • ; + +Subject: RE: US v. Maxwell - [conferral re photo an + +Hi Laura, + +I will work with our vendor and paralegals to look into the viewers for these file extensions. + +Best, + +**Subject:** RE: US v. Maxwell - [conferral re photo and other discovery deficiencies] + +[REDACTED]: + +Thank you for your explanation. We are able to open the file types you noted below (doc, pdf, etc.). Below are the file types that we cannot access. Can you please tell us what viewer you are using to view the following file types that you produced to us? + +apmaster +apversion +attr +bup +data +db +db-journal +ds\_store +f catalog +ifo +images #1 +images 2 +iphoto +ivc +mpg +NULL +psb +psd +raf +tropez +xml + +Thanks, + +-Laura + +**Laura A. Menninger** | Partner + +**Haddon, Morgan & Foreman, P.C.** + +150 | 10th Avenue | Denver, CO 80203 + +**From:** [REDACTED] < [REDACTED] > + +**Sent:** Wednesday, May 12, 2021 10:42 AM + +**To:** Laura Menninger [REDACTED] + +**Cc:** [REDACTED] (USANYS) < [REDACTED] >; [REDACTED] < [REDACTED] >; [REDACTED] + +[REDACTED] < [REDACTED] >; Jeff Pagliuca [REDACTED] + +'Bobbi Sternheim [REDACTED] + +**Subject:** RE: US v. Maxwell - [conferral re photo and other discovery deficiencies] + +Laura, + +Following up on the list of file types that you inquired about below, many of the file types you listed are standard and very common file types. For example: + +- avi and mov are video files that are playable with a standard media program such as VLC or Windows Media Player +- doc is a standard Microsoft Word format + +- • pdf is a standard Adobe format +- • xlsx is a standard Excel file +- • txt is a standard Text file viewable in Notepad or Wordpad +- • bmp, jpg, png, tif, and tiff are standard image files that should be viewable in Microsoft Paint or any standard image viewer +- • pps and ps appear to be viewable via PowerPoint +- • dat files can be viewed as standard text files in Notepad or Wordpad + +For the remaining file extensions, some may be system files without content. You may be able to view the files with the other extensions using Quick View Plus. + +If you continue to have difficulty, we can provide more specific assistance if you provide a list or even just examples of Bates numbers that present these issues. + +Best, + +**From:** [REDACTED] + +**Sent:** Tuesday, May 11, 2021 11:01 PM + +**To:** Laura Menninger [REDACTED] + +**Cc:** [REDACTED] (USANYS) <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]>; Jeff Pagliuca [REDACTED] + +[REDACTED] Bobbi Sternheim [REDACTED] + +**Subject:** RE: US v. Maxwell - [conferral re photo and other discovery deficiencies] + +Laura, + +I have responded to your comments below in **red**. + +I am working with the FBI to understand the discrepancy you pointed out, which I did not appreciate until receiving your May 7, 2021 email. The 2,100 estimate was the amount of files that the FBI verbally informed me had been loaded onto the second hard drive when I was arranging for your review of evidence at 500 Pearl. At the time, I did not recall that the 302 had a different number, and I did not check the number the FBI provided verbally against the 302. As soon as I receive clarification from the FBI, I will reach back out to you. + +As for your request to have access to Highly Confidential images and videos, paragraph 12 of the Protective Order in this case defines Highly Confidential information as discovery material that "contains nude, partially-nude, or otherwise sexualized images, videos, or other depictions of individuals." That definition does not limit this category to child pornography. Paragraph 14 of the Protective Order further provides that any Highly Confidential materials "Shall be made available for inspection by Defense Counsel and the Defendant, under protection of law enforcement officers or employees." Given those provisions, as well as the importance of maintaining the security of nude images of third parties, including victims, we are not prepared to provide you with copies of nude or partially-nude images from the hard drives. However, we appreciate your concern that images that do not contain nudity appear to have been designated as Highly Confidential. Accordingly, I am working with the FBI to de-designate any images that do not depict genitals, breasts, or buttocks. Once those images have been de-designated, our office will produce them to you. + +Best, + +[REDACTED] + +**From:** Laura Menninger [REDACTED] + +Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies] + +Thank you for your response of April 23. I haven't heard back from you last week as promised on this or my April 28 request, so I'm writing to follow up. I have responses to specific questions of yours below in blue. + +Additionally, I have more questions regarding your production of "highly confidential" ("NC") images and videos. When we met the week of April 13 in NY, during which time I requested to view all evidence in the government's possession, including all highly confidential material, you described for me two hard-drives that contained all of the HC images and videos from this case. + +- First, one of those hard-drives you said contained all of the materials extracted from the disks contained in the black binders. There were approximately 40,000 or so images (Excel spreadsheet SDNY\_GM\_00467567) of which 3,400 images were deemed HC and tagged "#nudity" by your team (SDNY\_GM\_00467568). (I still await a response regarding the problems with your metadata overlay). +- Second, the other hard-drive contained images extracted from Epstein's devices which were searched pursuant to a warrant. You said the responsive image/video files were contained on that second hard-drive, and there were approximately 2,100 "nude" or HC images on that hard-drive. You did not produce the metadata for those images because it was still present on the files which had been digitally extracted. + +As I understood it then, there were approximately 5,500 HC images that you made available for review. However, the FBI Report dated January 27, 2021 (produced at SDNY\_GM\_02742399) indicates there are approximately 33,747 NC images and 895 HC videos that were identified by a digital review of CART-processed evidence; I presume based on the CART numbers that this list is the same as the images extracted from Epstein's devices, or as I understood it, the content on your hard-drive #2 above. + +I am completely unclear as to why you informed me that there were 2,100 nude images from Epstein's devices, but this report seems to indicate there were approximately 34,000 HC images and videos. Please let me know if I am misunderstanding what you told me and if so, what the correct information is. + +I reiterate my request that you provide to us hard-drives with all of the HC material minus any child pornography. + +I am available to discuss if that would be more convenient. + +Thanks, Laura + +Laura A. Henninger I Partner Haddon, Morgan & Foreman, P.C. 1501. 10th Avenue I Denver, CO 80203 + +From: + +Sent: Friday, April 23, 2021 10:13 AM + +To: Laura Menninger + +Cc: (USANYS) ; >; + +;Jeff Pagliuca 'Bobbi Sternhei (CIV) + +Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies] + +I am working with our team as quickly as we can to address the issues you raised in the below email. In particular: + +- I have asked our vendor to look into the issues with SDNY\_GM\_00467566. When I attempt to access that document on our Relativity database, I also receive an error message saying that the document is corrupt. I am not sure what this spreadsheet is because the only two spreadsheets that I'm aware of that correspond with the SDNY\_PROD011 contained in the November 9, 2020 production are the two other Excel spreadsheets you referenced. In any event, I am looking into the issue. + +I understand from your subsequent email that the Excel spreadsheet at 467566 does not have any content. Are there any other "Bates-stamped" documents without content? + +It is possible that there are additional items that were recovered from electronic devices and storage media that do not have content. For example, as Chris and I discussed in a separate email exchange, certain attachments to emails on Epstein's devices were only partially recovered. Because they were attached to responsive emails, we produced those partially recovered attachments, even though many did not have content. + +- I am similarly working with our vendor to understand how to best identify for you which Bates number corresponds with the metadata in the index contained in the Excel spreadsheets. + +We received your overlay on April 27. On April 28, I wrote you back with the persistent problems despite the overlay. I do not see that you have responded to those concerns. Can you please advise? + +I have been working with our vendor and paralegals to look into this issue and will respond to your April 28 email shortly. + +- Can you please provide me with a list of the photos that you are unable to view? Once I have that list, I will check to see whether we are able to open them on our end. + +I am not able to provide you a list of the photos I am unable to view, for a number of reasons including my workproduct protections. I can highlight the file types that are contained on the disk and perhaps your vendor can tell us which reader will work with those file types: + +apmaster apversion attr avi bmp bup dat data db db-journal dot ds\_store f catalog ifo images #1 images 2 iphoto ivc jpg mov mpg + +NULL pdf png pps ps psb psd raf tif tiff tropez txt xlsx xml + +I will forward this response to the vendor and see what, if any, assistance we can provide. + +- Can you be more specific in identifying photographs that you believe should have been produced but have been omitted, please? We have endeavored with the FBI to produce copies of all non-nude photographs recovered from searches of Epstein's residence to the defense, and I am not aware of any intentional omissions. + +See above. + +Without specifics, I cannot address this issue further. + +- I am discussing with the FBI your request that we produce all Highly Confidential images to you. I will respond to that request next week. + +I do not believe I received a response to this last week as indicated. Can you please update me? + +Please see above. + +- Once we have a firm trial date, I will let you know by what date I expect to be able to provide you with a list of the Highly Confidential photographs we may introduce at trial. + +Please advise. + +We will discuss this request as a team now that we have a trial date of November 29, 2021. + +- I am working with our paralegals to assess the list of files that your client is unable to review at the MDC. As soon as we have finished looking into those issues, I will let you know. + +Is there any update on this project? + +As I mentioned above, our paralegals are still working through this list of documents. As soon as I have information to provide on this score, I will reach out. + +Best, + +From: Laura Menninger + +Sent: Wednesday, April 21, 2021 1:42 PM + +Subject: US v. Maxwell - [conferral re photo and other discovery deficiencies] + +I'm writing to follow-up on our discussion last Thursday regarding the photo evidence and to address a number of other critical problems with the discovery provided to date. + +Unfortunately, both in the production to defense counsel and on the hard-drive supplied by your office to our client at MDC, there are thousands, if not hundreds of thousands, of photos that are still unreadable. We have spent countless hours, and a chunk of our client's resources, trying to rectify a number of these problems ourselves, to no avail. Our ability, and our client's ability, to review all of the discovery in this case is absolutely critical and is constitutionally guaranteed. Unless you can quickly propose a solution, we believe we need to raise this with the Court. + +- We do not have a functional copy the Excel spreadsheet located at SDNY\_GM\_00467566. I have confirmed that the original spreadsheet provided to us is corrupt and the vendor and tdiscovery provider cannot open it. +- The other two Excel spreadsheets from the production (and presumably the one we cannot open) are insufficiently detailed to tell us which photo goes with which meta-data. o The index contains multiple instances of the same "file name" with different hash values. o The index does not match any particular file with a Bates stamp. o The index does not indicate which files were withheld as "highly confidential." +- Many of the photo files that were provided in discovery (M., SDNY011) do not have a discernible reader. I cannot open them. Ms. Maxwell does not have a reader on her MDC laptop that can read them. If the government is able to view them, then we should be provided the means to view them as well. +- A number of photo files appear to be missing from the MDC laptop and are not highly confidential, based on my review of documents last week. Because we do not have a list of what was/was not produced, however, we cannot confirm. +- As you know, the 2 x "highly confidential hard-drives" in NY did not work until Thursday once an appropriate reader was added to the laptop. I did not have enough time to view all of the files. I do not have the reader that you ultimately added to that laptop. +- The discs that I attempted to view in NY (from various binders) would not load on the government laptop. I was unable to match up disks with potential files on the hard-drives. Because I did not have a functioning Excel spreadsheet, I also was not able to match any highly confidential photos from the hard-drives with the associated metadata. + +I am requesting that you produce to defense counsel replicas of the two hard-drives that you made available for review last week, subject to all of the strictures of the protective order. + +I recognize that you have designated as "highly confidential" photos that you contend contain "nude, partially-nude, or otherwise sexualized images, videos, or other depictions of individuals." Among the photos on the hard-drive that I was able to view, there were a lot of "nude" and "partially-nude" photos of adults, but I did not see anything that would qualify as child pornography under the statute. Some of the photos only showed a woman's back or shoulder. If you have reason to believe that there is child pornography contained on the two hard-drives, then certainly defense counsel is not asking to possess that material; you can designate it as such and we can view it at an acceptable location as occurs in any CP case. + +Otherwise, I think the burden of reviewing adult nudity only in the government's office or courthouse imposes an extraordinary cost on our client and prevents us from analyzing the metadata, having our experts review the file + +In a similar vein, can you let me know when you are willing to disclose any photos that you intend to introduce at trial? As to any of those, I will need sufficient information and time to analyze them for foundation and admissibility purposes with an appropriate expert. + +Finally, I am attaching an incomplete list of the documents that our client still cannot read at MDC. It is a small sample, as she has had to spend hours of her "review" time communicating to our staff which files she cannot read. Also, the manner in which the discovery was provided to her (load file format) precludes her from comparing the "image" and the "native" files (they do not, for example, have clearly labeled bates-stamps). + +I would appreciate as prompt a response as you can provide so that we can address any issues with the Court on Friday. + +Thanks, Laura + +Laura A. 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[Contractor]" < To: Cc: ' (USANYSContract , (USANYS) [Contractor]" USANYS)" + +Subject: RE: Discovery Issues + +Date: Fri, 21 May 2021 17:00:25 +0000 + +Inline-Images: iinage001.jpg; image002.jpg + +Great, the disc and password under separate cover have been left for FedEx. + +From: Sent: Friday, May 21, 2021 12:33 PM To: (USANYS) [Contractor] Cc: (USANYS) (USANYS) [Contractor] c > (USANYS) [Contractor] + +Subject: RE: Discovery Issues + +Letters look good, thanks! This is good to go out. + +From: (USANYS) [Contractor] .'z . Sent: Friday, May 21, 2021 12:14 PM To: ) Cc: (USANYS) [Contractor] (USANYS) (USANYS) [Contractor] + +Subject: RE: Discovery Issues + +Disc is burned and ready to get sent out to MDC. Draft cover letters are attached and saved here. Please let me know if you have any revisions. + +Thanks, + +From: + +Sent: Thursday, May 20, 2021 10:46 PM + +To: Laura Menninger (: ); Christian Everdell (USANYS) + +Cc: Jeff Pagliuca Bobbi Sternheim (USANYS) [Contractor] .a; (USANYS) [Contractor] < 4 (USANYS) [Contractor] + +Subject: RE: Discovery Issues + +Counsel, + +Today we have an additional discovery production ready to send to you. This production is small enough to produce via USAfx. Please let us know if you do not already have a USAfx account, in which case our paralegals (cc'd) can assist you in creating an account. We are also sending a CD containing this production to the MDC via FedEx. + +Attached please find a cover letter accompanying this production. As you will see in the letter, the majority of this production consists of materials we are providing in response to your requests for additional information regarding the SUPP production (referenced in the below email exchange). I am also attaching the excel spreadsheet referenced in the cover letter to assist in your review of the materials from the SUPP production. + +Please let us know if you have any further questions regarding the SUPP production or if you have any difficulty accessing the materials. + +Best, + +From: Sent: Tuesday, May 11, 2021 10:42 PM + +To: Laura Menninger ; Christian Everdell (USANYS) Cc: Jeff Pagliuca c >; Bobbi Sternheim Subject: RE: Discovery Issues + +Laura, + +I am working with our paralegals to look into your requests below. Our paralegals are also still working on the list of files that you provided that Ms. Maxwell has been unable to review at the MDC. As soon as we are able to provide an update on these issues, I will reach back out. + +Best, + +Assistant United States Attorney Southern District of New York + +From: Laura Menninger Sent: Friday, May 7, 2021 4:53 PM C + +To: 1 ca ; Christian Everdell (USANYS) + +Cc: 'Jeff Pagliuca' Laura Menninger Bobbi Sternheim 1.S + +Subject: RE: Discovery Issues + +Chris, + +That all makes sense, thanks very much. I will reach back out once I have conferred with our vendor and have answers for you on #346. + +Best, + +Assistant United States Attorney Southern District of New York + +Subject: RE: Discovery Issues + +Apologies for the late response on this. It seems like it would be better to confer after you have heard back from your vendor, since the answers to #3-#6 will depend on what the vendor says. And I believe we have now resolved #7. + +As for #1 and #2, I will cal at MDC and represent to her that we have your concurrence to send the drive directly to Ms. Maxwell. If she agrees, we can add the additional productions to our drive before we send it. If she refuses, we will take it up with Judge Nathan. + +Thanks, + +Chris + +From: [mailto: + +Sent: Monday, March 29, 2021 3:36 PM + +To: Christian Everdell; ); USANYS + +Cc: 'Jeff Pagliuca'; Laura Menninger; Bobbi Sternheim + +Subject: RE: Discovery Issues + +Chris, + +We are available for a call to discuss tomorrow between 1pm and 2pm, between 3pm and 5pm, or after 5:30pm. Please let us know if there is a time in those windows that would work on your end. In the meantime, below are some initial responses: + +- 1. Our supervisors have indicated that we are not permitted to send a drive that our IT department did not load to the MDC. As a result, we cannot provide the drive directly to the MDC. That said, I am happy to join you in asking the MDC to accept the drive from you. If the MDC still refuses, then my office would not object to an application to Judge Nathan for an order directing the MDC to accept the drive from you, though we would need to allow MDC legal counsel the opportunity to note their objections to Judge Nathan. +- 2. The MDC recently alerted us to this issue, and our paralegal converted the excel files at issue to pdfs and sent a new CD with those pdfs to the MDC. If you client still cannot view them, then we are happy to load them to a drive if you would like to provide one for us. +- 3. I have asked our vendor to look into this issue and will get back to you when I have spoken with them. +- 4. I have asked our vendor to look into this issue and will get back to you when I have spoken with them. That said, similar to the note I sent in my email regarding highly confidential images on March 16, 2021, the electronic files recovered from Epstein's devices have the same metadata on the hard drive that was available when the FBI seized each file. For files that were carved or deleted, no metadata was recovered, so none is viewable, except for data showing when a particular file was saved to a drive by the investigative team or prepared for production. +- 5. As indicated in our November 9, 2020 discovery letter, all images within Bates range SDNY\_GM\_00467566 though SDNY\_GM\_00514100 were seized during the 2019 searches of Epstein residences. These are the images from the CDs that were recovered during those searches, so they did not come from any of the electronic devices that were the subject of extractions by CART. As a result, these images would not have CART numbers. As for the metadata, I have asked our vendor to look into this issue and will get back to you when I have spoken with them. + +- 6. I have asked our vendor to look into this issue and will get back to you when I have spoken with them. That said, I note again that the electronic files recovered from Epstein's devices have the same metadata on the hard drive that was available when the FBI seized each file. For files that were carved or deleted, no metadata was recovered, so none is viewable. Additionally, as indicated in our November 9, 2020 discovery letter, all images within the SDNY011 load file (Bates range SDNY\_GM\_00467566 though SDNY\_GM\_00514100) were seized during the 2019 searches of Epstein residences. These are the images from the CDs that were recovered during those searches, so they did not come from any of the electronic devices that were the subject of extractions by CART. As a result, these images would not have CART numbers. +- 7. I have asked our paralegals and vendor to look into the Bates gap and will get back to you when I have spoken to them. + +Best, + +Assistant United States Attorney Southern District of New York + +From: Christian Everdell < + +Sent: Monday, March 29, 2021 2:40 PM + +To: (USANYS) > >; + +Cc: 'Jeff Pagliuca' • Laura Menninger c: >• Bobbi Sternheim + +Subject: Discovery Issues + +and + +We write to raise a few issues concerning the discovery. Below is the list of items. Please let me know if you are free for a call to discuss. + +- 1. On our last call, we asked you if we could send our client a hard drive containing the discovery that we had created (without the highly confidential items). You had said you would check to see if you could facilitate this. We have not heard back from you. Are you able to send Ms. Maxwell the hard drive? +- 2. The last two productions you sent to Ms. Maxwell on disks. As you know, she cannot read disks on her laptop and must use the prison computer. But the prison computer cannot read some of the files. We can include these files on our hard drive to send to Ms. Maxwell. Otherwise, you will need to produce them on a hard drive. Please advise which way you would like to proceed. +- 3. A number of the emails in the discovery over 109,000 were produced without their attachments (see tab 1 of the attached Excel file). Instead, the attachments appear as slip-sheets (see example attached). Please provide the missing attachments, if they exist. + +- 4. A number of electronic documents over 110,000 —that were extracted from one of Epstein's devices, as identified by a CART number, have metadata that indicates a "date created" or "date last modified" date in July 2020 or afterwards (see tab 2 of the attached Excel file). We request that you produce a metadata overlay with the original metadata for these files. +- 5. A number of photographs over 6500 were produced in native format, but do not have a CART number and have "date created" and/or "date last modified" dates after July 2019 (see tab 3 of the attached Excel file). Please provide the CART number for these photographs or specify which device they came from. Also, we request that you produce a metadata overlay with the original metadata for these files. +- 6. A number of the audio/visual files over 460 have similar metadata issues (see tab 4 of the attached Excel file). These fall into the following buckets: + - a. SDNY GM SUPP: these have CART numbers, but were produced without metadata load files and have "date created" and "date last modified" dates in September-November 2020, after the date the device was seized. We request that you produce a metadata overlay with the original metadata for these files. + - b. SDNY005 (October 20 2020 production): these are a few videos from the SDFL or PBPD investigations that were produced in native form without metadata load files. They have Sept-Oct 2020 dates. We request that you produce a metadata overlay with the original metadata for these files. + - c. SDNY011 (November 9 2020 production): these were produced in native form with load files, but do not reference a CART number and have Sept 2020 dates. We request that you provide a CART number for these files or indicate their source. Also, we request that you produce a metadata overlay with the original metadata for these files. +- 7. There is a gap between 11/18 and 12/18 production numbers (SDNY\_GM02742044 to 2742183). Was that intentional or are we missing those documents? + +Please let us know your responses as soon as possible. + +Thanks, + +Chris + +Christian R Everdell + +COHEN & GRESSER LLP + +![](_page_6_Picture_6.jpeg) + +A cohengresser.com + +New York I Paris I Washington DC I London + +![](_page_6_Picture_9.jpeg) + +CONFIDENTIALITY NOTICE: The information contained in this e-mail may be confidential and/or privileged. This e-mail is intended to be reviewed initially by only the individual named above. If the reader of this e-mail is not the intended recipient or a representative of the intended recipient. you are hereby notified that any review. dissemination or copying of this e-mail or the information contained herein is prohibited. If you have received this e-mail in error. please immediately notify the sender by telephone and permanently delete this e-mail. 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b/marker2/ds9/EFTA00089781/EFTA00089781.md @@ -0,0 +1,247 @@ +To: (USANYS SANYS Contractor]" + +Cc: ' (USANYSCoitir>, (USANYS) [Contractor]" + +Subject: RE: Discovery Issues + +Date: Fri, 21 May 2021 17:12:56 +0000 + +Inline-Images: image001.jpg; image002.jpg + +Thank you! + +From: (USANYS) [Contractor] •c + +Sent: Friday, May 21, 2021 1:00 PM + +To: (USANYS) < > + +Cc: (USANYS) [Contractor] (USANYS) [Contractor] + +Subject: RE: Discovery Issues + +Great, the disc and password under separate cover have been left for FedEx. + +From: cfl + +Sent: Friday, May 21, 2021 12:33 PM + +To: (USANYS) [Contractor] (USANYS) + +Cc: (USANYS) [Contractor] 4 (USANYS) [Contractor] + +Subject: RE: Discovery Issues + +Letters look good, thanks! This is good to go out. + +From: (USANYS) [Contractor) + +Sent: Friday, May 21, 2021 12:14 PM + +To: (USANYS) > + +Cc: (USANYS) [Contractor] 4 (USANYS) [Contractor] + +Subject: RE: Discovery Issues + +Disc is burned and ready to get sent out to MDC. Draft cover letters are attached and saved here. Please let me know if you have any revisions. + +Thanks, + +(USANYS) [Contractor] ; Christian Everdell + +(USANYS) + +Cc: Jeff Pagliuca itc ; Bobbi Sternheim + +Subject: RE: Discovery Issues + +Laura, + +I am working with our paralegals to look into your requests below. Our paralegals are also still working on the list of files that you provided that Ms. Maxwell has been unable to review at the MDC. As soon as we are able to provide an update on these issues, I will reach back out. + +Best, + +Assistant United States Attorney Southern District of New York + +Subject: RE: Discovery Issues + +Also following up on your response to Chris. We have had a chance to take a look at these files again. + +For the SUPP production, many of the files were produced as PDFs, which seems as though they were converted prior to production. As I understand it (which is admittedly limited), carved or deleted files can still contain application metadata. + +We request that as to the SUPP production, you: + +- a. Provide a list of all files that were carved or deleted; +- b. Confirm if all those files were produced in native format or if any were converted to PDF; +- c. If any were converted, provide additional information including the MIME type (for all), and if available from application metadata original file name, file dates, etc. This would amount to the equivalent of the index you provided for SDNY011. +- d. In the absence of (b), confirm that no application metadata was recovered from those files which might indicate file creation/modified dates + +Please let me know if you have any questions. + +Thanks, + +Laura + +Laura A. Henninger I Partner + +Haddon, Morgan & Foreman, P.C. + +From: + +Sent: Friday, April 23, 2021 10:30 AM + +To: Christian Everdell + +(USANYS) + +Cc: Jeff Pagliuca Laura Menninger Bobbi Sternheim + +(Office) + +Subject: RE: Discovery Issues + +Chris, + +Following up on these issues: + +For #3, the attachments were not recovered from the searched devices. We do not have them, which is why they were not produced. For #4, the electronic files recovered from Epstein's devices have the same metadata on the hard drive that was available when the FBI seized each file. For files that were carved or deleted, no metadata was recovered, so none is viewable, except for data showing when a particular file was saved to a drive by the investigative team or prepared for production. I am not aware of any additional metadata in our possession that you do not have for these files. ► **For #5, those photographs were not processed by CART, which is why they do not have a CART number. They came from the CDs that your team reviewed last week. The available metadata for those photographs was produced in two excel spreadsheets with the same production — one with metadata for nude images (which were contained on one of the hard drives you reviewed last week), and one with metadata for non-nude images (which were** + +produced in the November 9, 2020 discovery production). As I mentioned in my email to Laura earlier today, I am working with our vendor to figure out how to best convey to you which Bates numbers correspond with which rows in the spreadsheet. + +## • For #6: + +o The SDNY\_GM\_SUPP contain electronic files recovered from Epstein's devices. As noted above, those files have the same metadata on the hard drive that was available when the FBI seized each file. For files that were carved or deleted, no metadata was recovered, so none is viewable. o The videos from SDNY005 (October 20, 2020 production) were converted by a vendor from VHS and cassette tapes, so there is no metadata to provide. The Sept-Octo 2020 dates reflect when these recordings were converted by our vendor. o The SDNY011 (November 9, 2020 production) consists of images from the CDs seized from Epstein's residences, which you reviewed last week. As referenced above, those photographs were not processed by CART, which is why they do not have a CART number. As referenced above, the available metadata for those photographs was produced in two excel spreadsheets with the same production — one with metadata for nude images (which were contained on one of the hard drives you reviewed last week), and one with metadata for non-nude images (which were produced in the November 9, 2020 discovery production). As I mentioned in my email to Laura earlier today, I am working with our vendor to figure out how to best convey to you which Bates numbers correspond with which rows in the spreadsheet. + +Best, + +Assistant United States Attorney Southern District of New York + +From: + +Sent: Tuesday, March 30, 2021 11:10 PM + +To: Christian Everdell c > >, (USANYS) + +Cc: 'Jeff Pagliuca' Laura Menninger >; Bobbi Sternheim + +Subject: RE: Discovery Issues + +Chris, + +That all makes sense, thanks very much. I will reach back out once I have conferred with our vendor and have answers for you on #3416. + +Best, + +From: Christian Everdell • + +Sent: Tuesday, March 30, 2021 10:58 PM + +To: >; + +(USANYS) + +Cc: 'Jeff Pagliuca' c. l>.; Laura Menninger >; Bobbi Sternheim + +Subject: RE: Discovery Issues + +Apologies for the late response on this. It seems like it would be better to confer after you have heard back from your vendor, since the answers to #346 will depend on what the vendor says. And I believe we have now resolved tt7. + +As for #1 and #2, I will cal at MDC and represent to her that we have your concurrence to send the drive directly to Ms. Maxwell. If she agrees, we can add the additional productions to our drive before we send it. If she refuses, we will take it up with Judge Nathan. + +Thanks, + +Chris + +From• rmailto + +Sent: Monday, March 29 2021 3:36 PM + +To: Christian Everdell; ); USANYS + +Cc: 'Jeff Pagliuca'; Laura Menninger; Bobbi Sternheim + +Subject: RE: Discovery Issues + +Chris, + +We are available for a call to discuss tomorrow between 1pm and 2pm, between 3pm and 5pm, or after 5:30pm. Please let us know if there is a time in those windows that would work on your end. In the meantime, below are some initial responses: + +- 1. Our supervisors have indicated that we are not permitted to send a drive that our IT department did not load to the MDC. As a result, we cannot provide the drive directly to the MDC. That said, I am happy to join you in asking the MDC to accept the drive from you. If the MDC still refuses, then my office would not object to an application to Judge Nathan for an order directing the MDC to accept the drive from you, though we would need to allow MDC legal counsel the opportunity to note their objections to Judge Nathan. +- 2. The MDC recently alerted us to this issue, and our paralegal converted the excel files at issue to pdfs and sent a new CD with those pdfs to the MDC. If you client still cannot view them, then we are happy to load them to a drive if you would like to provide one for us. +- 3. I have asked our vendor to look into this issue and will get back to you when I have spoken with them. + +- 4. I have asked our vendor to look into this issue and will get back to you when I have spoken with them. That said, similar to the note I sent in my email regarding highly confidential images on March 16, 2021, the electronic files recovered from Epstein's devices have the same metadata on the hard drive that was available when the FBI seized each file. For files that were carved or deleted, no metadata was recovered, so none is viewable, except for data showing when a particular file was saved to a drive by the investigative team or prepared for production. +- 5. As indicated in our November 9, 2020 discovery letter, all images within Bates range SDNY\_GM\_00467566 though SDNY\_GM\_00514100 were seized during the 2019 searches of Epstein residences. These are the images from the CDs that were recovered during those searches, so they did not come from any of the electronic devices that were the subject of extractions by CART. As a result, these images would not have CART numbers. As for the metadata, I have asked our vendor to look into this issue and will get back to you when I have spoken with them. +- 6. I have asked our vendor to look into this issue and will get back to you when I have spoken with them. That said, I note again that the electronic files recovered from Epstein's devices have the same metadata on the hard drive that was available when the FBI seized each file. For files that were carved or deleted, no metadata was recovered, so none is viewable. Additionally, as indicated in our November 9, 2020 discovery letter, all images within the SDNY011 load file (Bates range SDNY\_GM\_00467566 though SDNY\_GM\_00514100) were seized during the 2019 searches of Epstein residences. These are the images from the CDs that were recovered during those searches, so they did not come from any of the electronic devices that were the subject of extractions by CART. As a result, these images would not have CART numbers. +- 7. I have asked our paralegals and vendor to look into the Bates gap and will get back to you when I have spoken to them. + +Best, + +Assistant United States Attorney Southern District of New York + +From: Christian Everdell + +Sent: Monday, March 29, 2021 2:40 PM + +To: (USANYS) >; + +Cc: 'Jeff Pagliuca' Laura Menninger c: >• Bobbi Sternheim + +Subject: Discovery Issues + +and I. — + +We write to raise a few issues concerning the discovery. Below is the list of items. Please let me know if you are free for a call to discuss. + +- 1. On our last call, we asked you if we could send our client a hard drive containing the discovery that we had created (without the highly confidential items). You had said you would check to see if you could facilitate this. We have + +- 2. The last two productions you sent to Ms. Maxwell on disks. As you know, she cannot read disks on her laptop and must use the prison computer. But the prison computer cannot read some of the files. We can include these files on our hard drive to send to Ms. Maxwell. Otherwise, you will need to produce them on a hard drive. Please advise which way you would like to proceed. +- 3. A number of the emails in the discovery over 109,000 were produced without their attachments (see tab 1 of the attached Excel file). Instead, the attachments appear as slip-sheets (see example attached). Please provide the missing attachments, if they exist. +- 4. A number of electronic documents over 110,000 that were extracted from one of Epstein's devices, as identified by a CART number, have metadata that indicates a "date created" or "date last modified" date in July 2020 or afterwards (see tab 2 of the attached Excel file). We request that you produce a metadata overlay with the original metadata for these files. +- 5. A number of photographs over 6500 —were produced in native format, but do not have a CART number and have "date created" and/or "date last modified" dates after July 2019 (see tab 3 of the attached Excel file). Please provide the CART number for these photographs or specify which device they came from. Also, we request that you produce a metadata overlay with the original metadata for these files. +- 6. A number of the audio/visual files over 460 have similar metadata issues (see tab 4 of the attached Excel file). These fall into the following buckets: + - a. SDNY GM SUPP: these have CART numbers, but were produced without metadata load files and have "date created" and "date last modified" dates in September-November 2020, after the date the device was seized. We request that you produce a metadata overlay with the original metadata for these files. + - b. SDNY005 (October 20 2020 production): these are a few videos from the SDFL or PBPD investigations that were produced in native form without metadata load files. They have Sept-Oct 2020 dates. We request that you produce a metadata overlay with the original metadata for these files. + - c. SDNY011 (November 9 2020 production): these were produced in native form with load files, but do not reference a CART number and have Sept 2020 dates. We request that you provide a CART number for these files or indicate their source. Also, we request that you produce a metadata overlay with the original metadata for these files. +- 7. There is a gap between 11/18 and 12/18 production numbers (SDNY\_GM\_02742044 to 2742183). Was that intentional or are we missing those documents? + +Please let us know your responses as soon as possible. + +Thanks, + +Chris + +Christian R Everdell + +COHEN & GRESSER LLP + +![](_page_6_Picture_7.jpeg) + +![](_page_7_Picture_3.jpeg) + +CONFIDENTIALITY NOTICE: The information contained in this e-mail may be confidential and/or privileged. This e-mail is intended to be reviewed initially by only the individual named above. If the reader of this e-mail is not the intended recipient or a representative of the intended recipient. you are hereby notified that any review dissemination or copying of this e-mail or the information contained herein is prohibited. If you have received this e-mail in envy. please immediately notify the sender by telephone and permanently delete this e-mail. 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NATHAN, District Judge: + +The Court has considered the parties' proposals regarding the commencement of trial. Dkt. Nos. 275, 276. For the reasons stated in the Government's letter, the Court will request November 29, 2021 from the Clerk's Office as the trial start date—that is the date (pending approval from the Clerk's Office consistent with the SDNY COVID protocols) that opening statements will be made to the jury. However, the Court will also request from the Clerk's Office that jury selection occur during the week of November 15. Counsel shall plan accordingly. + +The Court grants the Government's motion to exclude time until November 29, 2021. The Court finds that the ends of justice served by granting an exclusion from speedy trial computations for the period from today's date through November 29, 2021, outweigh the interests of the public and the Defendant in a speedy trial, because this time is necessary to permit the defense to continue to review discovery and other materials in light of the superseding indictment; to permit the parties to prepare and file motions in limine; to permit the parties to make and review additional pretrial disclosures; and to allow adequate time for the parties to prepare for trial. Time is therefore excluded under the Speedy Trial Act, 18 U.S.C. § 3161(h)(7)(A), until November 29, 2021. + +In order to ensure that there is no delay in the commencement of trial, the Court will adjust the current pre-trial schedule. So that the Court can resolve motions *in limine* in advance of the November 29th trial commencement date, any such motions shall be fully briefed no later than four weeks in advance of the anticipated trial commencement date of November 29. The parties shall meet and confer to propose adjustments to other pre-trial disclosures accordingly. + +The parties are hereby ORDERED to meet and confer for at least 30 minutes by phone regarding the overall pretrial disclosure schedule and submit a joint letter by May 14, 2021. The Court will accept only a joint letter with a joint proposal or with each side's views briefly stated. The letter must attest to the meet and confer. Any separately filed letters will be struck. + +SO ORDERED. + +Dated: May 11, 2021 +New York, New York + +![]() + +--- + +ALISON J. NATHAN +United States District Judge \ No newline at end of file diff --git a/marker2/ds9/EFTA00089789/EFTA00089789.metadata.json b/marker2/ds9/EFTA00089789/EFTA00089789.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..ff4e45121d1f2f93566d6f3e6f6c5b0bcdb5e063 --- /dev/null +++ b/marker2/ds9/EFTA00089789/EFTA00089789.metadata.json @@ -0,0 +1,96 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089789.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2539, + "elapsed_seconds": 4.04, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 64 + ], + [ + "Line", + 32 + ], + [ + "Text", + 11 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 33 + ], + [ + "Line", + 16 + ], + [ + "Text", + 10 + ], + [ + "PageHeader", + 2 + ], + [ + "Caption", + 2 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089789" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089791/EFTA00089791.md b/marker2/ds9/EFTA00089791/EFTA00089791.md new file mode 100644 index 0000000000000000000000000000000000000000..3f47d3f70dc279e522dde7ddbd43ba18d367f7cf --- /dev/null +++ b/marker2/ds9/EFTA00089791/EFTA00089791.md @@ -0,0 +1,45 @@ +To:' ryi + +Subject: RE: Epstein victim interviews + +Date: Fri, 21 Jun 2019 15:47:09 +0000 + +Importance: Normal + +I may be upstate Friday — can't remember if I told you but it looks like we may be buying a house and have that day tentatively on the calendar for the inspection. But schedule it, and if I am not here I will try to dial in. + +From: )'ca + +Sent: Friday, June 21, 2019 11:43 AM + +To: + +Subject: FW: Epstein victim interviews + +I misread — what does Friday afternoon look like? I think we're open all day? + +From: + +Sent: Friday, June 21, 2019 11:22 AM + +To: ) ca; + +Cc: ) + +Subject: Re: Epstein victim interviews + +Helloand I are available at 1:30 on Wednesday or anytime on Friday afternoon. Let us know if any of those times work. Thank you! + +Child/Adolescent Forensic Interviewer FBI, Victim Services Division Child Victim Services Unit (cell) + +On Jun 21, 2019 10:30 AM, ' II < &gt;wrote: + +M, Following up on our discussion resting victim interviews in the Epstein case and a conference call to discuss the matter. In addition to I've copied Finnegan and who supervise our CAFIs and would be on the call. + +I'm in Seattle next Mon - Thur so I'll throw out some options for the group and we can all chime in until we lock it down. + +Tue or Wed at 2:00 or 4:00 EDT + +Fri any time. + +Thanks \ No newline at end of file diff --git a/marker2/ds9/EFTA00089791/EFTA00089791.metadata.json b/marker2/ds9/EFTA00089791/EFTA00089791.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..f10259007756d31ff0dc1faad1536c448ef0d43b --- /dev/null +++ b/marker2/ds9/EFTA00089791/EFTA00089791.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089791.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1294, + "elapsed_seconds": 1.23, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 77 + ], + [ + "Line", + 38 + ], + [ + "Text", + 26 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089791" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089792/EFTA00089792.md b/marker2/ds9/EFTA00089792/EFTA00089792.md new file mode 100644 index 0000000000000000000000000000000000000000..ea3352be346ca8e2b665e48b37809d93ab477ab3 --- /dev/null +++ b/marker2/ds9/EFTA00089792/EFTA00089792.md @@ -0,0 +1,113 @@ +From: ' To: + +Subject: FW: RE: RE: Epstein victim interviews + +Date: Mon, 24 Jun 2019 22:35:22 +0000 + +Importance: Normal + +As discussed, if of interest. + +From: + +Sent: Monday, June 24, 2019 11:46 AM + +To: + +Subject: Fwd: RE: RE: Epstein victim interviews + +All, See below call in number for Friday. + +E, Please pass on within your shop. + +From: ' + +Date: Jun 24, 2019 11:42 AM + +Subject: RE: RE: Epstein victim interviews + +To: " )° + +Cc: + +Forwarded message + +Your unclassified conference call was set up for 06/28/2019 at 2 pm Eastern Time as requested. Instructions to gain access to the conference call are below + +- Dial - +- When prompted to do so, please enter your pass code followed by the # sign. Your pass code is 6248068# +- If you need assistance, please call the SIOC's main number, + +Let me know if you need me to forward the information to anyone. + +Thanks, + +FBI NY Criminal Division Violent Crimes Task Force + +**From:** [REDACTED] +**Sent:** Friday, June 21, 2019 3:11 PM +**To:** [REDACTED] +**Subject:** RE: RE: Epstein victim interviews + +9 + +On Jun 21, 2019 3:03 PM, "[REDACTED]" > wrote: + +Yessir, how many people? + +**From:** [REDACTED] +**Sent:** Friday, June 21, 2019 1:39 PM +**To:** [REDACTED] +**Subject:** Fwd: RE: Epstein victim interviews + +[REDACTED], +Can you get us a call in number for next Friday? +Thanks + +- + +----- Forwarded message ----- + +**From:** "[REDACTED]" <[REDACTED]> +**Date:** Jun 21, 2019 1:26 PM +**Subject:** RE: Epstein victim interviews +**To:** "[REDACTED]", "[REDACTED]" ([REDACTED]) +<[REDACTED]> +**Cc:** "[REDACTED]" <[REDACTED]>, "[REDACTED]" +<[REDACTED]>, "[REDACTED]" + +Good for me as well. I'll get a call nun number. + +- + +On Jun 21, 2019 11:57 AM, "[REDACTED]" <[REDACTED]> wrote: +Thanks, [REDACTED] – it looks like next Friday afternoon is open for everyone. Would Friday, June 28 at 2 work? + +**From:** [REDACTED] +**Sent:** Friday, June 21, 2019 11:22 AM +**To:** [REDACTED] <[REDACTED]>; [REDACTED] ([REDACTED]) <[REDACTED]> +**Cc:** [REDACTED] <[REDACTED]>; [REDACTED] +**Subject:** Re: Epstein victim interviews + +Hello- +[REDACTED] and I are available at 1:30 on Wednesday or anytime on Friday afternoon. Let us know if any of those times work. +Thank you! +[REDACTED] +[REDACTED] +Child/Adolescent Forensic Interviewer + +## FBI, Victim Services Division Child Victim Services Unit (cell) + +On Jun 21, 2019 10:30 AM, '1 )" > wrote: + +S + +Following up on our discussion regaragil victim interviews in the E case and a conference call to discuss the matter. In addition to = I've copied and who supervise our CAFIs and would be on the call. + +I'm in Seattle next Mon - Thurso I'll throw out some options for the group and we can all chime in until we lock it down. + +The or Wed at 2:00 or 4:00 EDT + +Fri any time. + +Thanks \ No newline at end of file diff --git a/marker2/ds9/EFTA00089792/EFTA00089792.metadata.json b/marker2/ds9/EFTA00089792/EFTA00089792.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..65c150a2060920eb5e6aee2b0ebc936c122113f5 --- /dev/null +++ b/marker2/ds9/EFTA00089792/EFTA00089792.metadata.json @@ -0,0 +1,150 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089792.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 2778, + 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Call with FBI (Epstein) + +Date: Mon, 24 Jun 2019 22:35:38 +0000 + +Importance: Normal + +Attachments: unnamed \ No newline at end of file diff --git a/marker2/ds9/EFTA00089795/EFTA00089795.metadata.json b/marker2/ds9/EFTA00089795/EFTA00089795.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..07404cd75aa17aacc3c288abbfabe2fae5972c43 --- /dev/null +++ b/marker2/ds9/EFTA00089795/EFTA00089795.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089795.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 157, + "elapsed_seconds": 0.4, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": 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message 15m before start + +Reminder \ No newline at end of file diff --git a/marker2/ds9/EFTA00089796/EFTA00089796.metadata.json b/marker2/ds9/EFTA00089796/EFTA00089796.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..91eb4406a738188b4172a2656bbd7a02f0245ff4 --- /dev/null +++ b/marker2/ds9/EFTA00089796/EFTA00089796.metadata.json @@ -0,0 +1,82 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089796.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 338, + "elapsed_seconds": 0.55, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Event: Call with FBI (Epstein)", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 32.436, + 35.64 + ], + [ + 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22:36:48 +0000 + +Importance: Normal + +Attachments: unnamed \ No newline at end of file diff --git a/marker2/ds9/EFTA00089797/EFTA00089797.metadata.json b/marker2/ds9/EFTA00089797/EFTA00089797.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..436612b4048447eec09fa585cf6ad616dad4a790 --- /dev/null +++ b/marker2/ds9/EFTA00089797/EFTA00089797.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089797.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 142, + "elapsed_seconds": 0.38, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 21 + ], + [ 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Maxwell :: Blue Ant Studios - Kevina Tidwell + +Date: Thu, 05 Nov 2020 22:37:05 +0000 + +Thanks + +Is what we have GJ material? + +From: + +Sent: Thursday, November 5, 2020 5:36 PM + +To: (USANYS) + +Cc: (USANYS) < (USANYS) >; (USAEO) >; + +Subject: RE: EOUSA-2021-000288 2020R00719 20-CR-00330 USA v. Maxwell :: Blue Ant Studios - Kevina Tidwell + +Hi M, + +Our office has not made public any materials within the requested categories. To the extent we have any items in these categories, those materials are evidence in an ongoing investigation and a pending criminal case against Maxwell. + +Please let me know if you need any additional information. + +Thank you, + +Assistant United States Attorney + +Southern District of New York + +I St. Andrew's Plaza + +New York, NY 10007 + +212-637-2324 + +From: (USANYS) + +Sent: Thursday, November 5, 2020 5:28 PM + +To: >; + +Cc: (USANYS) < >; (USAEO) + +Subject: EOUSA-2021-000288 2020R00719 20-CR-00330 :: USA v. Maxwell :: Blue Ant Studios - Kevina Tidwell + +Good evening and M=, + +The requester is a media company and is entitled to public documents only. + +- 1) Virginia L Giuffre v. Ghislaine Maxwell 15-cv-7433 (LAP) This case did not involve the SDNY. +- 2) United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN). + +For the below events, I am requesting audio, video, photographic, and/or other still image records including but not limited to diagrams and drawings, as well as all transcripts and other metadata, physical or digital, associated with these audio-visual records. A. Any other 911 calls regarding JE or GM. B. All phone calls, interviews, or other recorded conversations with victims and possible victims of JE and/or GM. C. All phone calls, interviews, or other recorded conversations with the parents and other relatives of victims and possible victims of JE and/or GM. D. All phone calls, interviews, or other recorded conversations with witnesses and possible witnesses of JE and/or GM. E. Surveillance photographs, audio, and video of JE, GM, their properties, or their associates. F. All phone calls, interviews, or other recorded conversations with JE or GM, or representatives of JE or GM. A. All audio, video, photographs, or drawings of JE and GM, including depositions, subpoenas, or other interviews gathered during investigation or prosecution efforts. + +Thanks for your help, + +FOIA \ No newline at end of file diff --git a/marker2/ds9/EFTA00089798/EFTA00089798.metadata.json b/marker2/ds9/EFTA00089798/EFTA00089798.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..cdb5d69a4b1785ce55c21045eea51e980661057e --- /dev/null +++ b/marker2/ds9/EFTA00089798/EFTA00089798.metadata.json @@ -0,0 +1,92 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089798.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2407, + "elapsed_seconds": 1.32, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 73 + ], + [ + "Line", + 36 + ], + [ + "Text", + 29 + ], + [ + "ListItem", + 2 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 35 + ], + [ + "Line", + 18 + ], + [ + "Text", + 5 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089798" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089800/EFTA00089800.md b/marker2/ds9/EFTA00089800/EFTA00089800.md new file mode 100644 index 0000000000000000000000000000000000000000..11fbd133bb8ddac3558a6fbe2e8b5a67f0e930c4 --- /dev/null +++ b/marker2/ds9/EFTA00089800/EFTA00089800.md @@ -0,0 +1,60 @@ +From: (USANYS)" [=. To:" cti Cc: (USANYS)" + +Subject: RE: EOUSA-2021-000288 2020R00719 20-CR-00330 :: USA v. Maxwell :: Blue Ant Studios - Kevina Tidwell + +Date: Thu, 05 Nov 2020 22:55:09 +0000 + +Thank you for your help. The only other item we need for this request is to claim exemption 7. I will send you a prepopulated form for review and signature. + +Thanks again, + +From: Sent: Thursday, November 5, 2020 5:50 PM To: (USANYS) Cc: ) ca; (USANYS) < Subject: RE: EOUSA-2021-000288 2020R00719 20-CR-00330 :: USA v. Maxwell :: Blue Ant Studios - Kevina Tidwell + +That's fine, thank you. + +From: (USANYS) sc > Sent: Thursday, November 5, 2020 5:49 PM To: Subject: RE: EOUSA-2021-000288 2020R00719 20-CR-00330 :: USA v. Maxwell :: Blue Ant Studios - Kevina Tidwell + +Yes + +From: Sent: Thursday, November 5, 2020 5:40 PM To: (USANYS) Cc: (USANYS) Subject: RE: EOUSA-2021-000288 2020R00719 20-CR-00330 :: USA v. Maxwell :: Blue Ant Studios - Kevina Tidwell •= > + +By docket dump to you mean providing everything that has been publicly filed on PACER in the criminal case? + +From: (usows)fl Sent: Thursday, November 5, 2020 5:38 PM To: >; < Subject: RE: EOUSA-2021-000288 2020R00719 20-CR-00330 :: USA v. Maxwell :: Blue Ant Studios - Kevina Tidwell + +I will likely provide a docket dump. Is there any objection? + +From: Sent: Thursday, November 5, 2020 5:36 PM To: (USANYS) ; ; + +Cc: (USANYS) < >; Smith, Theodore B. (USAEO) + +Subject: EOUSA-2021-000288 2020R00719 20-CR-00330 :: USA v. Maxwell :: Blue Ant Studios - Kevina Tidwell + +Good evening and + +The requester is a media company and is entitled to public documents only. + +For these two cases: + +- 1) . Ghislaine Maxwell 15-cv-7433 (LAP) This case did not involve the SDNY. +- 2) United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN). + +For the below events, I am requesting audio, video, photographic, and/or other still image records including but not limited to diagrams and drawings, as well as all transcripts and other metadata, physical or digital, associated with these audio-visual records. A. Any other 911 calls regarding JE or GM. B. All phone calls, interviews, or other recorded conversations with victims and possible victims of JE and/or GM. C. All phone calls, interviews, or other recorded conversations with the parents and other relatives of victims and possible victims of JE and/or GM. D. All phone calls, interviews, or other recorded conversations with witnesses and possible witnesses of JE and/or GM. E. Surveillance photographs, audio, and video of JE, GM, their properties, or their associates. F. All phone calls, interviews, or other recorded conversations with JE or GM, or representatives of JE or GM. A. All audio, video, photographs, or drawings of JE and GM, including depositions, subpoenas, or other interviews gathered during investigation or prosecution efforts. + +FOIA \ No newline at end of file diff --git a/marker2/ds9/EFTA00089800/EFTA00089800.metadata.json b/marker2/ds9/EFTA00089800/EFTA00089800.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..95e5c0a2e5f7445d0beb2edcda4d0a5b1dee5232 --- /dev/null +++ b/marker2/ds9/EFTA00089800/EFTA00089800.metadata.json @@ -0,0 +1,122 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089800.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 3365, + "elapsed_seconds": 1.1, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 87 + ], + [ + "Line", + 38 + ], + [ + "Text", + 14 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 73 + ], + [ + "Line", + 37 + ], + [ + "Text", + 20 + ], + [ + "ListItem", + 2 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 5 + ], + [ + "Text", + 4 + ], + [ + "Line", + 3 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089800" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089803/EFTA00089803.md b/marker2/ds9/EFTA00089803/EFTA00089803.md new file mode 100644 index 0000000000000000000000000000000000000000..16b2b02aab0558c99d5ba441e7614aba0fb987e6 --- /dev/null +++ b/marker2/ds9/EFTA00089803/EFTA00089803.md @@ -0,0 +1,20 @@ +From: ' (USANYS)" < To: "I Cc: '=lairglYS)" >, I. (USAEO)" + +Subject: EOUSA-2021-000288 2020R00719 20-CR-00330 :: USA v. Maxwell :: Blue Ant Studios - Kevina Tidwell + +Date: Thu, 05 Nov 2020 22:28:14 +0000 + +Good evening and + +The requester is a media company and is entitled to public documents only. + +For these two cases: + +- 1) Virginia L Giuffre v. Ghislaine Maxwell 15-cv-7433 (LAP) This case did not involve the SDNY. +- 2) United States v. Ghislaine Maxwell, 20 Cr. 330 (AIN). + +For the below events, I am requesting audio, video, photographic, and/or other still image records including but not limited to diagrams and drawings, as well as all transcripts and other metadata, physical or digital, associated with these audio-visual records. A. Any other 911 calls regarding JE or GM. B. All phone calls, interviews, or other recorded conversations with victims and possible victims of JE and/or GM. C. All phone calls, interviews, or other recorded conversations with the parents and other relatives of victims and possible victims of JE and/or GM. D. All phone calls, interviews, or other recorded conversations with witnesses and possible witnesses of JE and/or GM. E. Surveillance photographs, audio, and video of JE, GM, their properties, or their associates. F. All phone calls, interviews, or other recorded conversations with JE or GM, or representatives of JE or GM. A. All audio, video, photographs, or drawings of JE and GM, including depositions, subpoenas, or other interviews gathered during investigation or prosecution efforts. + +Thanks for your help, + +FOIA \ No newline at end of file diff --git a/marker2/ds9/EFTA00089803/EFTA00089803.metadata.json b/marker2/ds9/EFTA00089803/EFTA00089803.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..27895b40f7ba1af3dc59f0ccae44ad2df527a923 --- /dev/null +++ b/marker2/ds9/EFTA00089803/EFTA00089803.metadata.json @@ -0,0 +1,62 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089803.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1572, + "elapsed_seconds": 0.56, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 61 + ], + [ + "Line", + 30 + ], + [ + "Text", + 9 + ], + [ + "ListItem", + 2 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089803" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089804/EFTA00089804.md b/marker2/ds9/EFTA00089804/EFTA00089804.md new file mode 100644 index 0000000000000000000000000000000000000000..c80c82957570f56168691b43e33432e8653c841f --- /dev/null +++ b/marker2/ds9/EFTA00089804/EFTA00089804.md @@ -0,0 +1,712 @@ +To: + +Cc: + +Subject: RE: Epstein priv review -- I B71 report + +Date: Fri, 06 Nov 2020 04:58:16 +0000 + +Will one of you be in tomorrow to generate the redacted report? I've tried but it keeps crashing. + +Thanks, + +From: Sent: Thursday, November 05, 2020 11:26 PM + +To: + +Subject: RE: Epstein priv review -- 1867 released and Filter memo + +Hi all, + +Just wanted to follow up on getting a full report. If someone can help us with this first thing tomorrow morning, we would be grateful. + +Thanks very much, + +From: Sent: Thursday, November 05, 2020 6:19 PM + +To: + +Cc: + +Subject: Re: Epstein priv review -- 1867 released and Filter memo + +The 1871 w/o chats/sms redacted report that was generated and released esterday is much smaller than it should be so I don't think the full report was generated. I will try to do it from home. I'm not sure my computer is strong enough. + +Assistant United States Attorney Southern District of New York + +New York, NY 10007 + +)ffice + +ell + +On Nov 5, 2020, at 6:08 PM, wrote: + +I already left the office. Are all the pictures blank or only some? Is it possible that FBI removed some photos beforehand if the they were cp? + +On Nov 5, 2020, at 5:36 PM, wrote: + +This also seems to be an issue with the audio files, video files, voicemails, recordings. Can someone advise? Thanks! + +From: + +Sent: Thursday, November 05, 2020 5:32 PM + +To: + +Cc: + +Subject: RE: Epstein priv review --1867 released and Filter memo + +When I open 1B71, Cellebrite indicates that there are over 205,000 images, but they all look empty to me. Can someone please take a look and let me know? We need to finish this review by tomorrow morning, so would appreciate assistance tonight. Sorry for the bother. + +Thanks, + +From: + +Sent: Thursday, November 05, 2020 1:21 PM + +To: + +Cc: + +Subject: RE: Epstein priv review --1B67 released and Filter memo + +I overlooked 1667 and 1868 (ipads) because we reviewed them and did not identify any PP material. 1867 is available in the From Filter Team folder and I will add 1868 this afternoon. Please see the attached memo describing the filter review and what we have withheld as PP. You should review the memo and as it indicates, stop your review and let me know if you come across anything that you think may be privileged. As the memo indicates, we only reviewed Chats, SMS, MMS, Emails, Documents, Notes, and VMs. + +Thanks, + +From: + +Sent: Thursday, November 05, 2020 1:09 PM + +To: + +Cc: + +Subject: RE: Epstein priv review -- 1B71 Redacted w/ Chats and SMS released + +No — the photos etc are on the one w/o the chats and sms, the other is chats and sms only. + +From: + +Sent: Thursday, November 05, 2020 1:05 PM + +To: + +Cc: + +Thanks very much. Since this device is split into two reports now, does that mean that the photos and videos are in both of those UFED files (duplicated)? + +Thanks, + +From: + +Sent: Thursda , November 5, 202011:22 AM + +To: + +c: + +Subject: RE: Epstein priv review --1B71 Redacted w/ Chats and SMS released + +The 1871 Redacted w/Chats and SMS report is now in the "From Filter Team" folder. So now you have all the NP material from the 7 Devices. + +We'll circulate the memo shortly. + +From: + +Sent: Thursday, November 05, 2020 7:53 AM + +To: + +Cc: + +Subject: RE: Epstein priv review -- 1B71 Redacted w o C ats an. SMS release. + +Yes, we just released the 1871 SMS/Chats yet. We will do that today, as soon as report. is working on a memo to the file which we will circulate later today. an generate the + +From: + +Sent: Wednesday, November 04, 2020 6:50 PM + +Subject: RE: Epstein priv review -- 1B71 Redacted w/o Chats and SMS released + +Thank you! + +To confirm, does this mean that the privilege review for all 7 of these devices is complete, and all non-PP content has been made available to the case team for responsiveness review? + +From: + +Sent: Wednesday, November 4, 2020 4:21 PM + +To: + +Cc: + +Subject: RE: Epstein priv review --1B71 Redacted w/o Chats and SMS released + +The 1871 Redacted report without chats and sms is now in your shared directory. As I mentioned below, we removed 1107 emails as PP so there should only be 4380 emails on the report. + +As always, please stop your review and let me know if you come across anything that you think may be privileged. + +Thanks, + +From: + +Sent: Wednesday, November 04, 2020 3:21 PM + +Subject: RE: Epstein priv review --1871 update + +The privilege review for 1B71 is almost done.aas the tags for the whole report except for the SMS/Chats so as soon as he has time to generate the redacted report (we are withholding 1107 emails as PP) and save it to the PRIV shared directory, I can release that. + +I am having technical issues with the 1B71 SMS/Chats but hope to have that finished in the next hour and will then senathose tags. + +I'm not sure ifavill have time to generate both redacted reports today. They are very backed up because Enriqueiit his whole day yesterday working on this. + +Thanks, + +From: + +Sent: ues ay, ovem er , : + +To: + +Cc: + +Subject: RE: Epstein priv review -- 1B72 released and update + +Great, thank you. + +From: + +Sent: Tuesday, November 03, 2020 6:55 PM + +To: + +Cc: + +Subject: RE: Epstein priv review — 1872 released and update + +1B72, 1B84 and 1869 are in the From Filter Team folder. I copied the full 1872 report which is why it took so long, you should just copy the UFED reader and the UFDR file to your desktop to review that device. + +From: + +Sent: Tuesday, November 03, 2020 5:39 PM + +To: + +Cc: + +Subject: RE: Epstein priv review -- 1B72 released and update + +Thanks, IM Where are they located on the shared drive? I don't see them in the folder titled From Filter Team. Thanks again! + +From: + +Sent: Tuesday, November 03, 2020 5:38 PM + +To: + +Cc: + +Subject: Re: Epstein priv review --1872 released and update It's on the share, not USAfx. + +Great, did you share them with the case team? 1B72 is still loading... + +From: Sent: Tuesday, November 03, 2020 5:17 PM + +To: Cc: + +Epstein pnv review -- 69 and 84 are now available. + +From Sent: Tuesday, November 03, 2020 5:13 PM + +To: Cc: + +u e : tpstem priv review -- ilsiz released and update I'm uploading 69 and 84 now. Network at STA seems to be running great. No one else is in. Should be done in about 10 minutes. + +From: Sent: Tuesday, November 03, 2020 5:10 PM + +To: Cc: + +ps ein priv review -- 113rz released and up Enrique — + +Can you USAfx the NP reports for 1884 and 1869 to the case team when they are done? I am worried about loading them to the shared directory. 1872 says it is going to take another 90 mins to load. + +Thanks,IM From: + +Sent: Tuesday, November 03, 2020 5:03 PM + +To Cc + +Subject: RE: Epstein priv review --1B72 released and update + +I'm loading 1872 to your shared directory now. We did not remove any potentially privileged materials. As stressed below, do not try to open from the shared directory. + +generating NP reports for 1869 and 1884. + +W/r/t 1884, we are removing 169 PP emails, so there will be 1762 emails, and we are removing one PP chat (with Darren Indyke) so there will be 243 chats. + +W/r/t 1869, we are removing 93 PP emails, so there will be 1074 emails. + +**Sent:** Tuesday, November 03, 2020 1:12 PM + +**To:** [REDACTED] +**Cc:** [REDACTED] + +**Subject:** RE: Epstein priv review -- 1B83 released + +Got it, thank you so much! + +**From:** [REDACTED] + +**Sent:** Tuesday, November 3, 2020 1:09 PM + +**To:** [REDACTED] +**Cc:** [REDACTED] + +**Subject:** Epstein priv review -- 1B83 released + +We just finished 1B83. 30 emails were removed as potentially privileged. The redacted report is saved to your shared directory below but DO NOT open it from the shared or it will shut down the office network. Save it to your D drive or [REDACTED] can put it on a flashdrive. + +**From:** [REDACTED] + +**Sent:** Tuesday, November 03, 2020 11:09 AM + +**To:** [REDACTED] +**Cc:** [REDACTED] + +**Subject:** RE: Help with Epstein Privilege Review + +Thank you so much, [REDACTED] + +**From:** [REDACTED] + +**Sent:** Tuesday, November 3, 2020 11:08 AM + +**To:** [REDACTED] +**Cc:** [REDACTED] + +**Subject:** RE: Help with Epstein Privilege Review + +The first two phones are up on the Priv share. (71 and 72). + +**From:** [REDACTED] + +**Sent:** Tuesday, November 03, 2020 10:23 AM + +**To:** [REDACTED] +**Cc:** [REDACTED] + +**Subject:** RE: Help with Epstein Privilege Review + +Thank you! + +**From:** [REDACTED] + +**Sent:** Tuesday, November 3, 2020 10:19 AM + +**To:** [REDACTED] +**Cc:** [REDACTED] + +[REDACTED] + +**Subject:** RE: Help with Epstein Privilege Review + +**To:** [REDACTED] +**Cc:** [REDACTED] + +**Subject:** RE: Help with Epstein Privilege Review + +Great, can you do 1B72 first and if we still don't have a PRIV shared directory, email it to just me? The case team is on a tight discovery deadline so I want to get [REDACTED] reviewing asap. + +Thanks, [REDACTED] + +**From:** [REDACTED] +**Sent:** Tuesday, November 03, 2020 10:13 AM + +**To:** [REDACTED] +**Cc:** [REDACTED] + +**Subject:** RE: Help with Epstein Privilege Review + +Got it. This will take me a few hours to complete. I'll let you know when it's done. + +**From:** [REDACTED] +**Sent:** Tuesday, November 03, 2020 9:51 AM + +**To:** [REDACTED] +**Cc:** [REDACTED] + +**Subject:** RE: Help with Epstein Privilege Review + +Great! Can you create the following extractions from the Epstein HD? And save them to the Priv shared directory as soon as I can create one? And then I'll have Elisabeth start reviewing them for privilege. + +1B71 – Chats and SMS + +1B72 – Chats + +1B69 - Chats + +1B84 – Chats + +1B83 - Chats + +**From:** [REDACTED] +**Sent:** Tuesday, November 03, 2020 9:47 AM + +**To:** [REDACTED] +**Cc:** [REDACTED] + +**Subject:** Re: Help with Epstein Privilege Review + +Yes I'm in. Let me know what you need. + +[REDACTED] +Investigative Analyst +U.S. Attorney's Office, SDNY + +On Nov 3, 2020, at 9:37 AM, [REDACTED] wrote: + +From: Korologos, MUSANYS) + +Sent: Tuesday, November 03, 2020 9:33 AM + +To: + +Su •led: RE: He p wit Epstein Prior ege Review + +Do you guys have a shared directory? Can you send me the link? I need to set up a Privilege shared directory. Thanks, Lisa + +From: + +Sent: Tuesda November 03 2020 9:16 AM + +Cc: + +• + +Subject: RE: Help with Epstein Privilege Review + +Hi + +will correct me if they have a better way but I think the best way to generate the Responsive Report is to deselect (by removing the x in the column on the far left) al/ the data in the report and then go to the Tags view and select (by putting the x back in the column on the far left) all your tags. You then go up to the top left and choose the Report drop down and then choose Generate a New Report. Be sure to name it something that makes it clear that it is the Responsive report and you can also choose whether to create a UFDR report or a PDF. I'll give you an update on the other reports shortly. + +Thanks, ■ + +**From:** + +**Sent: Monda November 02 2020 9:59 PM** + +**To:** + +**Cc:** + +**Subject: RE: Help with Epstein Privilege Review** + +**Hill.** + +**I've finished the responsiveness review of the four reports that generated last week. I've tagged all of the responsive items in each report. What should my next step be to generate reports that only include the tagged items?** + +**Now that these are done, and I are all just waiting on the release of the remaining portions of 1872 and 1869, as well as any content from 1871, 1883, and 1884. As soon as you can release even just some of those reports, we will dive into the responsiveness review.** + +**To give you a sense of timing: In order to give our paralegals enough time to prepare the responsive materials for production in time for our 11/9 deadline, we need to finish the responsiveness review by no later than Thursday 11/5. So the sooner we can get anything over the wall for us to review, the better.** + +**Thanks very much,** + +**From:** + +**Sent: Thursday, October 29, 2020 11:11 AM** + +**To:** + +**Cc:** + +Just to be safe, please double check when you open up the reports that they correspond to the notes below, i.e., 1B72 should not have chats and 1869 should not have chats and should only have 1074 emails. And as always please stop your review and let me know if you come across anything else that you think may be privileged. + +Thanks! + +1B72 — Release without chats + +1867 — Release entire report + +1868 — Release entire report + +1869 — Release without chats and without the 93 PP emails, as tagged on the attached .pas file (so only release 1074 emails) + +From: + +Sent: Thursday, October 29, 2020 11:08 AM + +To: + +Cc: + +Subject: RE: Help with Epstein Privilege Review + +You can stop by now if you'd like. I have the drive. + +From: + +Sent: Thursday, October 29, 2020 11:04 AM + +To: + +Cc: + +Subject: RE: Help with Epstein Privilege Review + +Thank you! + +, please let me know when would be a good time for me to swing by. + +From: + +Sent: Thursday, October 29, 2020 11:03 AM + +To: + +Cc: + +Subject: Re: Help with Epstein Privilege Review + +I'm not in the office today, but I left the reports copying overnight to a flash drive. See and he can give it to you. + +Sent from my iPhone + +On Oct 29, 2020, at 11:01 AM, rote: + +Hi all, + +I'm in the office today and available to pick up the released reports from these devices if they are ready. + +Thanks, + +From: + +Sent: Wednesday, October 28, 2020 12:09 PM + +To: + +Sent: Wednesday, October 28, 2020 11:36 AM + +To: [REDACTED] + +Cc: [REDACTED] + +Subject: RE: Help with Epstein Privilege Review + +Ok + +From: [REDACTED] + +Sent: Wednesday, October 28, 2020 11:36 AM + +To: [REDACTED] + +Cc: [REDACTED] + +Subject: RE: Help with Epstein Privilege Review + +I have it on 8; I can bring it down to you shortly. + +Thanks, + +From: [REDACTED] + +Sent: Wednesday, October 28, 2020 11:32 AM + +To: [REDACTED] + +Cc: [REDACTED] + +Subject: RE: Help with Epstein Privilege Review + +Yes I'm here. Where is the drive? + +From: [REDACTED] + +Sent: Wednesday, October 28, 2020 11:30 AM + +To: [REDACTED] + +Cc: [REDACTED] + +Subject: RE: Help with Epstein Privilege Review + +Hi: [REDACTED] + +Are you either of you in the office today? And if so, do you have time to help on this? It shouldn't take a lot of time. I need the following reports released to the pros team: + +1B72 – Release **without chats** + +1B67 – Release entire report + +1B68 – Release entire report + +1B69 – Release **without chats and without the 93 PP emails**, as tagged on the attached .pas file (so only release 1074 emails) + +Thanks! [REDACTED] + +From: [REDACTED] + +Sent: Wednesday, October 28, 2020 9:31 AM + +To: [REDACTED] + +Cc: [REDACTED] + +Subject: RE: Help with Epstein Privilege Review + +Yep! + +Subject: RE: Help with Epstein Privilege Review Awesome, thanks ill Are you in the office today? + +From: + +Sent: Wednesday, October 28, 2020 9:07 AM + +To: + +Cc: + +Su ject: RE: Help with Epstein Privilege Review + +Yes, I still have a copy of this drive. Let me know what you need, and I'll be happy to assist. + +Thanks, + +From: + +Sent: Tuesda , October 27, 2020 6:08 PM + +To: + +Cc: + +Subject: RE: Help with Epstein Privilege Review + +Hi + +Do you still have a copy of this drive in the office? If so, would you be able to coordinate with ato help get portions of those files ready for me to conduct a responsiveness review? + +Thanks very much, + +From + +Sent: Monday, August 24, 2020 11:26 AM + +To + +Cc + +Subject: RE: Help with Epstein Privilege Review + +The drive is done being copied and is going out via FedEx to Moday. It should arrive tomorrow. Please let me know if there is anything else I can do to be of assistance. + +From: + +Sent: Fr + +To: + +Subject: RE: Help with Epstein Privilege Review + +Got it, thanks. + +From: + +Sent: Friday, August 21, 2020 3:02 PM + +To: + +Cc: + +Subject: RE: Help with Epstein Privilege Review + +Just checked with IT again about the drive; they unfortunately ran into some issue when copying it and have to restart the copy over the weekend. Hopefully, per IT's diagnosis and apology for the delay, it will be ready Monday or Tuesday. + +Subject: RE: Help with Epstein Privilege Review + +Thanks for staying on top of it—appreciate the update. + +From: + +Sent: Wednesday, August 19, 2020 5:18 PM + +To: + +Cc: + +Subject: RE: Help with Epstein Privilege Review + +Just FYI, the drive is still being copied—I was apparently overeager with my expectations for how long it would take. I will let you know once it is ready and I've put it in the mail for= + +From: + +Sent: Monday, August 17, 2020 3:30 PM + +To: + +Cc: + +Subject: RE: Help with Epstein Privilege Review + +Thanks very much. + +From: + +Sent: anaavAugusr 11, LULU 3:L8 PM + +To: + +Cc: + +Subject: RE: Help with Epstein Privilege Review + +Update on this: I asked to copy the drive this morning with the aim that it would be done in time to mail this afternoon, but he's left for the day and did not leave me with an ETA for it being finished being copied. I'll check back in with him in the morning and hope to have it sent to Lisa tomorrow. + +From: + +Sent: Friday, August 14, 2020 8:20 PM + +Ti + +Cc: + +Subject: Re: Help with Epstein Privilege Review + +Perfect, thank you! + +On Aug 14, 2020, at 8:16 PM, Nrote: + +Hi + +Thanks for the welcome and for your emails. I will get on this first thing Monday morning, as I had just left the office when 's email came in. + +Hope you all have great weekends, and more soon. + +Best, + +Sent from my iPhone + +Thanks so much,M + +From: + +Sent: Friday, August 14, 2020 5:22 PM + +To: + +Subject: Help with Epstein Privilege Review + +Hi + +First, welcome to the unit! I'm sorry we have not met yet, but I'm looking forward to meeting you when we are both in the office one day. + +I'm hoping you would be able to help us with some logistics for the privilege review of data extracted from several of Jeffrey Epstein's devices. is going to leave a drive on your desk today, which contains data from several of Epstein's phones and ipads. Would you please copy of all of that data onto a second drive? + +Once the data is copied, we then need you to please mail one of the drives to (who is cc'd and will reply to this email with her mailing address). Please keep the second drive in your files in the office.= will then reach out to you if she needs any additional help coordinating the review of that data for privileged materials. + +Please let me know if you have any questions, and thanks so much for your help. \ No newline at end of file diff --git a/marker2/ds9/EFTA00089804/EFTA00089804.metadata.json b/marker2/ds9/EFTA00089804/EFTA00089804.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..1e5e25cabde7d2ee2136989f571b2aba0bbd12ee --- /dev/null +++ b/marker2/ds9/EFTA00089804/EFTA00089804.metadata.json @@ -0,0 +1,418 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089804.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 13, + "chars": 17977, + 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index 0000000000000000000000000000000000000000..31934004bb1e2a7a367f92d096626102db3a29ae --- /dev/null +++ b/marker2/ds9/EFTA00089817/EFTA00089817.md @@ -0,0 +1,103 @@ +From: "Tyrrell. Edward (USANYS)" To: '' < Cc: "Duncan, Michele (USANYS)" Subject: RE: travel approval request Date: Tue, 09 Jul 2019 18:07:39 +0000 + +Importance: Normal + +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: Tyrrell, Edward (USANYS) < >; Cc: Duncan, Michele (USANYS) Subject: RE: travel approval request + +Hi Ed, + +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, + +Alison + +\*\*\*we would never miss the BBQ. + +From: Tyrrell, Edward (USANYS) < Sent: Wednesday, June 12, 2019 3:28 PM To: Cc: Duncan, Michele (USANYS) Subject: RE: travel approval request cz > + +Approved. + +From: Sent: Wednesday, June 12, 2019 2:51 PM To: Tyrrell, Edward (USANYS) Cc: Duncan, Michele (USANYS) Subject: RE: travel approval request + +Ed, + +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, Alison, and/or Maurene, 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, Alex. + +From: + +Sent: Friday, May 24, 2019 14:57 + +To: Tyrrell, Edward (USANYS) + +Cc: Duncan, Michele (USANYS) + +Subject: RE: travel approval request + +Ed, + +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 Alison or Alison and Maurene, 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, Alex. + +From: + +Sent: Wednesday, April 03, 2019 20:57 + +To: Tyrrell, Edward (USANYS) + +Subject: RE: travel approval request + +Thank you + +From: Tyrrell, Edward (USANYS) < > + +Sent: Wednesday, April 03, 2019 20:46 + +To: + +Cc: Duncan, Michele (USANYS) + +Subject: Re: travel approval request + +Approved + +Sent from my iPad + +On Apr 3, 2019, at 8:02 PM, wrote: + +Ed, + +For the same case as below, United States v. Epstein, 2018R01618, an investigation relating to enticement of minors for sexual activity, Alison 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. + +Alex. + +From: + +Sent: Thursday, March 14, 2019 18:32 + +To: Tyrrell, Edward (USANYS) + +Cc: ) + +Subject: travel approval request + +Ed, + +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. + +Alex. + +Assistant U.S. Attorney Southern District of New York 212.637.2415 \ No newline at end of file diff --git a/marker2/ds9/EFTA00089817/EFTA00089817.metadata.json b/marker2/ds9/EFTA00089817/EFTA00089817.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..73f48930a21d59ed0c866aba9297dec029f9ec15 --- /dev/null +++ b/marker2/ds9/EFTA00089817/EFTA00089817.metadata.json @@ -0,0 +1,114 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089817.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 4231, + "elapsed_seconds": 1.32, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 86 + ], + [ + "Line", + 39 + ], + [ + "Text", + 15 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 75 + ], + [ + "Line", + 37 + ], + [ + "Text", + 26 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 39 + ], + [ + "Line", + 20 + ], + [ + "Text", + 13 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089817" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089820/EFTA00089820.md b/marker2/ds9/EFTA00089820/EFTA00089820.md new file mode 100644 index 0000000000000000000000000000000000000000..c4037c67e23f0844606422231287dbc1f3bf01c5 --- /dev/null +++ b/marker2/ds9/EFTA00089820/EFTA00089820.md @@ -0,0 +1,25 @@ +**To:** [REDACTED] (USANYS) [Contractor]" [REDACTED] >, " [REDACTED] + +(USANYS)" ██████████ + +Ce: [REDACTED] )" [REDACTED] >, " [REDACTED] )" + +(USANYS)" [REDACTED] >, [REDACTED] (USANYS)" + +**Subject:** Telephone calls about Jeffrey Epstein + +**Date:** Wed, 10 Jul 2019 19:02:47 +0000 + +**Importance:** Normal + +![Redacted box covering the main text area.]()[REDACTED] > "[REDACTED] (USANYS)" < [REDACTED] > + +[Redacted] "[Redacted]" [Redacted] + +We need to get this info to all the SSOs who might answer the phone when ██████ is gone for the day. + +![Square icon]()+++++ + +If we receive a call that sounds like it is from a victim of Jeffrey Epstein, or someone who says they have information, please respond this way. + +Tell the caller you are going to forward them to a special number for this where they should leave a message with a phone number where we can call them. Tell them someone will definitely call them. 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Ghislaine Maxwell Indictment.pdf + +**Inline-Images:** image001.png; image002.jpg + +![](_page_0_Picture_117.jpeg) + +## *United States Attorney Southern District of New York* + +There will be a press conference today at 12:00 p.m. to announce charges against Ghislaine Maxwell for her role in the sexual exploitation and abuse of multiple minor girls by Jeffrey Epstein. The press conference will be livestreamed on [Facebook @USAOSDNY](#). Relevant documents are attached. + +**Please note:** In order to comply with social distancing protocols and provide for the safety of all attendees and participants, press personnel should arrive at least 30 minutes before the start of the press conference, wear face coverings, submit to temperature screening, and comply with seating and standing demarcations. + +**WHO:** Audrey Strauss, Acting United States Attorney for the Southern District of New York + +William F. Sweeney Jr., Assistant Director-in-Charge of the New York Office of the Federal Bureau of Investigation + +**WHAT:** Press Conference + +**WHEN:** Thursday, July 2, 2020 +12:00 p.m. + +**WHERE:** U.S. Attorney's Office, Southern District of New York +1 St. Andrew's Plaza +New York, NY 10007 + +**CONTACT:** [REDACTED] + +**NOTE:** Please silence all cell phones, PDAs, and pagers before start of press conference. + +DO NOT REPLY TO THIS MESSAGE. 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X SEALED INDICTMENT 20 Cr. + +20 Cr. 330 + +## COUNT ONE (Conspiracy to Entice Minors to Travel to Engage in Illegal Sex Acts) + +The Grand Jury charges: + +# OVERVIEW + +1. The charges set forth herein stem from the role of GHISLAINE MAXWELL, the defendant, in the sexual exploitation and abuse of multiple minor girls by Jeffrey Epstein. In particular, from at least in or about 1994, up to and including at least in or about 1997, MAXWELL assisted, facilitated, and contributed to Jeffrey Epstein's abuse of minor girls by, among other things, helping Epstein to recruit, groom, and ultimately abuse victims known to MAXWELL and Epstein to be under the age of 18. The victims were as young as 14 years old when they were groomed and abused by MAXWELL and Epstein, both of whom knew that certain victims were in fact under the age of 18. + +2. As a part and in furtherance of their scheme to abuse minor victims, GHISLAINE MAXWELL, the defendant, and Jeffrey Epstein enticed and caused minor victims to travel to + +Epstein's residences in different states, which MAXWELL knew and intended would result in their grooming for and subjection to sexual abuse. Moreover, in an effort to conceal her crimes, MAXWELL repeatedly lied when questioned about her conduct, including in relation to some of the minor victims described herein, when providing testimony under oath in 2016. + +# FACTUAL BACKGROUND + +3. During the time periods charged in this Indictment, GHISLAINE MAXWELL, the defendant, had a personal and professional relationship with Jeffrey Epstein and was among his closest associates. In particular, between in or about 1994 and in or about 1997, MAXWELL was in an intimate relationship with Epstein and also was paid by Epstein to manage his various properties. Over the course of their relationship, MAXWELL and Epstein were photographed together on multiple occasions, including in the below image: + +![](_page_1_Picture_3.jpeg) + +4. Beginning in at least 1994, GHISLAINE MAXWELL, the defendant, enticed and groomed multiple minor girls to engage in sex acts with Jeffrey Epstein, through a variety of means and methods, including but not limited to the following: + +a. MAXWELL first attempted to befriend some of Epstein's minor victims prior to their abuse, including by asking the victims about their lives, their schools, and their families. MAXWELL and Epstein would spend time building friendships with minor victims by, for example, taking minor victims to the movies or shopping. Some of these outings would involve MAXWELL and Epstein spending time together with aminor victim, while some would involve MAXWELL or Epstein spending time alone with aminor victim. + +b. Having developed a rapport with a victim, MAXWELL would try to normalize sexual abuse for aminor victim by, among other things, discussing sexual topics, undressing in front of the victim, being present when aminor victim was undressed, and/or being present for sex acts involving the minor victim and Epstein. + +c. MAXWELL'S presence during minor victims' interactions with Epstein, including interactions where the minor victim was undressed or that involved sex acts with Epstein, helped put the victims at ease because an adult woman was present. For example, in some instances, MAXWELL would + +massage Epstein in front of a minor victim. In other instances, MAXWELL encouraged minor victims to provide massages to Epstein, including sexualized massages during which a minor victim would be fully or partially nude. Many of those massages resulted in Epstein sexually abusing the minor victims. + +d. In addition, Epstein offered to help some minor victims by paying for travel and/or educational opportunities, and MAXWELL encouraged certain victims to accept Epstein's assistance. As a result, victims were made to feel indebted and believed that MAXWELL and Epstein were trying to help them. + +e. Through this process, MAXWELL and Epstein enticed victims to engage in sexual activity with Epstein. In some instances, MAXWELL was present for and participated in the sexual abuse of minor victims. Some such incidents occurred in the context of massages, which developed into sexual encounters. + +5. GHISLAINE MAXWELL, the defendant, facilitated Jeffrey Epstein's access to minor victims knowing that he had a sexual preference for underage girls and that he intended to engage in sexual activity with those victims. Epstein's resulting abuse of minor victims included, among other things, touching a victim's breast, touching a victim's genitals, placing a sex toy such as a vibrator on a victim's genitals, + +directing a victim to touch Epstein while he masturbated, and directing a victim to touch Epstein's genitals. + +### MAXWELL AND EPSTEIN'S VICTIMS + +6. Between approximately in or about 1994 and in or about 1997, GHISLAINE MAXWELL, the defendant, facilitated Jeffrey Epstein's access to minor victims by, among other things, inducing and enticing, and aiding and abetting the inducement and enticement of, multiple minor victims. Victims were groomed and/or abused at multiple locations, including the following: + +a. A a multi-story private residence on the Upper East Side of Manhattan, New York owned by Epstein (the "New York Residence"), which is depicted in the following photograph: + +![](_page_4_Picture_4.jpeg) + +b. An estate in Palm Beach, Florida owned by Epstein (the "Palm Beach Residence"), which is depicted in the following photograph: + +![](_page_5_Picture_1.jpeg) + +c. A ranch in Santa Fe, New Mexico owned by Epstein (the "New Mexico Residence"), which is depicted in the following photograph: + +![](_page_5_Picture_3.jpeg) + +d. MAXWELL's personal residence in London, + +England. + +7. Among the victims induced or enticed by GHISLAINE + +MAXWELL, the defendant, were minor victims identified herein as Minor Victim-1, Minor Victim-2, and Minor Victim-3. In particular, and during time periods relevant to this Indictment, MAXWELL engaged in the following acts, among others, with respect to minor victims: + +a. MAXWELL met Minor Victim-1 when Minor + +Victim-1 was approximately 14 years old. MAXWELL subsequently interacted with Minor Victim-1 on multiple occasions at Epstein's residences, knowing that Minor Victim-1 was under the age of 18 at the time. During these interactions, which took place between approximately 1994 and 1997, MAXWELL groomed Minor Victim-1 to engage in sexual acts with Epstein through multiple means. First, MAXWELL and Epstein attempted to befriend Minor Victim-1, taking her to the movies and on shopping trips. MAXWELL also asked Minor Victim-1 about school, her classes, her family, and other aspects of her life. MAXWELL then sought to normalize inappropriate and abusive conduct by, among other things, undressing in front of Minor Victim-1 and being present when Minor Victim-1 undressed ih front of Epstein. Within the first year after MAXWELL and Epstein met Minor Victim-1, Epstein began sexually abusing Minor Victim-1. MAXWELL was present for + +and involved in some of this abuse. In particular, MAXWELL involved Minor Victim-1 in group sexualized massages of Epstein. During those group sexualized massages, MAXWELL and/or Minor Victim-1 would engage in sex acts with Epstein. Epstein and MAXWELL both encouraged Minor Victim-1 to travel to Epstein's residences in both New York and Florida. As a result, Minor Victim-1 was sexually abused by Epstein in both New York and Florida. Minor Victim-1 was enticed to travel across state lines for the purpose of sexual encounters with Epstein, and MAXWELL was aware that Epstein engaged in sexual activity with Minor Victim-1 after Minor-Victim-1 traveled to Epstein's properties, including in the context of asexualized massage. + +b. MAXWELL interacted with Minor Victim-2 on at least one occasion in or about 1996 at Epstein's residence in New Mexico when Minor Victim-2 was under the age of 18. Minor Victim-2 had flown into New Mexico from out of state at Epstein's invitation for the purpose of being groomed for and/or subjected to acts of sexual abuse. MAXWELL knew that Minor Victim-2 was under the age of 18 at the time. While in New Mexico, MAXWELL and Epstein took Minor Victim-2 to amovie and MAXWELL took Minor Victim-2 shopping. MAXWELL also discussed Minor Victim-2's school, classes, and family with Minor Victim-2. In New Mexico, MAXWELL began her efforts to groom Minor Victim-2 for abuse by Epstein by, among other things, providing + +an unsolicited massage to Minor Victim-2, during which Minor Victim-2 was topless. MAXWELL also encouraged Minor Victim-2 to massage Epstein. + +c. MAXWELL groomed and befriended Minor Victim-3 in London, England between approximately 1994 and 1995, including during a period of time in which MAXWELL knew that Minor Victim-3 was under the age of 18. Among other things, MAXWELL discussed Minor Victim-3's life and family with Minor Victim-3. MAXWELL introduced Minor Victim-3 to Epstein and arranged for multiple interactions between Minor Victim-3 and Epstein. During those interactions, MAXWELL encouraged Minor Victim-3 to massage Epstein, knowing that Epstein would engage in sex acts with Minor Victim-3 during those massages. Minor Victim-3 provided Epstein with the requested massages, and during those massages, Epstein sexually abused Minor Victim-3. MAXWELL was aware that Epstein engaged in sexual activity with Minor Victim-3 on multiple occasions, including at times when Minor Victim-3 was under the age of 18, including in the context of asexualized massage. + +## MAXWELL'S EFFORTS TO CONCEAL HER CONDUCT + +8. In or around 2016, in the context of a deposition as part of civil litigation, GHISLAINE MAXWELL, the defendant, repeatedly provided false and perjurious statements, under oath, regarding, among other subjects, her role in facilitating the + +abuse of minor victims by Jeffrey Epstein, including some of the specific events and acts of abuse detailed above. + +#### STATUTORY ALLEGATIONS + +9. From at least in or about 1994, up to and including in or about 1997, in the Southern District of New York and elsewhere, GHISLAINE MAXWELL, the defendant, Jeffrey Epstein, and others known and unknown, willfully and knowingly did combine, conspire, confederate, and agree together and with each other to commit an offense against the United States, to wit, enticement, in violation of Title 18, United States Code, Section 2422. + +10. It was apart and object of the conspiracy that GHISLAINE MAXWELL, the defendant, Jeffrey Epstein, and others known and unknown, would and did knowingly persuade, induce, entice, and coerce one and more individuals to travel in interstate and foreign commerce, to engage in sexual activity for which a person can be charged with acriminal offense, in violation of Title 18, United States Code, Section 2422. + +#### Overt Acts + +11. In furtherance of the conspiracy and to effect the illegal object thereof, the following overt acts, among others, were committed in the Southern District of New York and elsewhere: + +a. Between in or about 1994 and in or about 1997, when Minor Victim-1 was under the age of 18, MAXWELL participated in multiple group sexual encounters with Epstein and Minor Victim-1 in New York and Florida. + +b. In or about 1996, when Minor Victim-1 was under the age of 18, Minor Victim-1 was enticed to travel from Florida to New York for purposes of sexually abusing her at the New York Residence, in violation of New York Penal Law, Section 130.55. + +c. In or about 1996, when Minor Victim-2 was under the age of 18, MAXWELL provided Minor Victim-2 with an unsolicited massage in New Mexico, during which Minor Victim-2 was topless. + +d. Between in or about 1994 and in or about 1995, when Minor Victim-3 was under the age of 18, MAXWELL encouraged Minor Victim-3 to provide massages to Epstein in London, England, knowing that Epstein intended to sexually abuse Minor Victim-3 during those massages. + +(Title 18, United States Code, Section 371.) + +### COUNT TWO + +# (Enticement of a Minor to Travel to Engage in Illegal Sex Acts) + +The Grand Jury further charges: + +12. The allegations contained in paragraphs 1 through 8 of this Indictment are repeated and realleged as if fully set forth within. + +13. From at least in or about 1994, up to and including in or about 1997, in the Southern District of New York and elsewhere, GHISLAINE MAXWELL, the defendant, knowingly did persuade, induce, entice, and coerce an individual to travel in interstate and foreign commerce to engage in sexual activity for which a person can be charged with acriminal offense, and attempted to do the same, and aided and abetted the same, to wit, MAXWELL persuaded, induced, enticed, and coerced Minor Victim-1 to travel from Florida to New York, New York on multiple occasions with the intention that Minor Victim-1 would engage in one or more sex acts with Jeffrey Epstein, in violation of New York Penal Law, Section 130.55. + +(Title 18, United States Code, Sections 2422 and 2.) + +#### COUNT THREE (Conspiracy to Transport Minors with Intent to Engage in Criminal Sexual Activity) + +The Grand Jury further charges: + +14. The allegations contained in paragraphs 1 through 8 of this Indictment are repeated and realleged as if fully set forth within. + +15. From at least in or about 1994, up to and including in or about 1997, in the Southern District of New York and elsewhere, GHISLAINE MAXWELL, the defendant, Jeffrey Epstein, and others known and unknown, willfully and knowingly did combine, conspire, confederate, and agree together and with each other to commit an offense against the United States, to + +wit, transportation of minors, in violation of Title 18, United States Code, Section 2423(a). + +16. It was a part and object of the conspiracy that GHISLAINE MAXWELL, the defendant, Jeffrey Epstein, and others known and unknown, would and did, knowingly transport an individual who had not attained the age of 18 in interstate and foreign commerce, with intent that the individual engage in sexual activity for which a person can be charged with a criminal offense, in violation of Title 18, United States Code, Section 2423(a). + +# Overt Acts + +17. In furtherance of the conspiracy and to effect the illegal object thereof, the following overt acts, among others, were committed in the Southern District of New York and elsewhere: + +- a. Between in or about 1994 and in or about 1997, when Minor Victim-1 was under the age of 18, MAXWELL participated in multiple group sexual encounters with EPSTEIN and Minor Victim-1 in New York and Florida. +- b. In or about 1996, when Minor Victim-1 was under the age of 18, Minor Victim-1 was enticed to travel from Florida to New York for purposes of sexually abusing her at the + +New York Residence, in violation of New York Penal Law, Section 130.55. + +c. In or about 1996, when Minor Victim-2 was under the age of 18, MAXWELL provided Minor Victim-2 with an unsolicited massage in New Mexico, during which Minor Victim-2 was topless. + +d. Between in or about 1994 and in or about 1995, when Minor Victim-3 was under the age of 18, MAXWELL encouraged Minor Victim-3 to provide massages to Epstein in London, England, knowing that Epstein intended to sexually abuse Minor Victim-3 during those massages. + +(Title 18, United States Code, Section 371.) + +## COUNT FOUR (Transportation of aMinor with Intent to Engage in Criminal Sexual Activity) + +The Grand Jury further charges: + +18. The allegations contained in paragraphs 1 through 8 of this Indictment are repeated and realleged as if fully set forth within. + +19. From at least in or about 1994, up to and including in or about 1997, in the Southern District of New York and elsewhere, GHISLAINE MAXWELL, the defendant, knowingly did transport an individual who had not attained the age of 18 in interstate and foreign commerce, with the intent that the individual engage in sexual activity for which a person can be charged with acriminal offense, and attempted to do so, and + +aided and abetted the same, to wit, MAXWELL arranged for Minor Victim-1 to be transported from Florida to New York, New York on multiple occasions with the intention that Minor Victim-1 would engage in one or more sex acts with Jeffrey Epstein, in violation of New York Penal Law, Section 130.55. + +(Title 18, United States Code, Sections 2423(a) and 2.) + +## COUNT FIVE (Perjury) + +The Grand Jury further charges: + +20. The allegations contained in paragraphs 1 through 8 of this Indictment are repeated and realleged as if fully set forth within. + +21. On or about April 22, 2016, in the Southern District of New York, GHISLAINE MAXWELL, the defendant, having taken an oath to testify truthfully in a deposition in connection with acase then pending before the United States District Court for the Southern District of New York under docket number 15 Civ. 7344, knowingly made false material declarations, to wit, MAXWELL gave the following underlined false testimony: + +> Q. Did Jeffrey Epstein have ascheme to recruit underage girls for sexual massages? If you know. + +A. I don't know what you're talking about. + +- Q. List all the people under the age of 18 that you interacted with at any of Jeffrey's properties? +- A. I'm not aware of anybody that I interacted with, other than obviously [the plaintiff) who was 17 at this point. + +(Title 18, United States Code, Section 1623.) + +# COUNT SIX (Perjury) + +The Grand Jury further charges: + +22. The allegations contained in paragraphs 1 through 8 of this Indictment are repeated and realleged as if fully set forth within. + +23. On or about July 22, 2016, in the Southern District of New York, GHISLAINE MAXWELL, the defendant, having taken an oath to testify truthfully in a deposition in connection with a case then pending before the United States District Court for the Southern District of New York under docket number 15 Civ. 7344, knowingly made false material declarations, to wit, MAXWELL gave the following underlined false testimony: + +> Q: Were you aware of the presence of sex toys or devices used in sexual activities in Mr. Epstein's Palm Beach house? + +A: No, not that I recall. . . . + +Q. Do you know whether Mr. Epstein possessed sex toys or devices used in sexual activities? + +A. No. + +Q. Other than yourself and the blond and brunette that you have identified as having been involved in three-way sexual activities, with whom did Mr. Epstein have sexual activities? + +A. I wasn't aware that he was having sexual activities with anyone when I was with him other than myself. + +Q. I want to be sure that I'm clear. Is it your testimony that in the 1990s and 2000s, you were not aware that Mr. Epstein was having sexual activities with anyone other than yourself and the blond and brunette on those few occasions when they were involved with you? + +A. That is my testimony, that is correct. + +• • • + +Q. Is it your testimony that you've never given anybody a massage? + +A. I have not given anyone a massage. + +Q• You never gave Mr. Epstein a massage, is that your testimony? + +A. That is my testimony. + +Q. You never gave [Minor Victim-2] a massage is your testimony? + +A. I never gave (Minor Victim-2] a massage. + +(Title 18, United States Code, Section 1623.) + +FlaPERSON— AUDREY S RAUSS Acting nited States Attorney Form No. USA-33s-274 (Ed. 9-25-58) + +# UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +#### UNITED STATES OF AMERICA + +v. + +GHISLAINE MAXWELL, + +Defendant. + +# INDICTMENT + +(18 U.S.C. §§ 371, 1623, 2422, 2423(a), and 2) + +> AUDREY STRAUSS Acting United States Attorney + +> > Foreperson \ No newline at end of file diff --git a/marker2/ds9/EFTA00089823/EFTA00089823.metadata.json b/marker2/ds9/EFTA00089823/EFTA00089823.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..f58095c240b95d4dd17aa50f640c9698663fa3cd --- /dev/null +++ b/marker2/ds9/EFTA00089823/EFTA00089823.metadata.json @@ -0,0 +1,1064 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089823.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + 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b/marker2/ds9/EFTA00089841/EFTA00089841.md @@ -0,0 +1,79 @@ +From: ' To: "T rrell, Edward (USANYS)" Cc: "Duncan, Michele (USANYS)" ' )" + +Subject: RE: travel approval request + +Date: Tue, 16 Jul 2019 12:00:31 +0000 + +Importance: Normal + +Hi Ed, + +We would like to request approval to travel to Fort Lauderdale tomorrow to interview a victim who has recently come forward. The trip will be a round trip on the same day, so the flight will be the only expense. I think I will be only traveler, but it's possible will join as well. + +Thanks, + +From: Tyrrell, Edward (USANYS) Sent: Wednesday, June 12, 2019 3:28 PM To: Cc: Duncan, Michele (USANYS) Subject: RE: travel approval request + +Approved. + +From: Sent: Wednesday, June 12, 2019 2:51 PM To: Tyrrell, Edward (USANYS) Cc: Duncan, Michele (USANYS) Subject: RE: travel approval request + +Ed, + +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, M, 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: Tyrrell, Edward (USANYS) < > Cc: Duncan, Michele (USANYS) + +Ed, + +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: Tyrrell, Edward (USANYS) < > + +Subject: RE: travel approval request + +Thank you + +From: Tyrrell, Edward (USANYS)< > + +Sent: Wednesday, April 03, 2019 20:46 + +To: + +Cc: < M>; Duncan, Michele (USANYS) + +Subject: Re: travel approval request + +Approved + +Sent from my iPad + +On Apr 3, 2019, at 8:02 PM, > wrote: + +Ed, + +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: Tyrrell, Edward (USANYS) < > + +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 \ No newline at end of file diff --git a/marker2/ds9/EFTA00089841/EFTA00089841.metadata.json b/marker2/ds9/EFTA00089841/EFTA00089841.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..3c04033f9034c4226f8faef5a48a5f610671fbc1 --- /dev/null +++ b/marker2/ds9/EFTA00089841/EFTA00089841.metadata.json @@ -0,0 +1,114 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089841.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 3601, + "elapsed_seconds": 1.47, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 71 + ], + [ + "Line", + 35 + ], + [ + "Text", + 16 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 81 + ], + [ + "Line", + 35 + ], + [ + "Text", + 29 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 17 + ], + [ + "Line", + 9 + ], + [ + "Text", + 5 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089841" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089844/EFTA00089844.md b/marker2/ds9/EFTA00089844/EFTA00089844.md new file mode 100644 index 0000000000000000000000000000000000000000..f776d37a27a82e99f00080ff467ac5f2ca9e3168 --- /dev/null +++ b/marker2/ds9/EFTA00089844/EFTA00089844.md @@ -0,0 +1,27 @@ +From: "-(USANYS)" cMIMIMIN> + +To: ' (USANYS)" + +Cc: (USANYS)" + +Subject: Re: Epstein + +Date: Fri, 30 Nov 2018 12:31:22 +0000 + +Importance: Normal + +I think a way of firmly and likely publicly staking claim (which is probably the way to go here) is to subpoena the civil lawyer in case v Epstein for deposition transcripts and other materials. + +Sent from my iPhone + +> On Nov 30, 2018, at 7:04 AM, (USANYS) alMIE> wrote: + +> Mad asked for a memo, which we've ha' draft. We'll review this morning and circulate. As discussed, we're also in touch with FBI - they are in the process of pulling/reviewing the old case file. Can we plan to touch base on this and a few other outstanding issues this morning? + +> Sent from my iPhone + +>> On Nov 30, 2018, at 6:58 AM, (USANYS) allIMIN> wrote: + +>> Another article in the NYT today. How are we putting down our marker? + +>> Sent from my iPhone \ No newline at end of file diff --git a/marker2/ds9/EFTA00089844/EFTA00089844.metadata.json b/marker2/ds9/EFTA00089844/EFTA00089844.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..e81dbc38b2ea9bdaad2921eefe80acee251aac22 --- /dev/null +++ b/marker2/ds9/EFTA00089844/EFTA00089844.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089844.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 872, + "elapsed_seconds": 0.87, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 35 + ], + [ + "Text", + 18 + ], + [ + "Line", + 18 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089844" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089845/EFTA00089845.md b/marker2/ds9/EFTA00089845/EFTA00089845.md new file mode 100644 index 0000000000000000000000000000000000000000..50f14f1105754bb5d8eb4bfbde456597477acb50 --- /dev/null +++ b/marker2/ds9/EFTA00089845/EFTA00089845.md @@ -0,0 +1,89 @@ +From: ' To: ' Cc: (USANYS) [Contractor]" Sent: Tuesday, July 20, 2021 3:43 PM To: (USANYS) Cc: Subject: R + +can meet at 9:30am on Thursday 7/29. I'm going to coordinate with the local FBI office so we can do VTC. + +I've attached the chains of custody for the 1Bs. + +Her email is + +Special Agent FBI New York Field Office Child Exploitation/Human Trafficking Desk: + +From: (USANYS) Sent: Monday, July 19, 20216:38 PM To: (NY) (FBI) < Cc: (NYPD)c Subject: (EXTERNAL EMAIL] - R )S; + +Thanks, Here are some options next week: • 7/26 before 12pm or after 3pm • 7/28 12pm to 2pm + +- 7/29 before 11am + +From: + +Sent: Monday, July 19, 2021 1:52 PM + +To: (USANYS) > + +Cc: + +Subject: RE: + +s traveling Wednesday for vacation. Can you suggest some days/times next week? We will have the message pads and I'll see about getting a copy of the chains. + +Special Agent + +FBI New York Field Office + +Child Exploitation/Human Trafficking + +Desk: + +From: (USANYS) + +Sent: Monday, July 19, 2021 11:37 AM + +To: (NY) (FBI) c )'; >; + +Cc: (NYPD) < + +Subject: (EXTERNAL EMAIL) - R + +Thanks, + +in advance of the meeting, can you please track down any and all chains of custody in FBI possession? + +From: (USANYS) + +Sent: Monday, July 19, 2021 11:26 AM + +To: >; ) < >; + +Cc: + +Subject: RE + +Thanks, Does this week work fo If so, we could do between 12pm and 4pm on Wednesday or 10:30 am to 12pm on Thursday. If I should get so or next week instead, please let me know. Also, can you please have the physical message pads with you for the WebEx wiaint in case? + +From: + +Sent: Wednesday, July 14, 20215:57 PM + +To:' I < >; (USANYS) < >\*, + +Cc: + +Subject: + +I spoke with today. She can meet with us but may go into a local FBI office to get assistance with video setup. I told her I would touch base with her early next week to schedule a day and time that works for everyone. Let me know what you all are thinking on timing and I'll let her know. + +Thanks, \ No newline at end of file diff --git a/marker2/ds9/EFTA00089845/EFTA00089845.metadata.json b/marker2/ds9/EFTA00089845/EFTA00089845.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..b9cdca312f5eb1b49682a234e1fcf428dd763b93 --- /dev/null +++ b/marker2/ds9/EFTA00089845/EFTA00089845.metadata.json @@ -0,0 +1,122 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089845.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 2453, + "elapsed_seconds": 1.64, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 89 + ], + [ + "Line", + 38 + ], + [ + "Text", + 14 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 81 + ], + [ + "Line", + 38 + ], + [ + "Text", + 34 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ], + [ + "ListItem", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 9 + ], + [ + "Line", + 5 + ], + [ + "Text", + 3 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089845" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089848/EFTA00089848.md b/marker2/ds9/EFTA00089848/EFTA00089848.md new file mode 100644 index 0000000000000000000000000000000000000000..4f97f2e4d4bd849aabd843d4eaf79d46a899203d --- /dev/null +++ b/marker2/ds9/EFTA00089848/EFTA00089848.md @@ -0,0 +1,249 @@ +## 31E-MM-108062 - 1B1 + +#### Split To + +500-NY-3027571 Item 18132 + +(U) One (1) beige massage table. + +50D-NY-3027571 Item 18131 + +(U) Ono (1) brown massage table. + +50D-NY-3027571 Item 18130 + +(U) One flat box containing one (1) large framed photo. + +50D-NY-3027571 Item 16129 + +(U) One box containing four (4) framed photos. + +SOD-NY-3027571 Item 1B128 + +(U) One box containing twelve (12) framed photos. + +50D-NY-3027571 Item 18127 + +(U) One box containing five (5) framed photos and one (1) unframed photo. + +Evidence 31E-MM-108062 181 + +Item: + +Evidence Type: General + +> (U) Box containing 1) ONE PHONE MESSAGE BOOK PBPD05-1024 (1) 2) THREE PHONE MESSAGE BOOKS (2) 3) ONE FILE FOLDER WITH TWO FILES (3) 4) SHREDDED PAPER (4) 5) ONE FILE FOLDER - ORANGE (7) 8) BLACK FRAMED PHOTO OF NUDE GIRL (8) 9) NINE PICTURES IN FRAMES (9) 10) EIGHT PHOTOS FROM OFFICE (10) 11) TWO PHOTOS - SITTING ROOM (11) 12) TWO PHOTOS - TABLE (12) 13) + +Description:TWO VHS TAPES - POOL AREA (13) 14) TWO CDS - MARKED "HAPPY BIRTHDAY" (15) 16) ONE MESSAGE PAD - 1ST FLOOR (16) 17) ONE MESSAGE PAD - DESK (17) 18) THREE CDS - DESK (18) 19) ONE 8MM - DESK (19) 20) UNFRAMED PHOTOS - DESK (20) 21) TWO FRAMED PHOTOS - DESK (21) 22) TWO FRAMED PHOTOS - TABLE (22) 23) THREE SOAPS ON A ROPE (23) 24) TWO VIBRATORS - - TWIN TORPEDO" (24) 25) TWO SOAPS ON A ROPE (26) 27) ONE HIGH SCHOOL TRANSCRIPT 27) 28) ONE BOTTLE OF JOY JELLY - MASTER BEDROOM (28) 29) THREE VIDEO TAPES - MASTER BEDROOM + +Location: E03707388 - ECR8 + +Barcode: E4229228 + +### Details + +Collected On: 08/28/2006 11 50 AM + +CATS ID #: None + +FBI Seizure #: None + +Receipt Item #: None + +CATS Abandonment #: None + +Abandonment #: None + +#### Storage Location Discovery Location + +Holding Office: NY -NEW YORK Area: + +Finalized By: Seizing Individual: + +Last Inventory: 08/04/2020 12:00 AM Specific: + +Collected By: + +#### Retention + +N/A + +N/A + +# Shipping Log + +## History + +## Acquisition Event + +Acquisition Event: (UHFOUO) Items migrated on 2006-08-28 + +Collected From: (UHFOUO) + +PALM BEACH, FL, 33480 + +Receipt Given: No + +Holding Office: MM - MIAMI + +Evidence Log: Missing + +Missing + +Case ID . : 31E-MM-108062 + +1B1 + +Barcode . : 42492228 + +Accepted By: + +Printed Name + +Signature + +Reason: .. Collected ..... + +Date/Time: 08/28/2006 11:50AM + +Accepted By: + +Printed Name: + +Signature: + +Reason: STOAGE EXCLUDING ITEMS #1, 2, 16, 17. + +Date/Time: 2-8-08 330 PM + +Accepted By: + +Printed Name: + +Signature: + +Reason: Review of Items #s 1, 2, 16, 17. + +Date/Time: 02-08-08 3:31PM + +Accepted By: + +Printed Name: + +Signature: + +Reason: RELEASED TO SA. + +Date/Time: 04-10-08 1100 AM + +Accepted By: + +Printed Name: + +Signature: + +Reason: Review of 18 | excluding Items 6+7 + +Date/Time: 04/10/2008 1101 AM + +Accepted By: + +Printed Name: + +Signature: + +Reason: Return of all 18s + +Date/Time: 01/13/2009 3:14 PM + +Accepted By: + +Printed Name: + +Signature: + +Reason: STOAGE + +Date/Time: 01/13/2009 3:15 PM + +Accepted By: + +Printed Name: + +Signature: + +Reason: + +Date/Time: + +Accepted By: + +Printed Name: + +Signature: + +Reason: + +Date/Time: + +Accepted By: + +Printed Name: + +Signature: + +Reason: + +Date/Time: + +## EVIDENCE CHAIN OF CUSTODY + +| Relinquished Custody | Date and Time | Accepted Custody | Date and Time | +|---------------------------------|---------------|---------------------------------|---------------| +| Signature: [Redacted] | 6/17/19 | Signature: [Redacted] | 6/20/19 | +| Printed Name/Agency: [Redacted] | 9:35am | Printed Name/Agency: [Redacted] | 3:20am | +| Reason: Transferred to NY | | Reason: Evidence review | | +| Relinquished Custody | Date and Time | Accepted Custody | Date and Time | +| Signature: [Redacted] | 6/21/19 | Signature: [Redacted] | 6/21/19 | +| Printed Name/Agency: [Redacted] | 2:10am | Printed Name/Agency: [Redacted] | 2:10p | +| Reason: CTO | | Reason: Evidence review | | +| Relinquished Custody | Date and Time | Accepted Custody | Date and Time | +| Signature: [Redacted] | 7/5/19 | Signature: [Redacted] | | +| Printed Name/Agency: [Redacted] | 4:00am | Printed Name/Agency: [Redacted] | | +| Reason: Storage | | Reason: Changed in | | +| Relinquished Custody | Date and Time | Accepted Custody | Date 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1B133 + (U) One (1) green massage table (PBPD05-1024). + +**Evidence** + +Item: 31E-MM-108062 - 1B2 + +**Evidence** + +**Type:** + +General ONE BOX AND ONE CPU (MINKED BOX) 182 / 31-44 + +(U) Box containing (1 of 2): (31) 32) ONE THRIFTY RENTAL AGREEMENT.....(32) 33) NOTE FROM [REDACTED].....(33) 34) ELEVEN CDS - OFFICE .....(34) 35) MESSAGE BOOK - GUEST HOUSE.....(49) (36) ONE MESSAGE BOOK.....(50) (37) TWO COMPACT + +**Description:** FLASH CARDS.....(51) (38) SIX CDS - GUEST HOUSE.....(52) (39) POWER CORD TO CPU - GUEST HOUSE.....(54) (40) CPU - OFFICE.....(55) 41) ONE POWER CORD TO CPU - OFFICE.....(56) 42) THREE CDS - OFFICE.....(58) 44) ONE GREEN FRAMED PHOTO (59) Computer 2 of 2. + +**Location:** E03707388 - ECR8 + +**Barcode:** E4229229 + +**Details** + +**Collected On:** 08/28/2006 11:00 AM +**CATS ID #:** None +**FBI Seizure #:** None + +**Receipt Item #:** None +**CATS Abandonment #:** None +**Abandonment #:** None + +**Storage Location** + +**Holding Office:** NY - NEW YORK 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Date/Time: 08/28/2006 11:00am + +Accepted By: [REDACTED] Signature: [REDACTED] + +Reason: STOAGE EXCLUDING ITEM# 35 AND 36. .... Date/Time: 2-8-08 3:30PM + +Accepted By: [REDACTED] Signature: [REDACTED] + +Reason: Review of Item #s 35 and 36. .... Date/Time: 02-08-08 3:31PM + +Accepted By: [REDACTED] Signature: [REDACTED] + +Reason: RELEASED TO SA. .... Date/Time: 3-6-08 12:05PM + +Accepted By: [REDACTED] Signature: [REDACTED] + +Reason: Review ..... Date/Time: 03/06/2008 12:06am + +Accepted By: [REDACTED] Signature: [REDACTED] + +Reason: RELEASED TO SA. .... Date/Time: 04/08-08 11:00AM + +Accepted By: [REDACTED] Signature: [REDACTED] + +Reason: Review of IB2 excluding Items 31+43 ..... Date/Time: 04/10/2008 11:01am + +Accepted By: [REDACTED] Signature: [REDACTED] + +Reason: Return of all IBs ..... Date/Time: 01/13/2009 3:14PM + +Accepted By: [REDACTED] Signature: [REDACTED] + +Reason: STOAGE ..... Date/Time: 01/13/09 3:15PM + +Accepted By: [REDACTED] Signature: [REDACTED] + +Reason: REF ..... Date/Time: 01/14/09 + +# EVIDENCE CHAIN OF CUSTODY + +| Relinquished Custody Federal # 4783446170832 | | Date and Time | Accepted Custody | Date and Time | +|------------------------------------------------------------|--|----------------------|--------------------------------------------------|----------------------| +| Signature: [Redacted] | | 6/17/19 | Signature: [Redacted] | 6/20/19 | +| Printed Name/Agency: Rashida Pofana FBI | | 6:30am | Printed Name/Agency: [Redacted] | 3:20PM | +| Reason: Transferred to NY | | | Reason: RECEIVED CONSISTENT FROM RSI/MCAM | | +| Relinquished Custody | | Date and Time | Accepted Custody | Date and Time | +| Signature: [Redacted] | | 6/20/19 | Signature: [Redacted] | 6/24/19 | +| Printed Name/Agency: [Redacted] | | 2:08P | Printed Name/Agency: [Redacted] | 2:10P | +| Reason: CO | | | Reason: Evidence Review | | +| Relinquished Custody | | Date and Time | Accepted Custody | Date and Time | +| Signature: [Redacted] | | 1/25/19 | Signature: [Redacted] | | +| Printed Name/Agency: [Redacted] FBI | | 4:00PM | Printed Name/Agency: [Redacted] | | +| Reason: SOLD TO EOS/CORES | | | Reason: Changed out | | +| Relinquished Custody | | Date and Time | Accepted Custody | Date and Time | +| Signature: [Redacted] | | 3/15/21 | Signature: [Redacted] | 3/15/21 | +| Printed Name/Agency: [Redacted] | | 4:30P | Printed Name/Agency: [Redacted] | 4:30PM | +| Reason: Storage | | | Reason: Changed out | | +| Relinquished Custody | | Date and Time | Accepted Custody | Date and Time | +| Signature: [Redacted] | | 3/31/21 | Signature: [Redacted] | 3/31/21 | +| Printed Name/Agency: [Redacted] | | 3:35P | Printed Name/Agency: [Redacted] | 3:35P | +| Reason: CO | | | Reason: Review | | +| Relinquished Custody | | Date and Time | Accepted Custody | Date and Time | +| Signature: [Redacted] | | 4/8/21 | Signature: [Redacted] | 4/8/21 | +| Printed Name/Agency: [Redacted] | | 2:33 | Printed Name/Agency: [Redacted] | 2:33PM | +| Reason: Storage | | | 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containing 1) TAPED CONVERSATION PBPD 05-237(1) 2) AUDIO TAPE #1 PBPD 05-243(1) 3) AUDIO TAPE #2 (2) 4) COPY OF TAPE #1 (3) 5) MICRO TAPE PBPD 05-256(1) 6) PHOTO LINE-UP PBPD 05- 257(1) 7) AUDIO TAPE PBPD 05-294(1) 8) MICRO TAPE (2) 9) CD PBPD 05-295(2) 10) C-90 CASSETTE PBPD 05-313(1) 11) AO( MAIL N.M. PBPD 05-378(1) 12) WHITE PAPER G.M (2) 13) MESSAGE + +Description:P.S. (3) 14) WHITE PAPER J (4) 15) MONTGOMERY COUNTY, MD J.B. (5) 16) WHITE PAPER V. PBPD 05-379(1) 17) WHITE PAPER FLIGHT INFO (2) 18) THREE WHITE PAPERS PREMIO COMPUTER INC (3) 19) WHITE PAPER PHONE # PBPD 05-380(1) 20) YELLOW RECEIPT 04/04/05 (2) 21) WHITE PAPER C.W. (3) 22) WHITE PAPER J. (4) 23) WHITE PAPER FLIGHT 04/05/05 (5) 24) WHITE PAPER G. (6) + +Location: E03707388 - ECR8 + +Barcode: E4229230 + +31E-MM-108062 — 1B3 + +## Details + +Collected On: 08/28/2006 8:00 AM + +CATS ID #: None + +FBI Seizure #: None + +#### Storage Location + +Holding Office: NY - NEW YORK + +Finalized By: + +Last Inventory: 07/20/2021 12:00 AM + +#### Retention + +Retention: No + +### Legal Caveats + +None + +## Chain of Custody + +# Shipping Log + +## History + +## Acquisition Event + +Acquisition Event: (U//FOUO) Items migrated on 2006-08-28 + +Collected From: (U//FOUO) DET JOE RECAREY + +Receipt Item #: None + +CATS Abandonment #: None + +Abandonment #: None + +#### Discovery + +#### Location + +Area: Unavailable in data migrated from ACS + +Seizing + +Individual: Specific: Unavailable in data migrated from ACS + +Collected By: + +Receipt Given: No Holding Office: MM - MIAMI Evidence Log: Missing Missing + +Case ID . : 31E-MM-108062 1B3 Barcode . + +Accepted By: + +Printed Name: Signature. + +Reason:..Collected + +4 Date/Time:<9ks e.oOc, It ,a)(-4), + +Accepted By: + +Printed Name:. Signature: + +Reason:..,TOM E Date/Time. p-/-01 330YM. + +Accepted By: Printed Name:. Signature:. + +Reason. j'c(Attc o To S Date/Time- + +Accepted By: Printed Name: + +. Signature: + +Reason. Date/Time: .4 (i/ZyP cr. a" 4a/Cetl iN + +Accepted By: + +Printed Name: 'gnature:. + +Reason- SLCIVAIY' dAcA\ \C)) c.; Date/Time:21 + +Accepted By: + +Printed Name: + +Reason- XAGt.' + +Signature:. + +Date/Time- Q1 go/ 316 nil + +Accepted By: + +Printed Name. Signature. + +Reason- Date/Time: + +Accepted By: + +Printed Name + +Reason Date/Time- + +Accepted By: + +Printed Name. nature + +Reason- Date/Time. + +Accepted By: + +Printed Name. Signature. + +Reason Date/Time + +WEAPONS CHECKED & CLEARED BY FIREARMS INSTRUCTOR + +# EVIDENCE CHAIN OF CUSTODY + +| Relinquished Custody | Date and Time | Accepted Custody | Date and Time | +|-----------------------------------------|-----------------|---------------------------------------|-----------------| +| Signature: [Redacted] | 6/18/19 9:30 PM | Signature: [Redacted] | 6/18/19 7:35 PM | +| Printed Name/Agency: Rashida Fofana FBI | | Printed Name/Agency: [Redacted] | | +| Reason: Transferred to NY | | Reason: [Redacted] | | +| Relinquished Custody | Date and Time | Accepted Custody | Date and Time | +| Signature: [Redacted] | 6/18/19 3:15 PM | Signature: [Redacted] | 6/18/19 3:45 PM | +| Printed Name/Agency: [Redacted] | | Printed Name/Agency: Amanda Young/FBI | | +| Reason: [Redacted] | | Reason: Evidence Review | | +| Relinquished Custody | Date and Time | Accepted Custody | Date and Time | +| Signature: [Redacted] | 3/15/21 4:30 PM | Signature: [Redacted] | 3/15/21 4:39 PM | +| Printed Name/Agency: [Redacted] FBI | | Printed Name/Agency: [Redacted] | | +| Reason: Storage | | Reason: Changed in | | +| Relinquished Custody | Date and Time | Accepted Custody | Date and Time | +| Signature: [Redacted] | 3/31/21 3:35 PM | Signature: [Redacted] | 3/31/21 3:35 PM | +| Printed Name/Agency: [Redacted] | | Printed Name/Agency: [Redacted] | | +| Reason: Storage | | Reason: Review | | +| Relinquished Custody | Date and Time | Accepted Custody | Date and Time | +| Signature: [Redacted] | 4/8/21 2:33 PM | Signature: [Redacted] | 4/3/21 2:33 PM | +| Printed Name/Agency: [Redacted] | | Printed Name/Agency: [Redacted] | | +| Reason: Storage | | Reason: change in | | +| Relinquished Custody | Date and Time | Accepted Custody | Date and Time | +| Signature: [Redacted] | | Signature: [Redacted] | | +| Printed Name/Agency: [Redacted] | | Printed Name/Agency: [Redacted] | | +| Reason: [Redacted] | | Reason: [Redacted] | | +| Relinquished Custody | Date and Time | Accepted 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0000000000000000000000000000000000000000..e4a6b5a2e3ee6f9d1206c4e891b314647bccc351 --- /dev/null +++ b/marker2/ds9/EFTA00089860/EFTA00089860.md @@ -0,0 +1,99 @@ +From: ' c To: ' (USANYS) [Contractor]" Cc: ' Cc: Subject: FW: (USANYS) ::a + +Would you please add the attached documents to the to be produced discovery folder and to 3500 and witness folders on the Epstein share? + +Thanks, + +From: Sent: Tuesday, July 20, 2021 3:43 PM To: (USANYS) ) Cc: Subject: RE: + +can meet at 9:30am on Thursday 7/29. I'm going to coordinate with the local FBI office so we can do VTC. + +I've attached the chains of custody for the 1Bs. + +Her email is + +From: (USANYS) c ) + +Sent: Monday, July 19, 2021 6:38 PM + +To: (NY) (FBI) < >; )< + +Cc: (NYPD)c + +Subject: [EXTERNAL EMAIL] - RE: + +Thanks, Here are some options next week: + +- 7/26 before 12pm or after 3pm +- 7/28 12pm to 2pm +- 7/29 before 11am + +From: sc > + +Sent: Monday, July 19, 2021 1:52 PM + +To: (USANYS) + +Cc: + +Subject: RE: + +< >; + +is traveling Wednesday for vacation. Can you suggest some days/times next week? We will have the message pads and I'll see about getting a copy of the chains. + +Special Agent- + +FBI New York Field Office + +Child Exploitation/Human Trafficking + +Desk: + +From: (USANYS) + +Sent: Monday, July 19, 2021 11:37 AM + +To: (NY) (FBI) < >; ) + +Cc: (NYPD) + +Subject: [EXTERNAL EMAIL) - RE: + +Thanks, + +in advance of the meeting, can you please track down any and all chains of custody in FBI possession? + +From: (USANYS) + +Sent: Monday, July 19, 2021 11:26 AM + +To: ; + +Thanks, Does this week work for ? If so, we could do between 12pm and 4pm on Wednesday or 10:30 am to 12pm on Thursday. If I should get some times for next week instead, please let me know. Also, can you please have the physical message pads with you for the WebEx with just in case? + +From: + +Sent: Wednesday, July 14, 20215:57 PM + +To: I (USANYS) < ) + +Cc: + +Subject: + +Hi all, + +I spoke with today. She can meet with us but may go into a local FBI office to get assistance with video setup. I told her I would touch base with her early next week to schedule a day and time that works for everyone. Let me know what you all are thinking on timing and I'll let her know. + +Thanks, \ No newline at end of file diff --git a/marker2/ds9/EFTA00089860/EFTA00089860.metadata.json b/marker2/ds9/EFTA00089860/EFTA00089860.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..1a570871cceda62bc9b1a54526995a0de3ad397e --- /dev/null +++ b/marker2/ds9/EFTA00089860/EFTA00089860.metadata.json @@ -0,0 +1,122 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089860.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 2472, + "elapsed_seconds": 1.46, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 84 + ], + [ + "Line", + 37 + ], + [ + "Text", + 13 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 83 + ], + [ + "Line", + 37 + ], + [ + "Text", + 31 + ], + [ + "ListItem", + 3 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 29 + ], + [ + "Line", + 15 + ], + [ + "Text", + 10 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089860" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089863/EFTA00089863.md b/marker2/ds9/EFTA00089863/EFTA00089863.md new file mode 100644 index 0000000000000000000000000000000000000000..653cc4996fd07505b1479b21d08e3ddfd42dfdb9 --- /dev/null +++ b/marker2/ds9/EFTA00089863/EFTA00089863.md @@ -0,0 +1,11 @@ +From• IMe
    » Adam Johnson 7/25/2019 12:18 PM > » + +Please the below, please preserve the video footage of the SHU tier containing cell Z06-215 from 11 pm July 22, 2019, until 4 am July 23, 2019. Please provide a copy for the investigation and maintain a copy in the event we are ordered to produce it to the Court and counsel. Please advise when this has been done. Thank you. + +Adam M. Johnson + +Supervisory Staff Attorney + +CLC New York + +Metropolitan Correctional Center + +New York, New York 10007 + +f. + +»> Aida Leisenring 7/25/2019 11:54 AM »> + +Hello Adam, + +It was good to see you yesterday. Thank you for accommodating my visit with Tartaglione and giving him extra time to review his discovery. We very much appreciate that. + +I am writing to request the preservation of all video surveillance that captures the hallway outside of Tartaglione's cell on the date and time of the Epstein incident that is currently being investigated. I believe that the date and time is July 23 during the early morning hours. Accordingly, I would ask that all video surveillance from July 22 at 11 pm to July 23 at 4 am is preserved. If it is your understanding that the incident occurred at a different time, please let me know and preserve the relevant footage, including an hour before the incident and an hour afterwards. If the responding officers were wearing body cameras that captured the inside of the cell in the aftermath of the incident, I am requesting that such footage also be preserved. + +Thank you. + +Aida Ferrer Leisenring, Esq. + +Barket, Epstein, Kearon, Aldea & LoTurco LLP + +Garden City, NY 11530 + +F + +Please note that my emailed has changed to: + +This transmittal may be a confidential attorney client communication or may otherwise be privileged or confidential. If it is not clear that you are the intended recipient, you are hereby notified that you have received this transmittal in error; any review, dissemination, distribution or copying of this transmittal is strictly prohibited. If you suspect that you have received this communication in error, please notify us immediately by telephone or email and immediately delete this message and all its attachments. + +From Adam Johnson + +To Cody KizzierNicole McFarland, NYM/Executive Staff + +Date 2019/12/19 11:13 + +Subject: Re: Tartaglione 78514-054 + +Attachments: TEXT.htm + +As an update, I spoke with the AUSAs. They advised the Court thee was no video because the FBI had the DVR (pulled for the 8/10 incident) which went back to the 7/23 attempt. The FBI reported the DVR footage was corrupted as to the 7/23 video and, thus there was no footage. The AUSAs are asking that SIS check to see where Pina preserved the 7/22-23 video to see if that copy is not corrupted. They will be reaching out to her directly. + +The AUSAs also want to know where the orange rope from the 7/23 attempt is preserved. + +Thanks all, + +Adam + +Adam M. Johnson Deputy Regional Counsel Northeast Regional Office U.S. Customs House + +Philadelphia, PA 19106 + +f. ( + +>> > Adam Johnson 12/19/2019 10:01 AM >> > + +https://www.msn.com/en-ie/news/world/jai I -video-surveillance-from-jeffrey-epsteins-first-suicide-attemptin-jub61:rnissin + +Good morning all, + +Per the above article, the Court was advised by the USAO that MCC did not preserve video from outside the cell shared by Tartaglione and Epstein at the time of Epstein's alleged first suicide attempt. However, per the attached, SIS advised the footage was preserved. What search for the footage was performed prior to advising the USAO the footage could not be found? I would recommend searching again for the missing video. I have a call with the AUSAs in 20 minutes and will advise as to what other issues arose at yesterday's hearing. + +Thank you, + +Adam + +Adam M. Johnson Deputy Regional Counsel Northeast Regional Office U.S. Customs House + +Philadelphia, PA 19106 + +P: f.( + +From Adam Johnson Charisma EdgeCody Kizzier, Elissa Miller, Jermaine Darden, James To Petrucci, Lamine N'Diaye, Lee Plourde, Marti Licon-VitaleNicole McFarland, NYM/Executive Staff, Shirley V. Skipper-Scott Date 2019/12/19 10:01 Subject: Tartaglione 78514-054 Attachments: TEXT.htm, Re: Fwd: Preservation request + +https://www.msncom/en-ie/news/world/jail-video-surveillance-from-jeffrey-epsteins-first-suiride-attemptin-july-is-missing-prosecutor-says-according-to-reports/ar-BBY92ur + +Good morning all, + +Per the above article, the Court was advised by the USA0 that MCC did not preserve video from outside the cell shared by Tartaglione and Epstein at the time of Epstein's alleged first suicide attempt. However, per the attached, SIS advised the footage was preserved. What search for the footage was performed prior to advising the USA0 the footage could not be found? I would recommend searching again for the missing video. I have a call with the AUSAs in 20 minutes and will advise as to what other issues arose at yesterday's hearing. + +Thank you, Adam + +Adam M. Johnson Deputy Regional Counsel Northeast Regional Office U.S. Customs House + +Philadel hia, PA 19106 + +From America Pina To Adam Johnson, Marquea RiceNYM/Executive StaffStephanie Scannell, Tijuana Doctor Date 2019/07/25 13:03 Subject: Re: Fwd: Preservation request Attachments: TEXT.htm + +Done. + +A. Pina Special Investigative Technician MCC New York New York, NY 10007 + +> » Adam Johnson 7/25/2019 12:18 PM > » + +Please the below, please preserve the video footage of the SHU tier containing cell Z06-215 from 11 pm July 22, 2019, until 4 am July 23, 2019. Please provide a copy for the investigation and maintain a copy in the event we are ordered to produce it to the Court and counsel. Please advise when this has been done. Thank you. + +Adam M. Johnson Supervisory Staff Attorney CLC New York Metropolitan Correctional Center + +New Y rk N w Y rk 10007 + +P: + +f. + +>>> Aida Leisenring caleisenring@barketepstein.com> 7/25/2019 11:54 AM >> > + +Hello Adam, + +It was good to see you yesterday. Thank you for accommodating my visit with Tartaglione and giving him extra time to review his discovery. We very much appreciate that. + +I am writing to request the preservation of all video surveillance that captures the hallway outside of Tartaglione's cell on the date and time of the Epstein incident that is currently being investigated. I believe that the date and time is July 23 during the early morning hours. Accordingly, I would ask that all video surveillance from July 22 at 11 pm to July 23 at 4 am is preserved. If it is your understanding that the incident occurred at a different time, please let me know and preserve the relevant footage, including an hour before the incident and an hour afterwards. If the responding officers were wearing body cameras that captured the inside of the cell in the aftermath of the incident, I am requesting that such footage also be preserved. + +Thank you. + +Aida Ferrer Leisenring, Esq. + +Barket, Epstein, Kearon, Aldea & LoTurco LLP + +Garden Lay, NY 1153U + +T + +F + +Please note that my emailed has changed to: + +This transmittal may be a confidential attorney client communication or may otherwise be privileged or confidential. If it is not clear that you are the intended recipient, you are hereby notified that you have received this transmittal in error; any review, dissemination, distribution or copying of this transmittal is strictly prohibited. If you suspect that you have received this communication in error, please notify us immediately by telephone or email and immediately delete this message and all its attachments. + +From Adam Johnson Charisma EdgeCody Kizzier, Elissa Miller, Jermaine Darden, James To Petrucci, Lamine N'Diaye, Lee Plourde, Marti Licon-VitaleNicole McFarland, NYM/Executive Staff, Shirley V. Skipper-Scott Date 2019/12/19 10:01 Subject: Tartaglione 78514-054 Attachments: TEXT.htm, Re: Fwd: Preservation request + +https://www.msn comten-ie/news/world/jail-video-surveillance-from-jeffrey-epsteins-first-suiride-attemptin-july-is-missing-prosecutor-says-according-to-reports/ar-BBY92ur + +Good morning all, + +Per the above article, the Court was advised by the USA0 that MCC did not preserve video from outside the cell shared by Tartaglione and Epstein at the time of Epstein's alleged first suicide attempt. However, per the attached, SIS advised the footage was preserved. What search for the footage was performed prior to advising the USA0 the footage could not be found? I would recommend searching again for the missing video. I have a call with the AUSAs in 20 minutes and will advise as to what other issues arose at yesterday's hearing. + +Thank you, Adam + +Adam M. Johnson Deputy Regional Counsel Northeast Regional Office U.S. Customs House + +Philadelphia. PA 1 106 + +From America Pina + +To Adam Johnson, Marquca RiceNYM/Executive StaffStephanie Scannell, Tijuana Doctor + +Date 2019/07/25 13:03 + +Subject: Re: Fwd: Preservation request + +Attachments: TEXT.htm + +Done. + +A. Pina Special Investigative Technician MCC New York 150 Park Row New York, NY 10007 646-836-6300 Ext.6480 + +> » Adam Johnson 7/25/2019 12:18 PM > » + +Please the below, please preserve the video footage of the SHU tier containing cell Z06-215 from 11 pm July 22, 2019, until 4 am July 23, 2019. Please provide a copy for the investigation and maintain a copy in the event we are ordered to produce it to the Court and counsel. Please advise when this has been done. Thank you. + +Adam M. Johnson Supervisory Staff Attorney CLC New York Metropolitan Correctional Center + +New York, New York 10007 + +P: + +( + +»> Aida Leisenring 7/25/2019 11:54 AM »> + +Hello Adam, + +It was good to see you yesterday. Thank you for accommodating my visit with Tartaglione and giving him extra time to review his discovery. We very much appreciate that. + +I am writing to request the preservation of all video surveillance that captures the hallway outside of Tartaglione's cell on the date and time of the Epstein incident that is currently being investigated. I believe that the date and time is July 23 during the early morning hours. Accordingly, I would ask that all video surveillance from July 22 at 11 pm to July 23 at 4 am is preserved. If it is your understanding that the incident occurred at a different time, please let me know and preserve the relevant footage, including an hour before the incident and an hour afterwards. If the responding officers were wearing body cameras that captured the inside of the cell in the aftermath of the incident, I am requesting that such footage also be preserved. + +Thank you. + +Aida Ferrer Leisenring, Esq. + +Barket, Epstein, Kearon, Aldea & LoTurco LLP + +Garden City, NY 11530 + +T + +FII + +Please note that my emailed has changed to: + +This transmittal may be a confidential attorney client communication or may otherwise be privileged or confidential. If it is not clear that you are the intended recipient, you are hereby notified that you have received this transmittal in error; any review, dissemination, distribution or copying of this transmittal is strictly prohibited. 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Skipper-Scott + +Date 2019/12/19 11:13 + +Subject: Re: Tartaglione 78514-054 + +Attachments: TEXT.htm + +As an update, I spoke with the AUSAs. They advised the Court thee was no video because the FBI had the DVR (pulled for the 8/10 incident) which went back to the 7/23 attempt. The FBI reported the DVR footage was corrupted as to the 7/23 video and, thus there was no footage. The AUSAs are asking that SIS check to see wher her direct y. eserved the 7/22-23 video to see if that copy is not corrupted. They will be reaching out to + +The AUSAs also want to know where the orange rope from the 7/23 attempt is preserved. + +Thanks all, + +"xtmorilxO) + +Adam M. Johnson + +Deputy Regional Counsel + +Northeast Regional Office + +U.S. Customs House + +2nd and Chestnut Streets + +Philadelphia, PA 19106 + +p: (215)521 179807xe; + +f: (215)521-7483 + +flikigfff)Johnson 12/19/201910:01 AM >> > + +https://www.msn.com/en-ie/news/world/jail-video-surveillance-from-jeffrey-epsteins-first-suicide-attemptin-july-is-missing-prosecutor-says-according-to-reports/ar-BBY92ur + +Good morning all, + +Per the above article, the Court was advised by the USAO that MCC did not preserve video from outside the cell shared braftlidil one 4nd Epstein at the time of Epstein's alleged first suicide attempt. However, per the attached, SIS advised the footage was preserved. What search for the footage was performed prior to advising the USAO the footage could not be found? I would recommend searching again for the missing video. I have a call with the AUSAs in 20 minutes and will advise as to what other issues arose at yesterday's hearing. + +Thank you, + +Adam M. Johnson + +Deputy Regional Counsel + +Northeast Regional Office + +U.S. Customs House + +2nd and Chestnut Streets + +Philadelpfta6PV52196 + +p: (215)521-'7380 + +€ (215)521 7483 + +From rirrfourcle + +To Adam Johnson + +Date 2019/12/19 11:08 + +Subject: Re: riStigilone 78514-054 + +kttachments: TEXT.htm + +I will get wittigicly Dn this. Thank you + +» Ad'grfv,Johnson 112/19/2019 10:01 AM > » + +https://www.msn.com/en-ie/news/world/jail-video-surveillance-fromieffrey-epsteins-first-suicide-attem\_ptin-july-is-missing-prosecutor-says-according-to-reports/ar-BBY92ur + +Good morning all, + +Per the above article, the Court was advised by the USAO that MCC did not preserve video from outside the cell shared byircirt°,44,Thne and Epstein at the time of Epstein's alleged first suicide attempt. However, per the attached, SIS advised the footage was preserved. What search for the footage was performed prior to advising the USAO the footage could not be found? I would recommend searching again for the missing video. I have a call with the AUSAs in 20 minutes and will advise as to what other issues arose at yesterday's hearing. + +Thank you, + +Adam + +Adam M. Johnson + +Deputy Regional Counsel + +Northeast Regional Office + +U.S. Customs House + +2nd and Chestnut Streets + +Philadelphia, PA 19106 + +p: (215)521 + +E(215)521- + +From + +Adam Johnson + +To + +Cody Kizzier Nicole McFarland, NYM/Executive Staff + +Date + +2019/12/19 11:13 + +Subject: + +Re: Tartaglione 78514-054 + +Attachments: + +TEXT.htm + +As an update, I spoke with the AUSAs. They advised the Court thee was no video because the FBI had the DVR (pulled for the 8/10 incident) which went back to the 7/23 attempt. The FBI reported the DVR footage was corrupted as to the 7/23 video and, thus there was no footage. The AUSAs are asking that SIS check to see wher reserved the 7/22-23 video to see if that copy is not corrupted. They will be reaching out to her directly. + +The AUSAs also want to know where the orange rope from the 7/23 attempt is preserved. + +Thanks all, + +9e1`t1~th c' + +Adam M. Johnson + +Deputy Regional Counsel + +Northeast Regional Office + +U.S. Customs House + +2nd and Chestnut Streets + +Philadelphia, PA 19106 + +p: (215)521-RW1 + +f. (215)521-7483 + +rhagiii'Johnsor 12/19/2019 10:01 AM >> > + +https://vvww.msn.com/en-ie/news/world/jail-video-surveillance-from-jeffrey-epsteins-first-suicide-attempt- + +Good morning all, + +Per the above article, the Court was advised by the USAO that MCC did not preserve video from outside the cell shared by °ft rTg6flone and Epstein at the time of Epstein's alleged first suicide attempt. However, per the attached, SIS advised the footage was preserved. What search for the footage was performed prior to advising the USAO the footage could not be found? I would recommend searching again for the missing video. I have a call with the AUSAs in 20 minutes and will advise as to what other issues arose at yesterday's hearing. + +Thank you, + +Adam M. Johnson + +Deputy Regional Counsel + +Northeast Regional Office + +U.S. Customs House + +2nd and Chestnut Streets + +Philadelphia, PA 19106 + +p: (215)521 + +f (215)521- + +**From** [REDACTED] **Adam Johnson** + +**To** [REDACTED] **Charisma Edge [REDACTED] Cody Kizzier, Elissa Miller, Jermaine Darden, James** + +**To** [REDACTED] **Petrucci, Lamine N'Diaye [REDACTED] Lee Plourde, Marti Licon-Vitale Nicole** + +**Date** [REDACTED] **McFarland, NYM/Executive Staff, Shirley V. Skipper-Scott** + +**Subject:** [REDACTED] **Re: [REDACTED] Tartaglione 78514-054** + +**Attachments:** [REDACTED] **TEXT.htm** + +As an update, I spoke with the AUSAs. They advised the Court thee was no video because the FBI had the DVR (pulled for the 8/10 incident) which went back to the 7/23 attempt. The FBI reported the DVR footage was corrupted ( as to the 7/23 video and, thus there was no footage. The AUSAs are asking that SIS check to see wher 4ititipreserved the 7/22-23 video to see if that copy is not corrupted. They will be reaching out to her direct y. + +The AUSAs also want to know where the orange rope from the 7/23 attempt is preserved. + +Thanks all, + +Adam M. Johnson + +Deputy Regional Counsel + +Northeast Regional Office + +U.S. Customs House + +2nd and Chestnut Streets + +Philadelphia, PA 19106 + +p: (215)521 It7UP + +f. (215)521-7483 + +IJX6X (t)(7)(C) + +>> &gt;Adam Johnson 2/19/2019 10:01 AM >> > + +https://www.msn.com/en-ie/news/world/jail-video-surveillance-from-jeffrey-epsteins-first-suicide-attemptin + +Good morning all, + +Per the above article, the Court was advised by the USAO that MCC did not preserve video from outside the cell shared traffitli one and Epstein at the time of Epstein's alleged first suicide attempt. However, per the attached, SIS advised the footage was preserved. What search for the footage was performed prior to advising the USAO the footage could not be found? I would recommend searching again for the missing video. I have a call with the AUSAs in 20 minutes and will advise as to what other issues arose at yesterdays hearing. + +Thank you, + +Atf,TrWc) + +Adam M. Johnson + +Deputy Regional Counsel + +Northeast Regional Office + +U.S. Customs House + +2nd and Chestnut Streets + +Philadelphia, PA 19106 + +p: (215)521 pr3 8t1 AC, + +f (215)521 7483 + +From Ntfitilfrohnson + +Charisma EdgerOtirRizza.r, Elissa Miller, Jerniatne Darden, James + +To Petrucci, Lamine N'Diaye,rterfourde. Mani Licon-VitaleNicole + +"Ntenirland. NYM/Executive Staff, Shirley V. Skipper-Scott + +Date 2019/12/19 1 1 : 13 + +Subject: Re: trittgOione 78514-054 + +Attachments: TEXT.htm + +As an update, I spoke with the AUSAs. They advised the Court thee was no video because the FBI had the DVR (pulled for the 8/10 incident) which went back to the 7/23 attempt. The FBI reported the DVR footage was corrupted as to the 7/23 video and, thus there was no footage. The AUSAs are asking that SIS check to see where \*a oreserved the 7/22-23 video to see if that copy is not corrupted. They will be reaching out to her directly. + +The AUSAs also want to know where the orange rope from the 7/23 attempt is preserved. + +Thanks all, + +!met nom) + +Adam M. Johnson + +Deputy Regional Counsel + +Northeast Regional Office + +U.S. Customs House + +2nd and Chestnut Streets + +Philadelphia, PA 19106 + +p: (215)521 + +f. (215)521-7483 + +»>"%ffgitP? ohnson 12/19/2019 10:01 AM »> + +https://www.msn.com/en-ie/news/world/jail-video-surveillance-from-jeffrey-epsteins-first-suicide-attempt in-july-is-missing-prosecutor-says-according-to-reports/ar-BBY92ur + +Good morning all, + +Per the above article, the Court was advised by the USAO that MCC did not preserve video from outside the cell shared torrhittVione and Epstein at the time of Epstein's alleged first suicide attempt. However, per the attached, SIS advised the footage was preserved. What search for the footage was performed prior to advising the USAO the footage could not be found? I would recommend searching again for the missing video. I have a call with the AUSAs in 20 minutes and will advise as to what other issues arose at yesterday's hearing. + +Thank you, + +WelttRe' + +Adam M. Johnson + +Deputy Regional Counsel + +Northeast Regional Office + +U.S. Customs House + +2nd and Chestnut Streets + +Philadelphi. + +p: (215)521 + +I: (215)521-7483 + +From Lee Plourde + +To Adam Johnson + +Date 2019/12/19 12:13 + +Subject: Re: Tartaglione 78514-054 + +Attachments: TEXT.htm + +The video is being burned and sent over . Can you call me when you have a min, + +> >rgd'Afigohrison 12/19/2019 11:13 AM > » + +As an update, I spoke with the AUSAs. They advised the Court thee was no video because the FBI had the DVR (pulled for the 8/10 incident) which went back to the 7/23 attempt. The FBI reported the DVR footage was corrupted as to the 7/23 video and, thus there was no footage. The AUSAs are asking that SIS check to see wher reserved the 7/22-23 video to see if that copy is not corrupted. They will be reaching out to her directly. + +The AUSAs also want to know where the orange rope from the 7/23 attempt is preserved. + +Thanks all, + +bAdtAlif; + +0)16k (0)I7XC; + +Adam M. Johnson + +Deputy Regional Counsel + +Northeast Regional Office + +U.S. Customs House + +2nd and Chestnut Streets + +Philadelphia, PA 19106 + +p: (215)521 °Ittd"' + +f. (215)521 7483 + +> > rfitagii'Johnsori12/19/2019 10:01 AM > » + +httpc.//www.msn rom/en-ie/news/world/jail-video-surwillanre-from-erey-epsteins-first-suiride-attempt- + +Good morning all, + +Per the above article, the Court was advised by the USAO that MCC did not preserve video from outside the cell shared by `Thilqfronejand Epstein at the time of Epstein's alleged first suicide attempt. However, per the attached, SIS advised the ootage was preserved. What search for the footage was performed prior to advising the USAO the footage could not be found? I would recommend searching again for the missing video. I have a call with the AUSAs in 20 minutes and will advise as to what other issues arose at yesterdays hearing. + +Thank you, + +tr.(6Anfipi + +Adam M. 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"llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089877" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089888/EFTA00089888.md b/marker2/ds9/EFTA00089888/EFTA00089888.md new file mode 100644 index 0000000000000000000000000000000000000000..7cdf476122012941d2f43d059893b475d1ee72a3 --- /dev/null +++ b/marker2/ds9/EFTA00089888/EFTA00089888.md @@ -0,0 +1,63 @@ +From: To: ' Cc: na + +Subject: RE: Follow Up + +Date: Mon, 03 May 2021 00:30:00 +0000 + +Attachments: 2021.05.03\_Maxwell\_Discovery\_Letter.docx + +Inline-Images: image001.png + +Hi + +These have been prepped and saved here and a draft cover letter is attached and saved here. Let me know if there are any revisions you'd like me to make. + +When we load the drive for Maxwell tomorrow with the materials previously loaded onto a hard drive for her (per your Friday afternoon email), should these materials be loaded onto it as well, or would you prefer for them to be produced some other way separately? Please let us know. + +Thanks, + +From: + +Sent: Sunday, May 2, 20216:15 PM + +To: + +Cc: + +Subject: FW: Follow Up + +Hi, + +Tomorrow, would one of you please prep the attached files to be produced as discovery to Maxwell? All should be marked CONFIDENTIAL. + +Thanks very much, + +From: Sigrid McCawley < + +Sent: Wednesday, April 28, 2021 3:32 PM + +To: + +Cc: Sigrid McCawley + +Subject: Follow Up + +As to the one photo of — BSF only has electronic copies — the original would be with in Arkansas. + +You will see that the pictures have both the bates number and the bates number. As reference in the redacted 302 (clipped below) the originals of these photos were taken into custody by the FBI so does not have the originals of the photos but does have the CD that the FBI gave her. Please feel free to reach out if you have any additional questions. + +On March 18, 2011, writer, SAI land traveled to residence where she provided 20 ITM massage school certification. FD-597 Receipts for executed for the items and a copy was provided to the receipts were dated based on the United States Eastern Standard Time Zone date. The photographs, certification and original FD-597s were placed in a 1A envelopes of case file. photographs and her Property were . It is noted that + +Sigrid McCawley Partner + +BOIES SCHILLER FLEXNER LLP + +401 E. Las Olas Blvd. Suite 1200 + +Fort Lauderdale. FL. 33301 + +www.bsfllp.com + +b6 b7C + +The information contained in this electronic message is confidential information intended only fa the use of the named recipient(s) and may contan information Mat. among other protections. is the subject of attorney-client privilege. attorney work product or exempt from disclosure under applicable law. If the reader of this electronic message is not the named recipient. or the employee or agent responsible to deliver it to the named recipient, you are hereby notified that any disseminator,. distribution. copying or other use of this communication is strictly prohibited and no prMlege is waived. If you have received this communication in error. please immediately notify the sender by replying to this electronic message and then deleting this electronic message from your computer. (v.1 08201831BSF] \ No newline at end of file diff --git a/marker2/ds9/EFTA00089888/EFTA00089888.metadata.json b/marker2/ds9/EFTA00089888/EFTA00089888.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..10efdd0a408de9e00f6a34f43d546e30022ae8ff --- /dev/null +++ b/marker2/ds9/EFTA00089888/EFTA00089888.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089888.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2782, + "elapsed_seconds": 1.13, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 65 + ], + [ + "Line", + 32 + ], + [ + "Text", + 24 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 62 + ], + [ + "Line", + 30 + ], + [ + "Text", + 13 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089888" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089890/EFTA00089890.md b/marker2/ds9/EFTA00089890/EFTA00089890.md new file mode 100644 index 0000000000000000000000000000000000000000..b3b209778cdb6d26e72ae3a0ab0576771e6aa6c3 --- /dev/null +++ b/marker2/ds9/EFTA00089890/EFTA00089890.md @@ -0,0 +1,40 @@ +# SMITH | VILLAZOR + +Smith Villazor LLP +250 West 55th Street, 30th Floor +New York, NY 10019 +www.smithvillazor.com + +![](_page_0_Picture_117.jpeg) + +November 28, 2021 + +**BY E-MAIL to** [REDACTED] +The Honorable Alison J. Nathan +United States District Judge +Southern District of New York +40 Foley Square +New York, New York 10007 + +**Re: United States v. Maxwell, No. 20 Cr. 330** + +Dear Judge Nathan: + +On behalf of non-party [REDACTED] the independent administrator of the Epstein Victims' Compensation Program, and in accordance with the Court's memo-endorsement of our November 23, 2021 letter, we are making a third production to the Court of remaining documents responsive to defendant Maxwell's subpoena. We have posted the documents to a secure FTP site, which the Court, in its order dated November 27, 2021, indicated was a sufficient means of providing the documents. The credentials to the FTP site are the same as those we sent by email on November 26, 2021. + +We are producing in this production claim packets sent to attorneys for the four individuals identified in the subpoena and email communications with those attorneys relating to the four individuals. We have redacted these documents in accordance with Federal Rule of Criminal Procedure 49.1(a) and to remove references to claimants other than the four individuals identified in the subpoena. + +We are available should the Court have any questions. + +Respectfully submitted, + +[REDACTED] +[REDACTED] +[REDACTED] + +cc: + +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] \ No newline at end of file diff --git a/marker2/ds9/EFTA00089890/EFTA00089890.metadata.json b/marker2/ds9/EFTA00089890/EFTA00089890.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..85c7536b0eafe4bc7f5654216b8fe311d95626a9 --- /dev/null +++ b/marker2/ds9/EFTA00089890/EFTA00089890.metadata.json @@ -0,0 +1,92 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089890.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1545, + "elapsed_seconds": 5.94, + "image_assets": [ + "_page_0_Picture_117.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "SMITH | VILLAZOR", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 67.932, + 57.50999999999999 + ], + [ + 324.97200000000004, + 57.50999999999999 + ], + [ + 324.97200000000004, + 79.38 + ], + [ + 67.932, + 79.38 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 64 + ], + [ + "Line", + 30 + ], + [ + "Text", + 29 + ], + [ + "PageHeader", + 2 + ], + [ + "Picture", + 2 + ], + [ + "PageFooter", + 2 + ], + [ + "SectionHeader", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089890" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089890/_page_0_Picture_117.jpeg b/marker2/ds9/EFTA00089890/_page_0_Picture_117.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..5825de26bb0bac7bfd58ff6724abbbefc02e3bb9 --- /dev/null +++ b/marker2/ds9/EFTA00089890/_page_0_Picture_117.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:bd42df1f657145c996733a5310dd70e3c8f4a9fc84ecf2c1fbd4110793fdeee7 +size 2397 diff --git a/marker2/ds9/EFTA00089891/EFTA00089891.md b/marker2/ds9/EFTA00089891/EFTA00089891.md new file mode 100644 index 0000000000000000000000000000000000000000..7514aad042d8f4d0e510790e87d5bf43e74bec88 --- /dev/null +++ b/marker2/ds9/EFTA00089891/EFTA00089891.md @@ -0,0 +1,93 @@ +UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA, + +-against- + +TOVA NOEL and MICHAEL THOMAS, + +Defendants. + +USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC #: DATE FILED: 6/9/2020 + +19 Cr. 830-2 (AT) + +#### ORDER + +ANALISA TORRES, District Judge: + +On November 19, 2019, Defendant Michael Thomas was charged with one count of conspiring to defraud the United States in violation of 18 U.S.C. § 371, and three counts of making false statements with the intent to impede, obstruct, or influence the investigation or proper administration of a matter within the jurisdiction of a department or agency of the United States in violation of 18 U.S.C. § 1001(aX3). ECF No. 1. The indictment alleges that Thomas, in his capacity as a correctional officer at the Metropolitan Correctional Center (the "MCC"), along with another officer, co-Defendant Tova Noel, submitted several false "count slips" on the night of August 9, 2019 and the morning of August 10, 2019, certifying that he conducted counts of the inmates he was supervising in the MCC's Special Housing Unit ("SHU"), even though he did not conduct those counts. Id. ¶¶ 16, 30, 36, 38, 40. During that time period, one of the inmates in the SHU—Jeffrey Epstein—hanged himself in his cell. Id. ¶q 1, 26-27. + +Thomas now moves to compel the Government to produce evidence in connection with the trial scheduled to begin on January 4, 2021. Motion, ECF No. 33. Thomas seeks three categories of information: (1) "[t]re report of the Inspector General" for the United States Department of Justice related to Epstein's death, and "any and all supplemental memorandums, written statements, photos, videos, and incident reports" obtained by the Inspector General's investigation, id, at 5; (2) "[a]ly and all internal investigative reports created by the [Bureau of + +Prisons (the "BOP")] as to both [D]efendants, including[] any and all supporting memorandums, written statements, photos, videos, and incident reports," id. at 6; and (3) "any and all reports, memorandums, written statements, photos, videos, and incident reports created, manufactured, or possessed by any investigative or disciplinary agencies[] participating in the investigation of the [D]efendants, allied with the prosecution, and to which the prosecution has access," id. at 7. + +For the reasons stated below, Thomas' motion is DENIED. + +### DISCUSSION + +The Government has already produced "surveillance video going back to July 5, 2019 ... ; count slips, thirty minute round forms, and staffing rosters for the three-week period surrounding Epstein's suicide; internal MCC phone records; employee files and staffing history for Noel and Thomas; and a wide range of written [BOP] policies and regulations," as well as "statements for all of the witnesses interviewed during the investigation." Gov't Opp. at 8-9, ECF No. 35. + +Thomas argues that he is entitled to additional discovery on two grounds: (1) Rule 16 of the Federal Rules of Criminal Procedure, and (2) the constitutional guarantee of due process as expressed by the Supreme Court's decisions in Brady v. Maryland, 373 U.S. 83 (1963), and Giglio v. United States, 405 U.S. 150 (1972). Motion at 1. + +# I. Legal Standards + +### A. Rule 16 + +Rule 16 requires the Government to "permit the defendant to inspect and to copy or photograph books, papers, documents, data, photographs, tangible objects, buildings or places, or copies or portions of any of these items, if the item is within the government's possession, + +custody, or control and: (i) the item is material to preparing the defense; (ii) the [G]ovemment intends to use the item in its case-in-chief at trial; or (iii) the item was obtained from or belongs to the defendant." Fed. R. Crim. P. 16(a)(1)(E). "Evidence is material if it could be used to counter the [G]overnment's case or to bolster a defense." United States v. Ulbricht, 858 F.3d 71, 109 (2d Cir. 2017) (internal quotation marks and citation omitted), abrogated on other grounds by Carpenter v. United States, 138 S. Ct. 2206 (2018). "In order to compel the Government to produce certain evidence, a defendant must make a prima facie showing of materiality, and must offer more than the conclusory allegation that the requested evidence is material." United States v. Abdalla, 317 F. Supp. 3d 786, 790 (S.D.N.Y. 2018) (internal quotation marks and citation omitted). "There must be some indication that the pretrial disclosure of the disputed evidence would enable the defendant significantly to alter the quantum of proof in his favor." United States v. Urena, 989 F. Supp. 2d 253, 261 (S.D.N.Y. 2013) (internal quotation marks, citation, and alterations omitted). + +Evidence is "within the [G]ovemment's possession, custody, or control" if "(1) it has actually reviewed [the evidence], or (2) [the evidence is] in the possession, custody, or control of a government agency so closely aligned with the prosecution so as to be considered part of the prosecution team." United States v. Finnerty, 411 F. Supp. 2d 428, 432 (S.D.N.Y. 2006). "Legal ownership of the requested documents or things is not determinative, nor is actual possession necessary if the party has control of the items. Control has been defined to include the legal right to obtain the documents requested upon demand. The term `control' is broadly construed." United States v. Stein, 488 F. Supp. 2d 350, 361 (S.D.N.Y. 2007) (internal quotation marks and citation omitted) (collecting cases). + +If the Government represents that it "it has fully complied with [its Rule 16] obligations and will continue to do so," the defendant must put forward some "compelling demonstration to the contrary" by pointing to a "specific failure by the Government to comply with its disclosure obligations" in order to justify a motion to compel. United States v. Minaya, 395 F. Supp. 2d 28, 34 (S.D.N.Y. 2005). + +#### B. BradylGiglio + +Under the Supreme Court's decision in Brady v. Maryland, the Government "has a constitutional duty to disclose evidence favorable to an accused when such evidence is material to guilt or punishment," and as elaborated in Giglio v. United States, that obligation extends to "not only exculpatory material, but also information that could be used to impeach a key [G]ovemment witness." United States v. Coppa, 267 F.3d 132, 135 (2d Cir. 2001). "Evidence is material within the meaning of Brady when there is a reasonable probability that, had the evidence been disclosed, the result of the proceeding would have been different." Turner v. United States, 137 S. Ct. 1885, 1893 (2017) (internal quotation marks, citations, and alteration omitted)); see also Coppa, 267 F.3d at 135 ("[T]he prosecutor must disclose evidence if, without such disclosure, a reasonable probability will exist that the outcome of a trial in which the evidence had been disclosed would have been different."). + +"The prosecution's obligation to disclose Brady material extends to any material in the possession of any entity that has acted as an `arm of the prosecutor' in a given case." United States v. Middendorf, No. 18 Cr. 36, 2018 WL 3956494, at '4 (S.D.N.Y. Aug. 17, 2018) (quoting United States v. Blaszczak, 308 F. Supp. 3d 736, 741 (S.D.N.Y. 2018)). "A prosecutor's duty to review documents in the possession, custody, or control of another agency + +arises where the Government conducts a joint investigation with another agency." United States v. Collins, 409 F. Supp. 3d 228, 239 (S.D.N.Y. 2019) (internal quotation marks and citation omitted). In determining whether the prosecution has conducted a joint investigation, courts in this district look to a number of non-exhaustive factors, "including whether the other agency: (1) participated in the prosecution's witness interviews, (2) was involved in presenting the case to the grand jury, (3) reviewed documents gathered by or shared documents with the prosecution, (4) played a role in the development of prosecutorial strategy, or (5) accompanied the prosecution to court proceedings." Id. (internal quotation marks and citation omitted). + +As under Rule 16, if the Government has represented that it is aware of and has complied with its Brady and Giglio obligations, a defendant must make a "particularized showing that materials exist requiring disclosure" in order to sustain a motion to compel. United States v. Juliano, No. 99 Cr. 1197, 2000 WL 640644, at \*2 (S.D.N.Y. May 18, 2000); see United States v. Evanclzik, 413 F.2d 950, 953 (2d Cir. 1969) ("[T]he assurance by the [G]overnment that it has in its possession no undisclosed evidence that would tend to exculpate defendant justifies the denial of a motion for inspection that does not make some particularized showing of materiality and usefulness.") + +# II. Inspector General Materials + +Thomas seeks disclosure of both the investigatory materials from the Department of Justice Office of the Inspector General's ("OIG") investigation regarding Epstein's death, and a draft of the Inspector General's report arising from that investigation. Motion at 5. The Government concedes that attorneys from OIG participated in the Government's investigation that led to the indictment of Thomas. Gov't Opp. at 3, 19. But, the Government represents that it has already delivered to Thomas all of the materials gathered by OIG personnel in the course of investigating this case, and that "it is the prosecution's understanding that [OIG] attorneys have not conducted any additional interviews or otherwise discovered any potential Brady material." Id. at 23-24. Thomas has not identified any specific material that might be in OIG's possession that has not been disclosed. + +The Court, therefore, has no basis to compel the Government to disclose additional evidence underlying the Inspector General's report. "[C]ourts in this circuit have repeatedly denied requests for discovery orders where the [G]overnment represents that it has produced discovery to defendants pursuant to Rule 16 and has made a good faith representation to the defense that it recognizes and has complied with its obligations under Brady and its progeny." United States v. Garcia-Pena, No. 17 Cr. 363, 2018 WL 6985220, at \*6 (S.D.N.Y. Dec. 19, 2018) (internal quotation marks, citation, and alterations omitted); see also, e.g., United States v. Blonde:, No. 16 Cr. 387, 2019 WL 5690711, at \*5 ("[T]o the extent that these motions seek evidence pursuant to Brady [], Giglio [], and their progeny, they are [denied] on the basis of the Government's good-faith representation that it has complied with its obligations and will continue to do so." (citations omitted)); United States v. Goode, No. 16 Cr. 529, 2018 WL 919928, at \*18 (S.D.N.Y. Feb. 15, 2018) ("The Government represents that it has complied with Rule 16 obligations; the Rule 16 requests are therefore moot." (citation omitted)). + +As for the draft Inspector General's report itself, the Government reports that "attorneys from [OIG] responsible for writing the [r]eport have not yet completed a draft, and do not anticipate completing the [r]eport in the near term," and so "there are no drafts of the [r]eport to disclose." Gov't Opp. at 21-22. The Court cannot grant a motion to compel the Government to produce a report that, at the time of this order, does not exist.' + +Accordingly, Thomas' motion to compel disclosure of materials related to the Inspector General's investigation is DENIED. + +### III. BOP Materials + +Thomas also seeks disclosure of "reports generated by investigators within the [BOP] regarding" Epstein's death, and "any and all documents, reports, witness statements and disciplinary records of any and all MCC employees who have engaged in conduct" similar to that alleged against Thomas. Motion at 6. However, Thomas has adduced no evidence that the Government reviewed information arising from a BOP investigation. Nor has he shown that BOP officials "participated in the prosecution's witness interviews," were "involved in presenting the case to the grand jury," "reviewed documents gathered by or shared documents with the prosecution," "played a role in the development of prosecutorial strategy," "accompanied the prosecution to court proceedings," or in any other way played a role in the investigation that led to the charges against him. Collins, 409 F. Supp. 3d at 239 (internal quotation marks, citation, and alteration omitted). There is, therefore, no evidence that BOP personnel participated in the criminal investigation that led to Thomas' indictment. Thus, the Court concludes that the BOP was not part of the prosecution team for purposes of Rule 16 and Brady. + +To be sure, the BOP is a component of the Department of Justice, but that fact standing alone is not sufficient to make the BOP an arm of the prosecution. "The court cannot find that + +I Because the Court denies Thomas' motion on the ground that no material exists to disclose, it does not address whether the Inspector General's report might contain information material to his defense, nor whether it is protected by the deliberative process privilege. See Gov't Opp. at 12-15,22-23. + +the government is in constructive possession of the materials where, as here, defendant has not presented any evidence suggesting that the BOP was involved in the investigation or prosecution of this case." United States v. Rivera, No. 13 Cr. 149, 2015 WL 1540517, at \*3 (E.D.N.Y. Apr. 7, 2015); see, e.g., United States v. Merlin, 349 F.3d 144, 155 (3d Cir. 2003) (holding that Government did not violate Brady obligation in failing to turn over tapes in BOP possession because "the BOP was not part of the prosecutorial arm of the federal government as it was not at all involved in either the investigation or the prosecution of the defendants"); United States v. Battle, 264 F. Supp. 2d 1088, 1201-02 (N.D. Ga. 2003) ("Defendant implies that because the BOP employees are connected with the Department of Justice that the prosecution team constructively possessed exculpatory information that could have been within the knowledge of BOP staff.... Even if the Court assumes that some members of the BOP staff did possess favorable information that alone does not impute knowledge to the prosecution team." (citing United States v. Avellino, 136 F.3d 249, 255 (2d Cir. 1998)). + +Accordingly, Thomas' motion to compel the Government to disclose evidence in the possession of the BOP is DENIED. + +# IV. Other Materials + +Finally, Thomas seeks disclosure of information that he argues will tend to show that the conduct for which he is being prosecuted was: "1) rampant throughout the BOP; 2) made with knowledge and acquiescence by the leadership of the BOP; 3) made as a result of BOP policies that forced the defendant to engage in conduct for which he is now being charged criminally, and; 4) made in a manner which contains a possible discriminatory application of BOP policies by [G]overnment prosecutors." Motion at 7. But Thomas has not provided support for his + +assertion that the Government, or any other agency that has operated as an arm of the prosecution, is in possession or control of evidence that relates to the prevalence of falsifying count slips in federal correctional facilities, or BOP leadership's tolerance of such practices. + +Moreover, to the extent that Thomas is seeking discovery in support of a selective prosecution defense, he has not met the "rigorous" standard that applies for obtaining discovery in aid of such a claim. United States v. Armstrong, 517 U.S. 456, 468 (1996). "[A] defendant who seeks discovery on a claim of selective prosecution must show some evidence of both discriminatory effect and discriminatory intent." United States v. Bass, 536 U.S. 862, 863 (2002). Though Thomas claims that BOP supervisors may have acquiesced in his submission of false count slips in this case, and that other BOP employees have submitted false documents in other circumstances, he has not presented any evidence that those officers differed from him in any protected characteristic-for example, that they were of a different race, sex, or ethnicity. See Motion at 10. Nor has Thomas put forward any evidence of a discriminatory motive for his prosecution. + +Accordingly, Thomas' motion to compel the Government to disclose evidence that the submission of false count slips was widespread and tolerated at the BOP, and for discovery related to selective prosecution, is DENIED. + +# CONCLUSION + +For the reasons stated, Thomas' motion to compel is DENIED. The Clerk of Court is directed to terminate the motion at ECF No. 33. + +SO ORDERED. + +Dated: June 9, 2020 New York, New York + +ANALISA TORRES United States District Judge \ No newline at end of file diff --git a/marker2/ds9/EFTA00089891/EFTA00089891.metadata.json b/marker2/ds9/EFTA00089891/EFTA00089891.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..5cb4adb8da4917a05c98a88ebd7d740fcddc4bfc --- /dev/null +++ b/marker2/ds9/EFTA00089891/EFTA00089891.metadata.json @@ -0,0 +1,570 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089891.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 9, + "chars": 16674, + "elapsed_seconds": 1.23, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "ORDER", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 441.8639999999999, + 184.68 + ], + [ + 492.7633361816406, + 184.68 + ], + [ + 492.7633361816406, + 199.10302734375 + ], + [ + 441.8639999999999, + 199.10302734375 + ] + ] + }, + { + "title": "DISCUSSION", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 266.832, + 236.51999999999998 + ], + [ + 345.26641845703125, + 236.51999999999998 + ], + [ + 345.26641845703125, + 251.60302734375 + ], + [ + 266.832, + 251.60302734375 + ] + ] + }, + { + "title": "I. 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Maxwell question for you + +Date: Wed, 29 Jul 2020 18:59:44 +0000 + +Can you guys track down the filing if you don't have it already and circulate? Thanks + +From: + +Sent: Wednesda Jul 29 2020 2:59 PM + +To: + +Cc: + +Subject: FW: Hi all, hope you guys are well? Maxwell question for you + +I presume you'd suggest we decline to comment in response to Patty Hurtado's inquiry, below, about a filing by Maxwell's lawyers today in the civil suit by + +From: Patricia Hurtado (BLOOMBERG/ FEDERAL C + +Sent: Wednesda Jul 29 2020 2:51 PM + +To + +Su . + +Hope you're AC is working wherever you are. Especially in the Silvio Mollo building? + +I was wondering if you guys cared to comment on the allegations Ghislaine Maxwell's lawyers made in a filing to Judge Preska today in then Maxwell case 15-cv-7433, document 1078, in which she questions how prosecutors got hold of her sworn testimony in the case which was supposed to be under seal. + +She further alleges that set a "perjury trap" for her when April, 2016. lawyers, working with the government, took Maxwell's deposition in + +I know, I know, but I have to ask you. + +Thanks, + +[111.,4-k4r. \ No newline at end of file diff --git a/marker2/ds9/EFTA00089900/EFTA00089900.metadata.json b/marker2/ds9/EFTA00089900/EFTA00089900.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..c71a26d3bf8da859efcc4bc264344ecd4cacc41f --- /dev/null +++ b/marker2/ds9/EFTA00089900/EFTA00089900.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089900.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1165, + "elapsed_seconds": 1.02, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 69 + ], + [ + "Line", + 33 + ], + [ + "Text", + 22 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089900" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089901/EFTA00089901.md b/marker2/ds9/EFTA00089901/EFTA00089901.md new file mode 100644 index 0000000000000000000000000000000000000000..4e6bfb783ee95905464e26669fa0559ccd161fd5 --- /dev/null +++ b/marker2/ds9/EFTA00089901/EFTA00089901.md @@ -0,0 +1,64 @@ +**From:** [REDACTED] +**To:** "[REDACTED] (USANYS)" <[REDACTED]>; "[REDACTED]" +<[REDACTED]>; "[REDACTED]" <[REDACTED]>; "[REDACTED]" +[REDACTED] <[REDACTED]> +**Subject:** RE: [EXTERNAL] Maxwell CBP Documents - SDNY +**Date:** Thu, 25 Nov 2021 01:36:00 +0000 + +--- + +Saved here: [\\Usa.doj.gov\cloud\NYS\StAndrews\Shared\USvEpstein-2018R01618\Discovery\GM\Defense Rule 16 Disclosures\2021.11.24 CBP Records](#) + +--- + +**From:** [REDACTED] (USANYS) <[REDACTED]> +**Sent:** Wednesday, November 24, 2021 8:32 PM +**To:** [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] +[REDACTED] <[REDACTED]> +**Cc:** [REDACTED] (USANYS) [Contractor] <[REDACTED]> +**Subject:** FW: [EXTERNAL] Maxwell CBP Documents - SDNY + +As a reminder, we should take a look at these. [REDACTED] can you please save on the shared in defense discovery? + +--- + +**From:** [REDACTED] (USANYS) +**Sent:** Tuesday, November 23, 2021 11:23 AM +**To:** [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] +[REDACTED] <[REDACTED]> +**Subject:** Fwd: [EXTERNAL] Maxwell CBP Documents - SDNY + +Password: Maxwell112321 + +Begin forwarded message: + +[REDACTED] +**Subject:** [EXTERNAL] Maxwell CBP Documents - SDNY + +Mr. Everdell, + +This office writes in response to your request to utilize border crossing records of three named individuals. You initially requested this information via subpoena on October 14, 2021. We spoke on November 22, 2021 in a follow up conversation wherein the scope of the requested was altered. Further, you advised that these documents would be utilized in ongoing criminal proceedings captioned, United States v. Ghislaine Maxwell. Finally, in that November 22 conversation you stated that the documents released herein would be subject to the protective order which is already in place for that proceeding. The release of this information is subject to the conditions below and is password protected, with password coming under separate cover. + +Attached, please find the responsive information. The attached records may be subject to the Privacy Act (5 U.S.C. § 552a) and may include sensitive law enforcement information. This office has redacted the relevant documents for the purpose of excluding computer screen transaction codes, computer program transaction codes, computer function + +codes, information contained in the system that reflects the results of specific law enforcement database queries, and/or personally identifiable information of CBP officers. + +CBP releases these documents for use in the above-referenced case only. These records should not be used for any other purpose without the express, written consent of this office. The CBP Privacy Officer further advises that in the event of any unauthorized disclosure, your office will be expected to intercede on CBP's behalf and assume full responsibility for any and all expenses, costs, or liabilities arising from such disclosure. + +Finally, you asked for information about the CBP witness who will be available to testify. The CBP witness available to provide testimony is Chief CBPO + +Best, + +Senior Attorney + +Office of the Associate Chief Counsel, New York + +U.S. Customs and Border Protection + +One World Trade Center, 50th Floor + +New York, NY 10007 + +OCC NE Homepage + +I am currently teleworking. You may reach me by email or ce \ No newline at end of file diff --git a/marker2/ds9/EFTA00089901/EFTA00089901.metadata.json b/marker2/ds9/EFTA00089901/EFTA00089901.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..5e0756674dee2378a4da4f74bdb06501f7648342 --- /dev/null +++ b/marker2/ds9/EFTA00089901/EFTA00089901.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089901.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 3312, + "elapsed_seconds": 7.86, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 70 + ], + [ + "Line", + 34 + ], + [ + "Text", + 25 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 35 + ], + [ + "Line", + 17 + ], + [ + "Text", + 13 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089901" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089903/EFTA00089903.md b/marker2/ds9/EFTA00089903/EFTA00089903.md new file mode 100644 index 0000000000000000000000000000000000000000..0a2e629f1382e40e8563181815d481245744db8c --- /dev/null +++ b/marker2/ds9/EFTA00089903/EFTA00089903.md @@ -0,0 +1,31 @@ +From: + +To: Nathan NYSD Chambers + +Subject: US v. Maxwell, 20 Cr. 330 (AJN) - Proposed Redactions + +Date: Thu, 25 Nov 2021 01:38:00 +0000 + +Attachments: Mot to Excludeflall\_Reply\_Br. final jproposed redactions)].pdf; + +"CEverdell®CohenGresser.com" , bcsternheim\_mac.com , Laura Menninger , Jeff Pagliuca 1pagliuca®lunflaw.com> + +Motion—to\_preclude Hall et\_al\_rproposed redactionsi.pdf; + +2021.1 119\_Maxweli\_Res—ponse\_to\_Govisiotion\_to\_Preclude\_Expert\_Testimonyipropose d redactionsi.pdf; + +2521.11.22\_20cr330\_Hall\_Temp.\_Seal.\_Mem.\_Op.\_&\_Order\_11.22.21 jproposed\_redactio ns].pdf + +Chambers, + +Attached please find the proposed redactions references in the letter motion at Dkt. No. 506. + +Respectfully submitted, + +Assistant United States Attorney + +Southern District of New York + +1 Saint Andrews Plaza + +New York. New York 10007 \ No newline at end of file diff --git a/marker2/ds9/EFTA00089903/EFTA00089903.metadata.json b/marker2/ds9/EFTA00089903/EFTA00089903.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..99c0daf5aa6387e1191e48344707a140693eeeb0 --- /dev/null +++ b/marker2/ds9/EFTA00089903/EFTA00089903.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089903.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 911, + "elapsed_seconds": 0.76, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 48 + ], + [ + "Line", + 24 + ], + [ + "Text", + 16 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089903" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089904/EFTA00089904.md b/marker2/ds9/EFTA00089904/EFTA00089904.md new file mode 100644 index 0000000000000000000000000000000000000000..21a97064f472747dadb8ba29cb026ef071d40408 --- /dev/null +++ b/marker2/ds9/EFTA00089904/EFTA00089904.md @@ -0,0 +1,231 @@ +#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +United States of America, + +—v— + +Ghislaine Maxwell, + +Defendant. + +![](_page_0_Picture_5.jpeg) + +20-CR-330 (AJN) MEMORANDUM OPINION & ORDER + +ALISON J. NATHAN, District Judge: + +The Defense on November 1, 2021, noticed eight expert witnesses. Def. Br., Ex. 1 ("Notice"). Two of those experts, Dr. Park Dietz and Dr. Elizabeth Loftus, are expected to offer opinions that rebut opinions of the Government's expert witness, Dr. Lisa Rocchio. The Government on November 8, 2021, filed a motion to partially preclude the testimony of Dr. Dietz and Dr. Loftus. Dkt. No. 424. The Court has already addressed that motion. + +On November 15, 2021, the Government moved to fully or partially preclude the testimony of the remaining six experts. The Defense filed a response on November 19, 2021. + +The Court addresses the motion to preclude Dr. Hall in this separate opinion. It will address the other five experts in public rulings. + +## I. Legal standard + +Federal Rule of Evidence 702 governs the admissibility of expert testimony. That rule states: + +A witness who is qualified as an expert by knowledge, skill, experience, training, or education may testify in the form of an opinion or otherwise if: + +- (a) the expert's scientific, technical, or other specialized knowledge will help the trier of fact to understand the evidence or to determine a fact in issue; +- (b) the testimony is based on sufficient facts or data; +- (c) the testimony is the product of reliable principles and methods; and +- (d) the expert has reliably applied the principles and methods to the facts of the case. + +The Court exercises a "gatekeeper function" in assessing the admissibility of expert testimony. Restivo v. Hessemann, 846 F.3d 547, 575 (2d Cir. 2017). To determine whether an expert's method is reliable, the Court considers the non-exhaustive list provided by the Supreme Court in Dauber!, including whether the expert's method has been tested, whether it has been subjected to peer review, the rate of error, standards controlling the method's operation, and whether the method is accepted by the expert community. United States v. Kidd, 385 F. Supp. 3d 259, 263 (S.D.N.Y. 2019) (citing Dauber! v. Merrell Dow Pharms., Inc., 509 U.S. 579, 593-94 (1993)). + +But Rule 702 ultimately sets a "liberal" and "permissive" standard of admissibility. Nimely v. City of New York, 414 F.3d 381, 395-96 (2d Cir. 2005). In particular, not every expert admissible under Daubert need rely on a method that conforms with "the exactness of hard science methodologies." E.E.O.C. v. Bloomberg L.P., No. 07-CV-8383 (LAP), 2010 WL 3466370, at \*13-14 (S.D.N.Y. Aug. 31, 2010) (quoting United States v. Simmons, 470 F.3d 1115, 1123 (5th Cir. 2006)). + +Additionally, the procedure for disclosing expert witnesses is governed by Federal Rule of Criminal Procedure 16. That rule states that when the Government makes a request, the Defense "must ... give to the government a written summary of any testimony that the defendant intends to use under Rules 702... . This summary must describe the witness's opinions, the bases and reasons for those opinions, and the witness's qualifications." Fed. R. + +Crim. P. 16(b)(1)(C). The purpose of this rule is to "minimize surprise that often results from unexpected expert testimony, reduce the need for continuances, and to provide the opponent with a fair opportunity to test the merit of the expert's testimony through focused cross-examination." Fed. R. Civ. P. 16(b)(1)(C) advisory committee's note to 1993 amendment. Thus, to satisfy Rule 16, a notice must not merely describe the "general topics" on which experts will testify but actually "summarize the experts' opinions about those topics" and "describe the bases for the experts' opinions." United States v. Ulbricht, 858 F.3d 71, 115 (2d Cir. 2017) (emphasis added); United States v. Valle, No. 12-CR-847 (PGG), 2013 WL 440687, at \*5 (S.D.N.Y. Feb. 2, 2013) ("Merely identifying the general topics about which the expert will testify is insufficient; rather, the summary must reveal the expert's actual opinions."). + +If the Defense's disclosure of an expert witness does not satisfy Rule 16, the Court has "broad discretion" to fashion an appropriate remedy. Ulbricht, 858 F.3d at 115. That discretion is guided by factors including "why disclosure was not made, the extent of the prejudice, if any, to the opposing party, the feasibility of rectifying that prejudice by a continuance, and any other relevant circumstances." Id. (quoting United States v. Lee, 834 F.3d 145, 159 (2d Cir. 2016)). When a disclosure merely lists general topics on which the expert might testify, the Second Circuit has several times held that the district court has discretion to exclude the expert entirely. See id. at 118; United States v. Vaccarelli, No. 20-3768-CR, 2021 WL 4805218, at \*2 (2d Cir. Oct. 15, 2021). + +# II. Discussion + +As a preliminary matter, the Defense argues that the Government's motion is "premature" because the Government's arguments are about the relevance and prejudice of the witnesses' testimony, not their qualifications or the reliability of their methods under Rule 702. + +Def. Br. at 1, 5–6. But one aspect of the Rule 702 and *Daubert* inquiry is “fit,” which asks “whether expert testimony proffered in the case is sufficiently tied to the facts of the case that it will aid the jury in resolving a factual dispute.” *Alto v. Sun Pharm. Indus., Inc.*, No. 1:19-CV-09758 (GHW), 2021 WL 4803582, at \*3 (S.D.N.Y. Oct. 13, 2021) (quoting *Daubert*, 509 U.S. at 591). Fit is satisfied if the expert’s opinion would assist the jury’s decision on a relevant question of fact without “usurp[ing] either the role of the trial judge in instructing the jury as to the applicable law or the role of the jury in applying that law to the facts before it.” *Id.* (quoting *United States v. Duncan*, 42 F.3d 97, 101 (2d Cir. 1994)). The Court finds that at least some of the Government’s arguments that go to fit are ripe for preliminary resolution now. Other aspects of the Government’s motion can be resolved only with additional information and the context of trial. + +**A. The Court will preclude the expert testimony of Dr. Ryan Hall** + +The Government moves to preclude the expert testimony of Dr. Ryan Hall. Dr. Hall was retained [REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] The Defense anticipates that Dr. Hall will testify as to approximately four opinions. First, “[h]e will offer the opinions and diagnoses contained in his report.” Notice at 12. Second, he will testify on “the bases for those opinions[ ] and the significance of the diagnoses and opinions.” *Id.* Third, “[h]e will testify about the facts and circumstances surrounding the evaluation” and “disclosures made [Alleged Victim 4].” *Id.* And fourth, he will testify to “the fact that [Alleged Victim 4] did not identify Ms. Maxwell as a perpetrator of any abuse.” *Id.* + +The Government argues, and the Court agrees, that the first two opinions based on Dr. Hall's training and experience as a psychiatrist and so are expert opinions subject to Rule 702. The latter two opinions are not expert opinions but instead testimony of fact that may or may not be admissible under other rules of evidence. + +The Court will address the expert opinions first. The Government argues that Dr. Hall's testimony on psychological diagnoses is irrelevant and prejudicial under Rules 401 and 403. The Second Circuit has set out controlling case law to guide the Court's decision: + +Evidence of a witness's psychological history may be admissible when it goes to her credibility. In assessing the probative value of such evidence, the court should consider such factors as the nature of the psychological problem, the temporal recency or remoteness of the history, and whether the witness suffered from the problem at the time of the events to which she is to testify, so that it may have affected her ability to perceive or to recall events or to testify accurately. + +United States v. Sasso, 59 F.3d 341, 347-48 (2d Cir. 1995) (cleaned up); see also United States v. Hamlett, No. 19-3069, 2021 WL 5105861, at ■2 **(2d Cir. Nov. 3, 2021);** United States v. Vitale, 459 F.3d 190, 196 (2d Cir. 2006). + +Even if psychological history is probative according to these factors, the Court still retains discretion to exclude the evidence if it is substantially prejudicial under Rule 403. Sasso, 59 F.3d at 347-48. + +Dr. Hall's report lists the following + +The Court will preclude Dr. Hall's testimony on these psychological diagnoses. + +Applying the considerations in Sasso, the diagnoses have little probative value. First, the report is now over 12 years old. Courts in this circuit regularly find that diagnoses more than 10 years old lack probative value. E.g., United States v. Bari, 750 F.2d 1169, 1179 (2d Cir. 1984) (finding that more than 10 years is too remote); United States v. Glover, 588 F.2d 876, 878 (2d Cir. 1978) (per curiam) (12 years too remote); United States v. Dupree, 833 F. Supp. 2d 255, 264 (E.D.N.Y. 2011), vacated and remanded on other grounds, 706 F.3d 131 (2d Cir. 2013) (13 years too remote); United States v. Paredes, No. 99-CR-290 (PKL), 2001 WL 1478810, at \*1 (S.D.N.Y. Nov. 20, 2001) ("A psychological condition from ten years earlier, however, is likely to be irrelevant."). The diagnoses are therefore too remote to bear on Alleged Victim 4's credibility as a witness at trial. + +Second, the nature of the conditions and their effect on memory or perception at the time of the events in question do not favor admission. Dr. Hall's report does not delineate clearly which conditions existed at the time of Epstein's abuse, but it appears that at least + +But at no point in his report does Dr. Hall suggest that these conditions—or any other diagnosed conditions—may have affected Alleged Victim 4's perception of events or her recollection of those events. Like in Sasso, "there was no indication that [the witness] was delusional or paranoid, or had any difficulties in memory or perception." 59 F.3d at 348. + +In its response, the Defense homes in first + +[REDACTED] + +[REDACTED] + +[REDACTED] But none of these traits affect memory or recall, which is the primary purpose for admitting evidence of mental conditions identified in *Sasso*, 59 F.3d at 348. + +The Defense also emphasizes the diagnosis for [REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] But based on the current record, Dr. Hall's description falls short of demonstrating that this [REDACTED] "affect[s] her ability to perceive or to recall events or to testify accurately." *Vitale*, 459 F.3d at 196 (quoting *Sasso*, 59 F.3d at 348); see *United States v. Lopez*, 611 F.2d 44, 45 (4th Cir. 1979) ("[M]any psychiatric problems . . . which a witness may have had are without any relevancy to the witness' credibility, concerned as it is with whether the witness' mental impairment is related to his capacity to observe the event at the time of its occurrence, to communicate his observations accurately and truthfully at trial, or to maintain a clear recollection in the meantime." (cleaned up)). [REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +The Defense also argues that Dr. Hall diagnosed Alleged Victim 4 with [REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] In a similar line of cases, courts in + +this circuit have held that expert diagnoses of depression are not probative of credibility. *E.g.*, *Sasso*, 49 F.3d at 348 (finding that a diagnosis of depression lacked probative value); *United* + +States v. Giovinco, No. 18-CR-14 (JSR), 2020 WL 832920, at \*2 (S.D.N.Y. Feb. 20, 2020) (finding that depression did not impact the witness's "ability to accurately perceive or recall" relevant events); see also United States v. Cooper, No. 15-CR-152 (RMC), 2017 WL 11496709, at \*1 (D.D.C. Jan. 27, 2017) (excluding diagnosis of major depressive disorder). + +Last, the Defense points to the diagnosis Lot1 1 + +hut, again, this is not a basis for impeaching Alleged Victim 4's ability to testify truthfully under Sasso. 59 F.3d at 348; see also Hernandez v. Kelly, No. 09 CV 1576 TLM LB, 2011 WL 2117611, at \*5 (E.D.N.Y. May 27, 2011) (explaining that a condition must "bear[ ] on [a witness's] ability to rationally perceive events at the time and to accurately recollect and report his perceptions"). + +In assessing the relevance of each of these diagnoses, the Court also takes account of Dr. Hall's conclusion that despite her several conditions, Alleged Victim 4 has no "psychotic believes [sic], hallucinations or delusions." Report at 92; see also id. at 80 ("she reports no period of... hallucinations"). Further, Dr. Hall several times commented that Alleged Victim 4's memory was very accurate. E.g., id. at 85 ("No . . . alterations in memory, or changes in orientation or level of attention."); 92 ("Her memory was impeccable and at multiple times during the evaluation she pointed out to the examiner questions he did or didn't ask. She reported her memory is `perfect' and that she will remember every detail of the room in which the evaluation was done." (emphases in original)). On review, the Court cannot identify any point in the report at which Dr. Hall doubts Alleged Victim 4's account of events. Instead, he appears to summarize and accept her story of sexual conduct with Epstein. Id. at 100-01. In short, none of + +the diagnoses in Dr. Hall's report are adequately tied to Alleged Victim 4's credibility as a witness. See Hamlett, 2021 WL 5105861, at \*2. + +Even if any diagnosis were probative, the Court further finds that Rule 403 prejudice outweighs. First, the testimony may confuse jurors with old diagnoses that have little connection to the conduct at issue or Alleged Victim 4's credibility today. See id. Confusion is particularly likely here given that Dr. Hall's report is at times unclear and even contradictory, as with the confusion ove OM= explained above. Id. Second, the Court takes account of the risk that jurors will stereotype a witness with r incorrectly assume that a diagnosed mental condition renders the witness untrustworthy. See Hernandez, 2011 WL 2117611, at \*5. Third, mental health diagnoses are of a particularly sensitive nature and, if not relevant, the witness's privacy should not be invaded. Paredes, 2001 WL 1478810, at \*2 (citing In re Doe, 964 F.2d 1325,1328-29 (2d Cir. 1992)). + +And fourth, Dr. Hall's testimony would be cumulative and cause undue delay. The Government anticipates that several aspects of Alleged Victim 4's mental health history will be admitted either on direct or cross-examination, including that Alleged Victim 4 currently The Second Circuit has previously held that where relevant issues of mental conditions can be aired on cross-examination, the district court may preclude the witness's medical records and expert testimony. Vitale, 459 F.3d at 196; Dupree, 833 F. Supp. 2d at 265 (applying Vitale and Sasso). The Court concludes that here, the cross-examination identified by the Government on Alleged Victim 4's current medication fo along with lines of cross-examination unrelated to mental health, will provide the jury a sufficiently "discriminating appraisal" of Alleged Victim 4's credibility such that Dr. Hall's testimony and report is unnecessary. Drake v. + +Woods, 547 F. Supp. 2d 253, 266-67 (S.D.N.Y. 2008) (quoting United States v. Roldan-Zapata, 916 F.2d 795, 806 (2d Cir. 1990)). The Court therefore concludes that the minimal probative value of each of Dr. Hall's diagnoses of Alleged Victim 4 is substantially outweighed by the risk of unfair prejudice. + +But this balancing of Rules 401 and 403 is based on the present record. It is conceivable that an additional proffer from the Defense that raises the probative value of a diagnosis, such as that frina would change the Court's calculation. Cf. George, 532 F.3d at 937 ("We do not foreclose the possibility that testimony by an expert ... could have shown evidence of [the witness's] condition to be relevant to her credibility . . . . But without such testimony, [defense] counsel had only words such as 'episodes of rage' and `racing thoughts."); Hamlett, 2021 WL 5105861, at \*2 (affirming exclusion of a psychological witness that failed to show a "clear link between any particular mental health diagnosis and a witness's credibility"). + +The Defense argues that apart from diagnoses of her mental health conditions, the Defense should be permitted to admit Dr. Hall's conclusion as to Alleged Victim 4's substance abuse Def. Br. at 12-13 (collecting cases). The Second Circuit instructs: + +It is, of course, within the proper scope of cross-examination to determine whether a witness was under the influence of drugs or narcotics or alcohol at the time of observation of events in dispute or at the time the witness is testifying. As Wigmore points out, however, a general habit of intemperance tells us nothing of the witness's testimonial incapacity unless it involves actual intoxication at the time of the event observed or at the time of testifying. + +United States v. DiPaolo, 804 F.2d 225, 229-30 (2d Cir. 1986) (cleaned up) (cited in Gov't Br. at 11 and Def. Br. at 12); accord United States v. Robinson, 583 F.3d 1265, 1272 (10th Cir. 2009) ("Illegal drug use does not merely bear on the [confidential informant's] veracity but also on his capacity as a witness."). + +The Court will therefore permit the Defense to cross-examine Alleged Victim 4 about her use of substances during and after the conduct in question. Indeed, the Court was already under the impression that the Defense intended to pursue this line of cross-examination after the Dauber! hearing. Nov. 10 Tr. at 157 ("[D]o you intend to impeach any witnesses based on substance abuse? ... Yes."). + +But the extensive case law cited by the Defense about cross-examining witnesses on their substance use does not justify the request to admit Dr. Hall's testimony on substance use and + +For example, in United States v. Vitale, the district court gave the defense "wide latitude when cross-examining [the witness] about his drug use and rehabilitation, including questions about the effects that the drugs had on his ability to perceive events when they occurred as well as on his memory at the time of trial." 459 F.3d at 196. The district court did not, however, permit the defense to admit the witness's drug rehabilitation treatment records into evidence. Id. Citing Sasso, the Second Circuit affirmed, explaining that through crossexamination alone, "the jury was well aware of... [the witness's] drug abuse and treatment history." Id. The Second Circuit has made such a distinction—permitting cross-examination on drug use but excluding a formal diagnosis ofilM—in several cases. E.g., DiPaolo, 804 F.2d at 230; Dobson v. Walker, 150 F. App'x 49,52 (2d Cir. 2005) (explaining that crossexamination about a witness's drug use before witnessing a murder would be admissible, but the general fact that the witness uses drugs is not). The Defense does not cite any case law to the contrary. Even the nonbinding authority that the Defense refers to as "instructive," Def. Br. at 13, held only that a defendant had the right to review a witness's medical records and crossexamine the witness about his drug use, Robinson, 583 F.3d at 1271-75. + +In addition to diagnosing Alleged Victim 4's mental conditions, Dr. Hall also concluded tha + +The Government moved to exclude this conclusion and the Defense does not make a case for admitting it. The Court will also preclude the opinion. In this circumstance, the lasting mental impact of a crime is at best "minimally probative" of whether that crime was committed. United States v. Hendricks, 921 F.3d 320, 329 (2d Cir. 2019). It also carries a high risk of Rule 403 prejudice by suggesting that the psychological impact on Alleged Victim 4 is relevant to Ms. Maxwell's guilt beyond a reasonable doubt. It would also cause substantial delay by opening the door to rebuttal evidence by the Government on Alleged Victim 4's mental health, which would likely lead to mini-trials on irrelevant issues. + +Next, the disclosure states that Dr. Hall will testify to the "significance" of Alleged Victim 4's diagnoses. Notice at 12. First, the Court understands that Dr. Hall could not testify to the "significance" of mental health diagnoses without first testifying to what those diagnoses are. Because the Court is precluding Dr. Hall's testimony on Alleged Victim 4's diagnoses, the Court will also preclude Dr. Hall's testimony on their significance. Additionally, the current disclosure on this point does not satisfy Rule 16's requirement that the Defense provide Dr. Hall's opinion rather than just the general topic of the testimony. Even if the Court admitted Dr. Hall's testimony as to Alleged Victim 4's diagnoses, the Court would preclude his testimony on significance until more specific opinions are disclosed to the Government. + +Next, the Defense anticipates that Dr. Hall will testify to the "bases for those opinions" in his report. Id. Dr. Hall's report refers not only to what Alleged Victim 4 told him during their in-person interview but also other records like + +E.g., Report at 29- + +63. These out of court statements would be hearsay if admitted for their truth, and so are presumptively inadmissible at trial. Fed. R. Evid. 802. The Defense identifies several means by which it may admit these hearsay statements. Def. Br. at 14-17. + +First, "[u)nder Rule 703, experts can testify to opinions based on inadmissible evidence, including hearsay, if `experts in the field reasonably rely on such evidence in forming their opinions!" United States v. Mejia, 545 F.3d 179, 197 (2d Cir. 2008). But Rule 703 does not permit an expert to "simply transmit that hearsay to the jury." Id. Rather, those underlying facts and data that would otherwise be inadmissible may be disclosed to the jury "if their probative value in helping the jury evaluate the opinion substantially outweighs their prejudicial effect." Fed. R. Evid. 703. Here, the hearsay underlying Dr. Hall's diagnoses, including would have little probative value unless the I + +Government were to challenge the accuracy of Dr. Hall's diagnoses. See United States v. Chai, No. 13-CR-290 (PAC), 2015 WL 293995, at \*3 (S.D.N.Y. Jan. 22, 2015). The Government represents in its brief that it would not do so in the event that Dr. Hall's diagnoses are admitted. Gov't Br. at 13. And admitting the underlying hearsay, without a relevant need to substantiate the accuracy of Dr. Hall's conclusions, would result in significant prejudice, including confusing the jury and delaying the trial with a large volume of unnecessary details. The Court therefore concludes that, based on the parties' current proffers, the facts and data underlying Dr. Hall's opinions are not admissible via Rule 703. + +Second, the Defense says that Alleged Victim 4's statements are admissible under one of two hearsay exceptions in Rule 803. Def. Br. at 15. It says the statements were statements of her "then-existing state of mind ... or emotional, sensory, or physical condition." Fed. R. Evid. 803(3). But while a number of Alleged Victim 4's statements to Dr. Hall may pertain to motives + +or emotional condition, her statements made to Dr. Hall irillEabout events that took place years earlier cannot be said to be "then-existing." Id. The Defense also says Alleged Victim 4's statements were "made for medical diagnosis or treatment." Fed. R. Evid. 803(4). The Court finds that this may be a permissible basis for admitting some of Alleged Victim 4's statements, though they must be "made for ... medical diagnosis or treatment," must "describe[ ] medical history; past or present symptoms or sensations; their inception; or their general cause," and must otherwise satisfy Rules 401 and 403. Fed. R. Evid. 803(4)(A), (B); see In re Agent Orange Prod. Liab. Litig., 611 F. Supp. 1223, 1245-46 (E.D.N.Y. 1985), aff'd sub nom., 818 F.2d 187 (2d Cir. 1987) (Weinstein, C.J.).' But without additional detail from the Defense on which portions of Dr. Hall's testimony it would seek to admit under this exception, the Court cannot make a definitive ruling. + +The Defense does not mention Alleged Victim 4'sa cited by Dr. Hall in his report. The Court concludes that Alleged Victim 4's are inadmissible under Federal Rule of Evidence 609. Dr. Hall's report is not clear on the details of Alleged Victim 4's These incidents, however, are now all over 10 years old, none appear to require proving "a dishonest act or false statement," and, fo admitting the evidence is not necessary to fairly determine the guilt or innocence of Ms. Maxwell. Fed. R. Evid. 609 (a), (b), (d). + +&#x27; The Defense also argues that Alleged Victim 4's statements would be "admissible for their effect on Dr. Hall in forming his opinion." Def. Br. at 15. But, like Rule 703, this justification is a relevant basis for admission only if the validity of Dr. Hall's diagnoses is put in question. + +### B. The Court reserves Judgment on the admissibility of Dr. Hall's fact testimony + +Finally, two of Dr. Hall's anticipated opinions are fact testimony not subject to Rule 702. Specifically, Dr. Hall would testify that Alleged Victim 4 told him that she previously disclosed other sexual abuse to a prior mental health provider but did not disclose abuse by Epstein ton.. Def. Br. at 16.2 Further, Dr. Hall would testify that in their interview Alleged Victim 4 "did not identify Ms. Maxwell as a perpetrator of any abuse." Notice at 12. The Defense argues these statements are admissible as prior inconsistent statements. Def. Br. at 16-17. The Government concedes that Dr. Hall's testimony here would be admissible, including potentially as a prior inconsistent statement, if relevant and not otherwise excludable. Gov't Br. at 16, 18. + +The Court reserves judgment on this question, but provides this guidance. The Defense will cross-examine Alleged Victim 4 and, as the Court has previously ruled, it may ask whether Alleged Victim 4 on previous occasions implicated Ms. Maxwell in the alleged sexual abuse by Epstein. Nov. 1 Tr. at 27. Whether the Defense may then admit any of Dr. Hall's testimony will depend on Alleged Victim 4's response to that question, whether any prior statement is actually "inconsistent" with her response, see United States v. Trzaska, 111 F.3d 1019,1024-25 (2d Cir. 1997) (reversing a district court's admission of prior statements that were not inconsistent), and whether the Defense satisfies the other requirements of admitting extrinsic evidence of a prior inconsistent statement under Federal Rule of Evidence 613. + +2 From the parties' briefing, the Court understand the efense would not seek to admit Dr. Hall's testimony about what Alleged Victim 4 told for the truth of the matter asserted, as that would be hearsay with no a parent exception. See Def. Br. at 16 (referring to Alleged Victim 4's statements t and stating It]his evidence is admissible as a prior inconsistent statement"). Even then, however, the Court is skeptical that a situation would arise in which this statement could be used to contradict Alleged Victim 4' testimony without assuming the statement's truth. + +### **III. Conclusion** + +The Court therefore grants the Government's motion to preclude Dr. Hall's expert testimony. Because this is a preliminary pre-trial ruling, it is possible that facts and circumstances at trial would alter the Court's analysis. In that event, the Defense must re-raise its request to admit Dr. Hall as an expert witness. + +SO ORDERED. + +Dated: November 22, 2021 + +New York, New York + +![]() + +--- + +ALISON J. NATHAN +United States District Judge \ No newline at end of file diff --git a/marker2/ds9/EFTA00089904/EFTA00089904.metadata.json b/marker2/ds9/EFTA00089904/EFTA00089904.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..398a56d98b833bf0778b23cfc7768fdbea4d0753 --- /dev/null +++ b/marker2/ds9/EFTA00089904/EFTA00089904.metadata.json @@ -0,0 +1,719 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089904.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 17, + "chars": 28011, + "elapsed_seconds": 8.52, + "image_assets": [ + "_page_0_Picture_5.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 71.28 + ], + [ + 281.019775390625, + 71.28 + ], + [ + 281.019775390625, + 99.603515625 + ], + [ + 68.544, + 99.603515625 + ] + ] + }, + { + "title": "I. 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0000000000000000000000000000000000000000..98528f0e98edbff0ee36430f6cda0a3ccf48d5bb --- /dev/null +++ b/marker2/ds9/EFTA00089904/_page_0_Picture_5.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:3f1b7d8c3b84670740ce744fccd8a34d914b9bcc65488845517a412b67d8f8f0 +size 12426 diff --git a/marker2/ds9/EFTA00089921/EFTA00089921.md b/marker2/ds9/EFTA00089921/EFTA00089921.md new file mode 100644 index 0000000000000000000000000000000000000000..ba18a5f9ca9fe1908c7fc81e54535b1fa76862bf --- /dev/null +++ b/marker2/ds9/EFTA00089921/EFTA00089921.md @@ -0,0 +1,46 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +United States of America, + +—v— + +Ghislaine Maxwell, + +Defendant. + +| USDC SDNY | | +|----------------------|----------| +| DOCUMENT | | +| ELECTRONICALLY FILED | | +| DOC #: | | +| DATE FILED: | 11/24/21 | + +20-CR-330 (AJN) + +ORDER + +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. + +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 . + +SO ORDERED. + +Dated: November 24, 2021 +New York, New York + +![]() + +--- + +ALISON J. NATHAN +United States District Judge \ No newline at end of file diff --git a/marker2/ds9/EFTA00089921/EFTA00089921.metadata.json b/marker2/ds9/EFTA00089921/EFTA00089921.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..716b34daa832f590643676d186411039dd0c74c2 --- /dev/null +++ b/marker2/ds9/EFTA00089921/EFTA00089921.metadata.json @@ -0,0 +1,128 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089921.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 3161, + "elapsed_seconds": 6.23, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 72.08999999999999 + ], + [ + 281.019775390625, + 72.08999999999999 + ], + [ + 281.019775390625, + 99.603515625 + ], + [ + 68.544, + 99.603515625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 65 + ], + [ + "Line", + 33 + ], + [ + "Text", + 11 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "SectionHeader", + 1 + ], + [ + "Form", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 47 + ], + [ + "Line", + 24 + ], + [ + "Text", + 10 + ], + [ + "PageFooter", + 4 + ], + [ + "PageHeader", + 2 + ], + [ + "Caption", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089921" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089923/EFTA00089923.md b/marker2/ds9/EFTA00089923/EFTA00089923.md new file mode 100644 index 0000000000000000000000000000000000000000..9e0fa682171d91109c2d02d8ade6a4305abcb394 --- /dev/null +++ b/marker2/ds9/EFTA00089923/EFTA00089923.md @@ -0,0 +1,194 @@ +UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +UNITED STATES OF AMERICA + +TOVA NOEL and MICHAEL THOMAS, + +Defendants. + +X + +#### INDICTMENT + +109CRIM 830 + +# INTRODUCTION + +1. On or about August 10, 2019, TOVA NOEL and MICHAEL THOMAS, the defendants, in dereliction of their duties as correctional officers at the Metropolitan Correctional Center ("MCC"), repeatedly failed to perform mandated counts of prisoners under their watch in the MCC's Special Housing Unit ("SHU"). Instead, for substantial portions of their shifts, NOEL and THOMAS sat at their desk, browsed the Internet, and moved around the common area of the SHU. To conceal their failure to perform their duties, NOEL and THOMAS repeatedly signed false certifications attesting to having conducted multiple counts of inmates when, in truth and in fact, they never conducted such counts. As a result of those false statements, the MCC believed prisoners in the SHU were being regularly monitored and accounted for when, in fact, as a result of the defendants' conduct, no correctional officer conducted any count or round of the SHU from approximately 10:30 p.m. on August 9 until approximately 6:30 a.m. on August 10, at which time, as alleged herein, NOEL and THOMAS discovered the body of an MCC inmate, Jeffrey Epstein, who bad committed suicide overnight while unobserved. + +#### RELEVANT INDIVIDUALS AND ENTITIES + +2. The MCC is afederal administrative detention facility located in Manhattan that is run by the Federal Bureau of Prisons ("BOP"). The MCC is one of several facilities used to house inmates who have been charged with federal crimes in the Southern District of New York and are awaiting trial. The MCC employs correctional officers, whose primary duty is to ensure the care, custody, and control of the inmate population of the MCC. + +3. TOVA NOEL, the defendant, has been employed as a correctional officer at the MCC since approximately 2016. As of August 2019, NOEL's primary assignment was the SHU. On August 9, 2019, NOEL worked a regular shift from 4 p.m. to 12 a.m. in the SHU, and then worked an overtime shift from 12 a.m. to 8 a.m. on August 10, 2019, also in the SHU. NOEL had also worked a regular shift in the SHU the day before, August 8, 2019, from 12 p.m. to 8 p.m. + +4. MICHAEL THOMAS, the defendant, has been employed as acorrectional officer at the MCC since approximately 2007. Beginning in approximately 2013, THOMAS was assigned to work as a materials handler supervisor, although THOMAS regularly worked overtime shifts as acorrectional officer, including in the SHU. THOMAS worked an overtime shift in the SHU on August 10, 2019, from 12 a.m. to 8 a.m. THOMAS did not work his regular shift on August 8 or August 9, 2019, but did work an overtime shift in the SHU on August 9, 2019 from 12 a.m. to 8 a.m. + +5. As detailed herein, Jeffrey Epstein was incarcerated at the MCC between his arrest on July 6, 2019, and his suicide on August 10, 2019. Epstein was detained pending trial in the Southern District of New York on sex trafficking charges. + +#### THE MCC AND INSTITUTIONAL COUNTS + +6. The MCC, which houses approximately 750 inmates at any given time, assigns inmates to various housing units within the MCC. The SHU is a housing unit within the MCC where inmates are securely separated from the general inmate population to ensure their own safety as well as the safety of staff and other inmates. The SHU is located on the ninth floor of the MCC, and access to that floor is controlled by a locked door that can be opened remotely only by an officer in the MCC's centralized control center (the "Control Center"), which is located on the first floor of the MCC. Access into the SHU is also controlled by a second locked door to which only correctional officers assigned to the SHU have keys while on duty. Within the SHU, inmates are assigned to six separate tiers, each of which can be accessed only via a single locked door to which the correctional officers assigned to the SHU have keys while on duty. Each tier has eight cells, each of which can house either one or two prisoners, and each individual cell which is made of cement and metal - is accessed only through a single locked door, to which only correctional officers assigned to the SHU have keys while on duty. + +7. The BOP requires correctional officers assigned to guard inmates at the MCC to conduct institution-wide counts of inmates at regular, scheduled intervals to ensure that each inmate is alive and accounted for within the MCC (the "institutional count"). On weekdays, the MCC conducts five institutional counts at 4 p.m., 10 p.m., 12 a.m., 3 a.m., and 5 a.m. Performing an institutional count is one of the most basic and essential aspects of acorrectional officer's job, and the count is one of the most basic and essential functions of daily operation of the MCC. Two officers are required to perform the institutional count for each housing unit, including the SHU, and are further required to document their performance of the count on an official MCC form called acount slip. To perform the institutional count in the SHU, two officers must walk from tier to tier to observe and count each individual inmate. + +8. On the count slip, both correctional officers are required to fill in the date and time the count was performed, write the total number of inmates physically present in the unit counted, and then sign the count slip. Once the correctional officers have completed and signed the count slips, the count slips ' are then collected and delivered to the Control Center, where officers within the Control Center are responsible for comparing the count slips from each housing unit to the institution's inmate roster to ensure that each inmate is accounted for. Only after all the count slips are collected from each housing unit, and the numbers on the slips are matched to the institution's inmate roster, can the institutional count be deemed "cleared" or completed. If a housing unit's count slip is incorrect or incomplete, then the institution cannot "clear" the count. Instead, the count must be completely redone in that housing unit via amore-intensive version of the institutional count called a "bed book count," in which officers must compare every individual inmate to the institution's inmate roster. Records of each institutional count, including the count slips, are provided to a supervising official and retained by the MCC. + +9. In addition to the institutional count, the BOP requires correctional officers assigned to the SHU to walk each of the tiers of the SHU - which is called a"round" - every thirty + +minutes ("30-minute rounds"). Like the institutional counts, correctional officers conduct 30-minute rounds to ensure that each inmate is alive and accounted for within his cell. Correctional officers working in the SHU are required to complete a form, which is reviewed and signed by their supervisor, documenting the date and time of each 30-minute round in each tier of the SHU. + +## EPSTEIN'S PRIOR APPARENT SUICIDE ATTEMPT + +10. On July 6, 2019, inmate Jeffrey Epstein was arrested and detained at the MCC on sex trafficking charges. On July 10, 2019, Epstein was assigned to the SHU due to, among other things, risk factors for suicidality and safety concerns relating to housing him with the MCC's general population. + +11. On July 23, 2019, while Epstein was housed in the SHU, MCC officers responded to an emergency call, and found Epstein on the floor of his cell with a strip of bedsheet around his neck. MICHAEL THOMAS, the defendant, was one of the MCC officers who responded to the incident. Epstein was subsequently transferred out of the SHU and was placed on suicide watch. Inmates placed on suicide watch are housed in a cell on the hospital wing floor of the MCC, and are watched twenty-four hours a day by a staff member or a specially trained inmate companion. + +12. Epstein remained on suicide watch for approximately twenty-four hours, and then was transferred to psychological observation, until July 30, 2019. Psychological observation is less restrictive than suicide watch, but inmates are still housed in the hospital wing of the MCC and watched twenty-four hours a day. + +13. On July 30, 2019, Epstein was transferred back to the SHU, and, at the direction of the MCC's psychological staff, was required to have an assigned cellmate. Epstein was also assigned to the cell closest to the correctional officers' desk in the common area of the SHU, which was approximately fifteen feet from the cell. Conducting the required institutional counts and thirty-minute rounds in the SRO were also part of the MCC's procedures for ensuring the safety of inmates, including Epstein. + +#### EVENTS OF AUGUST 9-10, 2019 + +14. On August 9, 2019, Epstein's cellmate was transferred out of the MCC in a routine, pre-arranged transfer at approximately 8 a.m. Despite the MCC's psychological staff's direction that Epstein have a cellmate, no new cellmat6 was assigned to Epstein's cell. + +15. TOVA NOEL, the defendant, was one of the assigned officers on duty in the SHU from 4 p.m. on August 9, 2019 to 8 a.m. on August 10. From 4 p.m. to 12 a.m., two other officers were on duty with NOEL in the SHU: one officer was assigned to work from 2 p.m. to 10 p.m. ("Officer-1"), and one officer was assigned to work from 4 p.m. to 12 a.m. ("Officer-2"). MICHAEL THOMAS, the defendant, started his shift in the SHU at 12 a.m. on August 10. From 12 a.m. until 8 a.m. on August 10, NOEL and THOMAS were the only two officers on duty in the SHU. + +16. During the time period from 4 p.m. on August 9 to 8a.m. on August 10, the officers on duty in the SHU, including TOVA NOEL and MICHAEL THOMAS, the defendants, were responsible for conducting five institutional counts: 4 p.m. and 10 p.m. on August 9; and 12 a.m., 3 a.m., and 5 a.m. on August 10. NOEL, THOMAS and the other officers on duty were also responsible for completing paperwork attesting to each of those counts. While, as detailed herein, count slips were completed for each institutional count, in fact, not a single one of those institutional counts was done. + +17. TOVA NOEL, the defendant, and Officer-1 were responsible for conducting the 4 p.m. institutional count in the SHU. As video from the MCC's internal video surveillance system makes clear, NOEL and Officer-1 did not perform the 4 p.m. count. Nonetheless, NOEL and Officer-1 completed and signed acount slip that falsely stated that the 4 p.m. institutional count had been performed. In reliance on that falsified count slip, at approximately 5:03 p.m., the Control Center cleared the 4 p.m. count. + +18. That evening, Epstein returned to the SHU from his attorney visit and was escorted into his cell by TOVA NOEL, the defendant, and another officer at approximately 7:49 p.m. NOEL and the other officer left the tier in which Epstein was housed immediately thereafter. + +19. By or before 10 p.m., all inmates in the MCC were locked in their cells for the night. At or around that time, TOVA NOEL, the defendant, and Officer-2 were responsible for conducting the 10 p.m. institutional count in the SHU. However, video from the MCC's internal video surveillance system shows that NOEL and Officer-2 did not perform the 10 p.m. count. Nonetheless, NOEL and Officer-2 completed and signed a count slip falsely stating that the 10 p.m. institutional count had been performed. In reliance on that falsified count slip, at approximately 10:36 p.m., the Control Center cleared the 10 p.m. count. + +20. As reflected on video obtained from the MCC's internal video surveillance system, at approximately 10:30 p.m. on August 9, 2019 - after TOVA NOEL, the defendant, had signed and submitted the 10 p.m. count slip and the institutional count had been completed - NOEL briefly walked up to, and then walked back from, the door to the tier in which Epstein was housed. As confirmed by the video obtained from the MCC's internal video surveillance system, this was the last time anyone, including any correctional officer, walked up to, let alone entered, the only entrance to the tier in which Epstein was housed until approximately 6:30 a.m. on August 10. + +21. Officer-l's shift ended at approximately 10 p.m., and at approximately 12 a.m., MICHAEL THOMAS, the defendant, replaced Officer-2, joining TOVA NOEL, the defendant, as the only two correctional officers on duty in the SHU. NOEL and THOMAS were responsible for conducting the 12 a.m. institutional count in the SHU. As confirmed by video from the MCC's internal video surveillance system, NOEL and THOMAS did not perform the 12 a.m. count. Nonetheless, NOEL and THOMAS completed and signed a count slip for the 12 a.m. count that falsely stated that the institutional count had been performed. In reliance on that falsified count slip, at approximately 12:49 a.m., the Control Center cleared the 12 a.m. count. + +22. TOVA NOEL and MICHAEL THOMAS, the defendants, were additionally responsible for conducting the 3 a.m. and 5 a.m. institutional counts in the SHU. As confirmed by video from the MCC's internal video surveillance system, NOEL and THOMAS did not perform either the 3 a.m. or the 5 a.m. counts. NOEL and THOMAS nonetheless completed and signed count slips for both counts that falsely stated that they had performed the 3 a.m. and 5 a.m. institutional counts. In reliance on those falsified count slips, + +at approximately 3:24 a.m. and 5:30 a.m., the Control Center cleared the 3 a.m. and 5 a.m. counts, respectively. + +23. Moreover, despite the requirement that officers on duty in the SHU conduct and document regular, 30-minute rounds, TOVA NOEL and MICHAEL THOMAS, the defendants, did not perform any of the required 30-minute rounds during their shift between approximately 12 a.m. and 6:30 a.m. Nonetheless, NOEL completed and signed more than 75 separate 30-minute round entries falsely affirming that they had, in fact, conducted such rounds. + +24. During the night, instead of completing the required counts and rounds, TOVA NOEL and MICHAEL THOMAS, the defendants, were seated at the correctional officers' desk in the SHU common area (as noted above, approximately 15 feet from Epstein's cell), used the computers, and moved around the SHU common area. For a period of approximately two hours, NOEL and THOMAS sat at their desk without moving, and appeared to have been asleep. NOEL used the computer periodically throughout the night, including to search the Internet for furniture sales and benefit websites. THOMAS used the computer briefly around 1 a.m., 4 a.m., and 6 a.m. to search for motorcycle sales and sports news. + +25. At approximately 4 a.m., the overnight supervisor briefly visited NOEL and THOMAS in the SHU, and conferred with NOEL and THOMAS, who were seated at and around the officers' desk, before leaving. At approximately 5:30 a.m., another correctional officer briefly walked through the SHU common area. Aside from those two officers, as confirmed by video surveillance, no one else entered the SHU, no one conducted any counts or rounds throughout the night, and no one entered the tier in which Epstein was housed. + +26. Shortly after 6 a.m. on August 10, 2019, MICHAEL THOMAS and TOVA NOEL, the defendants, received a delivery of breakfast carts into the SHU, after which time they were again the only officers in the SHU. Shortly after 6:30 a.m., NOEL and THOMAS walked up to and entered the tier in which Epstein was housed to serve breakfast. At approximately 6:33 a.m., an alarm was activated in the SHU. Epstein was alone in his cell and not responsive, with anoose around his neck. A supervisor who had just started his shift ("Supervisor-1") responded to the alarm almost immediately thereafter, and as NOEL approached the door to the SHU to open the door for Supervisor-1, NOEL told Supervisor-1 that "Epstein hung himself." After arriving in the SHU, Supervisor-1 spoke with THOMAS and NOEL. NOEL told Supervisor-1 we did not complete the 3 a.m. nor 5 a.m. rounds." THOMAS stated, we messed up," and "I messed up, she's not to blame, we didn't do any rounds." + +27. Epstein was transferred to alocal hospital where he was declared dead shortly thereafter. The Office of the Chief Medical Examiner of the City of New York conducted an autopsy and determined that Epstein had committed suicide by hanging himself. + +#### STATUTORY ALLEGATIONS + +### COUNT ONE (Conspiracy) + +The Grand Jury charges: + +28. The Grand Jury incorporates the allegations contained in paragraphs 1 through 27 of this Indictment as though fully set forth herein. + +29. In or about August 2019, in the Southern District of New York, TOVA NOEL and MICHAEL THOMAS, the defendants, knowingly conspired with each other to: + +a. Knowingly defraud the United States by impairing, obstructing, and defeating the lawful functions of a department or agency of the United States, to wit, the MCC's function to ensure the care, custody, and control of its inmate population. + +b. Knowingly make and use a false writing or document knowing the same to contain a materially false, fictitious, and fraudulent statement and entry with the intent to impede, obstruct, or influence the investigation or proper administration of any matter within the jurisdiction of any department or agency of the United States, in violation of Title 18, United States Code, Section 1001 (a)(3). + +30. In furtherance of the conspiracy and to effect the illegal objects thereof, TOVA NOEL and MICHAEL THOMAS, the defendants, committed the following overt acts, among others, in the Southern District of New York: + +a. On August 10, 2019, NOEL and THOMAS falsely certified, on an MCC count slip, that they had performed the 12 a.m. institutional count of the SHU, when they had not in fact done so. + +b. On August 10, 2019, NOEL and THOMAS falsely certified, on an MCC count slip, that they had performed the 3 a.m. institutional count of the SHU, when they had not in fact done so. + +c. On August 10, 2019, NOEL and THOMAS falsely certified, on an MCC count slip, that they had performed the 5 a.m. institutional count of the SHU at MCC, when they had not in fact done so. + +d. On August 10, 2019, NOEL falsely certified that she and THOMAS had performed aseries of 30-minute rounds of the SHU between 12 a.m. and 6:30 a.m., when they had not in fact done so. + +(Title 18, United States Code, Section 371) + +#### COUNT TWO (False Records - 4 p.m. Count) + +The Grand Jury further charges: + +31. The Grand Jury incorporates the allegations contained in paragraphs 1 through 27 of this Indictment as though fully set forth herein. + +32. On or about August 9, 2019, in the Southern District of New York, TOVA NOEL, the defendant, willfully and knowingly did make and use a false writing or document knowing the same to contain a materially false, fictitious, and fraudulent statement and entry with the intent to impede, obstruct, or influence the investigation or proper administration of any matter within the jurisdiction of any department or agency of the United States, and did attempt to do the same, to wit, NOEL created, signed, and submitted to the MCC a materially false count slip indicating that she had performed the 4 p.m. institutional count of the SHU, when she had not in fact done so. + +(Title 18, United States Code, Sections 1001(a)(3) and 2) + +### COUNT THREE (False Records - 10 p.m. Count) + +The Grand Jury further charges: + +33. The Grand Jury incorporates the allegations contained in paragraphs 1 through 27 of this Indictment as though fully set forth herein. + +34. On or about August 9, 2019, in the Southern District of New York, TOVA NOEL, the defendant, willfully and knowingly did make and use a false writing or document knowing the same to contain a materially false, fictitious, and fraudulent statement and entry with the intent to impede, obstruct, or influence the investigation or proper administration of any matter within the jurisdiction of any department or agency of the United States, and did attempt to do the same, to wit, NOEL created, signed, and submitted to the MCC a materially false count slip indicating that she had performed the 10 p.m. institutional count of the SHU, when she had not in fact done so. + +(Title 18, United States Code, Sections 1001(a)(3) and 2) + +COUNT FOUR (False RecOrds - 12 a.m. Count) + +The Grand Jury further charges: + +35. The Grand Jury incorporates the allegations contained in paragraphs 1 through 27 of this Indictment as though fully set forth herein. + +36. On or about August 10, 2019, in the Southern District of New York, TOVA NOEL and MICHAEL THOMAS, the defendants, willfully and knowingly did make and use a false writing or document knowing the same to contain a materially false, fictitious, and fraudulent statement and entry with the intent to impede, obstruct, or influence the investigation or proper + +administration of any matter within the jurisdiction of any department or agency of the United States, and did attempt to do the same, to wit, NOEL and THOMAS created, signed, and submitted to the MCC a materially false count slip indicating that they had performed the 12 a.m. institutional count of the SHU, when they had not in fact done so. + +(Title 18, United States Code, Sections 1001(a)(3) and 2) + +## COUNT FIVE (False Records - 3 a.m. Count) + +The Grand Jury further charges: + +37. The Grand Jury incorporates the allegations contained in paragraphs 1 through 27 of this Indictment as though fully set forth herein. + +38. On or about August 10, 2019, in the Southern District of New York, TOVA NOEL and MICHAEL THOMAS, the defendants, willfully and knowingly did make and use a false writing or document knowing the same to contain a materially false, fictitious, and fraudulent statement and entry with the intent to impede, obstruct, or influence the investigation or proper administration of any matter within the jurisdiction of any department or agency of the United States, and did attempt to do the same, to wit, NOEL and THOMAS created, signed, and submitted to the MCC a materially false count slip indicating that they had performed the 3 a.m. institutional count of the SHU, when they had not in fact done so. + +(Title 18, United States Code, Sections 1001(a)(3) and 2) + +COUNT SIX (False Records - 5 a.m. Count) + +The Grand Jury further charges: + +39. The Grand Jury incorporates the allegations contained in paragraphs 1 through 27 of this Indictment as though fully set forth herein. + +40. On or about August 10, 2019, in the Southern District of New York, TOVA NOEL and MICHAEL THOMAS, the defendants, willfully and knowingly did make and use a false writing or document knowing the same to contain a materially false, fictitious, and fraudulent statement and entry with the intent to impede, obstruct, or influence the investigation or proper administration of any matter within the jurisdiction of any department or agency of the United States, and did attempt to do the same, to wit, NOEL and THOMAS created, signed, and submitted to the MCC a materially false count slip indicating that they had + +--- + +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK + +--- + +UNITED STATES OF AMERICA + +- v. - + +TOVA NOEL and +MICHAEL THOMAS, + +Defendants. + +--- + +INDICTMENT + +19 Cr. + +Title 18, United States Code, +Sections 371, 1001(a)(3), and 2. + +GEOFFREY S. BERMAN +United States Attorney + +![]()*Tolephone* + +*2 Arrest warrants +Indictment Filed +Assigned to Judge Turkes +Hon. 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GHISLAINE MAXWELL, FRIDAY, NOVEMBER 26, 2021 + +Date: Fri, 26 Nov 2021 20:39:28 +0000 + +To the extent it might be helpful to keep what press are in the room (or generally around) at bay, I have no problem doing that. + +Sent from my iPhone + +On Nov 26, 2021, at 3:32 PM, Echenberg, Janis (USANYS) > wrote: + +Sure - if you think it's helpful to be there. There is a whole protocol around seats. I believe we have a government row and Damian and Margaret are coming too. + +Sent from my iPhone + +On Nov 26, 2021, at 3:20 PM, Biase, Nicholas (USANYS) IMIM wrote: + +Understood, thanks. If you feel it would be helpful to have someone from the press office in the courtroom for openings, just let us know. I've mentioned it to Eric Blechman, I believe he's reserved a seat. + +From: Echenberg, Janis (USANYS) + +Sent: Friday, November 26, 2021 3:16 PM + +To: Biase, Nicholas (USANYS) < > + +Cc: (USANYS) ; Margolin, James (USANYS) [Contractor] + +Subject: Re: SDNY PRESS GUIDANCE I U.S. v. GHISLAINE MAXWELL, FRIDAY, NOVEMBER 26, 2021 + +I don't think we know exactly. Parties will be there at 8:30 and apparently the jury too. But not sure when things will actually start. + +Sent from my iPhone + +On Nov 26, 2021, at 2:54 PM, Biase, Nicholas (USANYS) wrote: + +Just checking back on this. Thx! + +Sent: Friday, November 26, 2021 10:34 AM + +To: Echenberg, Janis (USANYS) < >; (USANYS) + +Cc: Margolin, James (USANYS) [Contractor] <1 + +Subject: RE: SDNY PRESS GUIDANCE I U.S. v. GHISLAINE MAXWELL, FRIDAY, NOVEMBER 26, 2021 + +Awesome, thanks. Are we able to provide a time if i also include the following? + +9:30 a.m. — Jury charge followed by opening statements in U.S. v. Ghislaine Maxwell — the defendant is charged in connection to conspiring with Jeffrey Epstein to entice minors to travel to engage in criminal sexual activity — before Judge Alison Nathan (Courtroom 318, 40 Foley Square [overflow Courtrooms 110, 506, 905, and 906 of the Thurgood Marshall U.S. Courthouse]). + +From: Echenberg, Janis (USANYS) + +Sent: Friday, November 26, 2021 10:26 AM + +To: Biase, Nicholas (USANYS) < (USANYS) + +Cc: Margolin, James (USANYS) [Contractor] <1 + +Subject: RE: SDNY PRESS GUIDANCE I U.S. v. GHISLAINE MAXWELL, FRIDAY, NOVEMBER 26, 2021 + +I don't think so. + +From: Blase, Nicholas (USANYS) < > + +Sent: Frida November 26, 2021 10:25 AM + +To: (USANYS) >; Echenberg, Janis (USANYS) + +Cc: Margolin, James (USANYS) [Contractor] <1 + +Subject: SDNY PRESS GUIDANCE I U.S. v. GHISLAINE MAXWELL, FRIDAY, NOVEMBER 26, 2021 + +Importance: High + +Before circulating this shortly, just wanted to check to see if any other orders or info worth including have happened between Wednesday and today? Thanks I + +tage001.png> + +## PRESS GUIDANCE + +Friday, November 26, 2021 + +\*ADDITIONAL OFF-THE-RECORD GUIDANCE: Please note the Court has ruled that several of the government's witnesses, who are not alleged victims themselves, may testify under pseudonyms because the disclosure of their identities would ostensibly reveal the identities of the alleged victims. I believe most, if not all, news media outlets have a policy against identifying sex crime victims without their consent, and again urge you to abide by that policy with our witnesses and respect their privacy. + +If convicted, Ghislaine Maxwell faces the following statutory maximum penalties; however, her sentence would ultimately be at the sole discretion of the judge: + +- Count One: conspiracy to entice a minor to travel to engage in illegal sex acts, which carries a maximum sentence of five years in prison; +- Count Tw0: enticing a minor to travel to engage in illegal sex acts, which carries a maximum sentence of five years in prison; +- Count Three: conspiracy to transport a minor with the intent to engage in criminal sexual activity, which carries a maximum sentence of five years in prison; +- Count Four: transporting a minor with the intent to engage in criminal sexual activity, which carries a maximum sentence of 10 years in prison; +- Count Five: conspiracy to commit sex trafficking of minors, which carries a statutory maximum of 40 years in prison; and +- Count Six: sex trafficking of minors, which carries a statutory maximum of five years in prison. + +A trial logistics order from Judge Nathan is also attached. + + + +## PRESS GUIDANCE + +Tuesday, November 23, 2021 + +\*OFF-THE-RECORD, AND FOR GUIDANCE ONLY: Several of the government's anticipated witnesses will be testifying in this trial using a pseudonym or first name. The Court granted a Government motion (attacked/ requesting that they be able to do so, because the victim witnesses are expected to describe alleged sensitive, explicit and personal events concerning illegal sexual abuse, sexual contact and other acts of which they have been victims. I believe most, if not all, news media outlets have a policy against identifying sex crime victims without their consent, and urge you to abide by that policy with our witnesses and respect their privacy. + +9:30 a.m. — Final pretrial conference U.S. v. Ghislaine Maxwell — the defendant is charged in connection to conspiring with Jeffrey Epstein to entice minors to travel to engage in criminal sexual activity — before Judge Alison Nathan (Courtroom 318, 40 Foley Square [overflow Courtrooms 110, 506, 905, and 906 of the Thurgood Marshall U.S. Courthouse]). + +EXHIBITS: Government exhibits will be provided exclusively through the SDNY file share.If you are unable to access this link to the file share (USAFx), you must establish an account to access the files. To establish an account, request access by email to me or my colleague, Jim Margolin, Cc'd here, prior to Monday, November 29, 2021. + +Please also note that all case filings in U.S. v. Maxwell are available in the Court's electronic filing system; we encourage media representatives to establish a free PACER account, if they have not done so already. Credentialing and other matters relating to in-person attendance for the trial are handled by the SDNY District Executive's Office. + +Periodic updates to follow. + +Follow us on Facebook I Follow us on Twitter I SDNY website I YouTube + +\*\*\* FOR PLANNING PURPOSES ONLY \*\*\* + +DO NOT REPLY TO THIS MESSAGE. 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GHISLAINE MAXWELL, FRIDAY, NOVEMBER 26, 2021 + +Date: Fri, 26 Nov 2021 20:44:30 +0000 + +Perfect. + +Sent from my iPhone + +On Nov 26, 2021, at 3:39 PM, Biase, Nicholas (USANYS) < IMIIIM> wrote: + +To the extent it might be helpful to keep what press are in the room (or generally around) at bay, I have no problem doing that. + +Sent from my iPhone + +On Nov 26, 2021, at 3:32 PM, Echenberg, Janis (USANYS) wrote: + +Sure - if you think it's helpful to be there. There is a whole protocol around seats. I believe we have a government row and Damian and Margaret are coming too. + +Sent from my iPhone + +On Nov 26, 2021, at 3:20 PM, Biase, Nicholas (USANYS) alMINE> wrote: + +Understood, thanks. If you feel it would be helpful to have someone from the press office in the courtroom for openings, just let us know. I've mentioned it to Eric Blachman, I believe he's reserved a seat. + +From: Echenberg, Janis (USANYS) ‹ > + +Sent: Friday, November 26, 2021 3:16 PM + +To: Biase, Nicholas (USANYS) < > + +Cc: (USANYS) ; Margolin, James (USANYS) [Contractor] + +Subject: Re: SDNY PRESS GUIDANCE I U.S. v. GHISLAINE MAXWELL, FRIDAY, NOVEMBER 26, 2021 + +I don't think we know exactly. Parties will be there at 8:30 and apparently the jury too. But not sure when things will actually start. + +Just checking back on this. Thx! + +From: Biase, Nicholas (USANYS) + +Sent: Friday, November 26, 2021 10:34 AM + +To: Echenberg, Janis (USANYS) < (USANYS) + +Cc: Margolin, James (USANYS) [Contractor] + +Subject: RE: SDNY PRESS GUIDANCE I U.S. v. GHISLAINE MAXWELL, FRIDAY, NOVEMBER 26, 2021 + +Awesome, thanks. Are we able to provide a time if I also include the following? + +9:30 a.m. — Jury charge followed by opening statements in U.S. v. Ghislaine Maxwell — the defendant is charged in connection to conspiring with Jeffrey Epstein to entice minors to travel to engage in criminal sexual activity — before Judge Alison Nathan (Courtroom 318, 40 Foley Square [overflow Courtrooms 110, 506, 905, and 906 of the Thurgood Marshall U.S. Courthouse]). + +From: Echenberg, Janis (USANYS) + +Sent: Friday, November 26, 2021 10:26 AM + +To: Biase, Nicholas (USANYS) >; (USANYS) + +Cc: Margolin, James (USANYS) [Contractor] + +Subject: RE: SDNY PRESS GUIDANCE I U.S. v. GHISLAINE MAXWELL, FRIDAY, NOVEMBER 26, 2021 + +I don't think so. + +From: Biase, Nicholas (USANYS) < + +Sent: Frida , November 26, 2021 10:25 AM + +To: (USANYS) >; Echenberg, Janis (USANYS) + +Cc: Margolin, James (USANYS) [Contractor] + +Subject: SDNY PRESS GUIDANCE I U.S. v. GHISLAINE MAXWELL, FRIDAY, NOVEMBER 26, 2021 + +Importance: High + +Before circulating this shortly, just wanted to check to see if any other orders or info worth including have happened between Wednesday and today? Thanks I + + + +## PRESS GUIDANCE + +\*ADDITIONAL OFF-THE-RECORD GUIDANCE:Please note the Court has ruled that several of the government's witnesses, who are not alleged victims themselves, may testify under pseudonyms because the disclosure of their identities would ostensibly reveal the identities of the alleged victims. I believe most, if not all, news media outlets have a policy against identifying sex crime victims without their consent, and again urge you to abide by that policy with our witnesses and respect their privacy. + +If convicted, Ghislaine Maxwell faces the following statutory maximum penalties; however, her sentence would ultimately be at the sole discretion of the judge: + +- Count One: conspiracy to entice a minor to travel to engage in illegal sex acts, which carries a maximum sentence of five years in prison; +- Count Two: enticing a minor to travel to engage in illegal sex acts, which carries a maximum sentence of five years in prison; +- Count Three: conspiracy to transport a minor with the intent to engage in criminal sexual activity, which carries a maximum sentence of five years in prison; +- Count Four: transporting a minor with the intent to engage in criminal sexual activity, which carries a maximum sentence of 10 years in prison; +- Count Five: conspiracy to commit sex trafficking of minors, which carries a statutory maximum of 40 years in prison; and +- Count Six: sex trafficking of minors, which carries a statutory maximum of five years in prison. + +A trial logistics order from Judge Nathan is also attached. + +tage001.png> + +## PRESS GUIDANCE + +Tuesday, November 23, 2021 + +\*OFF-THE-RECORD, AND FOR GUIDANCE ONLY:Several of the government's anticipated witnesses will be testifying in this trial using a pseudonym or first name. The Court granted a Government motion (attached] requesting that they be able to do so, because the victim witnesses are expected to describe alleged sensitive, explicit and personal events concerning illegal sexual abuse, sexual contact and other acts of which they have been victims. I believe most, if not all, news media outlets have a policy against identifying sex crime victims without their consent, and urge you to abide by that policy with our witnesses and respect their privacy. + +9:30 a.m. — Final pretrial conference U.S. v. Ghislaine Maxwell — the defendant is charged in connection to conspiring with Jeffrey Epstein to entice minors to travel to engage in criminal sexual activity — before + +Judge Alison Nathan (Courtroom 318, 40 Foley Square [overflow Courtrooms 110, 506, 905, and 906 of the Thurgood Marshall U.S. Courthouse]). + +EXHIBITS: Government exhibits will be provided exclusively through the SDNY file share. If you are unable to access this link to the file share (USAFx), you must establish an account to access the files. To establish an account, request access by email to me or my colleague, Jim Margolin, Cc'd here, prior to Monday, November 29, 2021. + +Please also note that all case filings in U.S. v. Maxwell are available in the Court's electronic filing system; we encourage media representatives to establish a free PACER account, if they have not done so already. Credentialing and other matters relating to in-person attendance for the trial are handled by the SDNY District Executive's Office. + +Periodic updates to follow. + +Follow us on Facebook I Follow us on Twitter I SDNY website I YouTube + +\*\*\* FOR PLANNING PURPOSES ONLY \*\*\* + +DO NOT REPLY TO THIS MESSAGE. 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GHISLAINE MAXWELL, FRIDAY, NOVEMBER 26, 2021 + +Date: Fri, 26 Nov 2021 20:55:14 +0000 + +What do think? If jury is really there at 8:30 am, it's not clear to me it will take 1.5 hours to do strikes and prelim instructions. + +Sent from my iPhone + +On Nov 26, 2021, at 3:49 PM, Biase, Nicholas (USANYS) < IMIIIM> wrote: + +Or course! Not at all for press, but for my planning — would it be safe to assume that openings would happen around 10:00 am? + +Sent from my iPhone + +On Nov 26, 2021, at 3:44 PM, Echenberg, Janis (USANYS) wrote: + +Perfect. + +Sent from my iPhone + +On Nov 26, 2021, at 3:39 PM, Biase, Nicholas (USANYS) < IMIIIM> wrote: + +To the extent it might be helpful to keep what press are in the room (or generally around) at bay, I have no problem doing that. + +Sent from my iPhone + +On Nov 26, 2021, at 3:32 PM, Echenberg, Janis (USANYS) wrote: + +Sure - if you think it's helpful to be there. There is a whole protocol around seats. I believe we have a government row and Damian and Margaret are coming too. + +Sent from my iPhone + +On Nov 26, 2021, at 3:20 PM, Biase, Nicholas (USANYS) alMINE> wrote: + +Understood, thanks. If you feel it would be helpful to have someone from the press office in the courtroom for openings, just let us know. I've mentioned it to Eric Blachman, I believe he's reserved a seat. + +From: Echenberg, Janis (USANYS) Sent: Friday, November 26, 2021 3:16 PM To: Biase, Nicholas (USANYS) < => Cc: (USANYS) < M>, Margolin, James (USANYS) [Contractor] Subject: Re: SDNY PRESS GUIDANCE I U.S. v. GHISLAINE MAXWELL, FRIDAY, NOVEMBER 26, 2021 + +I don't think we know exactly. Parties will be there at 8:30 and apparently the jury too. But not sure when things will actually start. + +Sent from my iPhone + +On Nov 26, 2021, at 2:54 PM, Biase, Nicholas (USANYS)< > wrote: + +Just checking back on this. Thx! + +From: Blase, Nicholas (USANYS) Sent: Friday, November 26, 2021 10:34 AM To: Echenberg, Janis (USANYS) >; (USANYS) Cc: Margolin, James (USANYS) [Contractor] -4 Subject: RE: SDNY PRESS GUIDANCE I U.S. v. GHISLAINE MAXWELL, FRIDAY, NOVEMBER 26, 2021 + +Awesome, thanks. Are we able to provide a time if I also include the following? + +9:30 a.m. — Jury charge followed by opening statements in U.S. v. Ghislaine Maxwell — the defendant is charged in connection to conspiring with Jeffrey Epstein to entice minors to travel to engage in criminal sexual activity — before Judge Alison Nathan (Courtroom 318, 40 Foley Square [overflow Courtrooms 110, 506, 905, and 906 of the Thurgood Marshall U.S. Courthouse]). + +From: Echenberg, Janis (USANYS) Sent: Friday, November 26, 2021 10:26 AM To: Biase, Nicholas (USANYS) < (USANYS) Cc: Margolin, James (USANYS) [Contractor] < Subject: RE: SDNY PRESS GUIDANCE I U.S. v. GHISLAINE MAXWELL, FRIDAY, NOVEMBER 26, 2021 + +I don't think so. + +From: Blase, Nicholas (USANYS). Sent: Frida November 26, 2021 10:25 AM To: (USANYS) >; Echenberg, Janis (USANYS) + +Cc: Margolin, James (USANYS) [Contractor] -4 + +Subject: SDNY PRESS GUIDANCE I U.S. v. GHISLAINE MAXWELL, FRIDAY, NOVEMBER 26, 2021 + +Importance: High + +Before circulating this shortly, just wanted to check to see if any other orders or info worth including have happened between Wednesday and today? Thanks! + +tage001.png> + +## PRESS GUIDANCE + +Friday, November 26, 2021 + +\*ADDITIONAL OFF-THE-RECORD GUIDANCE:Please note the Court has ruled that several of the government's witnesses, who are not alleged victims themselves, may testify under pseudonyms because the disclosure of their identities would ostensibly reveal the identities of the alleged victims. I believe most, if not all, news media outlets have a policy against identifying sex crime victims without their consent, and again urge you to abide by that policy with our witnesses and respect their privacy. + +If convicted, Ghislaine Maxwell faces the following statutory maximum penalties; however, her sentence would ultimately be at the sole discretion of the judge: + +- **Count One: conspiracy to entice a minor to travel to engage in illegal sex acts, which carries a maximum sentence of five years in prison;** +- **Count Two: enticing a minor to travel to engage in illegal sex acts, which** carries a maximum sentence of five years in prison; +- **Count Three: conspiracy to transport a minor with the intent to engage in criminal sexual activity, which carries a maximum sentence of five years in prison;** +- **Count Four: transporting a minor with the intent to engage in criminal sexual activity, which carries a maximum sentence of 10 years in prison;** +- **Count Five: conspiracy to commit sex trafficking of minors, which carries a** statutory maximum of 40 years in prison; and +- **Count Six: sex trafficking of minors, which** carries a statutory maximum of five years in prison. + +A trial logistics order from Judge Nathan is also attached. + +## PRESS GUIDANCE + +Tuesday, November 23, 2021 + +\*OFF-THE-RECORD, AND FOR GUIDANCE ONLY:Several of the government's anticipated witnesses will be testifying in this trial using a pseudonym or first name. The Court granted a Government motion [attached] requesting that they be able to do so, because the victim witnesses are expected to describe alleged sensitive, explicit and personal events concerning illegal sexual abuse, sexual contact and other acts of which they have been victims. I believe most, if not all, news media outlets have a policy against identifying sex crime victims without their consent, and urge you to abide by that policy with our witnesses and respect their privacy. + +9:30 a.m. — Final pretrial conference U.S. v. Ghislaine Maxwell — the defendant is charged in connection to conspiring with Jeffrey Epstein to entice minors to travel to engage in criminal sexual activity — before Judge Alison Nathan (Courtroom 318, 40 Foley Square [overflow Courtrooms 110, 506, 905, and 906 of the Thurgood Marshall U.S. Courthouse]). + +EXHIBITS: Government exhibits will be provided exclusively through the SDNY file share. If you are unable to access this link to the file share (USAFx), you must establish an account to access the files. To establish an account, request access by email to me or my colleague, Jim Margolin, Cc'd here, prior to Monday, November 29, 2021. + +Please also note that all case filings in U.S. v. Maxwell are available in the Court's electronic filing system; we encourage media representatives to establish a free PACER account, if they have not done so already. Credentialing and other matters relating to in-person attendance for the trial are handled by the SDNY District Executive's Office. + +Periodic updates to follow. + +Follow us on Facebook I Follow us on Twitter I SDNY website I YouTube + +\*\*\* FOR PLANNING PURPOSES ONLY \*\*\* + +DO NOT REPLY TO THIS MESSAGE. 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GHISLAINE MAXWELL, FRIDAY, NOVEMBER 26, 2021 + +**Date:** Fri, 26 Nov 2021 21:09:57 +0000 + +--- + +Hey – just double checked with [REDACTED] on this and we agree it’s really hard to predict. The parties were told to be there at 8:30 am. It’s not crystal clear when the jurors will arrive, although there is already a qualified group so all they have to do is strikes, but there is a possibility of more questioning of certain jurors if either side has learned more about them since last week or they have learned more about the case. So....it’s hard to know how long that will take. The press should get there early and just wait I think? + +--- + +**From:** [REDACTED] > +**Sent:** Friday, November 26, 2021 3:50 PM +**To:** [REDACTED] > +**Cc:** [REDACTED] >; [REDACTED] > +**Subject:** Re: SDNY PRESS GUIDANCE | U.S. v. GHISLAINE MAXWELL, FRIDAY, NOVEMBER 26, 2021 + +Or course! Not at all for press, but for my planning — would it be safe to assume that openings would happen around 10:00 am? + +Sent from my iPhone + +On Nov 26, 2021, at 3:44 PM, [REDACTED] > wrote: + +Perfect. + +Sent from my iPhone + +On Nov 26, 2021, at 3:39 PM, [REDACTED] > wrote: + +To the extent it might be helpful to keep what press are in the room (or generally around) at bay, I have no problem doing that. + +Sent from my iPhone + +On Nov 26, 2021, at 3:32 PM, [REDACTED] > wrote: + +Sure - if you think it’s helpful to be there. There is a whole protocol around seats. I believe we have a government row and Damian and [REDACTED] are coming too. + +Sent from my iPhone + +Understood, thanks. If you feel it would be helpful to have someone from the press office in the courtroom for openings, just let us know. I've mentioned it to I believe he's reserved a seat. + +From: + +Sent: Friday. November 26. 202! 3:16 PM + +To: + +Cc: + +Subject: Re: SDNY PRESS GUIDANCE I U.S. v. GHISLAINE MAXWELL, FRIDAY, NOVEMBER 26, 2021 + +I don't think we know exactly. Parties will be there at 8:30 and apparently the jury too. But not sure when things will actually start. + +Sent from my iPhone + +On Nov 26, 2021, at 2:54 PM, wrote: + +Just checking back on this. Thx! + +From + +Sent: Friday. November 26, 2021 10:34 AM + +To: + +Cc: + +Subject: RE: SDNY PRESS GUIDANCE I U.S. v. GHISLAINE MAXWELL, FRIDAY, NOVEMBER 26, 2021 + +Awesome, thanks. Are we able to provide a time if I also include the following? + +9:30 a.m. — Jury charge followed by opening statements in U.S. v. Ghislaine Maxwell — the defendant is charged in connection to conspiring with Jeffrey Epstein to entice minors to travel to engage in criminal sexual activity — before Judge Alison Nathan (Courtroom 318, 40 Foley Square [overflow Courtrooms 110, 506, 905, and 906 of the Thurgood Marshall U.S. Courthouse]). + +From: + +Sent: Friday. November 26.2021 10:26 AM + +To: + +Subject: RE: SDNY PRESS GUIDANCE I U.S. v. GHISLAINE MAXWELL, FRIDAY, NOVEMBER 26, 2021 + +From: Sent: Friday,November 26, 2021 10:25 AM To: Cc: Subject: SDNY PRESS GUIDANCE I U.S. v. GHiSLAINE MAXWELL, FRIDAY, NOVEMBER 26, 2021 Importance: High + +Before circulating this shortly, just wanted to check to see if any other orders or info worth including have happened between Wednesday and today? Thanks! + +tage001.png> + +## PRESS GUIDANCE + +Friday, November 26, 2021 + +\*ADDITIONAL OFF-THE-RECORD GUIDANCE:Please note the Court has ruled that several of the government's witnesses, who are not alleged victims themselves, may testi.b, under pseudonyms because the disclosure of their identities would ostensibly reveal the identities of the alleged victims. I believe most, if not all, news media outlets have a policy against identifying sex crime victims without their consent, and again urge you to abide by that policy with our witnesses and respect their privacy. + +If convicted, Ghislaine Maxwell faces the following statutory maximum penalties; however, her sentence would ultimately be at the sole discretion of the judge: + +- Count One: conspiracy to entice a minor to travel to engage in illegal sex acts, which carries a maximum sentence of five years in prison; +- Count Two: enticing a minor to travel to engage in illegal sex acts, which carries a maximum sentence of five years in prison; +- Count Three: conspiracy to transport a minor with the intent to engage in criminal sexual activity, which carries a maximum sentence of five years in prison; +- Count Four: transporting a minor with the intent to engage in criminal sexual activity, which carries a maximum sentence of 10 years in prison; +- Count Five: conspiracy to commit sex trafficking of minors, which carries a statutory maximum of 40 years in prison; and +- Count Six: sex trafficking of minors, which carries a statutory maximum of five years in prison. + +tage001.png> + +## PRESS GUIDANCE + +Tuesday, November 23, 2021 + +\*OFF-THE-RECORD, AND FOR GUIDANCE ONLY: Several of the government's anticipated witnesses will be testifying in this trial using a pseudonym or first name. The Court granted a Government motion (attacked/ requesting that they be able to do so, because the victim witnesses are expected to describe alleged sensitive, explicit and personal events concerning illegal sexual abuse, sexual contact and other acts of which they have been victims. I believe most, if not all, news media outlets have a policy against identifying sex crime victims without their consent, and urge you to abide by that policy with our witnesses and respect their privacy. + +9:30 a.m. — Final pretrial conference U.S. v. Ghislaine Maxwell — the defendant is charged in connection to conspiring with Jeffrey Epstein to entice minors to travel to engage in criminal sexual activity — before Judge Alison Nathan (Courtroom 318, 40 Foley Square [overflow Courtrooms 110, 506, 905, and 906 of the Thurgood Marshall U.S. Courthouse]). + +EXHIBITS: Government exhibits will be provided exclusively through the SDNY file share. If you are unable to access this link to the file share (USAFx), you must establish an account to access the files. To establish an account, request access by email to me or my colleague, Cc'd here, prior to Monday, November 29, 2021. + +Please also note that all case filings in U.S. v. Maxwell are available in the Court's electronic filing system; we encourage media representatives to establish a free PACER account, if they have not done so already. Credentialing and other matters relating to in-person attendance for the trial are handled by the SDNY District Executive's Office. + +Periodic updates to follow. + +Follow us on Facebook I Follow us on Twitter I SDNY website I YouTube + +\*\*\* FOR PLANNING PURPOSES ONLY \*\*\* + +DO NOT REPLY TO THIS MESSAGE. 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I + +On the letter, I think it's good, but since all of the info comes from -we might want to be careful to source the facts that way. E.g. reported that may be mentally ill and reacting to her decision to move away. + +From: + +Sent: Friday, November 26, 2021 9:02 PM + +To: ) sc= > (USANYS) < >\*, + +Subject: Preclude cross + +Hey team, + +Letter to preclude cross attached. per our conversation, I left blanks for the facts of MV-1 and MV-2's drug use. I think you can just write a couple sentences — it doesn't have to be long. + +Otherwise, welcome all comments, and please make sure the section on MV-1's family is accurate! + +Thanks, + +Assistant United States Attorney Southern District of New York 1 Saint Andrews Plaza lark 10007 \ No newline at end of file diff --git a/marker2/ds9/EFTA00089959/EFTA00089959.metadata.json b/marker2/ds9/EFTA00089959/EFTA00089959.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..9a47b24048b3d8c52de07d39eccd56dd42741cab --- /dev/null +++ b/marker2/ds9/EFTA00089959/EFTA00089959.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089959.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1025, + "elapsed_seconds": 0.73, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 54 + ], + [ + "Line", + 26 + ], + [ + "Text", + 15 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089959" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089960/EFTA00089960.md b/marker2/ds9/EFTA00089960/EFTA00089960.md new file mode 100644 index 0000000000000000000000000000000000000000..aa1c1b52bedaa46978241661307c076214791527 --- /dev/null +++ b/marker2/ds9/EFTA00089960/EFTA00089960.md @@ -0,0 +1,82 @@ +From: "Besselsen, Daniel" To: ' Cc: Daniel Besselsen (NY) (FBI)" + +Subject: Re: [EXTERNAL] Re: travel + +Date: Thu, 18 Nov 2021 16:48:57 +0000 + +Attachments: 743\_(added\_pages).pdf; 742\_(added\_pages)\_.pdf; IMG\_1152jpg + +Hi + +See attached as requested for GX 742 and 743. I included all the pages in the attachments, those pages that you had previously and the few new pages. I also included a current picture of the "Epstein Scholarship Lodge" on our campus which was renamed "Green Lake Lodge". + +Per m revious email, if you are also interested in the summer Camp application and highschool school year application for the student in GX 742 just let me know and I can get those to you too. + +Let me know if you have any follow up questions, thanks. + +Dan Besselsen, CPA + +Assistant Vice President of Finance + +Interlochen Center for the Arts + +E: + +P: + +W: interlochen.org + +Arts Camp I Arts Academy I College of Creative Arts I Presents I Public Radio + +On Wed, Nov 17, 2021 at 7:25 PM ) < wrote: + +Hi Dan, + +Following up on our conversation, we would appreciate it if you would send us the rest of the admissions file for the students in GX 742 and 743. No need to send us the rest of the materials in GX 741. + +Thanks again, + +From: Besselsen, Daniel + +Sent: Thursda November 11, 2021 5:18 PM + +To: + +Cc: (NY) (FBI) + +Subject: [EXTERNAL] Re: travel + +(cell) + +Thanks. + +Dan Besselsen, CPA + +Assistant Vice President of Finance Interlochen Center for the Arts + +E: P: ir + +W: interlochen.org + +Arts Camp I Arts Academy I College of Creative Arts I Presents I Public Radio + +On Thu, Nov 11, 2021 at 2:52 PM ) < wrote: + +Hi Dan, + +Thanks very much for speaking with us today. Could you please send me the following information for your travel? I'll pass this along to our witness coordinator, who will be in touch with you to make arrangements. + +- Name as it appears on the government ID you'll be using to travel +- Date of birth +- Home address +- Phone number + +Thanks, + +Assistant United States Attorney + +Southern District of New York + +One Saint Plaza + +New York, NY 10007 \ No newline at end of file diff --git a/marker2/ds9/EFTA00089960/EFTA00089960.metadata.json b/marker2/ds9/EFTA00089960/EFTA00089960.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..91017b7a4671ddac9b8946a23f6ccc52d4f72eb8 --- /dev/null +++ b/marker2/ds9/EFTA00089960/EFTA00089960.metadata.json @@ -0,0 +1,92 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089960.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2042, + "elapsed_seconds": 1.26, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 73 + ], + [ + "Line", + 36 + ], + [ + "Text", + 27 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 45 + ], + [ + "Text", + 23 + ], + [ + "Line", + 22 + ], + [ + "ListItem", + 4 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089960" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089962/EFTA00089962.md b/marker2/ds9/EFTA00089962/EFTA00089962.md new file mode 100644 index 0000000000000000000000000000000000000000..1f83b9bda1bcc12f6b463554b7910c472f94d093 --- /dev/null +++ b/marker2/ds9/EFTA00089962/EFTA00089962.md @@ -0,0 +1,76 @@ +From: + +Subject: Re: [EXTERNAL] Re: travel Date: Thu, 18 Nov 2021 13:20:22 +0000 + +Hi For the student in GX 742 are you also interested in their summer Camp yeas application as well? application and highschool school + +GX 742 as it stands now is just the student's summer Camp application. Let me know, thanks. + +Dan Besselsen, CPA + +Assistant Vice President of Finance + +Interlochen Center for the Arts + +E: + +P: + +W: interlochen.org + +Arts Camp I Arts Academy I College of Creative Arts I Presents I Public Radio + +On Wed, Nov 17, 2021 at 7:25 PM wrote: + +Hi Dan, + +Following up on our conversation, we would appreciate it if you would send us the rest of the admissions file for the students in GX 742 and 743. No need to send us the rest of the materials in GX 741. + +Thanks again, + +From: Besselsen, Daniel + +Sent: Thursday,November 11, 2021 5:18 PM + +To: + +Cc: (NY) (FBI) + +Subject: [EXTERNAL] Re: travel + +HIM, + +Yes, certainly. See below: + +Thanks. + +Dan Besselsen, CPA + +Assistant Vice President of Finance + +Interlochen Center for the Arts + +E: + +P: + +W: interlochen.org + +Arts Camp I Arts Academy I College of Creative Arts I Presents I Public Radio + +On Thu, Nov 11, 2021 at 2:52 PM I> wrote: + +Hi Dan, + +Thanks very much for speaking with us today. Could you please send me the following information for your travel? I'll pass this along to our witness coordinator, who will be in touch with you to make arrangements. + +- Name as it appears on the government ID you'll be using to travel +- Date of birth +- Home address +- Phone number + +Thanks. + +Assistant United States Attorney + +Southern District of New York \ No newline at end of file diff --git a/marker2/ds9/EFTA00089962/EFTA00089962.metadata.json b/marker2/ds9/EFTA00089962/EFTA00089962.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..7396a137225a58ffd4f572af1e39716dcc6609c8 --- /dev/null +++ b/marker2/ds9/EFTA00089962/EFTA00089962.metadata.json @@ -0,0 +1,92 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089962.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 1587, + "elapsed_seconds": 1.2, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 58 + ], + [ + "Line", + 29 + ], + [ + "Text", + 26 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 40 + ], + [ + "Text", + 21 + ], + [ + "Line", + 20 + ], + [ + "ListItem", + 4 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00089962" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00089964/EFTA00089964.md b/marker2/ds9/EFTA00089964/EFTA00089964.md new file mode 100644 index 0000000000000000000000000000000000000000..4153a39accb16a9b06c9e20008f42c71fbe12f01 --- /dev/null +++ b/marker2/ds9/EFTA00089964/EFTA00089964.md @@ -0,0 +1,970 @@ +**About This Form** +*Fees ("w" in computer)* + +Please answer all questions below. The application deadline for first priority review is **February 15**. Applications made after this date are welcome and will be reviewed on a rolling admission basis. See the "Admissions" section of the Camp Extra (page 2) for complete application and scholarship/financial aid information. Sorry, but we cannot process an incomplete application. + +**Applicant Information** + + Yes No Are you applying for Scholarship/Financial Aid? Yes No Are you applying for The Governor's Scholar Program? + +What Division are you applying for? Junior Session A Junior Session B Junior A & B Intermediate High School + +*Ready* + +International students: When providing telephone number, include the country code and the city code *before* the local telephone number. + +First Name: [REDACTED] Last [REDACTED] Original Name: [REDACTED] Date of Admission: 5-7-94 + +First Name: [REDACTED] Last [REDACTED] Original Name: [REDACTED] Date of Admission: [REDACTED] Home Telephone: Area Code + Number (Fax available?) [REDACTED] + +First Name: [REDACTED] Last [REDACTED] Original Name: [REDACTED] Date of Admission: [REDACTED] + +First Name: [REDACTED] Last [REDACTED] Original Name: [REDACTED] Date of Admission: [REDACTED] + + Yes No Have you previously attended Interlochen Arts Camp (excluding All-State)? Write dates attended: + Yes No Is a parent an alumni of Interlochen? Father Mother / Maiden name: Year(s) of attendance: + +**Additional International Applicant Information** + + Yes No Are you a U.S. Citizen? If not a U.S. Citizen, indicate citizenship held: + +Is English the primary language spoken at home? Yes No If not, what is the primary language? **ENGLISH, SWEDISH** + +Full Name or a contact person in the United States Home Telephone: Area Code + Number (Fax available?) + +**Parent or Guardian Information** + +Applicant normally lives with: Father Mother Stepfather Stepmother Legal Guardian Other: + +If parent(s), what is current marital status? Single Married Divorced Separated **WIDOW** + +Mother or Guardian (note relationship) Name [REDACTED] Occupation **PALM BEACH FL. 33480** + +Home Street Address [REDACTED] State [REDACTED] Zip [REDACTED] + +Name of Employer [REDACTED] Office Telephone: Area Code + Number Office Fax: Area Code + Number **CONDUCTOR-COMPOSER** + +Father or Guardian (note relationship) Name (PASSED AWAY) Occupation [REDACTED] + +Home Street Address [REDACTED] City [REDACTED] State [REDACTED] Zip [REDACTED] + +Name of Employer [REDACTED] Office Telephone: Area Code + Number Office Fax: Area Code + Number + +Note any physical, psychological, medical or other condition requiring special attention or care (such as sleepwalking, fear of storms, bed wetting, etc.) + +How do you rate your child in terms of personal adjustment, such as his or her sense of self worth, ability, independence, etc.? + How do you rate your child in terms of social adjustment? Has many friends Has few friends Has one or two close friends + Has had close association with older children Younger children Children his or her own age + +Is there any phase of personal or social adjustment which you hope Camp will aid? **NO** + +Please give any information that might be helpful in guiding the educational and personal development of your child. + +**For Internal Use** + +| Sch/FA | Rec C | Tape # | NA | +|--------|-------|---------|------| +| Art | Rec D | Video # | Re | +| Work | FA E | Port # | I-20 | + +DO NOT LET ACCESS MEDICAL INFORMATION FOR ITEMS STRANGED APPLICATION FORMS. + +**VOIC** + 5/16 + +Please list Course Names in order of preference. +**Camp session A** at left. +**Camp session B** at right. + +Private Lessons? + +Students in the Junior Division will be assigned three periods of arts activities, including private lessons. Students who complete grade 6 have the option of selecting an additional arts class in place of land recreation. Please refer to the "Junior Division" section in the Camp Extra for a complete discussion of arts activities, daily class scheduling and prerequisites. + +1. Session A + +1. Session B + +2. Session A + +2. Session B + +3. Session A + +3. Session B + +4. Session A + +4. Session B + +5. Session A + +5. Session B + + 4 - 30-min. lessons. Instrument: + + 4 - 30-min. lessons. Instrument: + + 4 - 60-min. lessons. Instrument: + + 4 - 60-min. lessons. Instrument: + +**Intermediate & High School Arts Activities** + +Students in the Intermediate Division will be assigned four periods of arts activities, including private lessons. Students who complete grade 9 have the option of selecting an additional class in place of recreation. High School students will be assigned four periods of arts activities, including private lessons. Please refer to your division's section in the Camp Extra for a complete discussion of arts activities, daily class scheduling and prerequisites. **Note:** the Camp does not include prerequisites and audition requirements. + +Major Activity: + At left; list Course Names in order of preference. + +Minor Activities: + At right; list Course Names in order of preference. + +1. First Choice Major Course Name / Instrument (if applicable) + +1. THEATRE ARTS / MUSICAL + +2. Second Choice Major Course Name / Instrument (if applicable) + +2. MUSIC / VOCAL + +3. Third Choice Major Course Name / Instrument (if applicable) + +2. Minor Course Name + +2. BEGINNING INSTRUMENT + +3. Minor Course Name CLASSES / FLUTE + +4. MIDDERN DANCE + +4. Minor Course Name + +Private Lessons? + + 8-30-min. private lessons. Instrument: + + 8-60-min. private lessons with one period of practice daily. Instrument: + + 8-60-min. private lessons with two periods of practice daily. Instrument: + +Music Students - Please Answer: + +What is your primary instrument or interest? SINGING / VOCAL 7 years Maestro + +What is your primary instrument or interest? + +Number of Years Studied + +Name of teacher in this activity + +Teacher's Street Address + +HE PASSED AWAY IN OCTOBER OF 1993. + +City + +State + +Zip + +What is your secondary instrument or interest? + +Number of Years Studied + +Previous experience in Orchestra: Number of Years / Position + +Previous experience in Band: Number of Years / Position + +List two difficult works performed in orchestra, band or in ensemble within the past year. + +NOTHING HAS BEEN DIFFICULT FOR ME. + +List the two most difficult solos you have mastered on your primary instrument or sung. + +THEATRE / MUSICAL THEATRE = Training at [redacted] for stage craft, costuming, acting, improvisation, musical theatre, etc. Plays, performances, movies. + +Dance, Theatre, Visual Art Students - Please Answer + +**Additional** + +References given to whom? + +Name of person in receipt of Artistic Recommendation form "C." + +Name of person in receipt of Academic Recommendation form "D." + +[redacted] + +How did you first learn about Interlochen? + +Optional. Applicant please indicate: + + Native American/American Indian + + Asian American + + White/Caucasian + + Other, please specify: + + Other, please specify: + +No application can be processed without the signatures of Applicant and Parent/Guardian. + +**Send Admission Materials to:** + Admissions Office + +Applicant signature + +Date + +I have answered the questions on this application to the best of my ability and believe my answers are true and correct. + +Presently announcing signature + +I have read this application and the responses are true and correct to the best of my knowledge. I support this student's application to the Interlochen Arts Camp. + +**Please enclose the required \$225 with your application.** See page 2 of the Camp Extra for a complete discussion of Camp cost and refund policy. You may use a credit card: VISA, MasterCard, Discover and American Express. + +## Part I Applicant + +*Address* + +Please complete the following items and request that the person to whom you are giving this form fill out Part II and return it by **February 15** to the Interlochen Arts Camp Admissions Office. This recommendation should be completed by a teacher, instructor or director who is very familiar with your abilities in your particular arts area. + +Home Address: [Redacted] State: [Redacted] Zip: 33480 + City: [Redacted] State: [Redacted] Home Area: Code + Number (in available?): [Redacted] + In what capacity have you known the person completing this form? *AS FRIEND, PROTEGÉE, and STUDENT 7 years* +*In what capacity have you known the person completing this form? THEATRE ARTS/MUSICAL THEATRE* + What is your primary area of interest? If music, list instrument. + +## Part II Instructor + +The above student is making application for admission to the Interlochen Arts Camp and is asking that you complete this confidential recommendation form. **By returning this form by February 15**, you will insure a prompt review of his or her application. All information given will be treated in a strictly confidential and professional manner by the Camp. **Please return the completed form promptly to:** [Redacted] + +[Redacted] If you have questions, please call the Admissions Office at 616.276.7472. + + Please check if you would like to receive more information about Interlochen Center for the Arts and its year-round educational programs. + +### Estimate of applicant's success: + + Will probably be a superior student. Will probably be an above average student. Will probably be an average student. + + May have some difficulty and should have special guidance (please explain below). + +In relation to others in the candidate's age group whom you have known, please check the appropriate box for each item: + +| Artistic Potential | Outstanding | Very Good | Average | Below Average | +|------------------------|-------------------------------------------------|-----------------------------------------------|----------------------------------|----------------------------------------| +| Artistic Achievement | Outstanding | Very Good | Average | Below Average | +| Work/Practice Habits | Outstanding | Very Good | Average | Below Average | +| Initiative | Outstanding | Very Good | Average | Below Average | +| Creativity | Outstanding | Very Good | Average | Below Average | +| Common Sense | Outstanding | Very Good | Average | Below Average | +| Seriousness of Purpose | Outstanding | Very Good | Average | Below Average | +| Reaction to Criticism | Outstanding | Very Good | Average | Below Average | +| Self Discipline | Outstanding | Very Good | Average | Below Average | +| Peer Compatibility | Outstanding | Very Good | Average | Below Average | +| Conduct | Outstanding | Very Good | Average | Below Average | +| Integrity | Outstanding | Very Good | Average | Below Average | + +Additional comments, positive or otherwise, which the Camp should review when considering the applicant's acceptance. The Camp wishes to receive all information which will lead to a better understanding of the applicant and his or her experience to date. + +# C + +ALL COMMENTS I COULD MAKE FOR [REDACTED] + WOULD BE MOST POSITIVE. SHE IS SINGULARLY GIFTED IN MUSIC AND BRAMA AND HAS MANY FACETS OF HER TALENT AND INTEREST INCLUDING PRAYING FLUTE, PIANO and HARP, SINGING IN A LOVELY VOICE AND AN AMAZINGLY WIDE RANGE OF NOTES, IN FOUR OR FIVE LANGUAGES, AND TAKING MUSICAL DIRECTION LIKE A PROFESSIONAL, THOUGH SHE IS LARGELY UNTRAINED TO DATE. SHE ALSO ADDS THE PROUDNESS OF HER OWN CHARMING PERSONALITY TO ALL THESE SKILLS. HER DICTION IS PARTICULARLY GOOD, AND SHE IS MOST VERSATILE IN PRESENTING CHARACTERS. I RECOMMEND HER VERY HIGHLY AND AN SURE SHE WILL MAKE OPTIMAL USE OF HER TIME AT [REDACTED] + +Signature + +[REDACTED] + +July 27, 1994 + +Date + +AUTHOR-LYRIST + +FIRMERLY A DIRECTOR OF PROFESSIONAL CHURCHES School, NYC + +Title + +Name, City, State, Zip + +Office Telephone: Area Code + Number + +City [REDACTED] State FL Zip [REDACTED] Office Fax Area Code + Number [REDACTED] + +Please send admission materials to: +Admissions + +[REDACTED] + +By returning this form by **February 15** you will insure a prompt review of this student's application. The application is not considered complete until this information is received. + +## Part I Applicant + +Please complete the following items and request that the person to whom you are giving this form fill out Part II and return it by **February 15** to the [REDACTED] Admissions Office. This recommendation should be completed by a teacher in your school who knows you well and is working with you in an academic classroom setting. + +[REDACTED] +Applicant's Bull Name +[REDACTED] +[REDACTED] +[REDACTED] Home Telephone: Arts [REDACTED] State [REDACTED] Zip [REDACTED] + +City **GEOGRAPHY TEACHER** State **FL.** Zip **1 year** +In what capacity have you known the person completing this form? How Long? +**THEATREARTS/MUSICAL THEATRE** +What is your primary area of interest? If music, list instrument. + +## Part II Teacher + +The above student is making application for admission to the Interlochen Arts Camp and is asking that you complete this confidential recommendation form. **By returning this form by February 15**, you will insure a prompt review of his or her application. All information given will be treated in a strictly confidential and professional manner by the Camp. **Please return the completed form promptly to:** Admissions Office [REDACTED] +If you have questions, please call the Admissions Office at [REDACTED] + + Please check if you would like to receive more information about Interlochen Center for the Arts and its year-round educational programs. + +### Estimate of applicant's success: + +- Will probably be a superior student. Will probably be an above average student. Will probably be an average student. +- May have some difficulty and should have special guidance (please explain below). + +In relation to others in the candidate's age group whom you have known, please check the appropriate box for each item: + +| Academic Potential | Outstanding | Very Good | Average | Below Average | +|------------------------|-------------------------------------------------|------------------------------------|----------------------------------|----------------------------------------| +| Academic Achievement | Outstanding | Very Good | Average | Below Average | +| Work/Practice Habits | Outstanding | Very Good | Average | Below Average | +| Initiative | Outstanding | Very Good | Average | Below Average | +| Concern for Others | Outstanding | Very Good | Average | Below Average | +| Common Sense | Outstanding | Very Good | Average | Below Average | +| Seriousness of Purpose | Outstanding | Very Good | Average | Below Average | +| Reaction to Criticism | Outstanding | Very Good | Average | Below Average | +| Self Discipline | Outstanding | Very Good | Average | Below Average | +| Peer Compatibility | Outstanding | Very Good | Average | Below Average | +| Conduct | Outstanding | Very Good | Average | Below Average | +| Integrity | Outstanding | Very Good | Average | Below Average | + +Additional Comments + +Additional comments, positive or otherwise, which the Camp should review when considering the applicant's acceptance. The Camp wishes to receive all information which will lead to a better understanding of the applicant and his or her ability to fit into a social or group living situation. + +# D + +[REDACTED] is a very intelligent student. She is a delight to have in class. She maintains a superior rank among her peers. She is creative, sensitive, and witty in all her donatment. Please consider [REDACTED] for any position she seeks. + +*Hanke* +[REDACTED] + +Signature + +A 269839 + +[REDACTED] + +Signature of Teacher + +4-27-94 +Date + +[REDACTED] + +City + +State + +Zip + +Office Fax: Area Code + Number + +**Please send admission materials to:** + +Admissions +Interlochen Arts Camp +I +[REDACTED] +Interlochen, Michigan +49643-0199 + +By returning this form by **February 15** you will insure a prompt review of this student's application. The application is not considered complete until this information is received. + +# Greetings + +FLASHCOMP by AD CENTER FORT LAUDERDALE + +![](_page_6_Picture_12.jpeg) + +# From the [REDACTED] + +![](_page_6_Picture_14.jpeg) + +PHOTO by MARK HILL + +![](_page_7_Picture_10.jpeg) + +PHOTOS by AD CENTER FORT LAUDERDALE + +[Redacted] + +![](_page_7_Picture_13.jpeg) + +PHOTOS by MARK HILL + +![](_page_7_Picture_15.jpeg) + +![](_page_7_Picture_16.jpeg) + +![](_page_7_Picture_17.jpeg) + +3XS +NOV 18 REC'D +About This Form + +# Application for Admission + +A S# 269116 M# A269850 F# IG- BOTH +VIA IN 4/10/95 + +Answer all questions below. The application deadline for **first priority review is February 15**. Applications made after this date are welcome and will be reviewed on a rolling admission basis. See the "Admissions" section of the Camp Extra (page 2) for complete application and financial aid information. Sorry, but we cannot process an incomplete application. + +**Applicant Information** + +Are you applying for Financial Aid? Yes No Have you applied for The Governor's Scholar Program? Yes No +What Division are you applying for? Junior Session A Junior Session B Intermediate Session A Intermediate Session B High School + +[Redacted] 10-31-94 + +International students: When providing telephone number, include the country code and the city code *before* the local telephone number. + +[Redacted] FL. [Redacted] Home Telephone: Area Code + Number (Fax available?) + +City Female State Zip (Nickname?) Date of Application + +Sex: M or F Height: Weight: City: Age: Code and Number (Fax available?) + +Name of your school [Redacted] Names of citizens and their ages: [Redacted] + +Have you previously attended Interlochen Arts Camp (excluding All-State)? Yes No Year(s) attended: 1 year/1994 + +**International Applicants Only** + +Country of citizenship SWEDISH Country of birth +Primary language spoken at home Secondary language (if any) spoken at home +Full name of a contact person in the United States Home Telephone: Area Code + Number (Fax available?) + +**Parent or Guardian Information** + +Who does the applicant normally live with? Note relationship. [Redacted] +WIDOW [Redacted] Who should receive building? +[Redacted] + mother INTERIOR DECORATOR +Mother or Guardian (note relationship) Name [Redacted] PALM BEACH [Redacted] +Home Street Address " City " State " Zip +Name of Employer SELF-EMPLOYED " Office Telephone: Area Code + Number Office Fax: Area Code + Number +Father or Guardian (note relationship) Name Occupation +Home Street Address " City " State " Zip +Name of Employer Office Telephone: Area Code + Number Office Fax: Area Code + Number + +**Personal Information** + +Note any physical, psychological, medical or other condition requiring special attention or care (such as sleepwalking, fear of storms, bed wetting, etc.). +She adjusts extremely well and quickly, good self-worth and ability and is very independent. +How do you rate your child in terms of personal adjustment, such as his or her sense of self worth, ability, independence, etc.? + +How do you rate your child in terms of social adjustment? Has many friends Has few friends Has one or two close friends + Has had close association with older children Younger children Children his or her own age +NO +Is there any phase of personal or social adjustment which you hope Camp will aid? + +Please give any information that might be helpful in guiding the educational and personal development of your child. + +*Ready* + +For Internal Use +Ck. #269 +Ack. #1675/3x +18 KB + +| Sch/FA | Rec C | Tape # | MAJ | +|--------|---------|---------|---------| +| Amt | Rec D | Video # | Res | +| Work | EAF N/A | Port # | I-20 NO | + +**Dance, Theatre & Visual Art Students** + +Piano + +What is your secondary instrument or interest? + +3 years + +Previous experience in Orchestra: Number of Years / Position + +Flute: 1 year + +Previous experience in Band: Number of Years / Position + +List **two** difficult works performed in orchestra, band or in ensemble within the past year. + +Nothing has been very difficult for me. (I am at high level of reading music) + +List the **two** most difficult solos you have mastered on your primary instrument or sung. + +MUSICAL THEATRE. I have had fairly mount of acting experience. I go to the + +What is your primary interest? Describe previous training and experience in this area. + +School of Arts for music and theatre. I've done commercials, many performances singing, plays, skits, etc. + +**Junior and Intermediate Class Schedule** + +Students in the Junior Division will be assigned three periods of classes, including private lessons. Students who complete grade 6 have the option of selecting an additional class in place of land recreation. Intermediate Division students will be assigned four periods of classes, including private lessons. Students who complete grade 9 have the option of selecting an additional class in place of recreation. Please refer to your division's section in the Camp Extra for a complete discussion of classes, scheduling, prerequisites and audition requirements. + +**CHORUS** + +**CHORUS** + +Please list Class Names in order of preference. +**Camp session A** at left. +**Camp session B** at right. + +1. Session A (Intermediate: First Choice Major) +**MUSICAL THEATRE** + +1. Session B (Intermediate: First Choice Major) +**MUSICAL THEATRE ENTRO** + +2. Session A (Intermediate: Second Choice Major) +**OPERETTA** + +2. Session B (Intermediate: Second Choice Major) +**MUSIC THEORY (ADVANCED)** + +3. Session A +**VOCAL TECHNIQUES** + +3. Session B +**VOCAL TECHNIQUES** + +4. Session A +**MODERN DANCE (minor)** + +4. Session B +**MODERN DANCE (minor)** + +5. Session A +**BEGINNING WIND CLAS-FLUTE** + +5. Session B +**BEGINNING WIND CLASS-FLUTE** + +Private Lessons? + +- 4 - 30-min. lessons. Instrument: 4 +- 4 - 60-min. lessons. Instrument: 4 +- 4 - 30-min. lessons. Instrument: 4 +- 4 - 60-min. lessons. Instrument: 4 + +It doesn't matter which Session !!! + +**High School Class Schedule** + +High School students will be assigned five periods of classes, including private lessons. Please refer to your division's section in the Camp Extra for a complete discussion of classes, scheduling, prerequisites and audition requirements. **Note:** the Camp does not guarantee participation in more than one major activity. + +Major Courses: +At left; list Class Names in order of preference. + +1. First Choice Major Course Name / Instrument (if applicable) + +1. Minor Course Name + +2. Second Choice Major Course Name / Instrument (if applicable) + +2. Minor Course Name + +Minor Courses: +At right; list Class Names in order of preference. + +3. Third Choice Major Course Name / Instrument (if applicable) + +3. Minor Course Name + +4. Minor Course Name +5. Minor Course Name + +Private Lessons? + +- 8-30-min. private lessons. Instrument: 8 +- 8-60-min. private lessons. Instrument: 8 + +**Additional References given to whom?** + +Name of person in receipt of Artistic Recommendation form "C." + +Home Telephone: Area Code + Number + +Name of person in receipt of Academic Recommendation form "D." + +Home Telephone: Area Code + Number + +How did you first learn about Interlochen? + +**Optional.** Applicant please indicate: Asian American Black/African American Chicano/Mexican American Puerto Rican + Native American/American Indian White/Caucasian Other, please specify: + +No application can be processed without the signatures of Applicant and Parent or Guardian. + +**Send Admission Materials to:** +Admissions Office + +**Applicant Signature** +I have answered the questions on this application to the best of my ability and believe my answers are true and correct. + +10/31/94 + +Date + +**Parent Guardian Signature** +I have read this application and the response are true and correct to the best of my knowledge. I support this student's application to the Interlochen Arts Camp. + +**Please enclose the required \$225 with your application.** See page 2 of the Camp Extra for a complete discussion of Camp cost and refund policy. Your check is payable to [redacted] You may use a credit card: VISA, MasterCard, Discover and American Express. + +## About This Form + +Please answer all questions below. Refer to the "Admissions" section of the Camp Extra (page 2) for complete application and financial aid information. The application deadline for first priority review is **February 15**. Applications made after this date are welcome and will be reviewed on a rolling admission basis. **Send all materials to:** Admissions Office [redacted] + +MAR 01 1996 + +Complete address and phone information are on the back of this form. +**Sorry, but we cannot process an incomplete application.** + +## Application Checklist + +- Completed Application and Course Selection Form +- Application Form Signatures +- \$225. Application Fee +- Audition Materials Enclosed if Required (see your division's Course Descriptions in the Camp Extra). + +## Camp Application Fee + +Please enclose the required \$225. with your application. Make checks payable to [redacted] If you wish, you may charge the application fee to VISA, MasterCard, Discover or American Express. + +Credit Card Name and Number + +Expiration Date + +Print Card Holder Name + +Card Holder Signature + +## Signatures + +*We cannot process your application without the signatures of Applicant and Parent/Guardian.* + +Applicant Signature + +Date + +Parent/Guardian Signature + +Date + +*11/2/95* +I have answered the questions on this application to the best of my ability and believe my answers are true and correct. + +*I have read this application and the response are true and correct to the best of my knowledge. I support this student's application to the Interlochen Arts Camp.* + +## Applicant Information + +What Division are you applying for? Junior Session A Junior Session B Intermediate Session A Intermediate Session B + + High School Advanced String Quartet Institute (Session A-High School only) Creative Writing Institute (Session B-High School only) + +Non-U.S. students: When providing telephone number, include the country code and the city code before the local telephone number. + +[redacted] + +Date of this Application + +Seat [redacted] Zip + +Telephone: Area Code + Number + +Fax Number: Area Code + Number + +Grade completed by June. + +Age + +Sex M or F + +Applicant Social Security Number + +Nickname + +Birthdate (month/day/year) + + Yes + + No + +Have you previously attended Interlochen Arts Camp (excluding All-State)? Write years attended: + +*Friend* + +*2 (1994, 1995)* + +How did you first learn about Interlochen? + +**Optional.** Applicant please indicate: Asian American African American Mexican American Puerto Rican Asian + + Native American Caucasian Other, please specify: + +## Citizenship Information + +If you are **not** a U.S. Citizen, please complete this section. + +Country of Birth Country issuing the passport you will use to travel + +Full name of a contact person in the United States + +Home Street Address City State Zip + +Home Telephone: Area Code + Number Fax Number: Area Code + Number + +*3/7 CLW* + +## Teacher Information + +Name of current primary interructor in your arts area: [redacted] Title/Position: *CHORUS/VOICE INSTRUCTOR* + +Home Street Address City State Zip + +Home Telephone: Area Code + Number Fax Number: Area Code + Number Office Telephone: Area Code + Number + +Sch/FA N Audition # INT000048 I-20 MAJ *TMUCL ACCEPT* + +*TMUCL (3) participant* + +*Mista R* + +# *111494 \$55* + +### Parent or Guardian Information names' marital status + +Ito Sneer Address / if — Ern ioy/9 4 J + +c Father or Guardian (not + +Name of Employer and rem + +City State Zap + +state + +ephone: Area Code • Number Office Fax: Area Code • Number CO/ULU -Sr ConifeSer OcevpseicerTnle + +Home Stem Address + +Name of Employer and address Office Telephone: Area Code • Number Office Fax: Area Code • Number + +# Financial Information + +If you arc applying for aid. please fill out this section. + +Mother or Guardian Please Answer + +Father or Guardian Please Answer + +Please attach a copy of your most recent Federal Tax Form 1040 to this font. + +Arc you applying for financial aid' 0 Yes Er No e Arc you applying for The Gott/noes Scholar Program' 0 Yes ZCo + +Dora the student applying expert to be the recipient of any funds (scholarship. grant, award or prize) from any country, state. organization or individual specifically for attendance at the Intedochen Arts Camp) 0 Yes 21°..No + +If yes. name the title or award. scurry of award and amount What is the dollar amount applicant anti ipo or her family tan provide toward the Camp tuition' + +Earnings this year. + +Value of real estate. + +Earnings this year. + +Value of real estate. + +Please note unusual centrists or circumstances you would like taken into c + +# Choosing a Major + +In April a a wede orm in festiv al Sarasocompetition. , =ravels to Verona, Italy, for a vocal ish film . Mom, understandab their farmail ers, ' she said. be proud." fiat, :la& ssorned told me lenberg + +All Juniors (grades 3-6) are designated as General Arts below. Intermediate Division (grades 6-9) and High &I only minor courses, your designated major will be Gent a programs in the Intermediate and High School Divisiot . When he turns /8 he w The information below must be completed it at the am '...niuncr w ant + +Junior + +Please refer to the "Junior Division" section in the Camp Extra for a complete discussion of arts activities, class scheduling, prerequisites and audition requirements. + +- 1. Session A: Band or String Orchestra Instrument & Session B: Band or String 0rchesera Instrument + +# Intermediate + +Please enter the Major Code from the Camp Extra (i.e. DMODN or BCLAR-INET) + +Please refer to the "Intermediate Division" section in the Camp Extra for a complete discussion of major arts activities, course codes, class scheduling, prerequisites and audition requirements. + +- 1. Session A: (first choice maim. cedtrinuturnent) 1. Session B: (first choice major code:instrument) +- 2. Session A: (second choice major codelinstrumentl 2. Session B: (second choice major cede/imminent) + +# High School + +Please enter the Major and Code from the Camp Extra. (i.e. TMUCL OR OVIOLIN) + +- L First Choice Manx Course Name and Code WitargE napalm , MUSicilt TAI(ILL Instrument (if applicable) razr cfirne MrkFog +- 2. Second Choice Major Course Name and Code Instrument (if applicable) +- 3. Third Choke Maroc Cour,. Name and Code Inurement (if applicable) + +Please refer to the "High School Division" section in the Camp Extra for a complete discussion of major arts activities, daily class scheduling, prerequisites and audition requirements. + +## About This Form + +## Applicant Name + +This part of the application will be used for class registration. Your major will he determined through the Admissions process. You do not need to indicate your major on this page. Please complete the appropriate section to indicate classes that you would like in addition to your major. + +First Name Middle Lug + +### Junior + +Please list class names in order of preference. Do not list according to time. ' Remember to include all classes since there are no majors in this division. + +Students in the Junior Division will be assigned three periods of arts activities, including private lessons. Students who complete grade 6 have the option of selecting an additional arts class in place of land recreation. Please refer to the "Junior Division" section in the Camp Extra for a complete discussion of classes, scheduling and prerequisites. + +1..Saston A: (first choice area of interns) I -Session B. (lint choke stn of insane) + +Session A: (second choice arm cruxes's.) 2. Session B: (second Omer area al inteiels) + +&Session A: (third choice) 3-Session B: (third choice) + +4. Session A: (fourth choice) 4- Samuel B: (fourth choice) + +5. Session A: (alternate choice) 0.Session B: (alternate choice) + +Private Lessons 0 4- 30 minuet lemons. (Instrument) 0 4 30 minute lessons. (Inumunem) + +0 4 . 60 minute lemons. (Instrument) 0 4 . 60 minute lessons. (Sacrament) + +Poitnet Campers Only: Teacher preference for private lessons. Former (simpers Only Teaches preference for pr. lessons. + +# Internals!. + +Please list only minor class names in order of preference. Do not list according to time. Please note that most majors will count as two periods of classes. + +Private Lessons + +Students in the Intermediate Division will be assigned four periods of arts activities, including private lessons. Students who complete grade 9 have the option of selecting an additional class in place of recreation. Please refer to the "Intermediate Division" section in the Camp Extra for a complete discussion of classes, scheduling, prerequisites and audition requirements. + +1. Setae A: (fiat choice) 1. Session B. (line chart) + +2. Session A: (attend choice) 2. Seams B: (mad choice) + +3. Session A: (third choice) 3. Session B: (third choice) + +4. Session A. (alternate choice) 4. Session B: (alternate choice) + +O 4 30 minute lessons. (Inutomms) 0 4.30 minute lessons. (Instrument) + +O 4.60 minute lessons. (Instrument) 0 4 - 60 minute Irma fimuument) + +O 4 .60 minute lessons with 2 ponds wage. (Instrumem) 0 4 - 60 minute lessons with 2 periods pactire.Onunienent) + +Forme, Campers Only: Trochee prefennce for minor leuom. Fan\*. Campers Only Teacher preference for ptivase know.. + +# High School + +Please list only minor class names in order of preference. Do artist according to time. Please note that most majors will count as two periods of classes. + +High School students will be assigned five periods of arts activities, including private lessons. Please refer to the "flesh School Division" section in the Camp Extra for a complete discussion of classes, scheduling, prerequisites and audition requirements. + +0 eereitit L110 r KS hr) L Fi /Choice 1. First Altetnste + +2. Second Choice 2. Second Alternate + +3. Third enure + +4. Founts Choice + +.4., Voice soprano + +Describe previous training and experience in this area. + +CHECK LAST YEARS' RECORDS OF GREAT ACHEIVEMENTS! + +What is your secondary instrument or interest? + +Number of Years Studied + +Describe previous training and experience in this area. + +**Music Students:** + +Previous experience in Orchestra: Number of Years / Position + +Previous experience in Band: Number of Years / Position + +List **two** difficult works performed in orchestra, band or in ensemble within the past year. + +Nothing's too difficult! + +List the **two** most difficult solos you have mastered on your primary instrument or sung. + +**Personal Information** + +Names of brothers and ages + +Names of sisters and ages + + Father Mother/Maiden Name: + +[Redacted] + +Swedish + +Height + +Weight + +Primary language spoken at home + +English + +Secondary language (if any) spoken at home + +Note any physical, psychological, medical or other condition requiring special attention or care (such as sleepwalking, fear of storms, bed wetting, etc.). + +None + +How do you rate your child in terms of personal adjustment, such as his or her sense of self worth, ability, independence, etc.? + +See records and awards from last year + +How do you rate your child in terms of social adjustment? Has many friends Has few friends Has one or two close friends + + Has had close association with older children Younger children Children his or her own age + +No + +Is there any phase of personal or social adjustment which you hope Camp will aid? + +Please give any information that might be helpful in guiding the educational and personal development of your child. + +**Send all materials and direct inquiries to:** + +When using U.S. Pastal Service send to: + +When using Federal Express, UPS and Airborne Express send to: + +Telephone: + +[Redacted] + +[Redacted] + +[Redacted] \ No newline at end of file diff --git a/marker2/ds9/EFTA00089964/EFTA00089964.metadata.json b/marker2/ds9/EFTA00089964/EFTA00089964.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..f9644e0a0cb3f6f72f7bcb3e0953713cef7b523c --- /dev/null +++ b/marker2/ds9/EFTA00089964/EFTA00089964.metadata.json @@ -0,0 +1,1766 @@ +{ + "source_pdf": 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Refer to the "Admissions" section of the Camp Schedule (page 1) for complete application and financial aid information. The application deadline for first priority review is **February 15**. Applications made after this date are welcome but will be reviewed on a rolling admission basis. **Send all materials to:** Admissions Office ([redacted]) Camp, [redacted] Interlochen, MI 49642-61199. Complete address and phone information are on the back of this form. **Sorry, but we cannot process your application without the following materials:** + +### Application Checklist + +- Completed Application and Class Selection Form +- Application Form Signatures +- Audition materials enclosed if replaced (see audition requirements in the Camp Schedule) +- Tex forms of applying for financial aid + +### Camp Application Fee + +Please enclose the required \$35. with your application. Make check payable to "Interlochen Arts Camp." If you wish, you may charge the application fee to VISA, MasterCard, Discover or American Express. + +*SCHOLARSHIP from J Epstein & Ly Marcuell* + +Credit Card Name and Number + +Expiration Date + +Print Card Holder Name + +Card Holder Signature + +[redacted] + +[redacted] + +3-3-98 + +### Signatures + +We cannot process your application without signatures. + +**Applicant Signature** +I have answered the questions on this application to the best of my ability and believe my answers are true and correct. + +3-3-98 +Date + +### Parent/Guardian Signature + +Date + +I have read this application and the responses are true and correct to the best of my knowledge. I support the student's application to the Interlochen Arts Camp. + +### Applicant Information + +What division are you applying for? + +- High School +- Advanced String Quarter Institute (Session A - High School Only) +- Creative, Writing Institute (Session B - High School Only) + +- Tenplor Session A +- Tenplor Session B +- Intermediate Session A +- Intermediate Session B +- If my first session choice is full, I would be interested in an alternative session. + +Enter your Interlochen ID+ if located on your cover labor + +*AP000438147* + +First Name [redacted] + +Profession + +Last Suffix + +[redacted] + +*SOUTH AFRICA* + +Home Street Address + +City + +[redacted] + +Home Telephone And Code + Number + +[redacted] + +Home Fux Number Area Code + Number + +Age + +Sex M or F + +Birth Date (month/day/year) + +Homal Address + +Citizen is not completed by June + +International students: When providing telephone number, include the country code before the local telephone number. + +Nickname (If any) + +Applicant Social Security Number + + Yes No Have you previously attended Interlochen Arts Camp (excluding All-State)? Write years attended: *1997* + +How did you first learn about Interlochen? *from South African Society of Music Teachers* + +**Optional:** Applicant please indicate: Asian American African American Mexican American Porto Ram Asian + Native American Cucusian Other, please specify: + +### Citizenship Information + +If you are not a U.S. Citizen, please complete this section. + +*South Africa* + +*South Africa* +Country issuing the presport you will use to travel + +Full Name of a consult person in the United States + +[redacted] + +*NC* + +*USA* + +Home State Address + +Home Telephone Area Code + Number + +Fux Number Area Code + Number + +E-mail Address + +### Teacher Information + +[redacted] + +*PROF of Music* + +Homal Address + +Name or Profession + +Home Street Address + +*Danken* +*RTB* + +Parent or Guardian Information + +Parent or Guardian states (mortal discovered or not) DIVORCED who should receive billings + +Name of Children (Mother or Mother) Mary Mother Occupation/Title VIOLIN TENCHER + +Name of Children (Mother) SOUTH AFRICA Office Title (Rectification Code) SOUTH AFRICA Occupation/Title PROF + +Name of Employer and Address (Mother or Mother) SOUTH AFRICA Office Title (Rectification Code) SOUTH AFRICA Occupation/Title PROF + +Name of Employer and Address (Mother) SOUTH AFRICA Office Title (Rectification Code) SOUTH AFRICA Occupation/Title PROF + + Does the student have a physical health problem of which the Arts Camp should be award? NO + + Has the student consulted with or been refused to a psychiatrist, psychologist or mental health therapist for preliminary assessment within the past two years? NO + +Financial Aid Information + +Emerson Electric Co. Scholarship + +Note: Applications for the Emerson Electric Co. Scholars program must be postmarked by January 12, 1998. + +The Emerson Electric Co. Scholars program provides full audition grants for one student from each state, the District of Columbia and Puerto Rico. Students currently in grades 9-12 with a high proficiency in any of the following instruments: many apply: violin, virta, cello, buss, wireless and percussion instruments or harp. Please see page 7 of the Camp Schedule for the suggested reportaire list for an Emerson Electric Co. scholars audition. + +SCHOLARSHIP FROM J. EPSTEIN + G. MAXWELL +Note you applying for the Emerson Electric Co. Scholars program? Yes No I have enclosed the required audition materials. + +If not an Emerson Electric Co. Scholars winner would you still like to apply to the Arts Camp? Yes No + +If you are not an Emerson Electric Co. Scholars winner and would like to be considered for financial aid for the Arts Camp, please fill out the financial information below and attach a copy of your most recent 1040 Federal Tax Form. + +Are you applying for financial aid? Yes No I have enclosed the required audition materials. Does the student apply expect to be the receiptant of any funds (scholarship, grant, award or prize) from any country, state, organization or individual specifically for attendance at the Interstudent Arts Camp? Yes No + +If yes, name the title of award and amount. What is the dollar amount applicants and file or her family can provide toward the Camp station? + +Mother or Guardian Please Answer + +Father or Guardian Please Answer + +Earnings last year + +Value of net statute + +Earnings last year + +Value of net statute + +Earnings last year + +Value of net statute + +Springs amounts + +Please now universal expenses or circumstances you would like taken into consideration (select additional sheet if necessary). + +Please attach a copy of your most recent Federal Tax Form 1040 to this form + +Choosing Your Classes + +The information below must be completed in order to process your application. + +All juniors (grades 9-10) are attended based on the date of their completed application and the enrollment needs of the Camp. Juniors do not need to audition unless applying for financial aid. Intermediate (grades 6-9) and High School (grades 9-12) applicants must apply for audition-based or non-audition-based majors. The remainder of their schedules should be filed with non-audition-based major classes. Students selecting audition-based majors are attended based on their level of ability and the enrollment needs of the camp. Those selecting non-audition-based majors are attended based on the date of their completed application and the enrollment needs of the Camp. The applicant post is competitive and finished space is available therefore your early application is strongly recommended. Please note: very few spaces are available for the non-audition-based general arts major in the Intermediate division. + +Audition-Based and Non-Audition-Based Majors + +Intermediate Please enter the Class Code from the Camp Schedule (i.e. DMODN or CLARB) + +Please refer to the "Intermediate Division" section in the Camp Schedule for a complete discussion of classes, scheduling, prerequisites and audition requirements. Please fulfill audition requirements for each audition-based major entered below. + + If not admitted for the following major classes, please consider my admission for non-audition-based major classes only. + +1. Section A: first choice major class code/instrument Section B: first choice major class code/instrument + +2. Section A: alternative choice major class code/instrument Section B: alternative choice major class code/instrument + +High School + +Please enter the Class Code from the Camp Schedule (ie TMUCI or VIOLO) + +Please refer to the "High School Transition" section in the Camp Schedule for a complete discussion of classes, scheduling, prerequisites and audition requirements. Please fulfill audition requirements for each audition-based major entered below. + + If not admitted for the following major classes, please consider my admission for non-audition-based major classes only. + +1. ORCHESTRA (0) Instrument (if applicable) + +2. Alternate choice major class code + +3. Second alternate choice major class code + +CELLO + +Instrument (if applicable) + +Instrument (if applicable) + +Instrument (if applicable) + +# Non-Audition-Based Minor Class Selection Form + +A4381449 + +be sure to indicate that class on the preceding page. You do not need to indicate it on this page. Use this form only to select your non-audition-based minor classes. Please complete the appropriate section to indicate classes that you would like in addition to a major class, if applicable. + +**Applicant Name** + +[REDACTED] + +[REDACTED] + +[REDACTED] + +Past Name + +Middle + +Last + +(Please Print) + +### Junior + +Please list class names in order of preference, rather than in order of time. Remember to include all classes since there are no major classes in this division. + +Students in the Junior Division will be assigned three periods of classes, including private lessons. Students who complete grade 6 have the option of selecting an additional attendant class in place of land recreation. Please refer to the 'Junior Division' section in the Camp Schedule for a complete discussion of classes, scheduling and prerequisites. Do not schedule recreation classes on this form. They will be determined at the beginning of Camp. If interested in land or archeology, please list instrument and ensemble on the first line below. + +- 1. Session A: (first choice class) +- 2. Session A: (second choice class) +- 3. Session A: (third choice class) +- 4. Session A: (fourth choice class) +- 5. Session A: (fifth choice class) + +- 1. Session B: (first choice class) +- 2. Session B: (second choice class) +- 3. Session B: (third choice class) +- 4. Session B: (fourth choice class) +- 5. Session B: (fifth choice class) + +### Private Lessons + +- 4-30 minute lessons (Instrument) +- 4-60 minute lessons (Instrument) + +- 4-30 minute lessons (Instrument) +- 4-60 minute lessons (Instrument) + +Former Campers Only: Indicate Teacher preference for private lessons. + +Former Campers Only: Indicate Teacher preference for private lessons. + +### Intermediate + +Please list non-audition-based minor classes in order of preference rather than in order of time. Do not list major classes, if applicable. + +Students in the Intermediate Division will be assigned four periods of classes, including private lessons. Students who complete grade 9 have the option of selecting an additional class in place of recreation. Please refer to the "Intermediate Division" section in the Camp Schedule for a complete discussion of classes, scheduling, prerequisites and audition requirements. Do not schedule recreation classes on this form. They will be determined at the beginning of camp. + +- 1. Session A: (first choice class) +- 2. Session A: (second choice class) +- 3. Session A: (third choice class) +- 4. Session A: (fourth choice class) + +- 1. Session B: (first choice class) +- 2. Session B: (second choice class) +- 3. Session B: (third choice class) +- 4. Session B: (fourth choice class) + +### Private Lessons + +- 4-30 minute lessons (Instrument) +- 4-60 minute lessons (Instrument) +- 4-60 minute lessons with 2 periods practice (Instrument) + +- 4-30 minute lessons (Instrument) +- 4-60 minute lessons (Instrument) +- 4-60 minute lessons with 2 periods practice (Instrument) + +Former Campers Only: Indicate Teacher preference for private lessons. + +Former Campers Only: Indicate Teacher preference for private lessons. + +### High School + +Please list non-audition-based minor classes in order of preference rather than in order of time. Do not list major classes, if applicable. + +High School students will be assigned five periods of classes, including private lessons. Please refer to the "High School Division" section in the Camp Schedule for a complete discussion of classes, scheduling, prerequisites and audition requirements. + +- 1. ALEXANDER TECHNIQUE First Choice +- 2. ALEXANDER MUSIC FOR STRINGS Second Choice +- 3. CONDUCTING Third Choice + +- 4. Fourth Choice +- 5. Fifth Choice +- 6. Sixth Choice + +### Private Lessons + +- 4-30 minute lessons (Instrument) +- 4-60 minute lessons (If second Instrument) +- 4-60 minute lessons (If second Instrument) + +- 4-60 minute lessons (Instrument) +- 4-60 minute lessons (If second Instrument) + +Former Campers Only: Indicate Teacher preference for private lessons. + +**Artistic Information** + +All students please answer: + +What is your primary training or interest? + +Number of years of private study + +CELLO + +10 + +Does the previous training and experience in this area + +[REDACTED] + +Play in a symphony orchestra + +While is your primary instrument or interest? + +Number of years of private study + +Describe previous training and experience in this area + +[REDACTED] + +4 years + +Previous experience in Orchestra: Number of Years/Position + +Previous experience in Band/Number of Years/Position + +Reader of Section + +Reader of Section + +List two difficult works performed in orchestra, friend or in ensemble within the past year: + +Be Tchaikowsky for Symphony +Stravinsky for Fulcroid + +List the two most difficult solos you have plastered on your primary instrument or song: + +Haydon C may Cello Con. Saunt Saers Cello Concer + +**Personal Information** + +Names of involvers and ages + +Names of fathers and ages + +Child Name No. Is a statement of alignment of Interfachield? Father Mother/Muster Name + +[REDACTED] + +ENGLISH + +AFRIKANS + +Height + +Weight + +Primary language spoken at home + +Secondary language (if any) spoken at home + +Note any physical, psychological, medical or other condition requiring special attention or care (each as desperwilling, fear of storms, hod weather, etc.) + +How do you rate your child in terms of personal adjustment, such as his or her sense of self everything, ability, independence, etc? + +VERY FINE, IN EVERY RESPECT + +How do you rate your child in terms of social adjustment? has many friends has few friends has one or two close friends + has had close association with richer children younger children children has or have own age + +Is there any phase of personal or social adjustment which you hope Camp will add? + +Please give any information that might be helpful in guiding the educational and personal development of your child. + +**Send all materials and direct inquiries to:** + +When using U.S. Private Service send to: + +When using Federal Express, UPS and Airborne Express send to: + +Telephone: [REDACTED] +E-mail: [REDACTED] + +[REDACTED] \ No newline at end of file diff --git a/marker2/ds9/EFTA00089978/EFTA00089978.metadata.json b/marker2/ds9/EFTA00089978/EFTA00089978.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..ddb455846e104058e66617e65ac290cb286859ed --- /dev/null +++ b/marker2/ds9/EFTA00089978/EFTA00089978.metadata.json @@ -0,0 +1,778 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00089978.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 4, + "chars": 14933, + "elapsed_seconds": 107.22, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Interlochen Arts Camp Application for Admission", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 126.68399999999998, + 66.42 + ], + [ + 433.29599999999994, + 66.42 + ], + [ + 433.29599999999994, + 89.91 + ], + [ + 126.68399999999998, + 89.91 + ] + ] + }, + { + "title": "Instructions", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 95.58 + ], + [ + 77.724, + 95.58 + ], + [ + 77.724, + 105.30000000000001 + ], + [ + 30.6, + 105.30000000000001 + ] + ] + }, + { + "title": "Application Checklist", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 31.823999999999998, + 144.99 + ], + [ + 116.892, + 144.99 + ], + [ + 116.892, + 155.52 + ], + [ + 31.823999999999998, + 155.52 + ] + ] + }, + { + "title": "Camp Application Fee", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 33.048, + 177.39000000000001 + ], + [ + 119.952, + 177.39000000000001 + ], + [ + 119.952, + 188.73000000000002 + ], + [ + 33.048, + 188.73000000000002 + ] + ] + }, + { + "title": "Signatures", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 33.660000000000004, + 241.38 + ], + [ + 79.56, + 241.38 + ], + [ + 79.56, + 251.10000000000002 + ], + [ + 33.660000000000004, + 251.10000000000002 + ] + ] + }, + { + "title": "Parent/Guardian Signature", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 361.08, + 238.95 + ], + [ + 468.18, + 238.95 + ], + [ + 468.18, + 251.10000000000002 + ], + [ + 361.08, + 251.10000000000002 + ] + ] + }, + { + "title": "Applicant Information", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 35.496, + 286.74 + ], + [ + 122.4, + 286.74 + ], + [ + 122.4, + 298.08 + ], + [ + 35.496, + 298.08 + ] + ] + }, + { + "title": "Citizenship Information", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 39.78, + 538.6500000000001 + ], + [ + 131.57999999999998, + 538.6500000000001 + ], + [ + 131.57999999999998, + 550.8000000000001 + ], + [ + 39.78, + 550.8000000000001 + ] + ] + }, + { + "title": "Teacher Information", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 39.78, + 652.0500000000001 + ], + [ + 122.4, + 652.0500000000001 + ], + [ + 122.4, + 664.1999999999999 + ], + [ + 39.78, + 664.1999999999999 + ] + ] + }, + { + "title": "For Internal Use", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 39.78, + 733.05 + ], + [ + 110.16, + 733.05 + ], + [ + 110.16, + 745.2 + ], + [ + 39.78, + 745.2 + ] + ] + }, + { + "title": "Parent or Guardian Information", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 38.556, + 63.17999999999999 + ], + [ + 161.568, + 63.17999999999999 + ], + [ + 161.568, + 75.33 + ], + [ + 38.556, + 75.33 + ] + ] + }, + { + "title": "Financial Aid Information", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 44.676, + 236.51999999999998 + ], + [ + 164.62800000000001, + 236.51999999999998 + ], + [ + 164.62800000000001, + 248.67000000000002 + ], + [ + 44.676, + 248.67000000000002 + ] + ] + }, + { + "title": "Emerson Electric Co. 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NATHAN, District Judge: + +Before the Court is the Defendant's fourth motion in limine to "exclude evidence related to Accuser-3," to whom the Court refers as Witness-3, on the grounds that the testimony is not direct evidence of the charged conspiracies and is inadmissible under Federal Rules of Evidence 404(b) and 403. Dkt. Nos. 387, 444. The Court has twice heard argument related to this motion, including argument at the November 10, 2021 in camera hearing that was sealed pursuant to Federal Rule of Evidence 412. See generally Nov. 1, 2021 Transcript; Nov. 10, 2021 Transcript. At the November I, 2021 hearing, the Court provided a brief explanation of its current position based on the information then before it, but the Court ultimately reserved ruling pending additional briefing. The Court is now in receipt of the parties' additional briefing and accordingly is prepared to resolve the motion.' + +The Government now proffers that the anticipated testimony of Witness-3 will describe how she met the Defendant and her relationship with the Defendant and Mr. Epstein. In particular, Witness-3 is anticipated to testify how Defendant introduced her to Mr. Epstein, how + +I This Memorandum Opinion & Order is filed temporarily under seal to permit the parties the opportunity to propose sealing or limited redactions pursuant to Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006), and Federal Rule of Evidence 412(cX2). + +massages progressed to involve sexual activity, and Ms. Maxwell's role in facilitating those massages. Based on all of the information now before the Court, including a substantially more detailed proffer by the Government as to the anticipated testimony, see Gov. Supp. Ltr. at 2-3 (Nov. 5, 2021); see also Dkt. No. 452 at 42-43, the Court concludes that some of the anticipated testimony may serve as direct evidence of the Mann Act counts. + +The Government rightly acknowledged at the November 1 pretrial conference that Ms. Maxwell cannot be found guilty on this witness's testimony alone for any of the crimes charged in the Indictment. Nov. 1, 2021 Tr. at 67:12-25, 68:13-19, 69:4-9, 70:23-71:2, 72:22-25. As the Government acknowledged, with respect to the jury's determination in this case, this witness is not a victim of any of the crimes charged in the Indictment. See id. at 69:4-9; Nov. 10, 2021 Tr. at 164:19-165:3.2 However, evidence of legal conduct can of course be relevant evidence of illegality. And conduct that cannot itself form the basis of a conviction can serve as direct evidence of the crimes charged. See, e.g., United States v. Robinson, 702 F.3d 22, 37 (2d Cir. 2012) (affirming admission of defendant pimp's relationship with and control over women who worked as prostitutes as direct evidence of 18 U.S.C. § 1591(a) charge). Thus some of the anticipated testimony described above can serve as direct evidence, notwithstanding the fact that the alleged conduct as to Witness-3 was not illegal for the purpose of the charges in this case. + +Portions of the anticipated testimony may also serve permissible purposes under Rule 404(b), namely proving motive, intent, and knowledge. See Fed. R. Evid. 404(b)(2). The witness is expected to testify about certain statements by Ms. Maxwell. For example, the + +2 At the November I conference, the Court denied the Defendant's motion to preclude the Government from referring to alleged victims as "victims" and "minor victims." Nov. I, 2021 Tr. at 4. In contrast to the other alleged victim witnesses, it is not (nor could it be) the Government's litigating position that this witness is a victim of the crimes charged in the Indictment. Given this, the Government may not refer to this witness as a "victim" or a "minor victim" in front of the jury. Doing so would constitute prejudicial error for the reasons explained in this Memorandum Opinion & Order. + +Government expects the witness to testify: that after the witness massaged Mr. Epstein while he was nude, Ms. Maxwell asked the witness if she "had fun and whether Mr. Epstein liked the massage"; that Ms. Maxwell commented that if the witness were not engaging in sexual activities with Mr. Epstein, performing sexual acts would "fall" more to Ms. Maxwell or someone else; and that Ms. Maxwell commented on Mr. Epstein's "significant sexual needs." Gov. Supp. Ltr, at 2-3 (Nov. 5, 2021). These statements are relevant because the jury may conclude that they tend to establish that the Defendant knew the alleged massages were sexualized and the Defendant's motive for facilitating the encounters. The witness is also expected to testify that the Defendant asked the witness to find other girls to massage Mr. Epstein. Id. at 3, 9. This testimony is relevant because the jury may conclude that it tends to establish the Defendant's intent to recruit girls for sexualized massages. The Court will also permit testimony that Ms. Maxwell provided the witness with a schoolgirl uniform and told the witness to wear the uniform and bring Mr. Epstein tea. Id. at 3. Although it is not the only available interpretation of this evidence, the jury could conclude that Defendant's alleged instruction to an I8-year-old to wear a schoolgirl uniform tends to establish both the Defendant's knowledge of Mr. Epstein's sexual preferences for school-age girls and her intent to actively cater to those preferences. Such knowledge and intent are of course proper purposes under Rule 404(b).3 + +3 Defendant argues that this witness's testimony is impermissible propensity evidence as to Mr. Epstein under Rule 404(b). Def. Supp. Resp. at 5.7 (Nov. II, 2021). The Court is unpersuaded. The testimony is not offered to show that Mr. Epstein acted in accordance with a certain character trait on a particular occasion. Rather, it is probative of whether Ms. Maxwell knew of or at least believed he had a sexual interest in school-age girls, which a jury may find tends to establish the Defendant's intent and motive as to the charged crimes. See Roe v. Howard, 917 F.3d 229, 245-46 (4th Cir. 2019) (rejecting argument that husband's assault of a non-party housekeeper was improper character evidence under Rule 404(b) in a Trafficking Victims Protection Act action against the wife for facilitating husband's assaults of live-in housekeeper). + +The probative value of the anticipated testimony must of course be balanced with any potential prejudice under Rule 403. As the Court noted at the November 1 conference, there is a risk that the jury may confuse the issues and think that the sexual conduct this witness is describing itself constitutes the illegality charged in the Indictment due to the closeness in age of this witness to the age of consent. Nov. 1, 2021 Tr. at 89-90. There is also the risk that the jury may convict Ms. Maxwell due to feelings of immorality or sympathy for the witness despite the lack of illegality with regard to the crimes charged in the Indictment. However, the Court concludes that this risk of prejudice can be sufficiently minimized through two avenues. First, the testimony must be carefully limited. Second, there must be a clear limiting instruction. + +As to the first, the witness is limited to stating that sexual activity occurred but is precluded from providing detailed descriptions of the sexual activity. There is little to no probative value of a witness describing sexual activity when that witness's testimony regarding the sexual activity cannot form the basis for the conviction of the crimes charged. For example, any prejudice from the schoolgirl uniform testimony described above is substantially diminished by limiting the proffered testimony to the Defendant's interaction with the witness and testimony indicating that sexual activity allegedly took place without describing the details of that sexual activity. Unlike the details of the sexual conduct itself, this anticipated testimony would not be unduly prejudicial. In contrast, the minimal probative value of the details of sexual conduct would be substantially outweighed by the risk of the jury convicting Ms. Maxwell on an improper basis. The same is true of the witness's subjective experience of the sexual conduct and any emotional or other impact the sexual conduct had on the witness because such testimony cannot form the basis of a conviction in this case. Accordingly, the witness is limited, as the Government phrased it, to describing her "factual experience" as to the lines of testimony + +described above. See Gov. Supp. Ltr. at 12 (Nov. 5, 2021). For example, in a recent murder trial, the Court permitted the nephew of the victim to describe his uncle's wounds because the nephew, who had served as a caretaker, had some information that was not cumulative of the medical records. The Court expressly cautioned the Government that it would not permit emotional testimony, or the probative value would be outweighed by the prejudice: + +[I]t's clearly a 403 line here. You have cumulativeness with the medical testimony, you have graphic descriptions from a relative who cared for the victim which could very well produce sympathies and prejudice that would interfere with and overcome the medical facts that you need for purposes of proving causation.... I am certainly going to cut off the line at any graphic descriptions. To the extent that walking this person through questions regarding the medical condition is emotional testimony, I think we are — it will have to be stopped. + +United States v. Berry, No. 20 Cr. 84 (AJN), Dkt. No. 138 at 13; see also id. at 15. In that case, the Government agreed that the line had to be carefully guarded. Id. at 13-14. The transcript of that ruling is attached for counsel's reference. See Exhibit A. The Court cautions the Government to proceed carefully because the Court will not allow testimony that steps over this 403 line. The Court will allow some leading questions for this portion of the testimony to help ensure that it does not. + +Finally, the Court concludes that this witness's anticipated testimony as to the sex trafficking counts is inadmissible. Although the Government's letter points to some relevant direct evidence that this witness could provide regarding these counts, see Gov. Supp. Ltr. at 6-7, any minimal probative value of this evidence is diminished by its remoteness in time to the charged sex trafficking conspiracy, which is alleged to have run from 2001 to 2004. This evidence does not face the same problem as it relates to the Mann Act conspiracies, which are alleged to have begun in 1994 (and when the Defendant allegedly began her relationship with this witness.). Because the risk of unfair prejudice substantially outweighs the probative value of this evidence as to the sex trafficking counts, the witness is precluded from testifying that Mr. Epstein paid her for massages when she was an adult. + +The Court thus draws the line described above for limiting Witness-3's testimony. Permitting the entirety of the proffered testimony carries a risk that the jury may convict Ms. Maxwell due to conduct that cannot form the basis of a conviction for the charged crimes. But by limiting the testimony to the few categories of relevant testimony outlined above, the prejudice is substantially minimized. + +Moreover, whether as direct evidence of the Mann Act counts or offered for a proper purpose under 404(b), this testimony must be paired with a proper limiting instruction to guard against potential juror confusion. The Defense has submitted proposed limiting instructions, and the Government agrees that some sort of instruction is appropriate, although it disagrees with the basis for the instruction. Dkt. No. 452 at 50 n.12; Gov. Supp. Ltr. at 12 (Nov. 5, 2021). In accordance with this ruling, the Court proposes the following instruction before this anticipated witness testifies: + +You will hear testimony from the next witness about interactions that she says she had with the Defendant and Mr. Epstein. I instruct you that because the witness was over the relevant age of consent at the relevant time period, any sexual conduct she says occurred with Mr. Epstein was not "illegal sexual activity" as the Government has charged in the Indictment. I instruct you that this witness is not a victim of the crimes charged in the Indictment. To the extent you conclude that her testimony is relevant to the issues before you, you may consider it. However, you may not convict the Defendant on the basis of the testimony regarding the sexual conduct between this witness and Mr. Epstein. Nor may you consider this testimony as any kind of reflection on Mr. Epstein's nor Ms. Maxwell's character or propensity to commit any of the crimes charged in the Indictment. + +The Court also proposes the following instruction before any testimony by other witnesses regarding sexual activity that occurred after the relevant age of consent: + +I anticipate that you will hear testimony from the next witness about sexual conduct that she says she had with Mr. Epstein in [insert relevant jurisdiction, e.g. New Mexico]. I instruct you that because the witness was over the age of consent in [insert relevant + +jurisdiction, e.g. New Mexico] at the relevant time period, the sexual conduct she says occurred with Mr. Epstein was not "illegal sexual activity" as the Government has charged in the Indictment. However, to the extent you conclude that her testimony is relevant to the issues before you, you may consider it. However, you may not consider this testimony as any kind of reflection on Mr. Epstein's nor Ms. Maxwell's character or propensity to commit any of the crimes charged in the Indictment. + +The parties may submit any requested edits to the proposed limiting instructions that are consistent with the Court's ruling or indicate that they have none on or before November 21, 2021. + +This resolves Dkt. Nos. 387, 444. + +SO ORDERED. + +Dated: November 19, 2021 New York, New York )44 + +ALISON J. NATHAN United States District Judge + +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK + +-----x + +UNITED STATES OF AMERICA, New York, N.Y. + +v. 20 Cr. 84 (AJN) + +RALPH BERRY, + +Defendant. + +-----x + +September 21, 2021 +9:45 a.m. + +Before: + +HON. ALISON J. NATHAN, + +U.S. District Judge +And A Jury + +APPEARANCES + +AUDREY STRAUSS + +United States Attorney for the +Southern District of New York + +BY: [REDACTED] + +[REDACTED] + +[REDACTED] + +Assistant United States Attorneys + +LAW OFFICE OF MARK S. DEMARCO + +Attorneys for Defendant + +BY: MARK DEMARCO + +-AND- + +LAW OFFICES OF EZRA SPILKE, PLLC + +BY: EZRA SPILKE + +4 5 MR. HOBSON: Good morning, your Honor. Adam Hobson, Jacob Fiddelman, and Dominic Gentile for the government. + +6 THE COURT: Good morning. + +7 For the defendant? + +8 9 10 MR. DeMARCO: Good morning. For Mr. Berry, Mark DeMarco and Ezra Spilke, Ms. Mayerlin Ulerio, and of course Mr. Berry. + +11 THE COURT: Good morning, counsel. + +12 Good morning, Mr. Berry. + +13 THE DEFENDANT: Good morning. + +14 15 16 17 THE COURT: I had hoped to start at 9:00 but Mr. Berry wasn't brought until now. Hopefully that won't repeat going forward. We will make sure that things are in place to prevent that so we can timely get started each day. + +18 19 20 21 22 23 24 25 I thank everyone for being here on time. Let me ask, as a matter of procedure, we will wait for the jury department to let us know when the panel is checked in and assembled and in their seats, and then can head over to 500 Pearl to commence jury selection. My purpose for today is to confirm the receipt of the voir dire questionnaire that I sent yesterday with the noted change, make sure everybody got that. The second is to confirm that there have been no additional plea offers. And + +(Case called) + +THE DEPUTY CLERK: Counsel, please state your name for the record, starting with the government. + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +lastly, I made the note, make sure there are no questions regarding jury selection now that you have been to the walk-through in the jury selection room where selection will take place. + +So, let me ask, everybody received the voir dire with the noted changes? + +MR. HOBSON: Yes, your Honor. We did. + +THE COURT: Nothing additional, Mr. Hobson? + +MR. HOBSON: Nothing additional. + +MR. DeMARCO: Yes, your Honor; and nothing additional. + +THE COURT: Thank you. + +Any additional plea offers that I need to allocute on? + +MR. HOBSON: No additional plea offers have been extended, your Honor. + +THE COURT: OK. And then let me confirm if anybody has any questions about jury selections. To repeat the basic process, I will qualify 33 potential jurors that represents 12 jurors and three alternates, 10 peremptories as to the main panel for the defense, six peremptories for the government, one peremptory per side with respect to the alternates. And the way that we are operating under the COVID protocols, the jury department will, after the jury panel members are checked in, they'll be randomly assigned a number consistent with a list that the jury department generates, they will be seated in that numerical order in the jury selection room. I understand 1 + +through 42 will be in the main jury selection room and then 43 through, I believe 82 -- we will get the final number once we see what the return on the summons is -- will be seated in courtroom 9C also at 500 Pearl, with a live feed to 9C of everything taking place in the jury assembly room. + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +I will make preliminary instructions which you have seen after you and I enter the courtroom. The panel members will be seated at that point. I will make my preliminary remarks, the written questionnaire that the jurors can read along with will be handed out at that point, both in the jury assembly room and in 9C simultaneously through court staff. will instruct the jurors not to write anything on the questionnaire with the exception of circling a number if they have a "yes" response to that question as I read through the questionnaire. + +So, at that point I will turn to panel member juror no. 1 and go through and read the questionnaire getting "yes" or "no" response to each question. If the answer is "yes" following up as appropriate. To the extent that the matters touched upon could influence other jurors or are of a sensitive nature, we will bring that juror over to the plexiglass area to my right in the jury assembly room, there is markings on the floor where folks stand and the noise machine will be on so that others cannot hear, and I will inquire with the juror as to any necessary follow-up. + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +Once we get through, assuming we get through juror no. 1 without any for-cause issues, I will turn to juror no. 2 and say do you have any "yes" responses? And then we will take those in order as they come. + +If any juror needs to be dismissed for cause, let's say juror no. 2 needs to be dismissed for cause, then we will proceed with the same process with juror no. 3. Any "yes" questions, taking those 33 qualified jurors. one at a time, continuing until we have + +Once we have 33 qualified jurors you will exercise your peremptory strikes by list and simultaneously, that is, each side will produce a list with the government's six strikes as to the main panel and one strike as to the alternate panel, and the defense will write its list with 10 strikes as to the main panel and one strike as to the alternate panel. + +Obviously, before anyone is dismissed, I will hear from counsel if any applications or issues need to be raised if you are satisfied with our jury. Once we get there we will read the names of the selected jurors, dismiss to the jury department the unused jurors, and then proceed over back across the street over here. I believe what we will do is have Ms. Williams take the jurors to the jury room, which is an outfitted courtroom so they can put their belongings down, she can give them notebook and pen, bring them back in. At that point she will swear the jury and I will give preliminary instructions and opening + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +statements. Whether that happens today or tomorrow we will see. Hopefully today. + +Any questions or issues to raise with the process I have described? Mr. Hobson? + +MR. HOBSON: Your Honor, no. One small thing on the voir dire. We submitted a list of names for the Court to read. One thing I wanted to flag for the Court is one of the witnesses' names we asked you to include is Jesus Ortiz, and that's how he pronounces his name, with a hard J. I want to flag that for the Court so that his name is read accurately to the jury. + +THE COURT: Let me see if there are any other pronunciation issues. + +Mr. DeMarco, while I am pulling that up, any other questions or issues with respect to the process? + +MR. DeMARCO: No, your Honor. + +THE COURT: And, Mr. DeMarco, you are going to keep your mask on so I don't have to keep coming at you about it? + +MR. DeMARCO: I will do my best. + +THE COURT: OK. Don't take it off to talk. + +MR. DeMARCO: Sorry? + +THE COURT: Don't take it off to talk. + +MR. DeMARCO: OK. I took it off to listen the last time. + +THE COURT: That's an anatomical anomaly. + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +I should say, of course, once we are in the courtroom then counsel in the plexiglass box with the HEPA filter will be able to remove their mask for questioning, and to the extent outside of the jury we have argument or the like, we can do that in there to aid that that process. + +It's Ms. Ulerio, Mayerlin, am I saying that correctly? + +MS. ULERIO: Yes. + +THE COURT: And you have another paralegal Dylan Schneider who may be here? + +MR. DeMARCO: Yes, your Honor, but he won't be with us in court. + +THE COURT: And what about Jeremy Schneider? Mr. Schneider. + +MR. DeMARCO: He is unable to be with us. + +THE COURT: He won't be at trial at any point? + +MR. DeMARCO: No. I don't expect him to be here. + +THE COURT: Should I include him in the voir dire just in case. + +MR. DeMARCO: I think you should, Judge, because his name might come up and I just can't see how or where or under what scenario. But, just to be safe. + +MR. HOBSON: His name is on the stipulations, so maybe to be safe. + +THE COURT: Just to note, when I do introduce counsel for purposes of the voir dire, and Mr. Berry, and the + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +paralegals, I will ask each of you to stand as I say your name so that the jurors can see you, the panelists can see you. So, I will note Mr. Schneider is part of the team but not present today and may not be present every day of the trial. + +Appropriate, Mr. DeMarco? + +MR. DeMARCO: Yes, Judge. + +THE COURT: OK. So Jesus Ortiz is the pronunciation. + +How about, Mr. Hobson, how do I pronounce no. Q? + +MR. HOBSON: I believe, your Honor, it is Vyacheslav, and the last name is Polosin. + +THE COURT: Vyacheslav Polosin. OK. + +Special Agent Stefano Braccini? + +MR. HOBSON: And he is in the courtroom. + +THE COURT: OK. I think that's it. Other issues to take up? + +MR. HOBSON: I don't think so, your Honor. + +THE COURT: Mr. DeMarco? + +MR. DeMARCO: No, your Honor. Not now. + +Judge, how much time do we have before we walk over? Maybe we could use this time efficiently, because I do have I raised with the government an issue I was going to raise with their first witness so you tell me. + +THE COURT: I was told around between 10:00 and 10:30 but we won't know until they actually call over so I'm happy to use the time and if we get the call, we will pause. + +4 5 6 MR. DeMARCO: I did consult with the government. I was unpersuasive. I was hoping to be more successful with your Honor. + +7 THE COURT: OK. And the first witness is? + +8 MR. DeMARCO: Mr. Rasheen Vega. + +9 10 THE COURT: Go ahead. And if you could speak into the mic, please? + +11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. DeMARCO: It seems to me, your Honor, from my reading of the 3500 material, that we can expect Mr. Vega to testify to something like this: That he was the nephew of Mr. Jones, that he was 11 years old at the time that Mr. Jones was shot in June of 2000, that he witnessed a portion of that shooting or the aftermath of that shooting which I am OK with. The problem that I have with his prospective testimony is this: It also appears from reading the 3500 that the government will seek to elicit from Mr. Vega testimony about the horrific, horrific bedsores or compression sores that Mr. Jones was suffering from at the time of his death. I believe there is at least notes that Mr. Vega observed the sores to be oozing, observed Mr. Jones to be in terrible, terrible pain and suffering at or near the time of his death, and my concern is that, A, in light of the fact that two doctors are being called + +MR. DeMARCO: OK. + +THE COURT: Was it an issue you wanted to speak to the government about first? + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +by the government and, even apart from that, Mr. Vega is not qualified to testify about the injuries that he observed; and B, that this type of testimony serves no purpose but to elicit or garner sympathy from the jury and will be unduly prejudicial to Mr. Berry. + +So, that's the basis of my objection to Mr. Vega, should he be asked those types of questions. + +THE COURT: Understood. + +Mr. Hobson? + +MR. HOBSON: Your Honor, there are two large topics that Mr. Vega is anticipated to testify about. I think it is consistent with what Mr. DeMarco says is, one, he was a percipient witness to the shooting itself; and two, he observed the victim's injuries after the shooting and was involved in the victim's care in the 10 years between the shooting and the victim's death. I take it it is the second category that the defendant is objecting to. But here, cause of death is obviously a big issue in this case and it is something that it is our burden to prove, that the injuries from the shooting lead to his death. And we expect the evidence to show that, as a result of the shooting, the victim became paralyzed from the waist down and that meant that he was confined to a wheelchair -- whereas he was not in a wheelchair before -- and developed serious complications as a result of that including serious sores which later led to infection and the victim's + +death. + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +We will not be eliciting expert medical testimony or opinion from this witness, he will be simply testifying to what he observed with respect to the victim's physical condition during the 10 intervening years between the shooting and the death and that's important evidence, it's evidence that will then be consistent with things that medical experts to be qualified as experts will be called to testify about, but those experts did not observe these injuries during the 10 intervening years. They also did not observe Mr. Jones prior to the shooting. For instance, they wouldn't be able to tell you whether he was in a wheelchair before the shooting or after the shooting. They wouldn't be able to tell you if he developed those bedsores before the shooting or after the shooting. It is Mr. Vega's observations that will allow the jury to connect those dots. Given how important causation is in this case, we think it is important that the jury understand those injuries. + +THE COURT: Will medical records, that will be introduced, describe the bedsores? + +MR. HOBSON: They will describe the bedsores at the time of the autopsy which was in November of 2010. + +THE COURT: What is the connection between bedsores and cause of death? Infection? + +MR. HOBSON: Your Honor, essentially what I expect the + +testimony will be from the medical experts is that as a result of the gunshot wound, that caused paralysis and paraplegia in the victim. Paraplegia commonly leads to things such as bedsores or pressure sores from not being able to move one's body; also other conditions such as a colostomy bag, a collapsed rectum, a permanent catheter, all of which can lead to infections and that in this particular case it was the complications of the paraplegia that led into infections or sepsis and that it was the sepsis that ultimately, in 2010, killed Mr. Jones. + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +MR. DeMARCO: Your Honor, if I may? + +THE COURT: Sure. + +MR. DeMARCO: In my reading of the 3500 notes that were disclosed it's more than that. He describes oozing-type wounds, he describes a horrific odor, I think he described it as the smell of death in Mr. Jones' apartment at or near the time of his death. It's facts like these that I am focusing on. + +THE COURT: Yes. + +MR. DeMARCO: The paraplegia, the medical testimony from the medical examiners will establish that Mr. Jones was a paraplegic and he was in a wheelchair. But, my concern is about the graphic description of the bedsores, the compression sores, and also the horrific odor witnessed by Mr. Vega. + +MR. HOBSON: Your Honor, we are certainly cognizant of + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +not crossing the 403 line here. We think it is important that the jury understand the nature of these injuries and how they could lead to his death and what the injuries were during the intervening time between the shooting and the autopsy. We are not looking to be gratuitous or to pile on here. + +THE COURT: Yes. Well, it's clearly a 403 line here. + +You have cumulativeness with the medical testimony, you have graphic descriptions from a relative who cared for the victim which could very well produce sympathies and prejudice that would interfere with and overcome the medical facts that you need for purposes of proving causation. So, because this witness is testifying first it's difficult for me to know exactly what additional facts you need to extract from the witness but I am certainly going to cut off the line at any graphic descriptions. To the extent that walking this person through questions regarding the medical condition is emotional testimony, I think we are -- it will have to be stopped. + +So, I think what you need to think about is what and I'm going to allow a little bit of leading to ask the specific factual questions you believe that you need and that are not cumulative with the medical testimony, but I'm going to guard this line very carefully, and you should too. + +MR. HOBSON: Your Honor, I understand that. I will say that in meeting with this witness we have tried to follow that line and I am -- with the ability to maybe construct some + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +of my questions in a leading way, I will hope to enforce that line. It is, again, certainly not our intention to be gratuitous but to simply get in the nature of the injuries and their relationship. + +THE COURT: You don't have pre-autopsy medical records that you are putting in that describes these injuries? + +MR. HOBSON: No, your Honor. + +MR. DeMARCO: I'm sorry. What was that? Pre? + +THE COURT: No. I asked if there were -- + +MR. DeMARCO: I misunderstood your question, Judge. I'm sorry. + +THE COURT: I asked if there were pre-autopsy medical records that describes these infections and injuries and the answer is no. + +MR. DeMARCO: The government has disclosed, pursuant to Rule 16, some of these records that your Honor references, so. + +MR. HOBSON: Your Honor's question was I think if we are introducing them. There are voluminous medical records that are almost incomprehensive to a layperson. We are not introducing those records. + +THE COURT: But you have a medical expert. + +MR. HOBSON: We do have a medical expert. + +MR. DeMARCO: Your Honor, if I just might add another fact to this? Based on the exhibit list and the exhibits + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +provided to us by the government, the government intends to introduce, through the medical examiner, photographs of these bedsores. So, I think that expert testimony, by itself, sufficiently will describe the bedsores that Mr. Jones was suffering at the time of his death. + +MR. HOBSON: To be clear of what photographs we are introducing, we are not introducing the most graphic pictures of the bedsores. In fact, we were concerned in introducing some of the pictures that they wouldn't fully show how serious the bedsores were but we are not going to be putting in the most graphic pictures. + +THE COURT: What I am going to allow is you will have some permission to lead with respect to the description of the injuries and sores. It's going to be brief and extraction of facts that you need that is not cumulative with medical testimony and evidence that's coming in. We will see how it goes but I am -- I intend to be extremely cautious given that this is non-expert medical testimony coming from a relative. So, the prospect of prejudice and emotion and sympathy is real and I'm not going to let it happen. + +MR. HOBSON: Yes, your Honor. We understand. + +THE COURT: Anything else? + +MR. DeMARCO: No thank you, your Honor. + +THE COURT: OK. Any word, Ms. Williams? + +(Discussion off record) + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +THE COURT: They said 15 to 20 minutes so I imagine the marshals need time to get Mr. Berry across the street. So, unless anyone has anything further, we will break and re-assemble across the street at 500 Pearl. Thank you. + +So, one question. Mr. Hobson, is the government ready to commence trial? + +MR. HOBSON: Yes, your Honor. + +THE COURT: Mr. DeMarco? + +MR. DeMARCO: Yes, Judge. + +THE COURT: Thank you. + +MR. DeMARCO: Your Honor, we are going to meet over at the jury room? + +THE COURT: We will meet in the alcove outside the jury assembly room. 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a/marker2/ds9/EFTA00090009/EFTA00090009.md b/marker2/ds9/EFTA00090009/EFTA00090009.md new file mode 100644 index 0000000000000000000000000000000000000000..6a21c39f8d5a550f89debc70f73f2a63b1039ec6 --- /dev/null +++ b/marker2/ds9/EFTA00090009/EFTA00090009.md @@ -0,0 +1,401 @@ +From: "- + +To: "Stoddart, Allison" H + +Cc: "Salmi, Anjan" - • (USANYS)" + +Subject: RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +Date: Sat, 20 Nov 2021 21:54:31 +0000 + +Thanks, sounds good. + +From: Stoddart, Allison + +Sent: Saturday, November 20, 2021 4:53 PM + +To: + +Cc: Sahni, Anjan < (USANYS) + +Subject: RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +Thanks, ell send an invite with dial-in for 2pm tomorrow, but let me know if that doesn't work. + +Allison + +From: + +Sent: Saturday, Nove • + +To: Stoddart, Allison + +Cc: Sahni, Anjan (USANYS) + +Subject: RE: [EXTERNAL) RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +EXTERNAL SENDER + +Hi Allison, + +Thanks very much for following up on this. I'm free for a call at any point after 12 p.m. tomorrow. + +Thanks, + +From: Stoddart, Allison + +Sent: Saturday, November 20, 2021 11:48 AM + +To: + +Cc: Sahni, Anjan (USANYS) >; < + +Subject: RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +Apologies for the email over the weekend. We were wondering if you have time for a quick call tomorrow to follow up on our Wednesday meeting. Let us know if there are some times that might work. + +Thanks, Allison + +From: + +Sent: Friday, November 19, 2021 5:33 PM + +To: Stoddart, Allison + +Cc: Sahni, Anjan (USANYS) + +Subject: RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +EXTERNAL SENDER + + + +Hi Allison, + +Thanks very much. Let me look into it, and I'll let you know if Zoom is an issue, but otherwise let's plan for that. + +Best, + +From: Stoddart, Allison + +Sent: Friday, November 19, 2021 11:51 AM + +To: I < > + +Cc: Sahni, Anjan + +) °c >; + +Subject: RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +(USANYS) < >; + +Monday at 6pm works for us for our next meeting with Pat. To avoid Webex issues, it would be great if we could use Zoom. If that works for you, we can use the following Zoom meeting ID: + +Meeting ID: 3127323168 or ryankusmin + +I'll send an invite to hold the time, but please let me know if that doesn't work. + +Thanks, + +Allison + +From: + +Sent: Wednesday, November 17, 2021 8:17 AM + +To: Stoddart, Allison + +Cc: Sahni, Anjan (USANYS) + +Subject: RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) + +<= > + +**From:** Stoddart, Allison [REDACTED] > + +**Sent:** Wednesday, November 17, 2021 8:15 AM + +**To:** [REDACTED] <[REDACTED]> + +**Cc:** Sahni, Anjan [REDACTED] (USANYS) <[REDACTED]>; [REDACTED] + +[REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> + +**Subject:** RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +[REDACTED] + +Does tonight still work for a call with [REDACTED]? I know you're tied up during the day, but he is available from 6-9pm tonight. + +Thanks, +Allison + +**From:** Stoddart, Allison + +**Sent:** Monday, November 15, 2021 6:20 PM + +**To:** [REDACTED]' <[REDACTED]> + +**Cc:** Sahni, Anjan [REDACTED]; [REDACTED] (USANYS) <[REDACTED]>; [REDACTED] + +[REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> + +**Subject:** RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +Thanks [REDACTED] has been traveling, but returning tomorrow. I'll pass your schedule along, and I expect to get back to you tomorrow with some possible times. + +Thanks, + +Allison + +**From:** [REDACTED] <[REDACTED]> + +**Sent:** Monday, November 15, 2021 6:16 PM + +**To:** Stoddart, Allison [REDACTED] + +**Cc:** Sahni, Anjan [REDACTED]; [REDACTED] (USANYS) <[REDACTED]>; [REDACTED] + +[REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> + +**Subject:** RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +**EXTERNAL SENDER** + +Hi Allison, + +I wanted to follow up on scheduling, since this week is a bit tight and I know everyone is busy. I'm available from 7 p.m. onwards tomorrow evening, Wednesday, or Thursday. I'm also available this weekend, if that's easier. Apologies for proposing evening/weekend times, but jury selection this week makes scheduling a little difficult. I'm also free on Monday from 12-4 if it's not possible to meet sooner. + +Thanks, + +To: + +Cc: Sahni, Anjan (USANYS) < ; >; + +Subject: RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +Hi + +Apologies for not responding sooner. I am still trying to confirm timing, but looking at next week, not tomorrow. + +Thanks, Allison + +From: )1 + +Sent: Wednesday, November 10, 2021 7:48 PM + +To: Stoddart, Allison + +Cc: Sahni, Anjan ) (USANYS) C + +Subject: RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +EXTERNAL SENDER + +Hi Allison, + +Just checking in on timing, in case we're meeting tomorrow. If not, no worries, next week is fine. + +Thanks, + +From: Stoddart, Allison + +Sent: Tuesday, November 9, 2021 8:43 PM + +To: + +Cc: Sahni, Anjan ; (USANYS) ) P. + +Subject: RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) + +Thanks, I'll check and get back to you. + +Allison + +From: 14a + +Sent: Tuesday, November 9, 2021 8:07 PM + +To: Stoddart, Allison + +Cc: Sahni, Anjan (USANYS) + +Subject: Re: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) + +Are there times on Thursday afternoon or evening that would work? I can move a few things around if he is available. Otherwise, I'm available anytime next week in the the morning from 7:30-8:30, or in the evening from 5:30 p.m. onwards, or anytime on the weekend. Thanks very much for your help arranging the meeting. + +On Nov 9, 2021, at 7:23 PM, Stoddart, Allison > wrote: + +Thanks ,-is traveling on Friday and Monday unfortunately. I know jury selection is scheduled to be underway next week, but if tomorrow doesn't work, would there be times next week that might? + +Thanks, Allison + +From: + +Sent: Tuesday, November 9, 2021 6:32 PM + +To: Stoddart, Allison + +Cc: Sahni, Anjan (USANYS) + +> Subject: RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +EXTERNAL SENDER + +Hi Allison, + +Thanks very much. We'll be in court most of the day for a hearing tomorrow, but is there a time on Friday that would work? + +Thanks, + +From: Stoddart, Allison + +Sent: Tuesday, November 9, 2021 3:50 PM + +To: + +Cc: Sahni, Anjan + +>: < Subject: RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +(USANYS) < + +H + +When we last spoke, we discussed setting up a call with your team a for that call? Would tomorrow afternoon work + +Thanks very much, Allison + +From: + +Sent: Wednesday, Oct b r 27 2 21 : 2 AM + +To: Stoddart, Allison + +**EXTERNAL SENDER** + +Hi Allison, + +Thanks— would 3 p.m. work for a call today? + +--- + +**From:** Stoddart, Allison [REDACTED] > +**Sent:** Wednesday, October 27, 2021 7:48 AM +**To:** [REDACTED] <[REDACTED]> +**Cc:** Sahni, Anjan <[REDACTED]; [REDACTED] (USANYS) <[REDACTED]>; [REDACTED] +[REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> +**Subject:** RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +Hi [REDACTED] + +We wanted to provide an update on the trial witness topic. Do you have any time this afternoon or tomorrow for a brief call? + +Thanks, +Allison + +--- + +**From:** Stoddart, Allison +**Sent:** Monday, October 18, 2021 9:05 PM +**To:** [REDACTED]' <[REDACTED]> +**Cc:** Sahni, Anjan [REDACTED]; [REDACTED] (USANYS) <[REDACTED]>; [REDACTED] +[REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> +**Subject:** RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +Great. Thanks, [REDACTED] Appreciate it. + +Allison + +--- + +**From:** [REDACTED] <[REDACTED]> +**Sent:** Monday, October 18, 2021 8:58 PM +**To:** Stoddart, Allison [REDACTED] +**Cc:** Sahni, Anjan [REDACTED] (USANYS) <[REDACTED]>; [REDACTED] +[REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> +**Subject:** RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +**EXTERNAL SENDER** + +Hi Allison, + +Thanks, that's not a problem. I'm attaching a broadly worded subpoena to the bank, but please let me know if you'd like me to direct this more specifically to a particular entity or officer. + +[REDACTED] + +**From:** Stoddart, Allison <[REDACTED]> + +**Sent:** Monday, October 18, 2021 8:57 AM + +**To:** [REDACTED] <[REDACTED]> + +**Cc:** Sahni, Anjan [REDACTED] (USANYS) <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> + +**Subject:** RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +[REDACTED], + +Following up on our last discussion, JPMorgan is working on identifying a witness for trial. Are you able to provide JPMorgan with a trial appearance subpoena? + +Thanks very much, + +Allison + +**Allison Stoddart | WilmerHale** + +[REDACTED] + +**From:** [REDACTED] <[REDACTED]> + +**Sent:** Friday, October 8, 2021 12:15 PM + +**To:** Stoddart, Allison [REDACTED] + +**Cc:** Sahni, Anjan [REDACTED] (USANYS) <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> + +**Subject:** Re: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +**EXTERNAL SENDER** + +Hi Allison, + +I'm traveling for work for much of next week, but I'm available for a call anytime on Monday, or at 9 a.m. on Tuesday. I'm also available for a call this afternoon anytime from 4 pm onwards if that's easier. + +Thanks. + +On Oct 8, 2021, at 11:18 AM, Stoddart, Allison <[REDACTED]> wrote: + +Thanks [REDACTED] Could we find some time early next week to discuss? Are there certain windows that would work on your end? + +Thanks, +Allison + +**From:** [REDACTED] <[REDACTED]> + +**Sent:** Friday, October 8, 2021 10:01 AM + +**To:** Sahni, Anjan [REDACTED]; Stoddart, Allison [REDACTED] + +**Cc:** [REDACTED] (USANYS) <[REDACTED]>; [REDACTED] + +<[REDACTED]>; [REDACTED] <[REDACTED]> + +**Subject:** United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +**EXTERNAL SENDER** + +Anjan, Allison, + +Hope you're both doing well. Following up on our last conversation, we wanted to send along a few documents in order to facilitate our conversation about identifying an appropriate witness from JP Morgan. Attached is a zip file containing a few draft exhibits. We are still working on finalizing exhibits, but we thought it made sense to start the conversation about this sooner rather than later. 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I'm free this evening and tomorrow. + +From: Sent: Friday, May 7, 2021 5:32 PM To: 1< M> Cc: (USANYS) Subject: Re: Conferral Regarding Possible Violation of Local Criminal Rule 23.1 + +Makes sense to me. I'm free starting at 6:15 or 6:30, or pretty much anytime tomorrow. + +On May 7, 2021, at 5:25 PM, <-> wrote: + +The short answer is no, he does not, but let's discuss next time we talk. I'm around probably until 7 this evening if the team wants to talk about pending issues before then. I think we need to discuss: 1) this email, 2) the MDC letter, and 3) the letter due Monday. I think we should also schedule a time to talk on Monday about the motions they're filing tonight. + +Friday, May 7, 20211.0 From: Laura Menninger < Sent: To:I Cc: Jeff Pagliuca Sternheim Subject: Conferral Regarding Possible Violation of Local Criminal Rule 23.1 (USANYS) ; 'Bobbi + +Counsel — + +The linked article by the Sun dated yesterday contains a number of statements which, if made by a lawyer associated with a witness in this case, appear to violate Local Criminal Rule 23.1. See also Dkt. No. 28 (expectation of strict compliance with Rule 23.1 by "counsel for all involved parties"). The rule applies by its terms to any "lawyer participating in or associated with the investigation (including ... lawyers for targets, subjects, and witnesses in the investigation...)." + +I am writing to confer with you prior to bringing this to the Court's attention. Please let me know if you believe Mr. Spencer Kuvin represents any witness in this case. + +Given the urgency of this situation, I would appreciate a response by close of business Monday. + +Thanks, Laura + + + +Laura A. Menninger Haddon, Morgan and Foreman, P.C. 150 East 10th Avenue Denver, Colorado 80203 + +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. 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Ghislaine Maxwell, 20 Cr. 330 (AJN) + +**Date:** Sat, 08 May 2021 01:30:47 +0000 + +--- + +Bobbi, + +Thanks very much for letting us know your availability. Regarding the trial date, after considering the availability of witnesses and counsel, we plan to propose a trial date of November 29, 2021. Could you please let us know your position regarding that date, so that we can include it in our letter to the Court? In addition, please let us know whether you consent to an exclusion of time under the Speedy Trial Act between now and the new trial date the Court selects. + +With respect to other scheduling matters, we intend to propose that the Court set a deadline of three months before trial for the Government to disclose the identities of victims referenced in the indictment; this is an earlier proposal than the timeframe we had originally proposed for the July trial date. We also intend to propose that the deadline for defense expert disclosures be set for two months before trial, given the substantial length of the adjournment. Please let us know your position regarding those proposed dates and we'll include it in our letter. + +Thanks very much, and hope everyone has a nice weekend-- + +[REDACTED] + +--- + +**From:** BOBBI C STERNHEIM [REDACTED] + +**Sent:** Friday, May 7, 2021 5:26 PM + +**To:** [REDACTED] + +**Cc:** [REDACTED] + +Christian Everdell <[REDACTED]> Laura + +Menninger [REDACTED] + +Jeff Pagliuca <[REDACTED]> + +**Subject:** Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +[REDACTED] + +We are available to begin November 8th and to conclude by the end of the year. + +Laura has a civil trial scheduled for December 13th, but will try to move it. + +Bobbi + +BOBBI C. STERNHEIM, ESQ. + +Law Offices of Bobbi C. Sternheim + +[REDACTED] + +We continue to work regular business hours throughout this situation. + +Thank you for your consideration. Our best wishes for your good health and well being. + +This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim + +that may be confidential and/or privileged. + +If you are not the intended recipient, you may not read, copy, distribute, or use this information. + +If you have received this transmission in error, please notify the sender immediately by reply e-mail and then delete this message. Thank you. + +On May 7, 2021, at 5:16 PM, [REDACTED] wrote: + +Bobbi, + +We understand that you're requesting a November 8th date, and that you prefer that date. Separate from your preferences, our question was simply about your scheduling availability in light of the Court's order. Can you please let us know your availability and we will note that accordingly in our submission to the Court? + +[REDACTED] + +**From:** BOBBI C STERNHEIM [REDACTED] + +**Sent:** Friday, May 7, 2021 4:00 PM + +**To:** [REDACTED] + +(US) [REDACTED] + +**Cc:** Christian Teverdelle [REDACTED] + +; Laura Tvenningen [REDACTED] + +; Jen Pagliuca [REDACTED] + +**Subject:** Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +Good afternoon- + +For the reasons stated in our letter-motion of 4/22 (Dkt. 246), our earliest and preferred date in the fall is 11/8. + +In light of Ms. Maxwell's extended period of detention and its deleterious effect on her health and well-being, we cannot agree to a date far beyond 11/8. + +However, should you agree to her release pending trial, we would have greater date flexibility. + +Enjoy the weekend. + +Bobbi + +BOBBI C. STERNHEIM, ESQ. + +Law Offices of Bobbi C. Sternheim + +![](_page_1_Picture_156.jpeg) + +\*\*Covid-19 Notice: The West 19th Street office is currently closed but we continue to work remotely. + +Please use email or fax, instead of regular mail, for all correspondence during this time. + +We continue to work regular business hours throughout this situation. + +Thank you for your consideration. Our best wishes for your good health and well being. + +This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim + +that may be confidential and/or privileged. + +If you are not the intended recipient, you may not read, copy, distribute, or use this information. + +If you have received this transmission in error, please notify the sender immediately by reply e-mail and then delete this message. Thank you. + +On May 7, 2021, at 1:13 PM, [REDACTED] wrote: + +Hi Bobbi, + +Thanks for your response. Your April 22, 2021 letter does not address the defense's availability for trial dates after November 8th, and it would be helpful to get a complete picture of available dates throughout the balance of 2021 in order to provide the Court with comprehensive information. We're still in the process of conferring with witnesses regarding their availability, so we're gathering a variety of data points. Please let us know your availability and we can put together a proposal. + +Thanks, + +[REDACTED] + +From: BOBBI C STERNHEIM <[bcsternheim@mac.com](mailto:bcsternheim@mac.com)> + +Sent: Thursday, May 6, 2021 11:58 PM + +To: [REDACTED] + +Cc: Christian Everdell <[C.Everdell@mac.com](mailto:C.Everdell@mac.com)> [REDACTED] Laura Menninger [REDACTED] Jeff Pagliuca [REDACTED] + +Subject: Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +Good evening- + +Our 4/22 letter detailed our position. Please let us know your availability for 11/8. + +Thank you- + +Bobbi + +**BOBBI C. STERNHEIM, ESQ.** + +**Law Offices of Bobbi C. Sternheim** + +![](_page_2_Picture_138.jpeg) + +![](_page_3_Picture_0.jpeg) + +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 May 6, 2021, at 7:15 PM, ote: + +Counsel, + +We write to confer in accordance with the Court's Order about a trial date in this case. Please let us know your preferences and availability for trial dates from September 2021 through the end of the year. If you could please provide details for any conflicts, that would be helpful. + +Thank you, + +![](_page_3_Picture_9.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00090019/EFTA00090019.metadata.json b/marker2/ds9/EFTA00090019/EFTA00090019.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..f10c826b0ec026f29c596a9f0094c6c795975e7e --- /dev/null +++ b/marker2/ds9/EFTA00090019/EFTA00090019.metadata.json @@ -0,0 +1,161 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090019.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 4, + "chars": 6367, + "elapsed_seconds": 9.02, + "image_assets": [ + "_page_1_Picture_156.jpeg", + "_page_2_Picture_138.jpeg", + "_page_3_Picture_0.jpeg", + "_page_3_Picture_9.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 59 + ], + [ + "Text", + 52 + ], + [ + "Line", + 30 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 66 + ], + [ + "Text", + 56 + ], + [ + "Line", + 33 + ], + [ + "PageFooter", + 2 + ], + [ + "Picture", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 59 + ], + [ + "Text", + 48 + ], + [ + "Line", + 30 + ], + [ + "PageFooter", + 2 + ], + [ + "Picture", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 3, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 25 + ], + [ + "Line", + 13 + ], + [ + "Text", + 8 + ], + [ + "Picture", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00090019" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00090019/_page_1_Picture_156.jpeg b/marker2/ds9/EFTA00090019/_page_1_Picture_156.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..d84df015cdcaa384aa90a072efb88ac32b7fa1b3 --- /dev/null +++ b/marker2/ds9/EFTA00090019/_page_1_Picture_156.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:3b7307c2684552c1f324b3d8977371d04ee783148ccfe5f05a6b5bf5e102a56b +size 3277 diff --git a/marker2/ds9/EFTA00090019/_page_2_Picture_138.jpeg b/marker2/ds9/EFTA00090019/_page_2_Picture_138.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..ce3c9393ad53cb2b296c862f52d44a5f854a7548 --- /dev/null +++ b/marker2/ds9/EFTA00090019/_page_2_Picture_138.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:cff62f9b7816e13561322cabcfb8f2e6728dc420215898eb7269c348b3b66241 +size 3696 diff --git a/marker2/ds9/EFTA00090019/_page_3_Picture_0.jpeg b/marker2/ds9/EFTA00090019/_page_3_Picture_0.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..e5564920f381161baf651c23e764470fa1940890 --- /dev/null +++ b/marker2/ds9/EFTA00090019/_page_3_Picture_0.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:cd7f263f228aa5b9462f2b12cdc76592dd1a2ce4e80a4386fea8a2799ae16dcd +size 5322 diff --git a/marker2/ds9/EFTA00090019/_page_3_Picture_9.jpeg b/marker2/ds9/EFTA00090019/_page_3_Picture_9.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..a38d4a6b5ee8fcda18ff567bb2089b4ab926f327 --- /dev/null +++ b/marker2/ds9/EFTA00090019/_page_3_Picture_9.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:cdc6a3149006f1b52660fb49c2f9d0854d0184506106c3011e34e4922952624e +size 6519 diff --git a/marker2/ds9/EFTA00090023/EFTA00090023.md b/marker2/ds9/EFTA00090023/EFTA00090023.md new file mode 100644 index 0000000000000000000000000000000000000000..597c262bdf23ebfee5ab58bdc3bc35a8176c7274 --- /dev/null +++ b/marker2/ds9/EFTA00090023/EFTA00090023.md @@ -0,0 +1,82 @@ +**From:** "[REDACTED], [REDACTED] (USANYS) [Contractor]" <[REDACTED]> +**To:** "[REDACTED]" <[REDACTED]>; "[REDACTED] (USANYS)" +<[REDACTED]>; "[REDACTED]" <[REDACTED]>; +"[REDACTED]" <[REDACTED]> + +**Cc:** "[REDACTED] (USANYS) [Contractor]" <[REDACTED]> + +**Subject:** RE: [REDACTED] materials + +**Date:** Thu, 18 Nov 2021 00:49:28 +0000 + +**Attachments:** 2021.11.18\_Maxwell\_Discovery\_Letter.docx + +Sorry for the delay on prepping these materials for production—I noticed one discrepancy (one empty folder) that I asked the agents to check on, and they did confirm that it was empty originally rather than due to any sort of error. + +These production is saved here for your review: [REDACTED] + +And the draft cover letter is attached (saved [REDACTED]. Because there are several [REDACTED] deposition video clips that we could not find as having been produced the production is around 13GB, we will need a hard drive from defense counsel. While we haven't produced these clips, the transcript for this deposition was produced in April as [REDACTED] 3500, specifically 3501.183-020. We should request a hard drive of at least 32GB from defense counsel (we still have two hard drives for Maxwell, both of which are sufficiently large to accommodate the production). + +Let me know what you think or if you have any questions. + +**From:** [REDACTED] <[REDACTED]> +**Sent:** Monday, November 15, 2021 5:03 PM +**To:** [REDACTED], [REDACTED] (USANYS) [Contractor] <[REDACTED]>; [REDACTED] (USANYS) +<[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] +<[REDACTED]> +**Cc:** [REDACTED] (USANYS) [Contractor] <[REDACTED]> +**Subject:** RE: [REDACTED] materials + +Ah, okay. Rule 16, please. Thanks! + +**From:** [REDACTED], [REDACTED] (USANYS) [Contractor] <[REDACTED]> +**Sent:** Monday, November 15, 2021 4:25 PM +**To:** [REDACTED], [REDACTED] <[REDACTED]>; [REDACTED] (USANYS) <[REDACTED]>; [REDACTED] +<[REDACTED]>; [REDACTED] <[REDACTED]> +**Cc:** [REDACTED] (USANYS) [Contractor] <[REDACTED]> +**Subject:** RE: [REDACTED] materials + +No. All of the files at the link below were not produced in 3500, though it seems like some of the longer ones may have been produced in Rule 16 (a few hundred page docs that appear to be subpoena returns that we have not checked every page of which, for example, some of the docs [REDACTED]. Since they have either not been produced or not entirely confirmed as having been produced, I was wondering whether these documents at the link below should be produced as 3500 or Rule 16? + +**From:** [REDACTED] <[REDACTED]> +**Sent:** Monday, November 15, 2021 4:21 PM +**To:** [REDACTED], [REDACTED] (USANYS) [Contractor] <[REDACTED]>; [REDACTED] (USANYS) +<[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] + +Subject: RE: materials + +Thanks! Just to make sure I'm following: are you saying that all of these files have been produced to the defense already, either as Rule 16 or 3500? + +From: (USANYS) [Contractor] + +Sent: Monday, November 15, 2021 4:20 PM + +To: >; (USANYS) < >\*, + +c' + +Cc: (USANYS) [Contractor] < + +Subject: RE: materials + +and I reviewed these materials and confirmed that some of these files were definitely produced as 3500, but others were not (though so subpoena returns, that were roduced previously in Rule 16 + +There was one folder of miscellaneous files that seemed to be some sort of FBI audio software that had been marked as DNP for NTW production 2. Other than this folder, do you want the files that do not appear to have been produced for 3500 added to the pending NTW 3500 production (i.e., rather than produced as Rule 16)? + +Original Message + +From: + +Sent: Thursday, November 11, 2021 1:49 PM + +To: (USANYS) [Contractor] + +Cc: (USANYS) + +Subject: materials + +Hi M. + +We recently had an evidence inspection, and defense counsel inspected a number of items from the case. I have asked the FBI to scan the paper and give us a copy of any electronic materials that were in that set of materials, so that we could double check these items were produced in discovery. should be connecting with you to get you a copy so that we can cross reference items produced in discovery. + +Thanks, \ No newline at end of file diff --git a/marker2/ds9/EFTA00090023/EFTA00090023.metadata.json b/marker2/ds9/EFTA00090023/EFTA00090023.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..535181068d0b67d71ec72ae488b52aec2f1fbea0 --- /dev/null +++ b/marker2/ds9/EFTA00090023/EFTA00090023.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090023.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 4131, + "elapsed_seconds": 9.68, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 90 + ], + [ + "Text", + 41 + ], + [ + "Line", + 41 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 70 + ], + [ + "Line", + 34 + ], + [ + "Text", + 23 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00090023" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00090025/EFTA00090025.md b/marker2/ds9/EFTA00090025/EFTA00090025.md new file mode 100644 index 0000000000000000000000000000000000000000..a8d9b54f4abd15a468e71db9d5bf374f8bd46fc2 --- /dev/null +++ b/marker2/ds9/EFTA00090025/EFTA00090025.md @@ -0,0 +1,60 @@ +![](_page_0_Picture_0.jpeg) + +United States Attorney Southern District of New York + +The .Wlvio J. Mello Building One Saint Andrew's Plaza New York, New York 10007 + +The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse New York, New York 10007 + +Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +Dear Judge Nathan: + +The Government respectfully requests that Your Honor allow us to arrange for the provision of secure high-speed wired Internet access in the courtroom in connection with trial in the above-captioned matter. The secure Internet connection will enable the trial team in the courtroom to stay connected to our online case repository and resources in the office during critical moments of the proceedings. This will greatly facilitate the effective and efficient presentation of evidence. In addition, we will be able to reduce the files we bring into the courtroom, as well as the traffic to and from the courtroom during proceedings. While we understand that the courtroom also has Wi-Fi access, which we may use, a high-speed wired connection generally ensures a faster intemet connection and can avoid potential connectivity issues. + +Subject to your approval, we will retain Courtroom Connect to provide these services. Courtroom Connect does not require any court resources to provide service and currently maintains a network in the courthouse that is 100% independent of the Court's internal network. Set up, installation and service fees will be paid for by the Government at no cost to the Court. + +The following describes how Courtroom Connect restricts access to the network and ensures compliance with court security and directives: + +- The network will be a hard-wired, secure physical network connection utilizing a firewall and other security provisions. + +- Onsite support, maintenance and other measures are provided to ensure the highest levels of security and reliability. +- The network is totally separate from the court's internal network; it is therefore physically impossible for information on the court's existing systems to be accessed or compromised. + +Courtroom Connect will make all necessary arrangements with the Court's District Executive office and computer networking personnel. + +Many trials in federal courts have utilized a high-speed connection to the Internet in the courtroom, including United States v. Gatto, 17 Cr. 686 (LAK). + +If Your Honor is agreeable to these arrangements, the Government respectfully requests that you sign the enclosed order permitting us to proceed. + +Respectfully submitted, + +DAMIAN WILLIAMS United States Attorney + +By: s/ + +Assistant United States Attorneys Southern District of New York + +Cc: Defense Counsel (By email) + +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +x + +UNITED STATES OF AMERICA + +20 Cr. 330 (AJN) + +GHISLAINE MAXWELL, + +Defendant. + +x + +IT IS HEREBY ORDERED THAT Courtroom Connect, a Southern District of New York contracted vendor, may provide the Government in the United States v. Glzislaine Maxwell, S2 20 Cr. 330 (AJN), with an Internet connectivity feed for the duration of the trial proceedings, set to begin on Monday, November 29, 2021. Courtroom Connect should make proper arrangements with the District Executive Office of the Court and the official court reporter. + +SO ORDERED: + +Dated: November 2021 New York, New York + +> ALISON J. NATHAN UNITED STATES DISTRICT JUDGE \ No newline at end of file diff --git a/marker2/ds9/EFTA00090025/EFTA00090025.metadata.json b/marker2/ds9/EFTA00090025/EFTA00090025.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..8b5ac5811dff88a4a4156b9fb3c563321f28f7c9 --- /dev/null +++ b/marker2/ds9/EFTA00090025/EFTA00090025.metadata.json @@ -0,0 +1,195 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090025.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 3447, + "elapsed_seconds": 0.73, + "image_assets": [ + "_page_0_Picture_0.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "U.S. Department of Justice", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 313.956, + 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District of Florida/black book) +- USVP00343169 (black book) +- USVP00352026 (black book) +- USVP00352029 (subpoena request) + +JE + +- CASSELL 006927 +- EPS002-064013(listed in identified phone records and other phone records) +- EPS002-075002 (listed in identified phone records and other phone records) +- EPS002-075014 (listed in identified phone records and other phone records) +- EPS002-075065 (listed in identified phone records and other phone records) + +- 001573 (list of girls' names and black book. Listed a in black book) +- USGME03.830664 (subpoena request) +- USVP0000081.3(black book) +- USVP00001.032 (list of girls' names and black book) +- USVP00001.095 (list of girls' names and black book) +- USVP00001.1.05 (list of girls' names and black book) +- USVP00001.234 (list of girls' names and black book) +- USVP00001.543 (list of girls' names and black book) +- USVP003.93337 (subpoena request) +- USVP0034221.3 (Southern District of Florida/black book) +- USVP00352026 (list of girls' names and black book) +- USVP00352029 (subpoena request) + +# JE SW: + +- USGME01088970 (on list of masseuses) + +3. + +### JE + +- 1,102 hits (several clicked on were not matches) + +# JE SW + +- USGME01088970 (listed on document with list of masseuses: associated to + +4. + +### JE + +- EPS001-1200-1204 (2007 +- EPS001.1209.1255 (2007 Accurint report) +- EPS001-14683-14687 (2007 +- EPS001-14688-14692 (2007 +- EPS001.27924-28579 (Bill info fo interview) interview) interview) +- EPS002-013073 (2007 interview) +- EPS002-013079 (2007 interview) +- EPS002-013494 (2007 interview) +- EPS002-013499 (2007 interview) +- EPS002-041015 (2007 interview) +- EPS002-041025 (2007 interview) +- EPS002-041759 (2007 interview) +- EPS002-041769 (2007 Accurint report) +- EPS002-084127 (2007 interview) +- EPS002-084544 (2007 interview) +- GIUFFRE001573 (black book; listed as +- USGME01840128 (black book) +- USGME01848772 (black book) +- USVP00000082 (2018 interview of a) +- USVP00000910 (black book) + +- USVP00001032 +- USVP00001095 +- USVP00001105 +- USVP00001225 +- USVP00001234 +- USVP00001346 +- USVP00001543 +- USVP00001556 +- USVP00001590 +- USVP00157304 +- USVP00342213 +- USVP00343169 +- USVP00351961 +- USVP00351963 +- USVP00352026 +- USVP00352086 (list of girls' names and black book) (list of girls' names and black book) (list of girls' names and black book) (list of girls' names and black book) (list of girls' names and black book) (list of girls' names and black book) (list of girls' names and black book) (list of girls' names and black book) (list of girls' names and black book) (black book) (DOJ letter identifying victims in 2008 and black book) (black book) (FL Case information for victims) (FL Case information for victims) (black book) (FL Case informationivictimsheictim witnesses) + +# JE SW + +- USGME01099266 (message pads entries) +- USGME01157771 (won't open) \ No newline at end of file diff --git a/marker2/ds9/EFTA00090028/EFTA00090028.metadata.json b/marker2/ds9/EFTA00090028/EFTA00090028.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..069d12af7b56ff2fe57618047936454c7a8e651e --- /dev/null +++ b/marker2/ds9/EFTA00090028/EFTA00090028.metadata.json @@ -0,0 +1,285 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090028.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": 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"previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00090028" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00090031/EFTA00090031.md b/marker2/ds9/EFTA00090031/EFTA00090031.md new file mode 100644 index 0000000000000000000000000000000000000000..0415c4ac6905669987588edd8b9ee04bd7ff5804 --- /dev/null +++ b/marker2/ds9/EFTA00090031/EFTA00090031.md @@ -0,0 +1,118 @@ +**To:** Nathan NYSD Chambers <[REDACTED]>, +bcsternheim\_mac.com <[REDACTED]> + +**Cc:** "[REDACTED]" <[REDACTED]>; "[REDACTED]" <[REDACTED]>; "[REDACTED]" <[REDACTED]>; "[REDACTED]" (USANYS) <[REDACTED]>; "[REDACTED]" <[REDACTED]>; Jeff Pagliuca <[REDACTED]>; "Laura Menninger" <[REDACTED]>; "[REDACTED]" <[REDACTED]>; Patrick Smith <[REDACTED]> + +**Subject:** [EXTERNAL] RE: 20cr330, US v. Maxwell - Request for [REDACTED] to be added to ECF as "movant" + +**Date:** Thu, 18 Nov 2021 23:20:29 +0000 + +**Attachments:** 2021.11.18\_-\_Letter\_from\_Patrick\_J.\_Smith\_to\_Judge\_Nathan\_re\_ECF.pdf + +Dear Judge Nathan – Attached please find a letter requesting that [REDACTED] be added to ECF as a "movant" in this case so she may file papers on the docket as directed by the Court. We are available should the Court have any questions. + +Respectfully submitted, + +**Brian T. Burns** + +Smith Villazor LLP + +[REDACTED] +New York, New York 10019 + +**Office** [REDACTED] | **Direct** [REDACTED] | **Mobile** [REDACTED] + +**From:** Nathan NYSD Chambers <[REDACTED]> + +**Sent:** Monday, November 15, 2021 8:36 PM + +**To:** bcsternheim\_mac.com <[REDACTED]> + +**Cc:** Brian Burns <[REDACTED]>; [REDACTED] +[REDACTED]; [REDACTED]; Jeff Pagliuca <[REDACTED]>; Laura Menninger <[REDACTED]>; [REDACTED]; Patrick Smith <[REDACTED]> + +**Subject:** [EXTERNAL EMAIL] Re: 20cr330, US v. Maxwell + +Counsel: + +Attached please find a corrected memo endorsement. Please disregard the prior email, and please confirm receipt. + +Sincerely, +Chambers of the Hon. Alison J. Nathan + +**From:** BOBBI C STERNHEIM <[REDACTED]> + +**Sent:** Monday, November 15, 2021 8:32 PM + +[REDACTED] (USANYS) <[REDACTED]>; [REDACTED]; +Jeff Pagliuca <[REDACTED]>; Laura Menninger <[REDACTED]>; [REDACTED] +<[REDACTED]>; Patrick Smith <[REDACTED]> +Subject: Re: 20cr330, US v. Maxwell + +**CAUTION - EXTERNAL:** + +Received. +Thank you. + +**BOBBI C. STERNHEIM, ESQ.** +**Law Offices of Bobbi C. Sternheim** +[REDACTED] +**New York, NY 10007** + +**Main:** [REDACTED] +**Cell:** [REDACTED] +**Fax:** [REDACTED] +[REDACTED] + +*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 Nov 15, 2021, at 8:31 PM, Nathan NYSD Chambers <[REDACTED]> wrote: + +Counsel: + +Attached please find a temporarily sealed memo endorsement issued by Judge Nathan. + +Please confirm receipt. + +Sincerely, +Chambers of the Hon. Alison J. Nathan + +**From:** Brian Burns <[REDACTED]> + +**Sent:** Monday, November 15, 2021 7:08 PM + +**To:** Nathan NYSD Chambers <[REDACTED]> + +**Cc:** [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> + +<[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] + +[REDACTED] (USANYS) + +<[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] + +## CAUTION - EXTERNAL: + +Dear Judge Nathan — We represent and respectfully submit the attached letter from Patrick J. Smith by e-mail, pursuant to my call to Chambers this afternoon. We have copied counsel for the government and defense counsel on this email. We are available should the Court have any questions. + +Respectfully submitted, + +Brian T. Burns + +Smith Villazor LLP + +New York, New York 10019 + +Office Direct I Mobile + +CAUTION - EXTERNAL EMAIL: This email originated outside the Judiciary. Exercise caution when opening attachments or clicking on links. + +c20cr330 ME 11.15.21.pdf> + +CAUTION - EXTERNAL EMAIL: This email originated outside the Judiciary. 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Let's raise the stips again on our conferral call this afternoon. + +--- + +**From:** testimony <[REDACTED]> +**Sent:** Friday, November 19, 2021 10:13 AM +**To:** [REDACTED]; [REDACTED] <[REDACTED]> +**Subject:** [EXTERNAL] 227815.002 USA V GHISLAINE MAXWELL 20 CR 330 (AJN) + +Greetings, + +The name of the witness assigned to this appearance is [REDACTED], located in **Suffern, NY**. Would you like to have a prep call with the witness prior to the appearance? If so, please provide a few dates and times you're available. We will email a conference call invite. + +Thank you, + +[AT&T Court Appearance Team, JEF](#) +Finance – Global Legal Demand Center + +[REDACTED] +This e-mail and any files transmitted with it are the property of AT&T, may be confidential, and are intended solely for the use of the individual or entity to whom this e-mail is addressed. If you are not one of the named recipient(s) or otherwise have reason to believe that you have received this message in error, please notify the sender and delete this message immediately from your computer. Any other use, retention, dissemination, forwarding, printing, or copying of this e-mail is strictly prohibited without authorization. \ No newline at end of file diff --git a/marker2/ds9/EFTA00090034/EFTA00090034.metadata.json b/marker2/ds9/EFTA00090034/EFTA00090034.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..285b0d66faf494d70f9e71dfb8f332af143326e2 --- /dev/null +++ b/marker2/ds9/EFTA00090034/EFTA00090034.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090034.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1424, + "elapsed_seconds": 5.28, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 48 + ], + [ + "Text", + 22 + ], + [ + "Line", + 21 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00090034" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00090035/EFTA00090035.md b/marker2/ds9/EFTA00090035/EFTA00090035.md new file mode 100644 index 0000000000000000000000000000000000000000..591288d57bb7af0f2aa6e006ed69abb1382fc19d --- /dev/null +++ b/marker2/ds9/EFTA00090035/EFTA00090035.md @@ -0,0 +1,17 @@ +From: "a" alMIE> + +To: Druyan law + +Cc: " )" + +Subject: US v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +Date: Tue, 04 May 2021 14:06:19 +0000 + +Martin, + +I hope all is well. We wanted to let you know that the Court has adjourned the trial date to the fall of 2021. We will update you when we have more information. + +Best, Andrew + +Assistant United States Attorney Southern District of New York 1 Saint Andrews Plaza New York, New York 10007 \ No newline at end of file diff --git a/marker2/ds9/EFTA00090035/EFTA00090035.metadata.json b/marker2/ds9/EFTA00090035/EFTA00090035.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..58d5b040cbef30497b7e7de4cafd50bbf193bf37 --- /dev/null +++ b/marker2/ds9/EFTA00090035/EFTA00090035.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090035.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 436, + "elapsed_seconds": 0.53, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 34 + ], + [ + "Line", + 15 + ], + [ + "Text", + 10 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00090035" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00090036/EFTA00090036.md b/marker2/ds9/EFTA00090036/EFTA00090036.md new file mode 100644 index 0000000000000000000000000000000000000000..c5882038e8de55b0119138b715349e3e376f1a46 --- /dev/null +++ b/marker2/ds9/EFTA00090036/EFTA00090036.md @@ -0,0 +1,2283 @@ +UNITED STATES DISTRICT COURT +SOUTHERN DISTRICT OF NEW YORK + +|   |   x   |   |   |   |   | +|----------------|---------------------------------|----------------|----------------|----------------|----------------| +|   |   :   |   |   |   |   | +| : |   |   |   |   |   | +|

    :

    |   |   |   |   |   | +|   |   x   |   |   |   |   | + +Date: \_\_\_\_\_ + +Time: + +Participants: ■ + +[ [ ] ] +[ ] +[ UM1 ] + +2 [II]: Hey there. + +3 .]: - you- he's four and a half months. Say hi, come on, say hi to her. [U/I) + +4 [II]: Hi, hello. Hello. + +5 [II]: Say hi, get your baby. + +6 [II]: Hello. + +7 [II]: On (U/I) + +8 [II]: Say hi. Say hi. Get your baby. (U/I) baby. + +9 [II]: Oh, look at you guys. + +10 [II]: Say hi. Okay. Okay. Would you like some water? + +11 [UM1): No thanks. + +12 III): I'm good, thank you. + +13 14 [II]: No, you're- you've been more than gracious already, and I thank you for your time. + +15 [II]: Oh, you're welcome. + +16 [II]: Do you mind if we sit down? + +17 [II]: No, please that's- do you want one of those? I could get another chair if you want to sit there. + +18 (UM1): [U/I) + +19 [II]: They are good lookin' dogs. That's nice. + +20 [II]: Yeah, they're sweet. + +21 22 [II]: Good for them. Okay, um, you're probably under some time constraints. + +23 [II]: Okay. + +24 25 [II]: Yeah. But I have a little less than an hour because I have to walk my dogs. + +[II]: Hello. + +[II]: Happy to help in any way I possibly can. + +[II]: I have an hour. + +2 [II]: (U/I) not coming until 4:45. + +3 [II]: Okay. + +4 - quickly as we can and then if not, we can always reschedule. + +5 I'll (U/I1 + +6 [II]: Are you recording this? + +7 [II]: I am, is that okay? + +8 [II]: Okay. Alright, let me get this all set up. So, I'm Special Agent + +9 This ism. + +10 [II]: Okay. + +11 [II]: Uh, you can call me + +12 III): Okay. + +13 III): You're fine as far as that goes. Um, you are not in any trouble, uh- + +14 (II]: No, I know. + +15 16 17 18 19 [II]: You- I'm sure you already kinda have an idea in terms of what we're looking, uh, into and things like that, but just, uh, for clarity's sake, we are looking into some things that went on at Zorro Ranch, here in New Mexico. Uh, we've been given some information that you might be familiar with the ranch and with Jeff Epstein- Epstein. Uh- + +20 [II]: (U/I1 starting to watch (U/I) + +21 22 [II]: - and maybe some of the other people, so, we wanted to talk to you about it. Um, you're under no obligation to talk to us. + +23 24 25 [II]: Uh, you can kick us out if you want to kick us out. Uh, we don't plan on yelling or whatever it is that they do on TV, we plan on being incredibly nice. + +[II]: Well then, we will try to get this done as- + +[II]: Yes, go for it. + +[II]: Okay. + +2 II): So, uh, as long as you don't try to hit one of us, I think we'll all- + +3 [II): You won't have a problem. + +4 [II]: - I think we'll all just be okay. + +5 [II]: Not at all. + +6 [II]: Okay, so- + +7 [II]: Happy to help. + +8 9 [II]: We'll start off with the easy questions, and I know you're pressed for time, so we'll probably segue into some pretty direct questions after that. + +10 [II]: Okay. + +11 12 [II]: Usually it- we spend more time, uh, but don't take offense to it if we just kinda jump forward. + +13 [II]: Uh- + +14 [II]: I'll do my best to answer it however I can. + +15 [II]: Okay. So, what is your full name? + +16 [M]: I don't need to (U/I] + +17 [II]: And what's your date of birth? + +18 [M]: + +19 [III: Oh, III + +20 [II]: Okay. And where do you live? + +21 [U] I live in + +22 [II]: What's your address? + +23 [II]: Okay. And I've got a phone number for you: + +24 [II]: That's business, yes. + +25 [II]: Okay. Is that a good number to contact you at? + +[II]: That's fine. + +[II]: And how old are you right now, if you don't mind me asking? + +[a]: excuse me. + +2 II): Okay. And, despite the fact that we're sitting here, how are you employed? + +3 4 5 [II]: I'm a therapist. So, I've been a therapist for twenty-four years and do reflexology very rarely, but that's what I did at Zorro Ranch since, uh- for thirty-five years. Since 1984. + +6 [II]: So, reflexology for thirty-four years? + +7 [II]: Thirty-five. + +8 [II]: Twenty-four years as a psychotherapist. + +9 10 [II]: Okay. Well, you seem to be a jack of all trades. You can fix my mind and my body. + +11 12 (III: Well, I mostly do this. I do this very rarely, but sure, people who have neuropathy, recently, otherwise it's a storage table. + +13 [II]: Yeah. + +14 [II]: And just so you know, we'll take notes while you're talking. + +15 [II]: That's fine. + +16 17 [II]: It always looks really rude, `cause I'm not looking at you while you're talking but- + +18 [II]: Yeah. + +19 [II]: - with my counseling clients- + +20 [II]: Okay. + +21 [II]: - I get it. + +22 [II]: I just- + +23 24 25 [II]: - I don't want to come across that way, so. Okay, uh, so, therapist for twenty-four years, reflexology for thirty-four years. + +[II]: Thirty-five years. + +[II]: Okay. + +(III: I do that with my- + +[II]: No, no, I understand completely. + +2 [II]: Thirty-five. Sorry. + +3 4 [II]: So, 1985- or 84, uh, started reflexology back in and then, um, I've been out here since and then I've been a therapist since + +5 [II]: What part of + +6 [II]: Uh, + +7 [II]: I was born in + +8 [II]: I was. + +9 [II]: My family moved to + +10 [II]: Nice. My family moved to + +11 [II]: Did they? + +12 [III: Yeah. Okay, uh, what- what qualifications do you have to be a therapist and to be a reflexologist? + +13 14 15 16 17 [II]: Well, I got cer- as a reflexologist, I got certified through the National Institute of Reflexology and then, uh, through, uh, and then I went over to England and started (U/I] with (U/I]. Um, he founded the College of Reflexology in London, or n- outside of London. And then I kinda (U/I] him for about three weeks- + +18 [II - 5:04]: Okay. + +19 [II]: - while I was getting license certification. + +20 [II]: Okay. + +21 22 [II]: And here, I've a masters in, uh, excuse me- I'm an LPCC, which is a licensed professional clinical counselor. + +23 [II]: And that makes you a psychotherapist. I can't, um, diagnose. + +24 Excuse me, I can diagnose, but I can't prescribe meds. + +25 (II): Okay. + +[II]: You were? + +[II]: Okay. + +2 [II]: Is it? + +3 [II]: Good. Good for you. I may come see you at some point. + +4 [II]: Yeah, solution, focus-based therapist. + +5 6 7 8 9 III]: Good. Alright, um, for the most part, that's the background that I wanna go over, so now we'll kinda jump into some of the other stuff, again, just `cause you're kinda pressed for time. Um, you know that we're looking into Zorro Ranch and Jeff Epstein. Can you tell us how you're familiar- how you're familiar with, uh, Jeff and what the- and what the ranch- + +10 11 [II]: I was introduced to go over there as a reflexologist by a woman name dI , you probably have her information, too. + +12 III): Yeah. + +13 14 15 16 17 [III: She was, I think, a massage therapist for them. She was also a peer, she's a colleague, she's, uh, also a psychotherapist. I think she's recently retired, but I'm not sure, so I can't speak for her. I haven't talked to her ear-to-ear, but she's the one who said, "would you like to do reflexology? I [U/I] clients that- if you'd like that." + +18 [II]: So, that's how I originally was introduced to Zorro Ranch. + +19 [II]: Okay. Was she employed there? + +20 21 III]: She- I mean, she worked for them whenever they hired her for a massage. + +22 [II]: Okay. + +23 [II]: Okay. + +24 25 III]: I mean, she was working for them and then she- they want-Ghislaine Maxwell wanted her feet worked on and so, I'm the + +[II]: Yeah. Oh, I love it. + +[II): Okay. + +[II]: I don't- I can't really speak, `cause I don't know. + +2 [II]: Okay. + +3 [II]: Yeah. + +4 [II]: Right. + +5 [II]: What year was that? + +6 7 [II]: I think the first, uh, first treatment was probably in 1999. And the last one was in 2008 when I- + +8 [II]: Hey, sweetheart. + +9 [II]: Irvin come on sweetie, go lie down. Sorry. I don't want him to g- + +10 IUM1): No, no. + +11 III): Goof your pants up. + +12 III): No, you're okay. + +13 [III: I'll put him on a leash. + +14 IUM1]: I do. + +15 (II]: Yes. + +16 [II]: Yeah. + +17 [II]: Yeah, we'll be okay. We'll survive it. + +18 [II]: Good. + +19 20 21 (II]: I think was the very first treatment, I mean, I- I didn't do it regularly, but I- whenever they came into town, or I'd- actually, it was Ghislaine that I worked on mostly. + +22 [II]: Okay. + +23 III]: So, Jeffrey, I think I, I'd have to look at my records, but Jeffrey, I worked probably three times on from `99 to 2008. + +24 [II]: Okay. + +25 [II]: I hardly ever saw the man. Okay. + +[II]: Ghislaine Maxwell? + +[II]: You're okay. I have dogs. I'm pretty sure you- do you- + +[II]: Okay, so, I'm sorry, in 1999? + +2 [II]: Correct. + +3 [III: A 1- + +4 ICW): - uh, but Jeff sometimes? + +5 6 7 III): It's- no, I'm talking- I mean, like, Jeff, maybe three times in all those years. I don't know if it's two times, three times, but that was it. He was hardly ever there. + +8 [Il] : Yeah. + +9 [II]: And you said- + +10 [II]: If he was there, then I- I didn't see him. + +11 [II]: Okay. And you said that you have records for all of that stuff? + +12 [II]: I mean, in my invoice. When I say- + +13 [II]: Invoices, yeah. + +14 [II]: Okay. Who would you invoice? + +15 [II]: Zorro Ranch. + +16 [II]: Zorro Ranch. + +17 18 19 [II]: And I don't remember the name of the c- the housekeepers at the time. But then, so- I don't know what you want me- I'm just going to wait until you ask me questions versus just telling you my experience. Would that be better? + +20 21 22 [II]: If y- if you feel like there's something important that you need to say, you say it, what- I'm really linear, so, I'll- I'll make sure that, if we start to get off track, we'll come back on track. + +23 [II]: Okay. + +24 25 And again, I don't mean it in a rude way, we're just pressed for time. + +[II]: Okay. And you worked in- on Ghislaine mostly- + +[II]: Okay. + +[II]: Invoicing- + +2 [II]: So, go ahead, please. + +3 4 5 6 7 8 [II]: So, all I was gonna say is, I would go there and since I live in they would- um, she would want a treatment at nighttime, so I would drive- I would do that work at night after I finished my work here. Then I would go and I would wait in the kitchen until the housekeepers, and again, I don't remember their names, but, they would- I'd wait in the kitchen and then they would call me into the- into the library, whatever you call it, and then Ghislaine would come in and I'd work on her feet there. + +9 [II]: Okay. H- how were Jeff and Ghislaine related, if at all? + +10 [II]: Companions, or- + +11 [II]: Companions. + +12 13 14 15 16 [II]: I don't really know the intimacy details but my understanding, back then, I think that they'd been together for thirteen years, or whatever, and I think she sort of presented that she- she would manage his properties, but I think that they had a relationship, but I don't really know the details because that's not a part of my business. + +17 [II]: Okay. So- + +18 [II]: I mean, I never saw them where they were in any- + +19 [II]: Yeah, together. + +20 [II]: In any sort of- + +21 [II]: Yeah, obvious way. + +22 [II]: I guess romantic way- + +23 24 25 [II]: Or obvious way. Sure. How many times would you say, and it doesn't have to be exact, how many times would you say you were out at the ranch between '99 and '08? + +III]: Together-together. + +[III]: Right, exactly. + +2 [II]: Sure. + +3 4 5 (II]: As far as that invoicing goes, `cause that might help us narrow that down a little bit or get a little bit more exact, would you have any problem turning that stuff over to us at some point? + +6 [II]: No, I mean, I- + +7 [II]: Not the originals, obviously. + +8 [II]: Like, copies. + +9 [II]: I mean, I can give you information from it. + +10 [II]: Yeah. + +11 [II]: Yeah. + +12 (II): Okay. Would you- would you do that? + +13 14 (II- 10:001: But what I would do- what I would do in an invoice, is would- would say, "reflexology session- Ghislaine," and so if went back and looked, I would see Jeffrey was in there. Like- + +15 III): Okay. + +16 17 [II]: -like, it'd be, "reflexology for thirty-five min- uh, forty-five minutes," to Jeffrey, and Ghislaine it could have been two hours. + +18 (II]: Okay. + +19 20 (II]: Would you put something like that together for us? I mean, it doesn't have to be today or anything, but maybe just like a- + +21 [II]: I'll write something up. + +22 [II]: - like a list or a spreadsheet- + +23 [II]: - or something like that. + +24 25 [II]: I can write it up and just give you the dates or how many times I worked on them. + +[II]: Maybe thirty? In nine years. + +[II]: Right. + +Yeah. + +[II]: Sure, yeah. + +2 [II]: Is that what you'd like? Like- + +3 [II]: - how many times I worked on Jeffrey, and how many times- + +4 III]: Yeah. That w- yeah- + +5 [II]: - I worked on Ghislaine. That's fine? + +6 7 [II]: - yeah, dates, dates and how many- and- and who it was that you saw that day. + +8 [II]: Did you ever, uh, do any other work out there? + +9 [II]: No. + +10 [II]: Did you ever work on anybody else while you were out there? + +11 [II]: No. No. + +12 III): Okay. + +13 14 15 16 17 III]: The only thing that I remember doing, and you have to bear with me because I had a car accident, but it was back in 2000, but so, it affects my memory a little bit, but, that's why I have to refer to- to, like, looking at invoices, but, um, there was oneone time when I worked on Jeffrey, he asked one of his massage therapists to come down and have me teach him- her how to do reflexology. + +18 [II]: Do you remember who that was? + +19 20 21 22 [II]: So, she would sit- no, no idea. Who the name was or anything. So she came down and pulled up a chair and I'm telling her how to do- it- do a session, which isn't really teaching very much in that- + +23 24 [II]: - He liked my work. When I did it, again, I only worked on him a few times, but it was very professional. + +25 (II]: Okay. + +[.]: Yeah. + +[II]: Okay. Sure. + +[II]: (Laughter] + +2 II): And you said that your sessions typically lasted an hour? Is that right? + +3 4 5 6 [II]: Oh, I mean, it's whatever they- however people want it, but usually it's an hour, but sometimes she'd want extra time, Ghislaine would want extra time, so, like, an hour, hour and a half. + +7 [II]: Okay. Would you say on average it's about an hour? + +8 [II]: Okay. + +9 10 11 12 [II]: I mean, that's normally what my treatments are in general, but when people want, like, I have people coming in in a few weeks here, so, (U/II when they say, "can we have an hour and a half," it's (U/I). + +13 [II]: But that's pretty rare. + +14 15 [II]: Okay. And you said that you would drive yourself there? Is that right? + +16 [II]: Yes. + +17 [II]: And you would drive yourself back? + +18 [II]: Oh, yeah. + +19 [II]: Evening. Late at night. + +20 [II): What time are we talkin'? + +21 [II]: It could be- I mean, `cause I work here usually `till seven, so- + +22 [II]: Sure. + +23 24 [II]: - I may not get there `till eight or nine. Wasn't like I was there `till midnight, but I would work- it would depend, and sometimes, if I was asked to (U/I) I would. + +25 (III: Okay. What- and I know it's a big house, uh- uh- + +[II]: Yeah. + +tll): Okay. + +[II): And it was typically during the evening hours? + +1 2 3 4 III]: And I never saw- all I saw was the kitchen and the- the, I saw the kitchen and then the, I guess, for lack of better words, the, uh, off the kitchen, like a, not a maid's quarters, but I'd be asked to sit there and wait, `cause I wasn't allowed in the rest of the house. + +5 Okay. + +6 So, I'm sorry, I'm looking mostly at + +7 You're fine. + +8 9 10 11 12 13 14 15 16 17 Um, so, I would be- I'd have to sit and wait until she was ready, when she was finished dinner or if they had guests or whatever, I would have to wait. I would- sometimes it would be a long wait, but not often, they were pretty respect- she was pretty respectful. But I would wait there and then the housekeepers would just ask me if- "do you want some water," and then they would lead me into the room. I always worked- maybe there was one time I worked on her in her- in her bedroom, not one time that I work on her in her bedroom, but I mostly worked in the library or whatever you want to call it, right off the kitchen. So I never saw the rest of the fifty-thousand square-foot house. + +18 [II]: Yeah. + +19 [II]: You may have got lost. + +20 [II]: I know. They needed a walkie-talkie. + +21 [II]: Okay, so- + +22 [II]: But the housekeepers were lovely and everybody was nice to me. + +23 [II]: Okay. So we're lookin' at the library off of the kitchen and maybe one time in the bedroom? + +24 25 [II]: More- probably more- more than one time, it was dependent upon how she was feeling. So that was it. So, I would be escorted + +You're okay. + +[II]: Well, you- we- we may have never seen you again. + +1 2 3 upstairs to her bedroom, never saw him, and then- but most of the time it was downstairs right off the kitchen going into this library-study area, and then I- she got on- on a couch and I would sit on the couch and work on her feet. + +4 [II): Okay. + +5 6 III): Yeah. So I can't say- it was definitely more than once in her bedroom, but- + +7 okay. + +8 [Ilj: It was mostly in that library. + +9 [II): And you're referring to it as her bedroom, was it only her bedroom? + +10 [II): I mean, that's all- + +11 [III: As far as you know? + +12 [III: - I know. Yeah. + +13 [II): That's all I know. I don't know what else happens. + +14 15 16 17 [II): Okay. The times that you were there, it sounds like there was one time where you were kind of training a massage therapist. Uh, did anybody else ever sit in in the sessions, talk to Ghislaine or to Jeff while they were being worked on, or anything like that? + +18 [II): Okay. So, for the most part- + +19 [III: (U/I) + +20 [II): You guys had a fairly exclusive relationship. + +21 [II): That's right. + +22 23 24 25 [II): Okay. Um, just between gettin' your hair cut or gettin' reflexology done, or something like that, typically, uh, at least for me, like, I end up engaging in quite a bit of conversation. I imagine that you engaged in quite a bit of conversation over '99 to '08. What were those conversations like? + +[II): Yeah. + +(II): No. + +1 2 3 4 [IV Uh, I mean, they- they would talk to me about my work, to talk about, uh, she had a place in New York. Um, there was nothing- I know what you're- I think I know what you're leading up to, I don't- I never witnessed- I can just jump in, I never witnessed any of the things that Jeffrey is being accused of. + +5 [II - 15:15): Sure. + +6 7 8 9 10 11 12 13 14 15 [II]: That I never saw. There was only one time that I was there when his other- they were being driven from the airport or a helicopter and I was waiting in that room off the kitchen, where then they arrived as I'm waiting for Ghislaine, to work on Ghislaine, and there were, uh, several young women, that were girls, that would be there, and I was only- I don't know if told me or- or, uh, Ghislaine told me that they were, uh, working for the Limited or Victoria's Secret or they were just younger girls of who they- that they- I never talked to them, like, they never- I was never introduced to them, like, "this is the reflexologist," except for that one woman who was his massage therapist. But that's the only time I saw- saw, um, young women. + +16 [II]: Okay. And you said + +17 [II]: I never know where- what they did or where they went or anything. + +18 + +19 20 [II]: I just was sitting there, they arrived in the space I was in, then they walked- then they were escorted somewhere else that I'm- waiting to be called back to work on Ghislaine's feet. + +21 [II]: Okay. You said who's-? + +22 [II]: The- the woman who introduced me to- + +23 [II]: - (U/I) yeah, yeah. + +24 [II]: Okay. + +25 [II]: So, I really didn't know the- there's not a lot of questions + +[II]: Okay. + +[II]: Oh, + +1 2 because of her- who she is, I mean, `cause you obviously know who she- + +3 [II]: - is in the background. I just did my work and I left. Some- + +4 [II]: Yeah. + +5 6 7 [II]: I wasn't- I'm very professional, so, I went in, worked on her feet and she- and she might chat about- she always wanted me to tell her stories about my counseling clients. Not, like, any breaking any confidentiality- + +8 [II]: Sure. + +9 10 [II]: - but she would just be sorta fascinated, like, "tell me a story of what you work on," or- + +11 (II): Okay. + +12 (ll): - "what kind of- what kind of work you do with couples," or- + +13 [II]: - that's s- that's about it. + +14 15 [II]: Okay. This time where, uh, these people arrived from this plane or helicopter- + +16 [III]: Right. + +17 [II]: Um, you said that they were driven in. Do you know who drove them? + +18 19 20 21 22 [II]: Oh, I don't know if it was driven. I just know- I remember that Ghislaine, I think, had a helicopter license, so I don't know if they came in a helicopter, but I don't think that many people can fit in a helicopter, but I'm guessing that it's- I'd say- I still have no idea what airport they came from. + +23 [II]: Yeah. + +24 [II]: Okay. Do you know- + +25 [II]: Again, I never spoke to them. I just looked up, saw these people + +[II]: Sure. + +[II]: Okay. + +[II]: Okay. + +1 2 3 4 5 and some other- what- it- it- it was a chauffeur or a driver- the housekeeper, `cause there were- again, I can't remember, it was so long ago. But whoever the housekeepers were, who had managed their world, somebody went and picked them- picked them all up. So, it wasn't like they arrived and I saw Jeffrey come in. It was the- these young women and then other- adult- + +6 [II): Okay. + +7 [II]: - who had brought them, who I think was the driver or who worked for- who was one of their staff. + +8 9 10 [III: Okay. When you say, "young," so, we've kinda gone back and forth between young women and girls. What would you estimate their age to be? And again- + +11 (II): So, this is a guesstimate. + +12 (II): - it doesn't have to be specific. Sure. + +13 (II): So, I mean, certainly, uh, I'm looking at- I'm- again, it's hard as you get older to judge, but- + +14 [III: Sure. + +15 [II]: - I'm saying probably, uh, like, eighteen or under. + +16 [II]: Eighteen and under. + +17 18 [II]: But I never saw- I- `cause I've been watching the news, I never saw someone who looked fourteen or fifteen. But again, I don'tback then, I didn't- but they were just young, attractive girls. + +19 [II]: Sure. How were they dressed? + +20 21 [II]: Like, I mean, I didn't really, like- it wasn't, like, in any suggestive way, they were just dressed, like, in a normal- + +22 [II]: Like, normal way? + +23 [II]: Okay. + +24 III]: Yeah. But I really didn't- again, I didn't notice (U/I) not + +25 like I saw them for long, they literally came in the space, look + +[II]: Like I'm dressed right now. + +1 2 up, see them, and then they're moved- so, they're walked on through- + +3 4 III): - and then I'm still waiting there to be called back for Ghislaine. + +5 6 III): Okay. I know it was a very short time, like, they're basically just moving from left to right, essentially. + +7 [II]: Right. + +8 [II]: Did you ever see anyone, uh, mis- or hear, maybe, anyone mistreat them, or? + +9 [II]: No. + +10 [II]: `Cause I know they're kinda being guided through the house. + +11 [II]: Yeah, no, I never saw or heard any mistreatment. + +12 [III: And you said the housekeepers kinda managed- managed them? Or managed the whole house? + +13 14 [II]: Managed the whole- I mean, there were- I mean, it was such a large home, so I- + +15 [II): Yeah. + +16 17 18 19 20 21 [II): - I guess, like, they were the staff that would manage- I don't know what- all the things they managed, whether it was peopleguests coming, what they needed. So, like, they would come in and say, "would you like some water," and I would get it on a silver tray with a white laced [U/I] and a glass of [U/I1 something like that. So, they're very gracious to me, but, so, I- they just managed the house, so I guess you'd call them caretakers, maybe? + +22 [II]: Okay. + +23 [III: How many? + +24 [II]: Two. + +25 [II]: Male or f- + +[II): Okay. + +[II]: Right. I don't know. + +1 2 [II]: That I saw, but I don't know. I mean, I'm sure there were staff, like, gardeners or- + +3 4 5 Uh, just the people who were- who I met, um, were just, uh- I think actually they were a couple, but I'm not sure if that's + +6 [II]: Okay. + +7 [III: But they were- + +8 [II]: Yes, but they were lovely. + +9 [II]: Okay. + +10 [II]: To me they were lovely. Yeah. + +11 [II]: Okay. + +12 13 14 15 16 17 18 [II - 20:00]: And now I'm blanking on, like, who would call me upagain, I apologize for the memory, but I think it was- Ghislaine would never call me directly, but it was- one of the housekeepers would say, "they're coming into town," or, "she's coming into town early, and who- are you- when are you available `cause she wants her feet worked on." So, sometimes when she would be there, let's say she was there for five days, I might go for three- two or three of the nights and go give her a treatment and then go home. + +19 20 [II]: Okay. So you think it was the housekeepers? And you mentioned I'm sorry. + +21 [II]: I didn't- I didn't say\_. + +22 [II]: Oh, I thought you said or something. No? + +23 [II]: Okay. + +24 25 [II]: Just the house- I'm just saying they would call- it wasn't Ghislaine who would ever call me directly, ever. It was someone- + +[II]: Sure. + +[I : So, a male and a female? + +[II]: No. No. + +1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +whoever managed her world, um, they would call and say, "can you come- this is when they're coming." Uh, I keep saying "they" and I don't mean it, because I really, I- I think it's, like, three times I saw Jeffrey that- + +[Il]: Okay. + +[II]: Yeah. + +[II]: And definitely more Ghislaine? + +[II]: Oh, I mean, completely. It was all Ghislaine, most of the time, yeah. + +(II): Okay. Um, you're obviously a professional, you've mentioned that already. Uh, how about Ghislaine's con- conduct? + +[II]: Her conduct was complete- completely normal. + +[II]: Okay. + +(II): I mean, really, you have to remember- and I think, and I'm just saying this, it's not off the record `cause you're recording it, but it's- I'm- I'm not the young girls that have been violated. So- + +(II): Sure. + +(II): - I was just- all- the only that said is that if- actually, they wanted, `cause Ghislaine worked in- had a home, I guess, or I don't know who's home, uh, if it was Jeffrey's home or Ghislaine's home, but, um, she w- wanted to notify if I knew anyone to refer- ref- a reflexologist to in Manhattan. + +III]: Okay. + +[II]: They had- but she- they always said, "but you have to be attractive." So, that was the one thing that disturbed me. You know, that you can't really be on the property unless you're attractive. + +[II]: Whose rule was that? + +[II]: I don't know. + +1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 It's okay. [II]: It's hot here. [II]: That's [II]: Hey, baby. How are you? [II]: [U/II thanks. [II]: How are you sweetheart? Yeah. You are beautifully groomed. [II]: They help my- [II]: I know. [III: - counseling clients a lot. [UM1): Yeah. [II]: You are beautifully groomed. Yes, you are, ma'am. That's [II]: St- that's- [III: Oh, nd [II]: Okay. [II]: They are [U/I) particularly [U/I). [II]: That's not a bad thing. [II]: Okay, so, get back, sweetie pie. But all- go lie down. [II]: And who was the person that relayed that to you? [II]: Uh, [II]: Okay. [II]: I think it was yeah. It wasn't any staff- it wasn't that couple. [II]: Okay. How long had worked for them- [II]: I don't know. [II]: - before you? [II]: I- I would be a guest, so- [II]: Sure. [II]: I mean, I don't know if it was six months, I really- it's- I'm-I'm literally guessing. But- + +2 3 (II): - I have no idea. I don't speak with I mean, she's off in her world and we're not- she- like I said, we're both but she- + +4 ll.]: Yeah. When is the last time you spoke to her? + +5 6 III]: A 1- I mean, I saw her in the store probably three years ago or something. + +7 [II]: Okay. + +8 9 10 [II]: I really- again, I don't remember. She did send me an email saying, "look at- look what's going on with Jeffrey." So, I got that probably within the past month, but I haven't spoken to her ear-to-ear. + +11 (..): Did you guys have any sort of discussion after that email? + +12 (II): No, I have not yet. + +13 [II]: But I was- I'm going to. + +14 [U]: I imagine you will. + +15 16 [..]: Yeah. Have you- you haven't contacted her obviously yet or no, you can't tell me? + +17 18 19 Uh, so we went by her, uh- no, it's fine. So, we went by her house in uh, but it looks like somebody is renting it now. It doesn't look like she's there and I guess, and you might be able to clear it up, I guess she lives in + +20 [II]: She- she worked in I don't know where she lives. + +21 [II]: Okay. + +22 [II]: I knew she had a house in off, I think, (U/I) or something- + +23 [II]: Yeah. + +24 [II]: Yeah. But she worked in + +25 [II]: Okay. + +[II]: Okay. + +1 2 [II] : Yeah. So we would refer people to each other, counseling clients, but- + +3 [II]: Okay. + +4 [II]: Do you know if she- + +5 6 7 III]: But I don't even know if she- how long she- if she's doing this massage- I don't think she does that at all anymore. She's very successful- + +8 [] : Good. + +9 [II]: Good for her. + +10 [II]: Yeah. + +11 12 [II]: Do you know if she referred any people to the- to- to Ghislaine or Jeff? + +13 [II]: I don't know. + +14 15 16 17 [II]: `Cause really, the- the- so, I was the reflexologist and then, I don't know how often went there but she just- the reason why she originally got in touch with me is because Ghislaine wanted her feet work- worked on. + +18 [II]: Okay. + +19 20 [II]: And I'm a good so she then said, you know, "would you like me to refer you to them." And I said, "sure." And I didn't know anything more. + +21 22 III): Okay. Was there any sort of incentive or anything like that that you're aware of for referrals? So- + +23 [II): No. + +24 25 [II): You mean, like, if they were- if she was getting a commission? Or- + +[II]: Yeah. + +[Ill]: - + +[II]: Okay. Was there- + +[II): No. + +1 2 3 [Ili: N- so, uh, let's imagine that you- that approached you and she said, "hey, you know, if you know somebody in New York, if you'll refer them, as long as they're attractive, obviously, um, and there's incentive in it for you, which is-" + +4 [II]: Oh, no. + +5 [II]: Okay. + +6 7 [II]: You mean, like, if she said to me, "there's the incentive for you- would be-" for me? + +8 [II]: No. + +9 [II]: Okay. + +10 11 12 [II - 25:001: No, no. She just asked for- if there was a name. And Ghislaine would say, "if you ever come to New York, let me know. I'd love you to work on my feet." + +13 14 15 [II]: She really like- I mean, she really liked my work. She's justwho she- she was very relaxed and very, um- but she was not, um-I would never ask a client questions or- + +16 [II): Sure. + +17 18 [II): - anything like that, she just wanted to know about, like, "tell me- tell me a story, tell me what you work on," that's all she really did. + +19 [II]: Okay. Did you ever travel? + +20 [II]: No. To- to work on her feet? + +21 [II]: Uh, in general. Either- + +22 [II]: Oh, I travel- + +23 [] : - all my life. + +24 [II]: Well, sure. + +25 [II]: But not to work- yeah. + +[II]: Yeah. + +[III: Okay. + +[II]: - either to work- + +2 3 4 5 6 7 8 9 10 11 12 [II]: Oh, no. I know he had, um, people who fl- who he flew to wherever- either one of his homes, so I knew that, like a massage therapist or a cook, or- and all I ever heard was little things, like, I don't know if I heard that from or Ghislaine, but that every time they would have a guest, that they would, um, you had to do everything specifically, like, if they were at the dinner table, you would- they had to be served a certain way from a certain- like, "come to the left," or, I can't remember who told me that but I was sorta fascinated, it had to be that exact. And I'll sh- I'll also share that, um, this is probably significant, that they, um, at- wanted me to- this is sort of when I stopped working for them, but they wanted me to sign a contract that anything I saw- so, that's good for you, right? + +13 14 15 [II): Um, anything I saw that I- and that was towards the end `cause I was getting burnt out because I would go late at night after working on stuff, I mean, treating- uh, counseling people here. + +16 [II): Sure. + +17 [II]: And then at night it got exhausting for me. And driving- + +18 19 20 21 [II): -late at night. So, but they s- wanted me to sign a contract saying, like, a celebrity contract, like, "if you know anybodyif you see anything going on here you have to keep it private." And I refused to sign it. + +22 [II]: Sure. Who- who approached you with that? + +23 24 [II]: That's what I'm trying to remember. It wasn't, uh, Ghislaine, it might've been the housekeeper. One of the housekeepers, I wish I could remember, who it was. + +25 [II]: Okay. + +[II): Yeah. + +[II]: Yeah. + +1 2 3 4 5 [II): But it was something that was kind of floating around, like, it's about to happen where you need to, like, there's gonna be a contract and- what sits- remains in my mind, whether it's true or not, is if I did violate that contract, I'd be sued for two hundred and fifty thousand dollars. And I was like, uh, "no way. I'm-" + +6 [II]: Yeah. + +7 8 9 10 [II]: "- not doing that. I'm coming innocently giving you a treatment, I'm not getting involved- I don't even know what goes on, I don't have any idea, but I'm whatever-" `cause they would say- and then I was- it was kind of inferred that there could be celebrities there. And to respect their privacy. + +11 [II]: Okay. + +12 [II]: And obviously everything that's coming up in the news now, the people who could have been there. + +13 [II]: Sure. + +14 [II]: Or, the relationships with- with Jeffrey. + +15 [II]: Sure. + +16 17 [III: That they knew him. I mean, it's making me sick actually. The whole thing- + +18 19 [II]: - is- I don't want to cry right now, but the stuff that I'm hearing- + +20 [II]: I don't want to make you cry. + +21 22 23 24 25 [II]: Oh no, it's okay, but I just- I saw something, I think- on the other day of a woman who said he raped her and, um, it make- it was- made me feel sick that that was going on. `Cause that was never anything that I wit- like, I even sensed, being in their home. Just that they were big- all I- all I could say is, allfrom my sort of innocent place is that, I knew I- I'm in the + +(II): It's, uh- + +1 2 3 4 5 6 house of fifty- fifty thousand square foot house, I knew Ghislaine's background, right? And all I knew is that Jeffrey was a person who, I mean, who would only take accounts that had to be, like, a billion dollars or more, and that's all and so, I just did my work- and did my work and left. So I didn't- but there wasn't things that I saw or I'd tell you in a second `cause I want this man to be prosecuted appropriately. + +7 [II]: Sure. + +8 9 [II]: Uh, as far as your treatments for Jeffrey went, what- what would you treat for him? So, for Ghislaine, it was her feet. + +10 [II]: Well, I only did reflex- that's all I've been trained in. + +11 [II]: Okay. + +12 [II): I'm not a massage therapist. + +13 [II]: So, I would just work on his feet. + +14 [III: Okay. + +15 16 17 18 19 20 21 22 [II]: And sometimes he- sometimes Ghislaine would come in, like, 1- I'm thinking of the time- so, she- I worked on her mostly, like 98% of the time, 99% of the time, and the times that I worked on Jeffrey, s- like, maybe one or two times it would be a full treatment, and I can look at my invoices for you, but, um, sometimes he'd want to just come in and have, like, a thirty minute treatment and then- so, she'd have half of it and- or dno, that's when I- she would ask for extra time. So, I'd work on her for an hour, he'd come in, maybe took forty-five minutes and then he would leave. + +23 [II]: Okay. + +24 [II]: Yeah. + +25 [II]: Did anything odd or inappropriate ever happen during your + +[II]: Yeah. + +[II]: Okay. + +2 3 4 [II]: The only thing that happened that I did not appreciate is that he came down in his bathrobe and so- and he was not dressed underneath it and so, it- it seemed that- I mean, he didn't expose himself to me in any way or I would have left the house. + +5 [II]: Sure. + +6 7 8 9 10 11 [II]: And I would have said something, but it was just, uh- you could tell that he was, sort of- he was there, loving the treatment, and then the massage therapist that he wanted me to train was there but then the bathrobe would be there and you can tell that, like, even if something started to open up in the bathrobe, I never saw his body literally, but it was- he wasn't being mindful about covering himself. + +12 [II]: Okay. + +13 [II]: But again, I never saw his penis or anything. I'm being graphic, sorry. + +14 [II - 30:03]: No, no, no, you're fine. + +15 [II]: Yeah. + +16 [II]: We've- we've heard- + +17 [II]: Yeah, true, you've heard- + +18 [II]: - significantly worse, obviously. + +19 [II]: Um- + +20 [II]: So, I never- I never- he was never, ever inappropriate with me. + +21 22 23 24 He was very respectful to me, was fascinated about my work, he wanted to know about my work, my training, and he was like, "can you train," you know, "can you help," and I said, "I can help in an- like, have her watch me, but it took me a long time to learn what I'm doing but I can help her." + +25 [II]: Yeah. + +[II]: - you've heard a lot worse, right. + +1 2 (II): So, I would- that was it. But he was never inappropriate to me, always respectful. + +3 (II): Okay. Uh, this robe thing, was that every time or was it just the one time? + +4 5 6 (III: No. I don't rem- uh, I think it- I think it was just one time. But I- but I think that, you know, because I work from the feet up to the knee- + +7 [II]: Yeah. + +8 9 10 [II]: - so I don't remember, as you're asking that question, if he had jeans on so, he might- might have been in his bathrobe all the time, I don't- but I don't recall. I definitely remember one time he came down in a white bathrobe. + +11 12 (III: And the way that you described it, that was the same time that the massage therapist- + +13 [II): - was there? + +14 [II]: No. No, that was another time. + +15 [II): Or that was a different time. + +16 [II]: Right. + +17 [II]: Okay. + +18 [II]: I really- and again, I'm trying, to do my best to remember- + +19 [II]: No, you're fine. + +20 [II]: - (U/I) back then. + +21 [II]: You're fine. This was, if we're looking at that's what, + +22 + +23 No, years ago. + +24 yeah. + +25 Ah. + +[III: No. + +Or cl- or- + +2 [II]: Yeah. No, no, no, you're fine. + +3 4 5 6 7 8 9 [II]: And when- when if I work on Ghislaine, she would be there whether she was in, you know, shorts or whatever, she would, obviously, have her bare legs or if I worked at- often I would work on her, if it was in the library then she would, I don't know what she did after the treatment `cause I'd get up and leave `cause she'd often fall asleep, but if she was upstairs and she wanted me to work on her up in her bedroom, I would just tiptoe out, wash my hands in the bathroom, and esc- take myself out, no one escorted me out. + +10 [II]: Okay. + +11 [II]: Right. + +12 [II]: Were there any sorts of, uh, parties or large gatherings that you remember- + +13 [II]: Not that I ever saw. + +14 [II]: - during your time there? + +15 16 17 [II]: I never was there with any kind of- anything that I would've heard or saw, other than those young girls, um, coming in that time. + +18 19 [II]: I don't. I mean, I can't s- all those years, I can't remember what year it was if that's what you're asking. + +20 [II]: Sure. Do you know how long you had been there by that time? + +21 [II]: No. + +22 [II]: Okay. + +23 [II]: Summer or winter? + +24 [II]: Uh, if I had to guess, I don't remember them being- + +25 [II]: Nah d- + +(III: Do you remember when that was? + +[II]: I wish I could tell you that. + +2 [II]: -don't guess. + +3 [II]: But- okay. + +4 [II]: I really don't remember when it was. + +5 [II]: Okay. + +6 7 [II]: `Cause you have to remember, it was pretty much of a fleeting moment. + +8 9 10 [II]: It's literally like you coming in, me sitting here waiting to be called back, they come to the door and I see them for a moment and say hi, and then they walk out the other door. + +11 [III: How- + +12 [II]: And that's how fast it was. + +13 [II]: That time when I saw them, I'd say four? + +14 [II]: Four? + +15 [II]: Yeah. + +16 17 18 19 20 21 And I'm pretty naive a- so, I don't- so, it's not like I thought, "I wonder what they're doing here," except that all I knew is that I thought he worked for the Limited or was invested in the Limited, but maybe it was Victoria's Se- Secret, but that I thought they all seemed like they were in awe and kind of the unyoung models that wanted- that here they are in awe of this billionaire- + +22 [U]: Sure. + +23 [II]: - who's flying them in. And then- so, that's what makes- breaks my heart is that you're- they're so impressionable, right? + +24 [II]: Yeah. + +25 [II]: And seeing this, uh, tycoon or whatever, wealthy person and being + +[II]: Yeah. + +[II]: Sure. + +[II]: How many would you estimate? + +1 2 flown wherever and so, their- the innocence of them just breaks my heart, that that's- + +3 4 5 [III: And so, maybe they were saying, like, get- like that woman on the TV who said he would get- she would get paid three hundred dollars and prom- be promised to become a model. + +6 [II]: Yeah. + +7 [II]: So, I bet they were, at that age, and they don't say- they getthey get in awe of it. + +8 [II]: Yeah. + +9 [II]: The wealth. + +10 [II]: Yeah. + +11 [III: Yeah. + +12 [III: Did you ever see the plane or the helicopter? Okay. And you- + +13 14 [II]: Okay. And you said you think- you think Ghislaine had her own, uh, pilot's license? + +15 [III: Helicopter license- I think so. + +16 [II]: Helicopter license. See, look, now I'm out of paper. (U/I] + +17 18 19 20 21 22 23 24 [II]: And it always seemed that she was the, um, like she managed his world in the sense of their home, so she would go to Zorro Ranch but I don't- but he- but then she would manage the staff, and that's what I would hear, like, that they would train- that she had a s- again, I don't remember if it was from Ghislaine, it could've been, but that they- she'd be there to be- do trainings, and to also be at Zorro ranch but she would be there to, like, train if there were new staff and whoever- whoever they were entertaining, let's say it was a celebrity or, uh, I don't know, I'm just naming names, like, Trump or Clinton or- + +25 [II): Sure. + +[II]: Yeah. + +[II]: I never saw a landing strip. I just saw a massive home. + +1 2 3 4 [Il]: And I didn't see or know any of them, that I'm just hearing now, that's where she'd come in and she'd say n- she had to train the staff to make sure that they- these guests were being served appropriately and not, you know, that it was very private and personal. I mean- + +5 [II- 35:03]: Sure. + +6 7 [II]: - if you have a celebrity come in, you don't want someone gossiping and- + +8 9 10 11 12 [II]: So, they had to do it just that way, so, that's what I- and all I know is that he- that they had the New York home, the, um, Zorro Ranch, and I think an island that he own- uh, he either owned an island or he had a big home in the Caribbean. And I don't- and I don't know if- I think there might- is there one in New York? I- + +13 [II]: I don't know. + +14 [II]: Who knows? + +15 [II]: Exactly, yeah. + +16 [II]: Um, did you see Ghislaine training these people- + +17 [] : No. + +18 [II]: I just know about it. + +19 [II]: Okay. + +20 21 22 [II]: I- I- literally, I literally just went in, was- waited to be called back until we'd [U/I] each other at the library or bedroom, worked on her feet, and left. + +23 24 [Il]: And then if Jeffrey wanted the treatment a few times, that's when it- it was always f- down in the d- in the, uh, den. + +25 [II]: Okay. + +[II]: Right. + +[II]: I don't know. + +[II]: - or do you just know about it? + +[II]: Okay. + +2 [II]: Okay. How did you get paid? + +3 [II]: Okay. + +4 [II]: Right. + +5 [II]: And then- + +6 [II]: And then Zorro Ranch would pay me. + +7 [II]: By check? + +8 [II]: Do you still have copies of those checks? + +9 [II]: It should be in my Quicken- + +10 [II]: Okay. + +11 [II]: - oh, the checks? No, I mean, I'd have to go- + +12 [II): Okay. + +13 [II]: Okay. + +14 [II]: But I can find out the invoices or, does that matter? Like- + +15 16 17 [] : Nell, would the invoices- would the invoices or would your Quicken have things like the check numbers or the account numbers or anything like that? + +18 [II]: Okay. + +19 20 (III: It would just say, you know, "foot reflexology session, in parentheses Ghislaine, 1 and a- 1.5 hours." And then- + +21 22 (II): Okay. But the- it sounds like the- the account was the Zorro ranch account? + +23 [II]: Okay. + +24 [II]: It wasn't- there wasn't any personal name on it. + +25 [II]: Okay. Did you ever see or interact with any of the other guests? + +[II]: I invoiced them. + +[II]: Yes. Or cash. + +[III: -through my- yeah. + +(II): No. + +[II]: Yes. + +2 II]: Okay. I want to talk for a little bit about this massage therapist. What can you tell me about her? + +3 [II]: About + +4 [II]: No, no, no, no. The- the girl that he had you train. + +S 6 7 8 [II]: Oh, I mean, I literally don't remember what she looked like. It was just a young girl who came in, she pulled up a chair and I'm working on his feet and- and so, I was just talking to her aboutabout, uh, how to do reflexology, but she was young and I think she traveled with them. + +9 [II]: Okay. + +10 11 12 [II]: But I don't know how many different massage therapists they had in different- wherever their different homes were, but I got the impression that she flew with them, that they brought her withher with him. + +13 [II]: What gave you that impression? + +14 [II]: Just from hearing, like, the two- that- "she comes with me." + +15 16 [II]: Okay. Okay. You said, "young girl," how- how old would you estimate she was? + +17 18 19 II]: I wanna say, again, like, `cause I'm much older, `cause I wanna say maybe eighteen. If they were older than that, maybe. But she was not, like, fifteen years old, I (U/I) girl was, but I- she was not, like, a young, young girl. + +20 [II]: Okay. + +21 [II]: But she was y- I mean, what am I saying, she was young. + +22 [II]: Okay. + +23 [II]: Any idea how long she had been working for them? + +24 25 [II]: No. So I- I just have to say, I know nothing about the rest of their staff except those two c- that couple that ran them- the + +[II]: Right. + +2 (II): Okay. + +3 4 (II): Yeah. I don't know anything about, uh, those girls that came in, what they were doing there, why they were there, how long they worked- how long they were around, I have no idea. + +5 6 (II): Okay. As far as the ranch itself went, how would you get in, were there any sorts of gates, was there security? + +7 [II]: I got there (U/I1 there was a gate. + +8 9 10 [II]: So, I would come down whatever, heading towards Stanley, turn into the dr- entrance and then there was a gate code, I can't rem- don't ask me the gate code. + +11 [II]: No, I won't. + +12 13 [II]: And then I would push something and then they would- the gate would be open- open- it would automatically open and I would drive, like, quite a distance- + +14 (II]: Sure. + +15 [II]: - in, to get to the main house. + +16 [III]: Okay. And what would happen when you would get there? + +17 18 [II]: And I actually, now I'm thinking of it, back in the beginning I worked, it's just coming to me now, is that originally, I think while that house- home was being built, the big one- + +19 [II]: Okay. + +20 21 22 [II]: - that they had another home that was almost like a, uh, uh, like, a log cabin or, like, uh, an RV, you know what I'm- like a, what do you call it, a- not an RV, uh, help me, like a mobile home. + +23 [III: Okay. Mobile home? + +24 25 [II]: Like a double mot- but it was a b- you know, obviously they- it was made to be very nice, so, that was while the house was being + +[II]: Okay, can you describe that? + +1 2 built and then I worked over at the main house when they- when that was finished. + +3 [II]: I think so. Yeah, that was my memory of it, yeah. + +4 [II]: Okay. + +5 6 [II]: But it wasn't a mobile home that was- it was, like, a nice- theywhatever they did. + +7 [II]: Right. + +8 [II]: I think it was a mobile home- that's my impression because- but it looked like a log cabin design on the outside. + +9 [It: Okay. + +10 11 12 13 14 15 16 [Il]: And then so, anyway, going back to the main house, what made me think of- what- just remember that is because that was over this way as I'm driving and then I would go around to the main house eventually and then just- when I'd have to park in the back, notnever in the front. So, in fact, I would be parked in the back but what- I would enter through the kitchen. Not the kitchen, excuse me, the quarters that are next to the kitchen if that makes sense. Like a mud- + +17 [II - 40:15]: Okay- + +18 [II]: - so, there's a- so, it had its own- so, it had its own entryway? + +19 [II]: Yeah, like, about, like- + +20 From the outside? + +21 [II]: (U/I) yeah. + +22 [II]: Okay. Okay. When you would park back there, were there other cars that were back there as well? + +23 [II]: Uh, maybe one, or t- I mean, I didn't really note that. (U/I] + +24 [II]: Never, like, a bunch of `em or- + +25 [II]: -Yeah, no (U/I) + +[II]: Okay, so you actually started off in the mobile home? + +[II]: - like a mudroom. Like a- + +2 [II]: It was probably the housekeepers' cars or the staff but- + +3 [II]: Nope. That would be good if I could. + +4 [II]: Going back to the- to this girl you trained, um- + +5 6 III]: Well, you have to remember, you know, we're talkin' training for maybe- + +7 [II]: For forty-five minutes max- + +8 [II]: - probably. + +9 [II]: I mean- + +10 [II]: Yeah. + +11 12 [II]: - really, so- someone's sitting there saying, "oh, let me see what you do," like, "come in, show me- please show soand-so," don't remember her name, "how you do this." + +13 14 15 16 [II]: That actually brings up a good point. How- um, so, `cause it is a billion square foot house, um, did they- do you know if Jeff, uh, like, made a phone call to her or asked her to come down or, do you know how she ended up- + +17 (III: She was already in the home- + +18 - that's all I know. + +19 [II]: She was already there. + +20 [II]: Yup. + +21 [II]: Okay. + +22 [It: So, if- if it was her- if it was his hired- hired masseuse, she just came down. + +23 [II]: Okay. + +24 25 Ill]: Right. And I don't know if it was one, like, I don't know if it was, like, if she was trained as a massage therapist. I mean, she + +[II]: Do you remember what kind of car it was? + +[II]: L- less + +[II]: Okay. + +1 2 must, I mean, I don't if any of the- these girls who gave him massages who are- have been so violated, if they were trained, `cause I don't think that's the case. + +3 [II]: Sure. + +4 [II]: Yeah. + +5 [II]: Is there anything about her that you do remember? + +6 [II]: About this y- girl? + +7 [II]: About the girl, yeah. + +8 [II]: I mean, I don't- other than she was a young, attractive girl that sat next to me and I, `cause I'm focused on working on the feet- + +9 [II]: Sure. + +10 11 12 [II]: I'm telling her, you know, "this is where your adrenals are and the pancreas and this is how you do this and," so, she was just watching, fascinated, and she was very sweet. + +13 [II]: But I don't remember anything else. + +14 [II]: Okay. Did she and Jeff interact at all? + +15 [II]: Not other than just her sitting next to me and him- + +16 [II]: Okay. + +17 [II]: - saying, like, you know, "memorize what she's doing," or I didn't- she- that's not his exact words, but that's what- + +18 [II]: No, I get it. + +19 [II]: - he wanted her to learn how to work on the feet better. Yeah. + +20 [II]: Okay. + +21 22 23 [II]: That was my impression. (U/II he had never had, `cause I don't do- I was never trained as a massage therapist, I was only trained as a reflexologist, so, he- that's all I did- did then and so that's, um, that's what he wanted me to teach her. + +24 25 [II]: Okay. Did either of them ever approach you or did anybody, I guess, approach you about doing counseling out there? + +[II]: Okay. + +2 [II]: Did they know that you did that? + +3 [II]: Yes, that's why she asked about was- she wanted to hear stories. Yeah. + +4 [II]: Oh, yeah, I guess so. + +5 6 7 8 9 10 11 [II]: Yeah. And again, I want to say on the record that I would never violate confidentiality for my clients. She just wanted to know, like, "what kind of work- what kind of things couple- what coupissues do couples have? Or what- individuals, what kind of work do you do? And tell me something, a story," or she always wanted to hear, like, a- an interesting story and sometimes I'd say, "I don't have one," or that I would never say names or infer, anyway. + +12 13 14 [II]: Sure. Was there anything particular that she was interested in? So, uh, some people, so, like, in our line of work, typically what they- what people ask you is, "what's the worst thing you've ever seen," right? + +15 [II]: Yeah. + +16 17 [II): Or, things like that. Was- was there any sort of, like, specific thing that she wanted- that- that type of story that she was looking for? + +18 19 20 21 22 23 [II]: It was more like, uh, just more of a fascination about counseling, more like, "how can you do that," as, like, how, like, "how can you work with couples," or, "that must be hard," or, "tell me, like, what's the most difficult situation that- you might've had," or, you know, they- she just wanted to know something interesting, like, "what's- what's the typical conflict that couples have" or- + +24 III]: Okay. + +25 [II]: - "an individual have," but she wouldn't be specific, like, "have 1 + +2 + +3 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +you ever worked on somebody who's- had been violated or raped," or something like- nothing, she was never specific other than, "tell me a story." + +[II): Okay. + +(III: That was more, like, a, like, a curious sort of fascinated. Like, how is it- let's say I hadn't seen her for a month, you know, like, "did you have any- any- you know, "any- any interesting stories to tell about- of a certain circumstance," but again, would never violate anybody's privacy ever. + +[II]: Yeah. No I- + +[II]: It was more like an overarching, she wanted to know, like, from what, "what's that like," or, "oh my gosh, how can you do that, isn't that hard," or- I- + +[II]: Sure. And it sounded like Jeff was more interested in how you were doing what you were doing physically. Did you ever have those types of interactions with him? + +[II]: About counseling? + +[II]: About counseling? + +[II]: Never. + +[Il]: Okay. + +[Il]: He literally, like, would sorta stroll in, lie down on the- lie down on the couch in the- in the library, and I would work on his feet. But because of my impression of their- their status, or their- I was very private myself but I also respected their- + +[II - 45:02]: respected their privacy. + +[II]: - I didn't really know who this person was or what he did other than hearing snippets from or- again, just, it's not that she was telling me secrets or anything, it was more, I'm- I'm not a person who goes and starts googling until recently. + +[II]: Yeah. + +1 2 3 4 5 6 7 8 9 [Il]: I will tell you something, I- it- the- so- a client, a counseling client here, googled me and said, "you should google yourself," actually I saw him this morning, but he- he was saying, um, so I went and googled myself like he said, "just look," and some- two people were saying, "oh, must have become- become after working," for whatever, I don't know if it said Zorro Ranch or he said- he- "she's in- she's in Jeffrey's little black book," that's what it was and I was mortified. Because it's like one, how did they even tie it together, how'd they know all that, but with the internet. So, I was mortified that my name, if someone, because I'm very proud of my work- + +10 [II]: Sure + +11 12 [II]: - would google me and then wonder, like, now- I didn't want it to, like, taint anything. + +13 14 15 16 17 [II]: But they said something like, "she's in - hein little black book," but I'm- they didn't seem like professionals, it was like, so, who are these people? And I didn't- I never really pursued it or anything and I- you can't erase anything that's on Google. + +18 [II]: Right? + +19 [II]: Yeah, it's just gonna be there. + +20 21 22 [II]: But it was like, "she must've become a therapist- she must have become a therapist," or something like that, "because of- because of whatever she had to deal with, " or, it was just some absurd- + +23 [II]: Okay. + +24 [II]: (U/I] + +25 [II]: Nothing like that happened, though? + +[II]: Sure. + +[II]: Yeah. + +2 3 II]: Uh, them sending you to some sort o or you having to do that for yourself- + +4 [II]: - because of the things you saw? + +5 [II]: Oh, no, no, no, no. + +6 [II]: Okay. + +7 Ill]: I didn't see anything. + +8 [II]: Right. + +9 [II]: I'm just- + +10 [II]: Yeah, no. + +11 [II]: - just making sure. + +12 13 14 I went to graduated in■ **and graduated in** ■ **and I love my work, you know, there's not- no- there wasn't any counseling going on there, they never asked me to counsel anybody.** + +15 16 **(UI: Okay. Outside of the pay that you received for the reflexology, were you ever given any other money?** + +17 **[II]: No. No.** + +18 **[II]: Were you ever involved in-** + +19 **[] : - I'm sorry, go ahead.** + +20 21 **[II]: What would they pay me, other than reflexology? I guess, you just have to ask?** + +22 23 **[II]: Just have to ask. Uh, were you ever involved in any lawsuits that, uh, were also associated with them?** + +24 **[II]: Has anybody interviewed you about any of this before?** + +25 **[II]: No. That's why when you came to the door and I was happy to help** + +,II]: Oh- + +[II]: Yeah. + +**: What-** + +**[II]: Never.** + +1 2 you, but I don't- `cause I've had people come for counseling reasons, for other, you know, if somebody had to be, uh, had [U/I1 had records, whatever- + +3 [II]: Sure. + +4 5 [II]: - so, I didn't know who you were, so, I didn't mean to be rude- [II]: No, no, no. + +6 [II]: - who are you, how do I know who are? + +7 [II]: I- we- we've dealt with rude before- + +8 9 [Ill]: - you weren't rude. I wouldn't worry about that. Um, let's see. Do you know who any of the other staff were? + +10 11 12 (II): Just the housekeepers, I don't remember their name. I didn't see their cook. So, again, all I- all I was- was delivered was some water and then I never saw anybody, never saw a guest. + +13 14 15 16 17 [Il]: Never saw any, I mean, then I- you know, you wonder who was there. And I don't remember who told me who- who could've been there but I thought it was- they were saying that it could be somebody like Bill- Bill Clinton or, uh, I'm trying to remember who else is, I don't remember who told me but, um, but actors. + +18 [■]**: I didn't know about Trump until recently, in the news. Yeah.** + +19 20 **(II): Is there anything that stands out in your mind that we haven't talked about yet that might be important to what we're doing?** + +21 **[II]: I'm trying to give you everything I can-** + +22 **[II]: Sure.** + +23 **[II]: Sure.** + +24 **[II]: It makes me sick.** + +25 **[II]: Yeah.** + +[] : Okay. + +[II]: Okay. + +[II): Okay. + +**[II]: - to help you get him where he needs to be.** + +2 [II]: No, no, no, you're- you're fine. + +3 [II]: Sure. + +4 [II]: Yeah. + +5 6 [II]: Um, do you think- would s- or, sorry, do you think would speak with us? + +7 [II]: I'm sure, I imagine- I can't speak for her, but I don't know why she wouldn't. + +8 [II]: During your- + +9 [II]: Did you try to cont- did you- you just went to her home? + +10 11 [II]: Yeah, we just went to the Sante Fe house just `cause we're up here. + +12 (III: Okay. + +13 [II]: We're both based out of + +14 [III: So, we have an office (U/I) + +15 16 Did she ever talk to you about maybe feeling uncomfortable at being out at the ranch or anything like that? + +17 18 19 20 II]: No. And I don't remember how long she was their massage therapist. I don't know who she worked on, I don't know any of that but I think it was pretty m- we're both really professional people, so, I don't really know when she stopped or anything like that. + +21 22 (III: Okay. I know you, obviously, have her email, do you have a contact number for + +23 [II]: May I? + +24 [II]: Am I- am I being inappropriate giving that number? + +25 [II - 50:011: That is entirely up to you, ma'am. + +[II]: Yeah. I'll do anything to help you. + +[II]: Okay. + +[II]: I do. + +2 []: If you're- + +3 [II]: - if you're uncomfortable with it- + +4 5 [II]: What I think that I- I mean, just because I'd rather ask her and then give her- + +6 [II]: Yeah. + +7 [II]: - your information. + +8 [II]: Can I do that? Yeah. + +9 [II]: No, no, that's perfectly acceptable. + +10 [II]: Let me do that. I'd feel more appropriate. + +11 12 13 14 [II]: No, no, no, absolutely. Um, can you think of anybody else, `cause I know the- your field of expertise is probably relatively small, the same way that law enforcement is, it's big but it's also small, um, can you think of anybody else, uh, that it might be beneficial for us to talk to? + +15 16 (II): I don't- I don't kn- I didn't know anybody else involved with them so, I don't know. + +17 (II): Okay. + +18 19 (II): I mean, did you talk to the housekeepers? I'm sure that- if they're- whoever's still there- my impression too is that when everything started going down with the first arrest- + +20 [II]: Yeah. + +21 [II]: - they, basically, everybody stopped work- going there. + +22 [II]: Yeah. + +23 [II]: And working there. So, that's- that's- and I don't know what year that was. Do y- maybe you do. + +24 [II]: Yeah. + +25 [II]: Sure. Yup. + +[II]: - I'd rather do- + +[II]: Yeah. + +2 3 (III: So, it was kinda shut down so I nev- I never went back. I wasn't gonna go back anyway, but... I never heard from anybody. Not a word. + +4 5 [III: And you stopped going once they asked you to sign the- that disclosure- + +6 [II]: Yeah, I wasn't gonna- + +7 [] : - that non-disclosure form? + +8 9 [II]: - but I probably went a few more times, again, I don't remember, but I- I thought, "if they're gonna keep asking me this-" so they brought it up that there was gonna be this document- + +10 [II]: Right. + +11 12 13 14 [II]: - and then I thought, "I'm not doing it," and then it- and then so I kept going, however many times, but I thought, "if they actually say, `here it is,' I'm gonna leave." So, I was pretty close. It wasn't like they said, "you're gonna have to sign something," and I left and never went back. + +15 (II): Okay. + +16 17 III): I went back. I know of X amount of times and I knew that if they were gonna ask me to sign it, there's no way I'm signing anything. + +18 III]: Okay. + +19 [II]: That felt really in- not good. + +20 [II]: Yeah. + +21 [II]: Yeah. + +22 [II]: What- + +23 [] : Yeah. + +24 25 [II]: - and ask people, `cause of the confidentiality, but I still didn't even want to be a part of it. + +[II]: Oh, well, I do know that, I guess, celebrities can do that- + +2 [II]: Yeah. + +3 4 (II]: Pretty much the fact that- when I found that- out what was going on, like, the first arrest, whatever. + +5 [II]: Okay. + +6 [II]: Yeah. And it was also exhausting. + +7 [II]: Ha. + +8 9 10 11 12 [II]: Yeah. It really was. I mean, I- if it was something I had to do ev- you know, several nights a week, every week, I wouldn'tcouldn't have done it. But because she came in, you know, whenever she did, it could be- she could come in in Jan- I'm making this up, I'd have to look, she could come January and not come again until April or- + +13 14 [II]: - or then she could- again, I- I don't remember that far back, but- + +15 [II]: Okay. + +16 [II]: Yeah. + +17 [II]: Okay. Did you have anything else for her? + +18 [UM1]: Uh, yes and please stop me if I- + +19 20 [UM1]: So, you said that the housekeepers made a very good impression upon you with their kindness- + +21 [I: Yup. + +22 [UM1]: - and generosity- + +23 (II): Yeah. + +24 [UM1]: - if you were to see a picture of them, do you think you would be able recognize them? + +25 [II]: Uh, you could try me, but I don't- right now, I can't remember + +[II]: What did eventually make you stop going out there? + +[II]: Okay. + +(U): No, no, no, please. + +1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 their faces for the life of me, no. [II): Is that it? (UM1): Yeah, I have a [U/I]- (II): You have a picture? [UM1): - (U/I) a hotspot- (II): Oh, do you? [UM1): If you wanna (U/I) [III: Yeah, absolutely. But what time- what time is it? Let's start there. We've got about seven minutes. [UM1): It might- yeah, and I can text my next s- uh, client is a phone session, so I can tell them I'm running five minutes behind if you need, no rush, but. [UM1): May I get your keys so I can grab them [U/I] [III: Yeah, no, absolutely. [III: Are you [U/I) picture? [UM1): I'm great, let's see if I [U/I] [II): Oh my [U/I) uh, let me put that behind you because it's locked. I think it's locked. (UM1): Okay. [II]: Just c- crack it. Is it pronunciation? yeah. No, that's you're fine. [III: Okay. [II): Yeah, this, uh, it's pretty ugly. [II]: [U/I) [II]: Yeah and I'm sorry you're wrapped up in it, that's uh- [II]: Do I need to- is there any reason that I would have to do- do anything past this where I should get an- an attorney or, : don't-III): I, so2 II): - I- I can't give you legal advice. Like, I'm just not allowed to give you- + +3 II): Okay. + +4 5 6 [II]: - legal advice. If you feel like you should at least contact somebody, you should absolutely just contact somebody. Even if you just want to run it by `em. + +7 [II]: Okay. + +8 [] : I understand. + +9 [II]: -I'm just not allowed to either way. + +10 11 [II]: I just didn't think that because of what I'm telling you, I, like, wasn't involved in anything- + +12 [II): Yeah. + +13 III): -other than going in, doing my work, and leaving, that- that there- that I'm- + +14 [II]: Yeah. + +15 [II]: - kind of a benign, um- + +16 [II] : Yeah. + +17 [II]: - whatever, involved person. + +18 [II]: Yeah. Obviously, you know, you watch the news- + +19 [II]: It's just + +20 [1.]: get your baby. + +21 [II]: We're all friends here now. + +22 [II]: Come on, get your baby, say hi to Get your baby, come on, just... + +23 LUM1): God, that guy on the ropes, I'm gonna take him out. + +24 [II]: I'm going to, um, text my client and see if she- + +25 [II]: Yeah, no, absolutely, and we appreciate it. + +[II]: If you feel that you don't need to, don't. But I c- I can't- + +[1.]: stop, it's + +2 [II]: Sure. + +3 4 [II]: Yeah. What's the matter, Stella? Come here, baby. Want some waters? Huh? I know. Have all these strangers walking into your house. I know. + +5 6 III - 55:04): I'm gonna say, "ten minutes later," let's see, do you think that you- how much time do you think you need? + +7 [II]: Uh, however long it takes to boot up. + +8 [UM1): Ten minutes is pretty safe. + +9 [UM1): Please. + +10 [II]: [WI]. Okay. Okay. + +11 [II]: Thank you for doing that, we really appreciate it. + +12 [II]: (U/I1 + +13 [II]: No. + +14 [II]: - at all? + +15 [II]: Never heard of her. + +16 [II]: Okay. + +17 18 19 [II]: I know you can't say anything, I'm just saying it out loud, and that's why I was going to call but I was thinking because of Ghislaine and the whole involvement, if she's gonna go to jail but that's- that's not- + +20 [II]: Yeah, we can't. Yeah. + +21 22 [II]: No, I know you can't say a word. I'm not asking you to, but I just- + +23 [II]: I- I just want- obviously, it's a very disturbing- + +24 [II]: Yeah, I mean, you- + +25 [II]: - collaboration. + +[II]: Okay. Uh, let's see. + +[II]: Are you familiar, with, uh, + +[II]: Okay. + +2 [E] : Yup. + +3 - so, I mean, it's- it's- it's a pretty broad scope of issues. + +4 Uh, and all of it's, you know, ugly at best- + +5 [U] : Oh, yeah. + +6 [U] : - unfortunately. + +7 8 : But it seems like, I know you can't say anything, but it seems like he's not gonna get away with, uh- obviously, he's going- + +9 [U] : - he's gonna to jail. + +10 11 12 [U] : I know- I know the, uh, the feds are holding him. They didn't they denied him bail, uh, so they're holding him there in New York, you know? However, we're just doing our part at this- + +13 tEj : Yeah. + +14 [U] : - you know? Just trying to be part of the solution, I guess. You know? + +15 16 [M] : Do you have the staffs' names? I mean, do you- the housekeeper's name? + +17 (MI: So, we can't - + +18 [U] : You can't say that. + +19 [E] : Okay. + +20 : If you recognized them, then- + +21 [U] : Okay. + +22 [U] : - great, if you don't, that's okay too. But yeah, we + +23 [U]: Okay. + +24 : I- I understand. + +25 [U]: - that might push you in one direction or another- + +[M] : Oh, oh yeah. + +[: Well, the- + +[1.] : Yeah. + +[E] : - we can't give you anything any further than that- + +2 (II): - obviously. + +3 (UM1): Before I have to view the picture that I have to make sure there's no identifiers associated with it. + +4 5 (II): So, my client said, "not at all, not a problem. I just picked up my son." Okay. + +6 7 (II): Okay. And thank you, again, so much for doing that, you don't have to. + +8 9 10 [III: Okay. That should put us right on time. Give you a little bit of a break before you have to start with your client. Woah. + +11 (III: What did you say I mean, about the- + +12 (UM1): I- I have to view the picture to make sure that there is no i- + +13 (UM1): There's- there's a little issue here. I just wanna- + +14 15 16 17 (II): And there's something I'm remember- I, again, don't quote me because I don't remember that well, `cause I kind of went in myin my way and just did my work and left, but I- there might have been two sets of housekeepers, for some reason that's coming up for me now, I don't know- + +18 III]: Okay. + +19 20 21 22 [III: - if one of them had to leave and go back somewhere, wherever they lived. Like, if they were in another state or another- from another- I don't think they were from another country, but, thenbut they were- so, but I definitely- they were lovely people. + +23 24 [II]: They're obviously holding a lot of, you know, in- information in their... (U/I). + +25 (III: I would imagine. + +[III: So, I'll have `til five of. + +f.): Oh, I get it. Can you cover it with your finger? + +[II]: Okay. Okay. + +2 [II]: Yeah. + +3 4 [U]: Yeah. No, that's just not a good- that's just not a good situation, period. And it's unfortunate. + +5 (UM1): So, I'm just gonna [U/I] + +6 [II): Yeah, take your time. + +7 [UM1]: (U/I] right there. + +8 9 (II): So, am I (U/I] have. Yeah, I think that- I think that was her. One of the housekeepers- I- at this point, I won't swear my life, to- + +10 11 12 [UM1]: Based on- based on your description of how you interacted and how she presented herself to you, that is my guess. And tell me if the... + +13 14 [II): I think that, yeah. Was that what you're saying, based on my interaction with her, do I think that that was one of the housekeepers? + +15 [UM1]: I'm just asking you if that's who you interacted with. + +16 17 [II): I think so, yes. That's- she looked- but she had a husband, too, I think. + +18 [II]: Uh-huh. + +19 [II]: Okay, let's try again. + +20 21 III - 1:00:01): If you have a set of another- another set of Housekeepers I- or, just those, okay. + +22 23 See, though, I'm just trying to remember too, who was that otherthere was another woman that I don't remember. She was never in the main house, but they had horses. + +24 III]: Okay. + +25 [II]: At the ranch, right? + +[II]: [U/I] for everybody involved. + +[UM1): Do you- did you see both of them? + +2 II]: So, they had, like, there were all sorts of different, um, uh, homes, like, little cabins or guesthouses or- + +3 II]: Okay. + +4 5 6 [II]: - whatever you call- call them, where different staff would live, but I remember interacting with one nice woman, but it- there was nothing substantial to tell you about that. + +7 [II]: Okay. So, the staff lived on the property? + +8 [UM1): Here is the other female. + +9 (II): No, I don't know that one. + +10 [UM1): Nope? + +11 [II): Okay. + +12 [UM1): The other one- + +13 [UM1): Let me, um. Feel free to continue talking (U/I) + +14 (II]: Okay. + +15 16 [II]: So, you said, uh, there was at least one person who took care of horses. Do you know about the other staff or? + +17 (II): I mean, I don't know- you mean, about what they did? + +18 19 20 21 22 [II]: I would j- I'd be guessing too. So, there's the housekeepers, then there was, like, a groundskeeper, there was, like, people who was in charge of the horses, and that's- and then I think that there maybe was another person who was an assistant, but : don't remember, or- but maybe she was the one who was in that house- one of the houses when I first drove in? + +23 [II]: Okay. + +24 [II]: Yeah. + +25 [II]: Okay. + +[II]: Yes. That's what [U/I] + +(II): Maybe that was after I 1- I don't know. + +[II]: Well, like, how many, things like that. + +2 [II]: No, no, no, you're fine. Outside of this how are you doing? + +3 [II]: Good. + +4 [II]: Yeah. + +5 [II): Good to hear. + +6 [II]: Well, yeah. + +7 [II]: Good. + +8 [II]: Yeah, my, uh, my air conditioner- + +9 [II]: What's it like i. can't imagine. + +10 11 [II]: - my air was, uh, it was not pleasant last night in my house. conditioner went out yes- some time yesterday. So, it + +12 [III: Well- + +13 14 [II]: It must be awful, I mean, `cause it's like ten degrees hotter easily in + +15 16 [II]: Yeah. Yeah, it was. So, when I woke up, so, when I woke up it was about seventy outside, but it was eighty-five- + +17 (II): Ugh. + +18 [II]: I've never- + +19 [II]: Just awful, awful. + +20 21 22 [II]: - I've lived here since I've never wanted an air conditioning ever except in here but, um, now I- now I I think I wish I had one, but I don't really like AC that much. + +23 [II]: No. But it would be nice to have it. + +24 [II]: Yeah. + +25 [II]: Yeah. It seems like it's getting hot- + +[II]: Good. + +[II]: Except for the heat. + +[II): But- + +[II]: - inside the house. It was awful. + +[II]: Really? + +2 [II]: Yeah, that's right. + +3 [II]: It's supposed to be hot this weekend, I think, right? + +4 [II]: Yeah. + +5 [II]: Yeah. + +6 7 8 9 10 [II]: Yeah. Something tells me my AC's probably not going to get fixed by then, so I contacted, uh, people yesterday, um, and they were like, "well, we'll check the schedule and see when we can come out." I was just like- I just hung my head, there's nothing else I can do. So, I can beat on it with a hammer but that ain't gonna do no good, so- + +11 [II]: No. + +12 (II): I'm pretty much stuck. + +13 [II]: No? Okay. Okay, well, if it's not, it's not, so. + +14 15 16 [II]: I mean, I'll see you, I'll come to- anytime you want to ask me more, or, I mean, I don't think there's anything more I have, but if you want to show me pictures- + +17 [II]: Yeah. + +18 [II]: Yeah, as long as that's okay with- + +19 [] : Yeah. + +20 [II]: - you, then. Yeah. + +21 22 [II]: That's fine, yeah. The only thing wouldn't be fine is if I- like today when you just came, I'd rather have (U/I)- + +23 [II]: Yeah. + +24 [II]: - uh, text you or whatever- + +25 [II]: Okay. + +[II]: Yeah. Yeah, it's been awful and today it's hot again. + +(UM1): It's not (U/I] + +[II]: - another time. + +[II]: Yeah, no, we'll definitely call ahead of time- + +1 2 [II]: - the case may be and yeah, we'll make- we'll make better arrangements next time- + +3 - for certain. Are you all good? + +4 (UM1): I'm just trying one more thing since we're here, sir. + +5 [II]: Absolutely. Yeah, it's- + +6 7 [II]: Do you feel like you've covered up everything that you can think of? + +8 9 10 11 [II]: I know, I'm try- no, I'm trying to tell you as things pop in, `cause they- you know how you- when you start talking about something and then you remember, like, "oh," um\_ Yeah, no, never saw any guests ever, except for the girls that came in that time. + +12 [II]: Okay. + +13 [II]: Yeah. + +14 15 16 17 18 19 20 [II]: - that I was just always- I wasn't up- supposed to go in any other part of the house. Although I never- but I would walk upstairs as- like, whoever that other woman was, or, I wish I could remember the- see a picture of the man, but, they were lovely and they would just say, um, "okay, you can go upstairs now to Ghislaine's bedroom if she's up there," or they'll, "wait down here in the kitchen," off, you know, the mudroom, whatever and- and then, "you're gonna be going into the library today." + +21 [II]: Okay. + +22 [II]: And that's just it. So, then I would just sit there, set up. + +23 24 25 [II]: Then she'd come in and she'd plop down, and then sometimes she'd call and ask for something to eat, but... I don't remember him. But who knows? If that was his- but I'm pretty sure the first woman + +[II]: Okay. + +[II]: I think so, yeah. Is- oh- feel free, if you don't think I have. + +[II]: Um. And ag- and, you understand, because of their privacy- + +[II]: Just hang out and wait. + +2 (II): Okay. Alright. + +3 [II - 1:05:02): It's probably her husband or something. + +4 [II]: All set? + +5 (UM1): (U/I) + +6 [II]: Alright, well, we are gonna get out of here. Thank you- + +7 [II]: You're welcome. + +8 [II]: You're welcome. + +9 10 [II]: Um, if you'll give a call, uh, and see if she's- if she would be willing to speak to us, that would also be incredibly- + +11 (II): Okay. + +12 13 14 (II): - helpful. Um, and that's it. If you remember anything, uh, that we haven't covered, or if you remember anything better, or anything like that, feel free to contact, uh- get with me, specifically- + +15 [] : Okay. + +16 [II]: - um, and then we'll just go from there. + +17 [II]: Okay. And so wait and talk to you ear-to-ear, don't leave it on your voicemail, right? + +18 [II]: Um, yeah, I would- + +19 [II]: Okay, yeah (U/I)- + +20 21 III]: - yeah, I would wait. Just- just let me know that you need to talk to me. + +22 [II]: Okay. + +23 [II]: Um, I don't always answer the work phone, uh, so you can either leave me a text message or just leave me a voicemail- + +24 [II]: Okay. + +25 [II]: - and just let me know that you need to talk to me. + +(UM1): We have, like, one picture that's resisting my- + +[II]: -again for talking to us, we really appreciate it. + +2 [II]: Okay? Alright, well, we're going to get out of here. + +3 [II]: [U/I] + +4 [II]: Yeah. + +5 [II]: Thank you so much. + +6 [UM1): Thank you very much for your time. + +7 [II]: (U/I1 + +8 [II]: [U/I] + +9 [II]: It seems like an awful lot, but- + +10 11 12 [II]: It's really, like, with what I've- I almost can't watch it, theand I'm not a big news person, but s- I have- other people will come in and just, like, talk about re- recent news or something, and it's like unbelievable what they've discovered. + +13 [II]: Yeah. + +14 [II]: The money and everything. + +15 [II]: Yeah. + +16 [II]: It's really disturbing. + +17 [II]: Yeah. + +18 [UM1]: Yeah but what you might hear might jog your memory and- + +19 [UM1): [U/I] should have- + +20 [II]: That's right. + +21 [II]: Thank you so much. + +22 [II]: Thank you. Have a good weekend. + +23 [II]: You too. + +24 [II]: Smells like somebody's bakin' bread. Is it pizza? + +25 (UM1): (U/I) that right. (U/I) + +[II]: Yeah, no, absolutely. + +[II]: Yeah. + +(II): Yeah. + +[UM1]: You too. + + [III: What's the- no, I don't think so. 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Engelmayer United States District Judge Southern District of New York 40 Foley Square New York, NY 10007 + +Re: The New York Times Co. v. Federal Bureau of Prisons, 20 Civ. 833 (PAE) + +Dear Judge Engelmayer: + +This Office represents defendant the Federal Bureau of Prisons ("BOP") in this Freedom of Information Act ("FOR"), 5 U.S.C. § 552, action brought by plaintiff the New York Times Company (the "Times") seeking the release of certain records related to Jeffrey Epstein. Enclosed please find the Government's first in camera production. As directed by the Court, this production consists of certain records identified in Exhibit 1 to the supplemental Christenson declaration. + +The production consists of 986 pages, including 375 pages of non-email documents and 611 pages of emails. Pursuant to the Court's directions, the Government has, for each page, indicated which portions of the page are withheld under which FOIA Exemption and, if a portion or the entire page is withheld under FOIA Exemption 7(A), indicated which criminal case, United States v. Tartaglione, 16-cr-832 (KMK), or United States v. Noel, 19-cr-830 (AT), is the basis for the exemption. + +Because of technological and other constraints, the Government used two systems to mark the redactions on the pages. Under one system, a redaction is marked out by a pink box, and the associated exemption is noted next to or within the box. Under the second system, the Government highlighted redacted material as follows: material withheld under Exemption 7(A) on the basis of Noel is highlighted red, material withheld under Exemption 7(A) on the basis of Tartaglione is highlighted goldenrod yellow, material withheld under Exemptions 6 and 7(C) is highlighted green, material withheld under FOIA Exemption 5 and the deliberative process privilege is highlighted blue, and material withheld under FOIA Exemption 7(E) is highlighted purple.' Under this second system, pages withheld in full are marked as such by a box in the color corresponding to the exemption, with text noting the withholding in full. On certain pages, both systems are used, with some redactions marked out using pink boxes, and other redactions marked out with highlighting. + +1 If the entirety of a paragraph on a given page is withheld, then parallel lines in the appropriate color have placed on either side that paragraph to indicate redaction. + +The Government notes that upon compiling this submission, it identified and removed some duplicate pages from the production. In addition, it re-ordered the documents, roughly by type and content such that the Bates numbers on the documents are no longer strictly in order. These steps were taken to facilitate the Court's review. + +The production includes emails between Tartaglione's defense counsel and the Bureau of Prisons, which typically discuss the conditions of Tartaglione's confinement and have been withheld in full under Exemption 7(A) on the basis of Tartaglione. The Government believes that many of these emails are not directly responsive to the Times's FOIA requests, but were collected by BOP pursuant to electronic search terms generally because Jeffrey Epstein may be mentioned at some point in a chain of emails and also possibly because Tartaglione's defense counsel, Bruce Barket, is associated with the firm Barket, Epstein, Kearon, Aldea & LoTurco, LLP, and so the name "Epstein" typically appears in the signature block of his emails. If the Court would benefit from further submissions on why release of these emails in the context of a FOIA request about Jeffrey Epstein could reasonably be expected to interfere with Tartaglione, the Government is prepared to provide such submissions. However, upon re-reviewing these materials and in light of representations by the Times as to its area of greatest interest, the Government does not believe that these emails are of central concern in this matter and could be fairly described as non-responsive to the Times's requests. + +I thank the Court for its consideration of this submission. + +Respectfully submitted, + +AUDREY STRAUSS + +United States Attorney + +By: /s/ Steven J. Kochevar + +Steven J. Kochevar + +Assistant United States Attorney + +300 Quarropas Street + +White Plains, NY 10007 + +Telephone: (914) 993-1928 + +Email: steven.kochevar@usdoj.gov \ No newline at end of file diff --git a/marker2/ds9/EFTA00090099/EFTA00090099.metadata.json b/marker2/ds9/EFTA00090099/EFTA00090099.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..a16ca401a4ad0217e0bf39b8246e653c297059e4 --- /dev/null +++ b/marker2/ds9/EFTA00090099/EFTA00090099.metadata.json @@ -0,0 +1,149 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090099.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 4504, + "elapsed_seconds": 0.84, + "image_assets": [ + "_page_0_Picture_0.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "U.S. Department of Justice", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 318.24, + 31.589999999999996 + ], + [ + 463.6681213378906, + 31.589999999999996 + ], + [ + 463.6681213378906, + 46.353515625 + ], + [ + 318.24, + 46.353515625 + ] + ] + }, + { + "title": "By Hand Delivery and ECF", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 160.38 + ], + [ + 216.3724365234375, + 160.38 + ], + [ + 216.3724365234375, + 174.9735107421875 + ], + [ + 68.544, + 174.9735107421875 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 83 + ], + [ + "Line", + 41 + ], + [ + "Text", + 9 + ], + [ + "SectionHeader", + 2 + ], + [ + "Picture", + 1 + ], + [ + "Footnote", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 65 + ], + [ + "Line", + 31 + ], + [ + "Text", + 14 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00090099" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00090099/_page_0_Picture_0.jpeg b/marker2/ds9/EFTA00090099/_page_0_Picture_0.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..f7a37d281e8b6c6127421e7b5db86a115116ec32 --- /dev/null +++ b/marker2/ds9/EFTA00090099/_page_0_Picture_0.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:b09969d54c4b8a992d94a07e4d010d4d80030c5a71245beefc4612b4edd37dc9 +size 3589 diff --git a/marker2/ds9/EFTA00090101/EFTA00090101.md b/marker2/ds9/EFTA00090101/EFTA00090101.md new file mode 100644 index 0000000000000000000000000000000000000000..3cec879d851907b87dea0aaee17d6751a8409e0b --- /dev/null +++ b/marker2/ds9/EFTA00090101/EFTA00090101.md @@ -0,0 +1,7 @@ +## Public Corruption Unit Short Form Updates April 2, 2021 + +## A. SIGNIFICANT DEVELOPMENTS IN CASES + +US v. Ghislaine Maxwell USAO 2018R01618 (AUSAs : On June 29, 2020 a grand jury returned a six count indictment charging Maxwell for her role in facilitating Epstein's abuse of minor girls. Maxwell was arrested on July 2 at a residence in New Hampshire and has been detained since. + +The team made an initial discovery production on or about August 21, 2020, and is working on a second discovery production of electronic materials in the coming month. The team is also working with the USAO-SDFL, OPR and the West Palm Beach Police Department among other sources to obtain and review materials relevant to the prior investi ation. Additionally, the team is in the process of reaching out to counsel for to begin initial discussions about the possibility of a felony disposition. We are also continuing to pursue a potential interview with Prince Andrew, and after his counsel declined to make him available for a voluntary interview, we notified OIA that we wished to proceed with an MLAT. We completed discovery in November 2020. Maxwell's second bail application was denied in December 2020. Pretrial motions were filed in late January and include anticipated motions to dismiss the indictment based on the NPA or, alternatively, the statute of limitations; motions to suppress materials obtained from Boies Schiller pursuant to grand jury subpoena and from the civil case; and various discovery related motions, including ones seeking a bill of particulars and/or early production of Giglio and 3500 material. On February 26, the team filed an omnibus brief in opposition to the defendant's pretrial motions. A reply brief is due on March 15. Maxwell has also recently filed a third bail motion. Our brief in opposition is due March 9. Trial has been adjourned to the fall of 2021. Judge Nathan recently denied Maxwell's pretrial motions but deferred ruling on a suppression motion related to materials obtained via a subpoena to a law firm. Maxwell's bail appeal to the Second Circuit was recently denied as well. \ No newline at end of file diff --git a/marker2/ds9/EFTA00090101/EFTA00090101.metadata.json b/marker2/ds9/EFTA00090101/EFTA00090101.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..73fd5332aed6b7db199e2507d8cfd18756868027 --- /dev/null +++ b/marker2/ds9/EFTA00090101/EFTA00090101.metadata.json @@ -0,0 +1,269 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090101.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 7, + "chars": 2116, + "elapsed_seconds": 0.64, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Public Corruption Unit \nShort Form Updates \nApril 2, 2021", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 241.74, + 69.66 + ], + [ + 369.64799999999997, + 69.66 + ], + [ + 369.64799999999997, + 114.20999999999998 + ], + [ + 241.74, + 114.20999999999998 + ] + ] + }, + { + "title": "A. 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New York 10007 + +May 5, 2021 + +## BY ECF + +The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 + +Re: United States v. Chislaine Maxwell, 20 Cr. 330 (AJN) + +Dear Judge Nathan: + +The Government respectfully submits this letter in response to the Court's Order dated April 29, 2021, which directed the Government to confer with legal counsel at the Metropolitan Detention Center ("MDC") regarding the use of flashlights in security checks at MDC. (Dkt. No. 257). The Government has conferred with legal counsel at MDC in accordance with the Court's Order, and legal counsel provided the information set forth herein. + +MDC staff conduct flashlight checks at night as a matter of course throughout the facility for the safety and security of the inmates at the institution. During these flashlight checks, MDC staff point a flashlight at the ceiling of each cell to illuminate the cell sufficiently to confirm that the inmate is present in the cell, breathing, and not in distress. MDC staff conduct flashlight checks every 30 minutes for inmates housed in the Special Housing Unit (the "SHU") and conduct flashlight checks of inmates in the general population multiple times each night at irregular intervals, but at an average of at least once per hour. + +With respect to the defendant, MDC staff conduct flashlight checks every fifteen minutes because the defendant, while not on suicide watch, is on an enhanced security schedule. That is because MDC has identified a number of factors that raise heightened safety and security concerns with respect to this defendant, including: (1) the nature of the charges, (2) the potential stress for inmates that can arise in high-profile cases, and (3) the need to ensure the defendant's safety while she is incarcerated in a cell by herself—a housing determination made by MDC staff based on various factors, including the defendant's expressed concern for her safety if she were to be housed in the general population.' + +As to the Court's question whether the defendant can be provided with "appropriate eye covering," MDC legal counsel has informed the Government that the defendant cannot be provided with an eye mask. Eye masks are not available for purchase in commissary and are not issued to inmates and, therefore, are considered contraband. The defendant is permitted, however, to use non-contraband items to cover her eyes at night. + +Should the Court have any questions or require any additional details regarding this topic, the Government will promptly confer with legal counsel at MDC and provide additional information. + +Respectfully submitted, + +AUDREY STRAUSS United States Attorney + +By: s/ + +Assistant United States Attorneys Southern District of New York + +Cc: Defense Counsel (By ECF) + +The MDC has determined the defendant's current housing assignment based, in part, on her concerns about being housed in the general population and as an alternative to her being housed in the SHU. 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Ghislaine Maxwell, 20 Cr. 330 (AJN) +**Date:** Wed, 05 May 2021 20:26:47 +0000 + +--- + +Sigrid, + +Do you have a few minutes to speak tonight or tomorrow? Please let us know when works for you. + +Thanks, + +[REDACTED] + +--- + +**From:** Sigrid McCawley <[REDACTED]> +**Sent:** Tuesday, May 4, 2021 9:18 AM +**To:** [REDACTED] (USANYS) <[REDACTED]> +**Cc:** [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] +[REDACTED] <[REDACTED]> +**Subject:** RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +Just as a follow up. I just heard back from [REDACTED] and she said her strong preference is as early as possible in the fall – early September would be her preference. [REDACTED] and her husband are going through the process of trying to adopt a baby and the birth mother is due in early November (and of course babies can sometimes come a bit earlier). The birth mother has not finalized the match so this is a fluid situation but [REDACTED] wants to make sure she is able to be there when the baby is born and of course care for her newborn immediately following the birth. I will keep you updated but [REDACTED] strong preference is for as early as possible. + +All my best, +Sigrid + +**Sigrid McCawley** + +Partner + +--- + +**BOIES SCHILLER FLEXNER LLP** + +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] + +[www.bsfilp.com](http://www.bsfilp.com) + +--- + +**From:** [REDACTED] (USANYS) [[mailto: \[REDACTED\]](mailto:[REDACTED])] +**Sent:** Monday, May 3, 2021 6:34 PM +**To:** Sigrid McCawley <[REDACTED]> +**Cc:** [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]>; +[REDACTED] <[REDACTED]> +**Subject:** United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +Thanks, + +Assistant United States Attorney + +United States Attorney's Office + +Southern District of New York + +The information contained in this electronic message is confidential information intended only for the use of the named recipient(s) and may cents., information that. among other protections, is the subject of attomey.client privilege, attorney work product or exempt from disclosure under applicable law. If the reader of this electronic message is not the named recipient. or the employee or agent responsible to deliver it to the named recipient, you are hereby notified that any dissemination. distribution. copying or other use of this communication is strictly prohibited and no privilege is waived. If you have received this communication in error, please immediately notify the sender by replying to this electronic message and then deleting this electronic message from your computer. (v.1 08201831889 \ No newline at end of file diff --git a/marker2/ds9/EFTA00090110/EFTA00090110.metadata.json b/marker2/ds9/EFTA00090110/EFTA00090110.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..512fbe6491c81f8611d27c30d4d1b03ae3e37192 --- /dev/null +++ b/marker2/ds9/EFTA00090110/EFTA00090110.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090110.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2782, + "elapsed_seconds": 7.38, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 74 + ], + [ + "Text", + 41 + ], + [ + "Line", + 37 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 21 + ], + [ + "Text", + 11 + ], + [ + "Line", + 11 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00090110" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00090112/EFTA00090112.md b/marker2/ds9/EFTA00090112/EFTA00090112.md new file mode 100644 index 0000000000000000000000000000000000000000..bf20ba50494042e5b281701f92ae3098fc947972 --- /dev/null +++ b/marker2/ds9/EFTA00090112/EFTA00090112.md @@ -0,0 +1,123 @@ +To: !grid l'v vir> (USANYS)" + +Cc: ' " )II + +Subject: RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +Date: Wed, 05 May 2021 21:56:30 +0000 + +Hi Sigrid, + +Thanks so much for making the time to talk. We're free at 6:45 tonight, if that still works. We can use this conference line: + +Thanks, + +From: Sigrid McCawley < + +Sent: Wednesday, May 5, 2021 4 31 PM + +To: (USANYS) + +Cc: >; + +Subject: RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +Yes. I can talk anytime now until 5:30 and then from 6:00 - 7:15 if any of those times work? Tomorrow I am open from 9- 10 or 12-2. + +Please let me know what works for you. + +Best, + +Sigrid + +Sigrid McCawley + +Partner + +BOIES SCHILLER FLEXNER LLP + +www.bsfllp.com + +From: (USANYS). + +Sent: Wednesday, May 5, 20214:27 PM + +To: Sigrid McCawley + +Cc: + +Thanks, + +[REDACTED] + +--- + +**From:** Sigrid McCawley <[REDACTED]> + +**Sent:** Tuesday, May 4, 2021 9:18 AM + +**To:** [REDACTED] (USANYS) <[REDACTED]> + +**Cc:** [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] + +[REDACTED] <[REDACTED]> + +**Subject:** RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +Just as a follow up. I just heard back from [REDACTED] and she said her strong preference is as early as possible in the fall – early September would be her preference. [REDACTED] and her husband are going through the process of trying to adopt a baby and the birth mother is due in early November (and of course babies can sometimes come a bit earlier). The birth mother has not finalized the match so this is a fluid situation but [REDACTED] wants to make sure she is able to be there when the baby is born and of course care for her newborn immediately following the birth. I will keep you updated but [REDACTED] strong preference is for as early as possible. + +All my best, + +Sigrid + +**Sigrid McCawley** + +Partner + +--- + +**BOIES SCHILLER FLEXNER LLP** + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[www.bsfllp.com](http://www.bsfllp.com) + +--- + +**From:** [REDACTED] (USANYS) [[mailto:\[REDACTED\]](mailto:[REDACTED])] + +**Sent:** Monday, May 3, 2021 6:34 PM + +**To:** Sigrid McCawley <[REDACTED]> + +**Cc:** [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] + +[REDACTED] <[REDACTED]> + +**Subject:** United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +Sigrid, + +Please see the attached order regarding the trial date in this case. We will update you when we have more information. + +Thanks, + +[REDACTED] + +[REDACTED] + +Assistant United States Attorney + +United States Attorney's Office + +The information contained in this electronic message is confidential information intended only fa the use of the named recipient(s) and may contaii information that. among other protections, is the subject of attomey-dient privilege, attorney work product or exempt from disclosure under applicable law. If the reader of this electronic message is not the named recipient. or the employee or agent responsible to deliver it to the named recipient, you are hereby notified that any dissemination. distrioution. copying or other use of this communication is strictly prohibited and no privilege is waived. If you have received this communication in error, please immediately notify the sender by replying to this electronic message and then deleting this electronic message from your computer. (v.1 08201831BSO + +The information contained in this electronic message is confidential information intended only for the use of the named recipient(s) and may contain intimation that, among other protections, is the subject of attomey.client privilege. attorney work product or exempt from disclosure under applicable law. If the reader of this electronic message is not the named recipient. or the employee or agent responsible to deliver it to the named recipient, you are hereby notified that any dissemination, distribution. copying or other use of this communication is strictly prohibited and no pookige is waived. If you have received this communication in error, please immediately notify the sender by replying to this electronic message and then deleting this electronic message from your computer. 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Ghislaine Maxwell, 20 Cr. 330 (AJN) + +Date: Fri, 07 May 2021 03:57:42 +0000 + +Good evening- + +Our 4/22 letter detailed our position. Please let us know your availability for 11/8. + +Thank you- + +Bobbi + +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 email and then delete this message. Thank you. + +On May 6, 2021, at 7:15 PM, wrote: + +Counsel, + +We write to confer in accordance with the Court's Order about a trial date in this case. Please let us know your preferences and availability for trial dates from September 2021 through the end of the year. If you could please provide details for any conflicts, that would be helpful. + +Thank you, + +Assistant United States Attorney Southern District of New York One Saint Andrew's Plaza New York, NY 10O07 + +![](_page_1_Picture_1.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00090115/EFTA00090115.metadata.json b/marker2/ds9/EFTA00090115/EFTA00090115.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..b2037bb08d6cdc839e7677d5bda7e4b79509202b --- /dev/null +++ b/marker2/ds9/EFTA00090115/EFTA00090115.metadata.json @@ -0,0 +1,90 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090115.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 1180, + "elapsed_seconds": 1.42, + "image_assets": [ + "_page_1_Picture_1.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 45 + ], + [ + "Text", + 31 + ], + [ + "Line", + 24 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 9 + ], + [ + "Line", + 5 + ], + [ + "Text", + 1 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00090115" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00090115/_page_1_Picture_1.jpeg b/marker2/ds9/EFTA00090115/_page_1_Picture_1.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..e22412163e9736399d529c48d713048c0a873ec1 --- /dev/null +++ b/marker2/ds9/EFTA00090115/_page_1_Picture_1.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:d243fb25358caa0cd62c93d32105bda913c887ed0b7750790106af209d99287f +size 1563 diff --git a/marker2/ds9/EFTA00090117/EFTA00090117.md b/marker2/ds9/EFTA00090117/EFTA00090117.md new file mode 100644 index 0000000000000000000000000000000000000000..2b002d6438adce7308459e71b13c2a685da95e67 --- /dev/null +++ b/marker2/ds9/EFTA00090117/EFTA00090117.md @@ -0,0 +1,143 @@ +To: + +Cc• + +, Jeff Pagliuca Laura Menninger + +Subject: Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +Date: Fri, 07 May 2021 21:26:15 +0000 + +USANYS + +We are available to begin November 8th and to conclude by the end of the year. + +Laura has a civil trial scheduled for December 13th, but will try to move it. + +Bobbi + +BOBBI C. STERNHEIM, ESQ. + +Law Offices of Bobbi C. Stemheim + +![](_page_0_Picture_13.jpeg) + +"Covid-19 Notice: The West 19th Street office is currently closed but we continue to work remotely. + +Please use entail or fax, instead of regular mail, for all correspondence during this time. + +We continue to work regular business hours throughout this situation. + +Thank you for your consideration. Our best wishes for your good health and well being. + +This message and any attached documents contain information from the Law Offices of Bobbi C. Stemheim + +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 May 7, 2021, at 5:16 PM wrote: + +Bobbi, + +We understand that you're requesting a November 8th date, and that you prefer that date. Separate from your preferences, our question was simply about your scheduling availability in light of the Court's order. Can you please let us know your availability and we will note that accordingly in our submission to the Court? + +![](_page_0_Picture_25.jpeg) + +Sent: Friday, May 7, 2021 4:0 PM + +To: (USANYS) + +Cc: Christian Everdell Laura Menninger < eff Pagliuca + +Subject: Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +Good afternoon- + +For the reasons stated in our letter-motion of 4/22 (Dkt. 246), + +our earliest and preferred date in the fall is 11/8. + +In light of Ms. Maxwell's extended period of detention + +and its deleterious effect on her health and well-being, + +we cannot agree to a date far beyond 11/8. + +However, should you agree to her release pending trial, + +we would have greater date flexibility. + +Enjoy the weekend. + +Bobbi + +BOBBI C. STERNHEIM, ESQ. + +Law Offices of Bobbi C. Sternheim + +![](_page_1_Picture_17.jpeg) + +• •Covid-19 Notice: The West 19th Street office is currently closed but we continue to work remotely. + +Please use email or fax, instead of regular mail, for all correspondence during this time. + +We continue to work regular business hours throughout this situation. + +Thank you for your consideration. Our best wishes for your good health and well being. + +This message and any attached documents contain information from the Law Offices of Bobbi C. Sternheim + +that may be confidential and/or privileged. + +If you are not the intended recipient, you may not read, copy, distribute, or use this information. + +If you have received this transmission in error, please notify the sender immediately by reply e-mail and then delete this message. Thank you. + +On May 7, 2021, at 1:13 P rote: + +Hi Bobbi, + +Thanks for your response. Your April 22, 2021 letter does not address the defense's availability for trial dates after November 8th, and it would be helpful to get a complete picture of available dates throughout the balance of 2021 in order to provide the Court with comprehensive information. We're still in the process of conferring with witnesses regarding their availability, so we're gathering a variety of data points. Please let us know your availability and we can put together a proposal. + +From: BOBBI C STERNHEIM - > + +Sent: Thursday, May 6, 2021 11:58 PM + +To: + +>; Laura Menninger ; Jeff Pagliuca + +ec v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +Good evening- + +Our 4/22 letter detailed our position. Please let us know your availability for 11/8. + +Thank you- + +Bobbi + +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. + +On May 6, 2021, at 7:15 PM, wrote: + +Counsel, + +We write to confer in accordance with the Court's Order about a trial date in this case. Please let us know your preferences and availability for trial dates from September 2021 through the end of the year. 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Ghislaine Maxwell, 20 Cr. 330 (AJN) + +Date: Mon, 22 Nov 2021 15:44:03 +0000 + +Hi Allison, + +In addition to the records we've been discussing, we'd also like to request account ownership documents for account tt O78859008. I'm available for a call today if it would be helpful to discuss that before our meeting this evening. + +Thanks, + +Alison + +From: Stoddart, Allison + +Sent: Saturday, November 20, 2021 4:53 PM + +To: + +Cc: Sahni, Anjan ; (USANYS) ) ; + +Subject: RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +Thanks, Alison. I'll send an invite with dial-in for 2pm tomorrow, but let me know if that doesn't work. + +Allison + +From• + +Sent: Saturday, November 20, 2021 12:00 PM + +To: Stoddart, Allison + +Cc: Sahni, Anjan • (USANYS) > + +Subject: RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) + +EXTERNAL SENDER + +Hi Allison, + +Thanks very much for following up on this. I'm free for a call at any point after 12 p.m. tomorrow. + +Thanks, + +Alison + +Hi Alison, + +Apologies for the email over the weekend. We were wondering if you have time for a quick call tomorrow to follow up on our Wednesday meeting. Let us know if there are some times that might work. + +Thanks, Allison + +From: Sent: Friday, November 19, 2021 5:33 PM To: Stoddart, Allison Cc: Sahni, Anjan ; ) Subject: RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) (USANYS) + +EXTERNAL SENDER + +Hi Allison, + +Thanks very much. Let me look into it, and I'll let you know if Zoom is an issue, but otherwise let's plan for that. + +Best, + +Alison + +From: Stoddart, Allison + +Sent: Friday, November 19, 2021 11:51 AM To: ) \*c > Cc: Sahni, Anjan • (USANYS) ; Subject: RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) + +Alison, + +Monday at 6pm works for us for our next meeting with Pat. To avoid Webex issues, it would be great if we could use Zoom. If that works for you, we can use the following Zoom meeting ID: + +Meeting ID: 3127323168 or ryankusmin + +I'll send an invite to hold the time, but please let me know if that doesn't work. + +Thanks, + +Allison + +From: Sent: Wednesday, November 17, 2021 8:17 AM To: Stoddart, Allison Cc: Sahni, Anjan • (USANYS) <= > Subject: RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +EXTERNAL SENDER + +Thanks, yes. Let's plan to meet at 7. I'm heading to court now and will circulate a webex invitation later today. Thanks very much. + +From: Stoddart, Allison + +Sent: Wednesday, November 17, 2021 8:15 AM + +To: + +Cc: Sahni, Anjan • -)< >; (USANYS) < >; + +Subject: RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +Alison — + +Does tonight still work for a call with Pat? I know you're tied up during the day, but he is available from 6-9pm tonight. + +Thanks, + +Allison + +From: Stoddart, Allison + +Sent: Monday, November 15, 2021 6:20 PM + +To: + +Cc: Sahni, Anjan • (USANYS) + +Subject: RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) + +Thanks, Alison. Pat has been traveling, but returning tomorrow. I'll pass your schedule along, and I expect to get back to you tomorrow with some possible times. + +Thanks, + +Allison + +From: + +Sent: Monday, November 15, 2021 6:16 PM + +To: Stoddart, Allison + +Cc: Sahni, Anjan • (USANYS) st > + +Subject: RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +EXTERNAL SENDER + +Hi Allison, + +I wanted to follow up on scheduling, since this week is a bit tight and I know everyone is busy. I'm available from 7 p.m. onwards tomorrow evening, Wednesday, or Thursday. I'm also available this weekend, if that's easier. Apologies for + +proposing evening/weekend times, but jury selection this week makes scheduling a little difficult. I'm also free on Monday from 12-4 if it's not possible to meet sooner. + +Thanks, + +Alison + +From: Stoddart, Allison + +Sent: Wednesday, November 10, 2021 8:35 PM + +To: + +Cc: Sahni, Anjan . (USANYS) + +Subject: RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +Hi Alison, + +Apologies for not responding sooner. I am still trying to confirm timing, but looking at next week, not tomorrow. + +Thanks, + +Allison + +From: + +Sent: Wednesday, November 10, 2021 7:48 PM + +To: Stoddart, Allison + +Cc: Sahni, Anjan . + +) + +Subject: RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +(USANYS) ca; + +EXTERNAL SENDER + +Hi Allison, + +Just checking in on timing, in case we're meeting tomorrow. If not, no worries, next week is fine. + +Thanks, + +Alison + +From: Stoddart, Allison + +Sent: Tuesday, November 9, 2021 8:43 PM + +To: ) c==e + +Cc: Sahni, Anjan . (USANYS) + +Subject: RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +Thanks, Alison. I'll check and get back to you. + +Allison + +Cc: Sahni, Anjan • fl , (USANYS) Subject: Re: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) + +## EXTERNAL SENDER + +Are there times on Thursday afternoon or evening that would work? I can move a few things around if he is available. Otherwise, I'm available anytime next week in the the morning from 7:30-8:30, or in the evening from 5:30 p.m. onwards, or anytime on the weekend. Thanks very much for your help arranging the meeting. + +On Nov 9, 2021, at 7:23 PM, Stoddart, Allison wrote: + +Thanks, Alison. Pat is traveling on Friday and Monday unfortunately. I know jury selection is scheduled to be underway next week, but if tomorrow doesn't work, would there be times next week that might? + +Thanks, Allison + +From: Sent: Tuesday, November 9, 2021 6:32 PM To: Stoddart, Allison Cc: Sahni, Anjan • (USANYS) ; Subject: RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +## EXTERNAL SENDER + +Hi Allison, + +Thanks very much. We'll be in court most of the day for a hearing tomorrow, but is there a time on Friday that would work? + +Thanks, + +Alison + +From: Stoddart, Allison Sent: Tuesday, November 9, 2021 3:50 PM To: Cc: Sahni, Anjan • (USANYS) < Subject: RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +Hi Alison, + +When we last spoke, we discussed setting up a call with your team and Pat McHugh. Would tomorrow afternoon work for that call? + +**From:** [REDACTED] <[REDACTED]> +**Sent:** Wednesday, October 27, 2021 9:02 AM +**To:** Stoddart, Allison <[Allison.Stoddart@wilmerhale.com](mailto:Allison.Stoddart@wilmerhale.com)> +**Cc:** Sahni, Anjan <[Anjan.Sahni@wilmerhale.com](mailto:Anjan.Sahni@wilmerhale.com)>; [REDACTED] (USANYS) <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> +**Subject:** RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +**EXTERNAL SENDER** + +Hi Allison, + +Thanks— would 3 p.m. work for a call today? + +**From:** Stoddart, Allison <[Allison.Stoddart@wilmerhale.com](mailto:Allison.Stoddart@wilmerhale.com)> +**Sent:** Wednesday, October 27, 2021 7:48 AM +**To:** [REDACTED] <[REDACTED]> +**Cc:** Sahni, Anjan <[Anjan.Sahni@wilmerhale.com](mailto:Anjan.Sahni@wilmerhale.com)>; [REDACTED] (USANYS) <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> +**Subject:** RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +Hi Alison, + +We wanted to provide an update on the trial witness topic. Do you have any time this afternoon or tomorrow for a brief call? + +Thanks, +Allison + +**From:** Stoddart, Allison +**Sent:** Monday, October 18, 2021 9:05 PM +**To:** [REDACTED]' <[REDACTED]> +**Cc:** Sahni, Anjan <[Anjan.Sahni@wilmerhale.com](mailto:Anjan.Sahni@wilmerhale.com)>; [REDACTED] (USANYS) <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> +**Subject:** RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +Great. Thanks, Alison. Appreciate it. + +Allison + +**From:** [REDACTED] <[REDACTED]> +**Sent:** Monday, October 18, 2021 8:58 PM +**To:** Stoddart, Allison <[Allison.Stoddart@wilmerhale.com](mailto:Allison.Stoddart@wilmerhale.com)> +**Cc:** Sahni, Anjan <[Anjan.Sahni@wilmerhale.com](mailto:Anjan.Sahni@wilmerhale.com)>; [REDACTED] (USANYS) <[REDACTED]>; [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> +**Subject:** RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +Thanks, that's not a problem. I'm attaching a broadly worded subpoena to the bank, but please let me know if you'd like me to direct this more specifically to a particular entity or officer. + +Thanks, + +Alison + +From: Stoddart, Allison + +Sent: Monday, October 18, 20218:57 AM + +To: c > + +Cc: Sahni, Anjan ; (USANYS) + +Subject: RE: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) + +Alison, Maurene, Lara, + +Following up on our last discussion, JPMorgan is working on identifying a witness for trial. Are you able to provide JPMorgan with a trial appearance subpoena? + +Thanks very much, + +Allison + +Allison Stoddart I WilmerHale + +7 World Trade Center + +250 Greenwich Street + +New York, NY 10007 USA + ++1 212 295 6401(t) + +allison.stoddart@wilmerhale.com + +From: + +Sent: Friday, October 8, 2021 12:15 PM + +To: Stoddart, Allison + +Cc: Sahni, Anjan • (USANYS) c r ; + +Subject: Re: [EXTERNAL] RE: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) + +EXTERNAL SENDER + +Hi Allison, + +I'm traveling for work for much of next week, but I'm available for a call anytime on Monday, or at 9 a.m. on Tuesday. I'm also available for a call this afternoon anytime from 4 pm onwards if that's easier. + +Thanks. + +Thanks, Allison + +Allison Stoddart I WilmerHale 7 World Trade Center 250 Greenwich Street New York, NY 10007 USA +1 212 295 6401(t) allison.stoddart@wilmerhale.com + +From: Sent: Friday, October 8, 2021 10:01 AM To: Sahni, Anjan • Stoddart, Allison Cc: (USANYS) Subject: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) + +EXTERNAL SENDER + +Anjan, Allison, + +Hope you're both doing well. Following up on our last conversation, we wanted to send along a few documents in order to facilitate our conversation about identifying an appropriate witness from JP Morgan. Attached is a zip file containing a few draft exhibits. We are still working on finalizing exhibits, but we thought it made sense to start the conversation about this sooner rather than later. 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States Attorney's Office Southern District of New York 1 St. Andrew's Plaza New York, NY 10007 + +Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AIN) + +Dear Counsel: + +> 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 FX 303.832.2628 www.hmllciw.COM JPagliuca@hmilaw.com + +Defendant Ghislaine Maxwell through counsel, submit the following summary pursuant to Fed. R. Crim. P. 16(b)(1)(C). + +# I. EXPERT DISCLOSURE BY THE DEFENSE + +A. Dr. Elizabeth Loftus + +Dr. Loftus is the Distinguished Professor of Psychological Science and Law at the University of California, Irvine School of Law. Dr. Loftus is one of the nation's leading experts on the science of memory. In addition to her experience as an academic and clinical researcher, she has been an expert witness or consultant in hundreds of cases. Her extensive experience and credentials are recited in her curriculum vitae. Exhibit A. + +It is expected that Dr. Loftus, a psychologist who specializes in the study of memory, will focus on the memory aspects of this case. Based on her education, training, experience, and research, her testimony will concern the workings of human memory, the effects of suggestion on memory, the mechanism of creation of false memories, the characteristics of false memories, how memory fades and weakens over time, and how memory becomes more vulnerable to contamination. She will describe scientific research showing that false memories can be + +described with confidence, detail, and emotion, just like true memories. This can occur when people come to believe in these experiences and are not deliberately lying. Dr. Loftus would identify some of the suggestive activities that occurred in the current case. + +Suggestive activities can explain how it is that a person might go from having no memory of sexual abuse, and even denying sexual abuse, to later having "memories" for numerous abusive acts, if the memories are false. She will explain the mechanism by which false and/or distorted memories can be created as a result of post-event information and occurrences, suggestion, influence or the like. She will also testify about the characteristics of false and/or distorted memories. In particular "memories" can be described with confidence, detail and emotion, even when they are false. She will point out some of the suggestive activities that occurred in this case. She will explain how media coverage and other publications (including but not limited to newspaper and magazine articles, news reports, television shows, documentaries, books, podcasts, websites, etc.) and discussions/ conversations with others, can be sources of suggestion. She will explain how, in a case like this one, suggestion can lead individuals to the construction of distorted memories. + +## B. Park Dietz, M.D., M.P.H., PH.D. + +Dr. Park Dietz is a psychiatrist specializing in forensic psychiatry with over 40 years of experience. He has been previously qualified as an expert in psychiatry and forensic psychiatry. + +Dr. Dietz received a bachelor's degree in psychology and biology from the Cornell University College of Arts and Sciences (1970), an M.D. degree from the Johns Hopkins University School of Medicine (1975), a Master's degree in Public Health from the Johns Hopkins School of Hygiene and Public Health (1975), and a Ph.D. in sociology from the Johns Hopkins University (1984). He completed psychiatric residency at the Johns Hopkins Hospital (1975-77) and the Hospital of the University of Pennsylvania (1977-78), where he was Chief Fellow in Forensic Psychiatry. He has been board certified in psychiatry by the American Board of Psychiatry and Neurology since 1979. + +He is a Clinical Professor of Psychiatry and Biobehavioral Sciences at the UCLA School of Medicine. From 1986 to 1989, he was a Professor of Law at the University of Virginia School of Law and a Professor of Behavioral Medicine and Psychiatry at the University of Virginia School of Medicine. From 1982 to 1986, he was an Associate Professor of Law and of Behavioral Medicine and Psychiatry at the University of Virginia Schools of Law and Medicine. From 1978 to 1982, he was an Assistant Professor of Psychiatry at Harvard Medical School. In those positions he taught and lectured on forensic psychiatry for diverse audiences, including law students, practicing attorneys, law enforcement officers, psychiatry residents, forensic psychiatry fellows, and practicing forensic psychiatrists and psychologists. + +He is a Past President of the American Academy of Psychiatry and the Law, a Distinguished Life Fellow of the American Psychiatric Association, and a Fellow of the American Academy of Forensic Sciences. He has served on the editorial boards of the Bulletin of the American Academy of Psychiatry and the Law, the Journal of Forensic Sciences, Behavioral Sciences and the Law, the Journal of Threat Assessment and Management, and other professional publications. He has authored more than 100 articles and book chapters, primarily on forensic psychiatry. + +He has conducted more than 1,000 evaluations of persons charged with crime and, in his role as President of Park Dietz & Associates, Inc., has evaluated or supervised over 1,000 evaluations of allegations of sexual victimization. He has testified as an expert witness in forensic psychiatry on hundreds of occasions, including testimony in criminal matters in federal courts throughout the U.S. and the trial courts of nearly every state. + +Dr. Dietz will be qualified as an expert in the areas of psychiatry and behavioral science. Dr. Dietz's curriculum vitae is attached as Exhibit B. Attached as Exhibit C is a list of material reviewed by Dr. Dietz. + +His testimony may include, but will not be limited to, the following: + +## a. Opinions about Dr. Rocchio's Disclosed Opinions + +The first use of the word "grooming" to refer to strategies that sometimes enable nonforceful, nonthreatening, and nonviolent sexual victimization of minors was the proposition that "the perpetrator involves children in sexual abuse through a grooming process in which a combination of kindness, attention, material enticement, special privilege, and coercion are expertly applied" (Conte, 1984, p. 558). Since then, this usage has been widely adopted by social scientists, clinicians, journalists, and others. But this usage has some unintended consequences that threaten the integrity of the adjudicative process, including these: + +- (1) Because use of the term "grooming" commonly assumes that the grooming party is intentionally using these strategies to gain sexual access to children, to abuse them, and to prevent them from disclosing the abuse, the word "grooming" has acquired meaning beyond an objective description of behaviors; it imputes motive and intent without adequate evidence of either. +- (2) In the litigation context, "when `grooming' is applied to such common and desirable behaviors as being kind or attentive or helpful or caring, there is considerable risk of misleading the fact finder into believing that these latter behaviors are well established predictors of child sexual abuse," when they are not. Park Dietz, Grooming and Seduction, 33 J. Interpersonal Violence, 28, 31 (2018). Dr. Rocchio characterizes "grooming" as "a strategic pattern of behavior[] ... that can take a variety of forms and function to render the victims vulnerable to abuse, to obscure the nature of the abuse, and to build trust and attachment with their abuser." This vague opinion about "grooming" carries the risk of imputing motive and intent to the Defendant, when the determination of motive and intent is a task for the fact finder charged with determining the credibility of witnesses, the weight of the evidence, and the ultimate issues. Moreover, this opinion carries the risk of implying that innocuous and even desirable behaviors are associated with nefarious or criminal conduct. + +Moreover, grooming has no consistent definition, and concerns have been raised that "there is no valid method to assess whether grooming has occurred or is occurring." Natalie Bennett & William O'Donohue, The Construct of Grooming in Child Sexual Abuse, 23 J. Child Sexual Abuse 957, 974 (2014). + +In any particular population of alleged victims, patients, or plaintiffs—including those whom Dr. Rocchio has treated or evaluated—the determination of whether grooming has occurred is a subjective judgment hinging largely on the credibility of the individuals. Such judgments have no known error rate and cannot be tested, verified, or reproduced. + +Although the Government's Expert Notice regarding Dr. Rocchio's proposed testimony is silent as to whether she is expected to impute a theory of "grooming-by-proxy" to the Defendant, it is important to note that there is no generally accepted theory of grooming by third parties or empirical evidence regarding the prevalence, characteristics, or mechanisms of such a phenomenon. Ms. Maxwell is not accused of soliciting or enticing sexualized massages for herself. Instead, the claim appears to be that Ms. Maxwell recruited and groomed minors to provide sexualized massages for Mr. Epstein, which would amount to grooming-by-proxy. + +Dr. Dietz is aware of no authority—no journal articles, no studies, no tests, nothing—to support a theory of grooming-by-proxy. Such a theory has not gained any acceptance (let alone general acceptance) in the relevant community; it has not been peer-reviewed; it has not and cannot be tested; and there is no known or potential rate of error. + +Dr. Rocchio's opinion that "[i]ndividuals with particular vulnerabilities are often targeted by perpetrators of sexual abuse" is a commonly accepted bit of clinical lore derived from the frequent observation of highly vulnerable children among those children who allege sexual abuse, but it is not based on empirical data regarding the likelihood of abuse among children with varying degrees of vulnerability. To the extent that less vulnerable children, such as those with intact families, attentive parents, good social support, little psychopathology, less prior trauma, no substance use, and higher resilience are less likely to allege abuse than the more vulnerable, the generalization could be proved weak or false, if only there were such empirical data. And even if there were such data, it would be important to devise a means of verifying that abuse did occur to those who allege it, which is a difficult task at best because of the pains so many abusers take to avoid confession, witnesses, or physical evidence. The clinical, criminal justice, and forensic populations from which the observation of prevalent vulnerabilities is derived—including those clients whom Dr. Rocchio has treated or evaluated—rarely represent groups in which all allegations of abuse have been verified by confession, witnesses, physical evidence, or other means. + +Other opinions put forth in the disclosure of Dr. Rocchio's proposed testimony also rest on assertions that are untestable, cannot be reproduced, and have no known error rate. + +# b. Opinions About Hindsight Bias + +Hindsight bias must be considered when evaluating sex abuse allegations and or "grooming behavior." Many claims of sexual abuse of minors involve behaviors that are, in + +hindsight, labeled "grooming" or otherwise imputed as knowledge to onlookers. Hindsight bias refers to the tendency to overestimate how predictable or foreseeable an event is after being informed about the outcome of an event. Simply put, knowledge of the outcome of the event, i.e. Epstein pleaded guilty to having sexual contact with post-pubescent minors, makes the importance of pre-conviction behaviors obvious. Retrospective judgments about the predictability or foreseeability of the outcome are systemically inflated or biased compared to judgments made without information about the outcome. Hindsight bias refers to the tendency to overestimate how predictable an event is after learning the outcome of the event (Fischhoff, 1975). For example, after a political election, people believe their pre-election estimates of the outcome were closer to the outcome than they actually were (Blank, Fischer, & Erdfelder, 2003). Hindsight bias has been discussed in over 800 scholarly articles across a variety of different domains including medicine, financial decision making, consumer satisfaction, and within the legal domain (see Roese & Vohs, 2012; Arkes, 2013; Strohmaier et al., 2021) and using a variety of different experimental designs (Pohl & Erdfelder, 2016) and a variety of different stimuli such as written vignettes, visual stimuli (e.g., Bernstein & Harley, 2007), and auditory stimuli (e.g., Bernstein, Wilson, Pernat, & Meilleur, 2012). Even individuals with specialized training and expertise succumb to hindsight bias (Musch & Wagner, 2007). One notable study detected hindsight bias among actual judges making civil liability decisions, in which judges with outcome knowledge perceived the harm to be significantly more foreseeable than judges who did not receive outcome information and were thus more likely to render a finding of negligence (Oeberst & Goeckenjan, 2016). Another notable study detected hindsight bias in a sample of mental health professionals who gauged the dangerousness of a psychiatric patient; again, outcome knowledge affected the reported dangerousness and predictably of harm posed by the patient (Beltrani et al., 2018). + +Hindsight bias affects legal judgments. Civil or criminal prosecutions related to events occurring decades ago may be compromised by this bias in many ways, from the investigation either ignoring evidence or attributing significance in hindsight—through the presentation of evidence, to the deliberation of any factfinder. Awareness of the impact of the hindsight bias should temper any claims that so called "grooming" behaviors should have been noticed and either reported or avoided and that failing to do so constitutes knowledge or intent. + +## c. Opinions Related to the Halo Effect + +The term "Halo effect" was coined by Thomdike (1920) a century ago. The Halo effect is a cognitive bias in impression formation whereby the positive evaluation of one characteristic has a radiating effect on how other, non-related characteristics of the individual are evaluated. For example, one classic study found that physical attractiveness influenced evaluations of the target's personality, life satisfaction, and expected future personal and occupational success despite the fact that no information about any of these attributes was provided (Dion et al., 1972). Physical attractiveness has also been found to influence culpability judgments, with attractive individuals being held less-responsible than unattractive individuals (Dion, 1972; Efran, 1974). Halo effects have been found to be cued by factors other than attractiveness, such as the described status of the target (Wilson, 1968), the name of the target (Harari & McDavid, 1973), and even one's mood when evaluating the target (Forgas, 2011). Studies have documented halo effects when making diagnoses of psychopathology, such that symptoms of one mental disorder influence the interpretation of other symptoms indicative of other mental disorders and vice versa (see e.g., DeVries, Hartung, & Golden, 2017). + +Halo effects are a means to achieving cognitive consistency, which roughly refers to a state in which attitudes, perceptions, beliefs, predictions, and thoughts are aligned. Cognitive consistency serves many important goals. As noted by Read and Simon (2012), cognitive consistency is "essential for reasons of parsimony and economy of effort, as well as to allow for the predictability of, and hence adaptability to, subsequent encounters" (p. 67). Indeed, the noted psychologist Leon Festinger "was convinced that the psychological need for cognitive consistency is as basic as hunger and thirst" (Gawronski, 2012, p. 652). But because the world is often not so neat, orderly, or unequivocal, humans engage in complicated reasoning processes to impose consistency. These processes involve bi-directional reasoning in which "decisions follow from evidence, and evaluations of the evidence shift toward coherence with the emerging decision" (Simon, Snow, & Read, 2004, p. 814; Greenspan & Scurich, 2016). As a result, perceptions and decisions become highly skewed toward one interpretation while alternatives are neglected or dismissed, hence consistency is achieved. This reasoning process occurs unconsciously, i.e., outside conscious awareness, and is not intentional self-deception. + +Halo effects can have serious practical consequences. As noted by Forgas and Laham (2016): + +Once unjustified initial expectations are formed about a person, they can easily become self-perpetuating with serious implications for how a target is treated. If we expect a person to have positive characteristics, we may selectively look for and find such features from the rich array of information available (a self-fulfilling prophecy), and positive impressions may in turn lead to preferential treatment in a range of domains: + +interpersonal relations, the work place, the health and legal systems, and even for decision making and consumer choices. (p. 286) + +Like many people who achieve great power and wealth, Jeffery Epstein exploited the Halo effect to surround himself with people who would serve his needs. At the most primitive level, his wealth attracted those seeking for themselves some of what he had. At the most sophisticated level, others with halos of their own—through any combination of power, influence, fame, brilliance, attractiveness, social standing, or other positive characteristics—mingled with Epstein for reasons of their own, and being seen in their company empowered him and made him look above suspicion. In a videotaped interview with Steve Bannon, Epstein differentiated between different kinds of power—such as Bill Clinton's political power, wrestlers' and weight lifters' physical power, and Gerry Edelman's intellectual power—and acknowledged that he gravitated to people of power. [CONFIDENTIAL] SDNY\_GM\_SUPP\_00219000.mov. + +The materials reviewed reflect that Jeffrey Epstein was a brilliant man who was flawed by enduring personality traits familiar to psychiatrists as "Cluster B personality traits," found among those with antisocial, narcissistic, borderline, and histrionic personality disorders. + +American Psychiatric Association, Diagnostic and Statistical Manual of Mental Disorders, 5th Ed., Arlington, VA: American Psychiatric Association (2013), pp. 659-672. These flaws allowed him to use his brilliance to manipulate people to do his bidding and to compartmentalize people into isolated cells in which none had complete information about his activities. These were not his only flaws, and Dr. Dietz is also prepared to address Jeffrey Epstein's sexual behavior should it prove relevant. + +#### d. Opinions Related to the Multiple Pathways to False Sex Assault Allegations + +Studies concerning the accurate reporting of alleged sexual assaults undermine the assertions made by Dr. Rocchio to the extent they are based on uncorroborated allegations and are also otherwise relevant here. False allegations of sexual assault do occur, and there are multiple pathways to these false allegations of sexual assault. + +Not all allegations of sexual assault are true. Unfortunately, there has been little work on understanding the prevalence of false allegations or pathways to these, particularly in a sample most relevant to a jury—currently adjudicated cases. A peer reviewed journal article has proposed 11 pathways to false allegations of sexual assault: (a) lying, (b) implied consent, (c) false memories, (d) intoxication, (e) antisocial personality disorder, (t) borderline personality disorder, (g) histrionic personality disorder, (h) delirium, (i) psychotic disorders, (j) dissociation, and (k) intellectual disability. Jessica Engle and William O'Donohue, Pathways to False Allegations of Sexual Assault, 12 J. Forensic Psychology Practice, 97. These pathways originate in the psychological proclivities or state of the individual making these false allegations. The descriptions of these pathways that follow include material drawn nearly verbatim from the article by Engle and O'Donohue (2012), which was published before the latest edition of the Diagnostic and Statistical Manual of Mental Disorders but nonetheless remains accurate in characterizing certain personality disorders. + +Ly\_int : Lying involves the alleged victim knowingly making a false claim of sexual assault. Humans do lie, and their lies can be difficult to detect. Often, humans lie because of what they perceive as the favorable consequences for lying; for sexual assault these consequences could be: + +- I. the severe negative consequences that the alleged perpetrator experiences, +- 2. secondary gain from victim status, +- 3. excusing behaviors or characteristics of the alleged victim (e.g., sexual activity, pregnancy, sexually transmitted diseases) +- 4. financial gain. + +Implied Consent: A fact finder's determination of whether consent was competently given is often problematic, and some allegations are regarded as unfounded or false based on determinations regarding consent before cases reach the stage of adjudication. A false allegation can arise when it was reasonable to believe consent was given but the alleged victim falsely believes that it was not. + +False Memory: The existence and prevalence of repressed memories is a source of controversy, and yet research does exist demonstrating the successful implantation of fabricated memories. In one of the first studies on the implantation of false memories, participants were given short narratives of childhood experiences, purportedly obtained from relatives, and asked to try to remember these experiences. Research by Elizabeth Loftus has revealed how subtle information introduced after an event may alter the memory of that event. Loftus and her students have conducted more than 200 studies with more than 20,000 participants demonstrating how misinformation introduced after an event can induce people into creating false memories. + +Intoxication: Intoxication can substantially increase the likelihood of a false allegation of sexual assault. Alcohol and other intoxicants pose a significant problem in sorting out the validity of a sexual assault allegation. The information-processing errors induced by intoxicating substances may cause confusion surrounding events that occurred while a person was intoxicated. A person who does not accurately recall events that occurred while he or she was under the influence or while experiencing the side effects of withdrawal from a substance may attempt to make sense out of the disjointed and seemingly incoherent memories of events that occurred while intoxicated. In an effort to make sense of and organize what memories are intact, a person may confabulate or fill in the memory lapses with events that seem probable or which for some reason they come to believe "must have" taken place. + +Antisocial Personality Disorder: The essential feature of antisocial personality disorder is a pervasive pattern of behavior that disregards and violates of the rights of others. It often begins in early childhood or early adolescence and continues into adulthood. If an individual with antisocial personality disorder is likely to lie to achieve power and pleasure, a false allegation of sexual assault might be the means by which he or she attempts to achieve power over the falsely accused. Falsely claiming someone sexually assaulted you can be an aggressive act and a lack of remorse could allow the individual to file an allegation of sexual assault and maintain this allegation with few, if any, conflicts of conscience. Thus, a pathway to a false allegation of sexual assault can occur when an individual with antisocial personality disorder makes a false claim of assault. + +Borderline Personality Disorder: Borderline personality disorder (BPD) is a serious mental condition characterized by affective dysregulation, impulsiveness, difficulties in interpersonal relationships, and difficulties with self-image. Of particular note is the rapid switching from idealization to devaluation, impulsivity, and manipulative features of borderline personality disorder. The instability of relationships experienced by an individual with BPD may be rooted in the tendency to quickly switch from idealizing significant others or lovers to devaluing them. This sudden change in conceptualization of a partner is often caused by feeling that the partner is not caring enough or giving enough or by suspicion of abandonment. The rapid shifting between idealizing and demonization may bring about a change in perspective such that a relationship that was viewed idealistically in the past is now seen through the devalued lens of abuse or mistreatment. Past events then may become construed as "abuse" and may lead a person with BPD to believe he or she is a victim of sexual assault. Previous research has found that two of the three major motivations to file a false allegation of rape were attention-seeking and revenge. The switch from idealization to devaluation of the relationship and/or relationship partner may spur a desire for revenge for any past behaviors that are, in the devaluation phase, newly construed as mistreatment. Also, there is some evidence that individuals with BPD engage in behaviors that are viewed as "manipulative." Manipulative behaviors are often outside the conscious awareness of the individual and are learned through positive reinforcement, as manipulation frequently results in positive outcomes for the manipulator. Thus, an individual with BPD may use a sexual assault allegation as a way of impacting a third party for some desired outcome. + +Histrionic Personality Disorder: Diagnostic criteria for histrionic personality disorder include: 1) feeling uncomfortable in situations in which he or she is not the center of attention; 2) interactions with others are often characterized by inappropriate sexually seductive or provocative behavior; 3) displaying rapidly shifting and shallow expressions; 4) consistently uses physical appearance to draw attention to the self; 5) has a style of speech that is excessively impressionistic and lacking in detail; 6) shows self-dramatization, theatricality, and exaggerated expression of emotion; 7) is suggestible (i.e., easily influenced by others or circumstances), and 8) considers relationships to be more intimate than they actually are. Other relevant behaviors include the tendency to play out stereotyped roles in their relationships with others; an intense desire for novelty and excitement; and the upset and depression that may follow periods in which they received little attention. Filing a false allegation of sexual assault may serve to benefit individuals with histrionic personality disorder in several important ways. The sexualized behavior of individuals with histrionic personality disorder can lead to sexual relationships that may be used to seek attention (e.g., having sex with a person and telling all of their friends about it). Filing a false sexual assault claim may regain lost attention, either from the desired partner or from other individuals, providing a novel and exciting environment that may be stimulating to a person who is histrionic. They may enjoy the large amounts of attention received for filing a sexual assault charge and for the "victim" role that can be played out in other relationships (a dynamic also common in false allegations by those with borderline personality disorder). In times when attention is not being received to the desired level, a false allegation of sexual assault may help to pull individuals with histrionic personality disorder out of their depressed state. + +Delirium: Delirium is a disturbance of consciousness that is accompanied by a change in cognition that cannot be better accounted for by a preexisting or evolving dementia. Relevant to this pathway are the perceptual disturbances that may be present, including misinterpretations, illusions, or even hallucinations. Many substances induce delirium, particularly in excessive doses. + +Psychotic Disorders: The term psychotic generally refers to conditions that are marked by delusions, hallucinations, or markedly illogical thinking. Such conditions cause gross impairments in functioning. Studies investigating the content of delusions have found delusions that are sexual in nature are not uncommon and occur more often in women than in men. Some cases of sexual delusions have been documented. These delusions may lead a person to claim adamantly that sexual relations or events occurred that may be impossible or highly improbable. + +Dissociation: Dissociation is `the lack of the normal integration of thoughts, feelings, and experiences into the stream of consciousness and memory. Dissociation involves a disruption or splitting off of memory, personality, identity, consciousness, or general perceptions of the self and surroundings; it can be recurring, gradual, or transient. It is likely associated with memory distortions. Thus, it is possible that in the event of a sexual assault, dissociation may cause a person to fill in the parts of the experience that are not clearly remembered with events that for them feasibly could have occurred. Of course, memory lapses will not necessarily be filled in with a confabulated event, let alone a sexual one. However, individuals who dissociate at a high frequency may seek to make their stories more coherent by adding details to an incomplete memory that would make sense to them when considered in the context of the event. Thus, these confabulations may lead to erroneous claims that have forensic relevance, including who the perpetrator was, what happened, where, and how many times. + +Intellectual Disability: Intellectual disability, is characterized by below average IQ and adaptive functioning. Limitations in functioning include deficits in the acquisition of social, occupational, academic, and general self-care skills. Intellectual disability has several etiologies that often are related to biological or pathological processes affecting the central nervous system. Many of the specific vulnerabilities that arise from intellectual disability overlap to some extent with other disorders (e.g., autism spectrum disorders, cerebral palsy, fetal alcohol syndrome) and individuals with other developmental disabilities may also have intellectual disability. Intellectually disabled individuals, compared to individuals without ID, have vulnerabilities related to memory and communication that the legal system may not be equipped to handle adequately. Individuals with moderate-to-profound ID may have significant difficulty communicating about the events that occurred because of language skills deficits or other communication-interfering conditions (e.g., related neurological conditions). Research findings indicate that communications skills are essential in filing a sexual assault charge; alleged victims with mild ID were more likely than individuals with moderate or severe ID not only to file sexual assault charges but to have their allegations confirmed. Difficulties with memory may also complicate the investigation process for individuals with ID. + +Changes in the core details of the allegation are often used by professionals as indices in determining the credibility of a victim's claims. Peace and colleagues (2015) conducted a narrative analysis of 147 sets of allegations of sexual assault across short (3 month) and long (6 month) intervals since the alleged event took place. In reviewing the existing literature, Peace and colleagues found that genuine traumatic experiences have a demonstrable resiliency to drastic impairments in recall. However, some inconsistencies especially in less core matters are to be expected due to some less important details fading or varying over time. In examining their sample of 147 allegations, the researchers discovered that truthful allegations contained more detail relative to false allegations at each of the assessment intervals. Specifically, the researchers found that fabricated allegations of traumatic experiences contained more inconsistent details both at 3 months and 6 months. The total amount of detail for each type of allegation (true or false) does tend to decrease over time. Additionally, as these figures suggest, the researchers found that the number of details present in genuine reports continued to decrease over time whereas fabricated stories `levelled off in detail. + +Hunt and Bull (2012) reviewed signs that can be used to differentiate true allegations of sexual assault from false ones and concluded that the literature did not support the hypothesis that emotional distress was predictive of the truthfulness of the allegation. This is consistent across the literature, and emotional distress (e.g., crying) is not regarded as a reliable predictor of the accuracy or truthfulness of an allegation. Additional research is needed, but at this point there is little empirical support to indicate that being emotionally upset, distressed, or crying while reporting an assault indicates that the report is more likely to be true. This is likely due to the fact that such reactions can also occur in false allegations for various reasons, including a false memory or an attempt to mislead by those who know this sort of reaction would be expected of a true allegation. + +Individuals who have been sexually assaulted have higher rates of mental disorders than individuals who have not been sexually assaulted, and this includes significantly higher rates of post-traumatic stress disorder, depression, bipolar disorder, drug use disorders, and alcohol use disorders. Emily R. Dworkin, Risk for Mental Disorders Associated with Sexual Assault: A Meta-Analysis, 21 Trauma, Violence, & Abuse (2020), pp. 1011-1028. Any of these mental disorders that occur more frequently among those who have been sexually assaulted can affect memory and recall, requiring assessment on a case-by-case basis. + +Varying degrees of post-traumatic stress symptomatology occur in significant proportions of victims following sexual assault and last for varying durations. Emily R. Dworkin, Anna E. Jaffe, Michele Bedard-Gilligan, and Skye Fitzpatrick, PTSD in the Year Following Sexual Assault: A Meta-Analysis of Prospective Studies, Trauma, Violence, & Abuse (2021) https://doi.org/I0.1177/15248380211032213. A substantial number of people never fully remit from their PTSD even after many years, and variables associated with a longer time to remit from an episode of chronic PTSD include a history of alcohol abuse and a history of childhood trauma. Caron Zlotnick, Meredith Warshaw, et al., Chronicity in Posttraumatic Stress Disorder (PTSD) and Predictors of Course of Comorbid PTSD in Patients with Anxiety Disorders,12 J. Traumatic Stress (1999), 89-100. + +Symptoms of PTSD include distressing memories of the event; intense or prolonged psychological distress at exposure to cues that symbolize or resemble an aspect of the traumatic event; marked physiological reactions to cues that symbolize or resemble an aspect of the traumatic event; avoidance or efforts to avoid distressing memories, thoughts, or feelings about or closely associated with the traumatic event(s); and avoidance of or efforts to avoid external reminders (people, places, conversations, activities, objects, situations) that arouse distressing memories, thoughts, or feelings about or closely associated with the traumatic event(s). American Psychiatric Association, Diagnostic and Statistical Manual of Mental Disorders, 5th Ed., Arlington, VA: American Psychiatric Association (2013), pp. 271-272. Individuals with any of these symptoms are particularly unlikely to engage in continued communication or friendly gestures with an alleged perpetrator, to wear clothing provided by an alleged perpetrator, or to unnecessarily recreate a sexual assault event, any of which would be expected to elicit intense distress. + +#### C. Dr. Ryan Hall + +Dr. Hall's curriculum vitae is attached as Exhibit D. His report is attached as Exhibit E. Attached as Exhibit F is a list of material reviewed by Dr. Hall. + +Dr. Hall is an expert in the field of forensic psychiatry and will offer opinions as such. He will offer the opinions and diagnoses contained in his report, the bases for those opinions, and the significance of the diagnoses and opinions. + +## D. Bennett Gershman + +Professor Gershman is a Distinguished Professor of Law at the Elisabeth Haub School of Law of Pace University since its founding as the Pace Law School in 1976. He has also taught as a visiting professor at Cornell Law School and Syracuse Law School. Prior to coming to Pace, he was a prosecutor in the Manhattan District Attorney's Office and the New York State Anti-Corruption Office. Professor Gershman's extensive scholarship has had an essential role in establishing the study of prosecutorial misconduct, a subject at the intersection of criminal procedure and professional ethics. He is a leading authority on prosecutorial misconduct and the author of the treatise, Prosecutorial Misconduct, a preeminent resource for scholars and practitioners. + +We expect Professor Gershman to provide testimony on best practices to ensure the integrity of any prosecution, focusing on investigation, witness preparation, media contact, neutrality, obligations to provide accurate information, and relationship with crime victims, their counsel, and case-related civil litigation. His extensive experience and credentials are recited in his curriculum vitae, annexed as Exhibit G. + +## E. Robert Kelso + +Mr. Kelso is CEO of Forensic Pursuit. He has over 25 years of experience in computer forensics, engineering and software technology. He holds Bachelor's and Master's degrees from University of Colorado at Boulder in aerospace engineering and astrodynamics, respectively. He is currently an adjunct professor at University of Denver teaching computer forensics at the Master's level. He holds multiple computer forensics certifications including EnCE, CHFI, ACE and AME. His curriculum vitae is attached. Exhibit H. Mr. Kelso has previously testified in federal and state courts as an expert witness in computer forensics and has been appointed a "special master" by the court on multiple occasions. + +We anticipate that Mr. Kelso will testify about the user data associated with certain devices seized and searched by the government's team in this case, documents and photographs extracted from certain of those devices, and the metadata associated with certain documents and photographs. He may also testify generally about computer forensic principles associated with the creation of documents, storage and retrieval of digital documents and photographs, including the limits to the information that can be gleaned from the metadata. Mr. Kelso may testify in rebuttal to any testimony offered by the government through M=. As trial preparation proceeds, the defense will update the topics for Mr. Kelso if any arise. + +F. + +was a Special Agent with the United States Department of the Treasury, Internal Revenue ServiceCriminal Investigation ("IRS-CI") for over twenty-five years. During his tenure at IRS-CI, led the New York Asset Forfeiture Task Force and participated in numerous criminal investigations involving complex fraud, corruption, bribe evasion, money laundering, and asset forfeiture. Since retiring from the IRS in 2013, has worked as a financial investigator and consultant for several private investigation companies and government enforcement agencies. He current) runs his own private financial investigation and consulting company called JDL Services, Inc. holds a bachelor's degree in Business Administration, Accounting and Finance from Pace University. His curriculum vitae is attached as Exhibit I. + +It is expected that will testify about his review of certain financial records provided by the government in discovery. Specifically, will discuss various transfers of funds that are reflected in the financial records and explain the information contained in the financial records regarding those transfers.' + +G. Gerald LaPorte + +Mr. LaPorte is a Forensic Chemist and Document Dating Specialist with the firm Riley Welch LaPorte &Associates Forensic Laboratories. He currently is the Director of Research Innovation for Florida International University, Global Forensic and Justice Center. Prior to that, he was the Director of the U.S. Department of Justice, National Institute of Justice, Office of Investigative and Forensic Sciences. He has testified as an expert witness in numerous cases and has multiple professional honors in this field. His curriculum vitae is attached. Exhibit J + +Defendant anticipates the receipt of documents produced by the government and documents received pursuant to defense subpoena included but not limited to These documents may require analysis regarding the dates of creation, completeness, alteration and manipulation. When these documents are disclosed, Defendant will seek to have them analyzed and present testimony on the analysis as needed. + +&#x27; The defense does not believe that the Court needs to ualif as an expert to offer the proposed testimony. Nevertheless, we hereby notice as a potential expert witness in an abundance of caution. + +#### H. Jennifer Naso + +Ms. Naso is a Forensic Document Examiner who worked for and received specialized training from the United States Secret Service as a Document Analyst. Ms. Naso has a Master's of Science in Forensic Science and a Bachelor of Arts in Psychology. She has over 15 years of experience examining and determining authorship and authentication of documents. Her curriculum vitae is attached as Exhibit K. + +Defendant anticipates the receipt of documents produced by the government and pursuant to defense subpoena included but not limited t These documents may require analysis regarding the dates of creation, completeness, alteration and manipulation. When these documents are disclosed, Defendant will seek to have them analyzed and present testimony on the analysis as needed. + +# IL RESERVATION OF RIGHTS + +The defense reserves the right to amplify the disclosures contained herein based on testimony and other evidence presented during the government's case-in-chief. The defense also reserves the right to call additional expert witnesses and will promptly provide additional disclosure notice. + +# III. RIGHT TO SUPPLEMENT + +Ms. Maxwell reserves the right to supplement these opinions depending on the evidence produced at trial. To the extent that any accuser claims to have been "groomed" or otherwise testifies to the challenged opinions of Dr. Rocchio or other opinions properly rebutted by expert testimony Ms. Maxwell reserves the right to identify and rebut this testimony after the close of the government's case in chief. + +Very Truly Yours, + +![](_page_14_Picture_10.jpeg) + +Jeffrey S. Pagliuca + +Enclosures \ No newline at end of file diff --git a/marker2/ds9/EFTA00090129/EFTA00090129.metadata.json b/marker2/ds9/EFTA00090129/EFTA00090129.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..e9f250c41eb0e5049fe89e98b10839ceddfb6cab --- /dev/null +++ b/marker2/ds9/EFTA00090129/EFTA00090129.metadata.json @@ -0,0 +1,898 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090129.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 15, + "chars": 43374, + "elapsed_seconds": 2.26, + "image_assets": [ + "_page_1_Picture_0.jpeg", + "_page_1_Picture_5.jpeg", + "_page_14_Picture_10.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Exhibit A", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 200.73600000000002, + 144.99 + ], + [ + 417.2411804199219, + 144.99 + ], + [ + 417.2411804199219, + 195.52325439453125 + ], + [ + 200.73600000000002, + 195.52325439453125 + ] + ] + }, + { + "title": "I. 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W. Hall, M.D., DFAPA + +Updated 10/11/21 + +#### TABLE OF CONTENTS + +| PRESENT POSITION | 2 | +|----------------------------------------|----| +| EDUCATION | 2 | +| MEDICAL LICENSE | 3 | +| CERTIFICATION | 3 | +| ADDITIONAL TRAINING | 3 | +| SOCIETY MEMBERSHIPS. PAST AND PRESENT | 5 | +| INVITATIONAL OFFICES AND ORGANIZATIONS | 5 | +| EDITORIAL POSITIONS | 6 | +| COMMITTEES | 6 | +| HONORS | 9 | +| PROFESSIONAL ACTIVITIES | 10 | +| REVIEWER | 11 | +| BOOK REVIEWS | 12 | +| PUBLICATIONS | 12 | +| NEWSLETTERS | 19 | +| ABSTRACTS POSTERS | 21 | +| AND INVITATIONAL ACADEMIC LECTURES | 22 | +| VIRTUAL LECTURES | 33 | +| MEDIA | 37 | + +NAME: Ryan Chaloner Winton Hall, M.D. + +DATE OF BIRTH: + +PLACE OF BIRTH: Titusville, Florida + +MARITAL STATUS: Married + +#### PRESENT POSITION: + +08/01/17 - Present Psychiatrist Ryan C. W. Hall, MD, PA 2500 West Lake Mary Blvd; Ste 219 Lake Mary, FL 32746 Ph: 407-322-8199 + +07/2008 - 08/01/2017 Psychiatrist Richard C. W. Hall, MD, PA 2500 West Lake Mary Blvd; Ste 219 Lake Mary, FL 32746 + +10/19/2017 06/30/2022 Associate Professor of Psychiatry University of Central Florida College of Medicine Department of Psychiatry + +03/03/2009 - 10/19/2017 Assistant Professor of Psychiatry University of Central Florida College of Medicine Department of Medical Education + +08/01/2016- 07/31/2022 Affiliate Associate Professor University of South Florida Department of Psychiatry and Behavioral Neurosciences + +10/17/2009 - 07/31/2016 Affiliate Assistant Professor University of South Florida Department of Psychiatry + +2010 - 2021 Adjunct Faculty Member — Law & Psychiatry Barry University Dwayne O. Andreas School of Law, Orlando + +## EDUCATION: + +1995 - 1999 Johns Hopkins University Baltimore, Maryland Double Major - Biology and Psychology B.A. Degree, graduated Phi Beta Kappa with honors 1999 - 2003 Georgetown University School of Medicine Washington, DC M.D. Degree + +2003 -2004 Internal Medicine Internship Sinai Hospital of Baltimore/Johns Hopkins Baltimore, Maryland + +2004 -2007 Psychiatric Residency Johns Hopkins Hospital Department of Psychiatry and Behavioral Sciences Baltimore, Maryland + +2007 - 2008 Fellow in Forensic Psychiatry Case Western Reserve University Cleveland, Ohio + +## MEDICAL LICENSE: + +2004 Maryland — D62746 - Inactive 2007 Ohio — 89483 - Inactive 2007 Florida — ME99792 2021 New Mexico — FELMD2021-063 (Federal Emergency MD)-Inactive 2021 -2022 New Mexico — MD2021-0674 + +## CERTIFICATION: + +2008 Diplomate, American Board of Psychiatry and Neurology, #58286 2009 with added qualifications for Forensic Psychiatry + +2009-2018 Certified Forensic Physician American College of Forensic Examiners Institute + +2011-2014 Diplomate, American Board of Forensic Medicine, #111779 American College of Forensic Examiners Institute + +2015- 2018 Fellow, American College of Forensic Examiners Institute, #111779 + +07/19/2015 - 07/31/2023 Diplomate, National Board of Physicians and Surgeons for Psychiatry and Forensic Psychiatry, #001999 + +04/23/2018 Diplomate, American Board of Psychiatry and Neurology, #58286 and Forensic Psychiatry, #1735, Maintenance of Certification + +## ADDITIONAL TRAINING: + +2006 Forensic Psychiatry Review Course + +| 2007 | Forensic Psychiatry Review Course | +|-------------------|------------------------------------------------------------------------------------------------------------| +| 2008 | Florida Forensic Examiner Training Sciences, Ft. Lauderdale, FL | +| 2012 | MMPI-2-RF: Basic Overview, with Yossef S. Ben-Porath,l-hr Corp (Pearson): February 15, 2012 | +| 2012 | MMPI-2-RF: Forensic Practice Briefing, with Yossef S. Ben Discussion) PsychCorp (Pearson): March 20, 2012 | +| 2013 | Use of the MMPI-2-RF in Police & Public Safety Assessments, | +| 2014 | Evaluation of Malingered Psychosis: Testing and Testifying. C Law, October 24, 2014 | +| 2015 | Psychological Testing for Psychiatrists. C Dike and M Baranoski. | +| 2015 | Psychological Testing of Claimed Amnesia: A Guide to Psychiatry and the Law, October 24, 2015 | +| 2016 | MMPI-2-RF: Use in Trauma and Stressor-Related Disorders with PsychCorp (Pearson): February 25, 2016 | +| 2017 | Forensic Psychiatry Review Course, American Academy of | +| 12/02/20-12/02/22 | Certificate of Completion of Montreal Cognitive Assessment Ziad Nasreddine, MD. | + +#### SOCIETY MEMBERSHIPS, PAST AND PRESENT: + +Member, Academy of Psychosomatic Medicine Distinguished Fellow, American Psychiatric Association Member, Maryland Psychiatric Society Member, American Academy of Psychiatry and the Law Member, American Medical Association Member, Ohio Psychiatric Association Member, Florida Psychiatric Society Fellow, Southern Psychiatric Association Member, The American College of Psychiatrists Member, Florida Medical Association Member, Seminole County Medical Society Member, American College of Forensic Examiners Institute Member, Physicians Society of Central Florida + +# INVITATIONAL OFFICES AND ORGANIZATIONS: + +2009 - 2012 Secretary/Treasurer, Southern Psychiatric Association + +2012 - 2014 Councilor, Florida Psychiatric Society + +2012 - 2013 Vice President, Southern Psychiatric Association + +2013 - 2014 President-elect, Southern Psychiatric Association + +2012 - 2015 Councilor, American Academy of Psychiatry and the Law + +2013 - 2014 Physician Leadership Academy, Florida Medical Association + +2013 - 2019 Member, Specialty Society Section (SSS) Governing Council, Florida Medical Association + +7/2014-8/2021 Council on Legislation, Florida Medical Association + +2014 - 2015 President, Southern Psychiatric Association + +2015 - 2016 Secretary, Florida Psychiatric Society + +2016 - 2017 Treasurer, Florida Psychiatric Society + +2017 - 2018 Treasurer, Seminole County Medical Society + +2017 - 2018 Vice President, Florida Psychiatric Society + +2018 - 2019 President-Elect, Florida Psychiatric Society + +2018 - 2019 Vice President, Seminole County Medical Society + +| 2019 - 2020 | President, Florida Psychiatric Society | +|-------------|-----------------------------------------------------------------| +| 2018 - 2019 | President, Seminole County Medical Society | +| 2019 - 2020 | Vice Chair, Specialty Society Section (SSS) Governing Council, | +| 2019 - 2020 | President-Elect, Physicians Society of Central Florida | +| 2020 - 2021 | President, Physicians Society of Central Florida | +| 2020 - 2021 | Immediate Past-President, Florida Psychiatric Society | +| 2020 - 2021 | Immediate Past-President, Physicians Society of Central Florida | +| 2021 - 2024 | Chairman, Specialty Society Section (SSS) Governing Council, | + +## EDITORIAL POSITIONS: + +| 2016–2020 | Editorial Board, Clinical Geriatrics (ended 06/2014) | +|-------------|-------------------------------------------------------------------------------------------------| +| 2016–2020 | Associate Editor, American Academy of Psychiatry and the Law Newsletter | +| 2011 – 2020 | Faculty Reviewer/Faculty Advisor for First Aid for the USMLE Step 1 , psychiatry chapter | + +#### COMMITTEES: + +| 2005 - 2007 | Public Relations Committee, Maryland Psychiatric Society | +|-------------|---------------------------------------------------------------------------------| +| 2005 - 2007 | Legislative Committee, Maryland Psychiatric Society | +| 2005 - 2007 | Disaster Committee, Maryland Psychiatric Society | +| 2005 - 2007 | Resident and Fellows Committee, Maryland Psychiatry Society | +| 2007 - 2009 | Corresponding Committee on Graduate Education, American Psychiatric Association | +| 2008 - 2009 | Member, New Member Task Force, Southern Psychiatric Association | +| 2007 – 2019 | Psychopharmacology Committee, American Academy of Psychiatry and the Law | + +| 2007 - 2021 | Research Committee, American Academy of Psychiatry and the | +|-------------|-------------------------------------------------------------| +| 2009 - 2010 | Chairman, Early Career Psychiatry Committee, Southern | +| 2009 - 2010 | Chairman, New Member Task Force, Southern Psychiatric | +| 2009 - 2010 | Member, Constitution and Bylaws Committee, Southern | +| 2010 | YPS Reference Committee, AMA House of Delegates-YPS, | +| 2010 - 2011 | Various YPS Handbook Review Committees (e.g, Constitution & | +| 2009 - 2022 | CME Committee, Florida Psychiatric Society | +| 2009 - 2019 | Forensic Psychiatry Committee, Florida Psychiatric Society | +| 2009 - 2012 | Academic Affairs Committee, Florida Psychiatric Society | +| 2010 - 2019 | Ethics Committee, Florida Psychiatric Society | +| 2010 - 2011 | Member, New Member Task Force, Southern Psychiatric | +| 2010 - 2011 | Member, Nominating Committee, Seminole County Medical | +| 2011 | Chairman, AMA-YPS Handbook Review Committee, AMA Interim | +| 2012 - 2020 | Member, Rappeport Fellowship Committee, American Academy of | +| 2012 | YPS Reference Committee on Amendments to Constitution and | + +| 2014- 2015 | Member, Nominating Committee, American Academy of Psychiatry and the Law | +|-----------------|----------------------------------------------------------------------------------------------------| +| 2014 | Member, AMA-YPS HOD Handbook Review Committee, AMA YPS Annual Meeting, Chicago | +| 2014 | Member, AMA-YPS HOD Reference Committee on Amendments | +| 2014 | Chairman, AMA-YPS HOD Handbook Review Committee for the Meeting, Dallas | +| 2014 - 2018 | Member, Geriatric Psychiatry Committee, American Academy of Psychiatry and the Law | +| 2016 - 2020 | Member, AIER Research Committee, American Academy of | +| 2016 - 2017 | Chair, Long Range Planning Committee, Southern Psychiatric Association | +| 2016 - 2017 | Chair, Nominating Committee, Southern Psychiatric Association | +| 2017 - 2018 | Executive Committee, Seminole County Medical Society | +| 2017 - 2018 | Physician Wellness Task Force, Orange County Medical Society | +| 2018 - 2019 | Oversight Committee, Florida Psychiatric Society | +| 2018 | Reference Committee I — Health, Edu. & Public Policy, Florida Medical Association | +| 2019 - 2021 | Committee on Physician Wellness, Florida Medical Association | +| 2019 - 2021 | Legislative and Regulatory Issues Committee, Florida Psychiatric Society | +| 2019 | Reference Committee — Science and Public Health, Florida | +| 2019 - 2021 | Chair, Forensic Psychiatry Committee, Florida Psychiatric Society | +| 3/2020 - 2/2024 | Committee on the Award for Research in Geriatric Psychiatry, The American College of Psychiatrists | + +| 2020 - 2021 | Member, MOC Committee, American Academy of Psychiatry and | +|-------------|-------------------------------------------------------------| +| 2020 - 2021 | Member, Transparency Task Force, Physicians Society Central | +| 2021 | Member, Reference Committee II, Florida Medical Association | + +#### HONORS: + +| 1999 | Phi Beta Kappa, Johns Hopkins University | +|-------------|----------------------------------------------------------------------| +| 2004 | "Superior" performance rating, 1st-year residency, by Sinai | +| 2005 | Dorfman Award, presented by The Academy of Psychosomatic | +| 2007 - 2008 | Rappeport Fellowship, American Academy of Psychiatry and the | +| 2009 - 2020 | Selected by peers to be included in Best Doctors in America | +| 2010 | Day TR, Hall RCW: Déjà vu: From Comic Books to Video | +| 2010 - 2019 | The Best Doctors in Orlando - Orlando Magazine | +| 2014 | Appointed, Fellow, American Psychiatric Association | +| 2014 | Certificate of Appreciation for recognition of service for | +| 2015 | Selected as Practitioner of the Year for Florida Psychiatric Society | +| 2016 | Appointed, Distinguished Fellow, American Psychiatric Association | +| 2018 | Approved provider for FL Top Docs | +| 2018 | Friendship Award recipient, Florida Psychiatric Society | + +| 2019 | Superior Public Service Award, Broward County Crime Commission | +|------|-------------------------------------------------------------------------------------------| +| 2020 | Appointed, Fellow, The American College of Psychiatrists (to be inducted at 2022 meeting) | +| 2020 | Listed in Top Doctors and Premier Doctors – Orlando Magazine | + +#### PROFESSIONAL ACTIVITIES: + +| 2008 | Written testimony on Elder Abuse in support of bills | +|------|---------------------------------------------------------------| +| 2009 | Central Florida Psychiatric Society representative to Florida | +| 2009 | Testified before the Florida Senate Banking and Insurance | +| 2009 | Florida Psychiatric Society delegate to Florida Medical | +| 2010 | American Academy of Psychiatry and the Law's Young Physician | +| 2011 | American Academy of Psychiatry and the Law's Young Physician | +| 2011 | Area V Assembly Representative to the American Psychiatric | + +| 2012-2015 | American Academy of Psychiatry and the Law's Young Physician | +|---------------|--------------------------------------------------------------------| +| 2013- present | Interviewer of prospective medical school candidates | +| 2017 - | FIRE Research Mentor, University of Central Florida | +| 2017 | Specialty Advisor for forensic and general psychiatry | +| 2018 | Simulation Leader, Global Health Conference: Healthcare as a | +| 2019 | Florida Medical Association's Alternate Delegate to the American | +| 2019 | Foundation Board of Directors, Physicians Society of Central | +| 2020 | Participant in Florida Division of Emergency Management's | +| 2020 | Participant in University of Central Florida College of Medicine's | +| 2020 | Florida Medical Association's representative to Florida's Suicide | +| 2021 | Virtual Forensic Psychiatry discussion with UCF PsychSign group | + +## REVIEWER: + +-AIMS Neuroscience -American Journal of Disaster Medicine -Archives of Internal Medicine -Clinical Geriatrics -Disaster Medicine and Public Health Preparedness -European Psychiatry -Journal of Adolescent Health -Journal of Clinical Psychopharmacology -Journal of Ethics -Journal of Immigrant and Minority Health -Journal of Neuropsychiatry and Clinical Neuroscience -Mayo Clinic Proceedings -Nature Clinical Practice Neurology + +-Neurology India -Oxford University Press (advisor on a book proposal) -Psychosomatics -Social Science & Medicine -The American Journal on Addictions -The Forensic Examiner -Violence and Victims -World Journal of Surgical Oncology + +## BOOK REVIEWS: + +- 1. Clark MR and Treisman GJ: Pain and Depression: An Interdisciplinary, Patient-Centered Approach. Psychosomatics, July-August 2006, 47(4)365-366. +- 2. Brown K, Beech A, Craig L, Chou S: Assessment in Forensic Practice: A Handbook. Journal of Psychiatric Practice, July 2018, 24(4):305 +- 3. Feldman M, Yates G: Dying to be III: True Stories of Medical Deception. Journal of American Academy of Psychiatry and the Law +- 4. Houdek V, Gibson: Treating Sexual Abuse and Trauma with Children, Adolescents, and Young Adults with Developmental Disabilities: A Workbook for Clinicians. Journal of American Academy of Psychiatry and the Law + +# PUBLICATIONS: + +- 1. Hall RCW, Dunlap PK, Hall RCW, Pacheco CA, Blakey RE, Abraham J: Thyroid disease and abnormal thyroid function tests in patients with eating disorders and depression. The Journal of the Florida Medical Association, Inc. 82(3)187-192, 1995. +- 2. Hall RCW, Hall RCW: Anxiety and Endocrine Disease. In Popkin, MK, Seminars in Clinical Neuropsychiatry 4(2)72-83, 1998. +- 3. Hall RCW, Platt DE, Hall RCW: Suicide Risk Assessment: A Review of Risk Factors for Suicide in 100 Patients Who Made Severe Suicide Attempts. Psychosomatics 40:(1)18-27, 1999. +- 4. Hall RCW, Hall RCW: Long-term Psychological and Neurological Complications of Lindane Poisoning. Psychosomatics 40(6)513-517, 1999. +- 5. Hall RCW, Hall RCW: False Allegations: The Role of the Forensic Psychiatrist. Journal of Psychiatric Practice 7(5)343-346, September 2001. +- 6. Hall RCW, Hall RCW: Principles of Physician Recruiting. In Handbook of Mental Health Administration and Management; Reid WH and Silver S (ed.): Brunner-Routledge, New York, NY; Chapter 34:440-448, 2003. + +- 7. Hall RCW, Hall RCW, Chapman M: Identifying Geriatric Patients at Risk for Suicide and Depression. Clinical Geriatrics 11(10)36-44, October 2003. +- 8. Hall RCW, Hall RCW: Establishing Liaison Before Disaster Strikes. http://www.psych.orgidisasterpsych/pdfs/apadisasterhandbk.pdf; Chapter 2:12-19. 2004. +- 9. Hall RCW, Hall RCW, Chapman MJ: Emotional and Psychiatric Effects of Weapons of Mass Destruction in First Responders. In: Bioterrorism: Psychological and Public Health Interventions; Ursano RJ, Norwood AE & Fullerton CS (eds). Cambridge University Press:Cambridge; Chapter 14:250-273; 2004. +- 10. Hall RCW, Appleby B, Hall RCW: Atypical Neuroleptic Malignant Syndrome Presenting as Fever of Unknown Origin in the Elderly. Southern Medical Journal 1(98) 114-117, January 2005. +- 11. Hall RCW, Hall RCW, Chapman MJ: Exploitation of the Elderly: Undue Influence as a Form of Elder Abuse. Clinical Geriatrics 13(2)28-36, February 2005. +- 12. Hall RCW, Hall RCW, Chapman MJ: Definition, Diagnosis, and Forensic Implications of Postconcussional Syndrome. Psychosomatics, 46(3)195-202, May-June 2005. +- 13. Hall RCW, Hall RCW: Abuse of Supraphysiologic Doses of Anabolic Steroids. Southern Medical Journal, 98(5)550-555, May 2005. +- 14. Hall RCW, Hall RCW, Chapman MJ: Psychiatric Complications of Anabolic Steroid Abuse. Psychosomatics, 46(4)285-290, July-August 2005. +- 15. Hall RCW, Hall RCW, Chapman MJ: Medical and Psychiatric Casualties caused by Conventional and Radiological (Dirty) Bombs. General Hospital Psychiatry, 28(3):242-248, May-June 2006. +- 16. Hall RCW, Hall RCW, Chapman MJ: Postconcussional Syndrome: A Work in Progress (Response to Dr. Smith). Letter to the Editor. Psychosomatics, 47(3):272, May-June 2006. +- 17. Hall RCW, Hall RCW, Chapman MJ: Neuroleptic Malignant Syndrome in the Elderly: Diagnostic Criteria, Incidence, Risk Factors, Pathophysiology, and Treatment. (CME article) Clinical Geriatrics, 14(5):39-46, 2006. +- 18. Hall RCW, Hall RCW, Chapman MJ: Effects of Terrorist Attacks on the Elderly, Part I: Medical and Psychiatric Complications of Bombings and Biological, Chemical, and Nuclear Attacks. Clinical Geriatrics, 14(8):26-35. 2006. +- 19. Hall RCW, Hall RCW, Chapman MJ: Effects of Terrorist Attacks on the Elderly, Part 2: Posttraumatic Stress, Acute Stress, and Affective Disorders. Clinical Geriatrics, 14(9):17-24, 2006. + +- 20. Hall RCW, Hall RCW: Malingering of PTSD: forensic and diagnostic considerations, characteristics of malingerers and clinical presentations. General Hospital Psychiatry, 28(6):525-535, 2006. +- 21. Hall RCW, Hall RCW: A Profile of Pedophilia: Definition, Characteristics of Offenders, Recidivism, Treatment Outcomes, and Forensic Issues. Mayo Clinic Proceedings, 82(4):457-471, 2007. +- 22. Hall RCW, Hall RCW: Detection of Malingered PTSD: An Overview of Clinical, Psychometric, and Physiological Assessment: Where Do We Stand? Journal of Forensic Sciences, 52(3):717-725, 2007. +- 23. Hall RCW, Macvaugh GS III, Merideth P, Montgomery J: Commentary: Delving Further Into Liability for Psychotherapy Supervision. The Journal of the American Academy of Psychiatry and the Law, 35(2):196-9, 2007. +- 24. Hall RCW, Hall RCW, Chapman MJ: Psychiatric Effects of Terrorism: Medical and Societal Implications of Recent Attacks. In: Focus on Terrorism, Vol. 9; Linden EV (ed), Nova Science:New York; Chapter 11, Publication date: 3'd Quarter, 2007. +- 25. Hall RCW, Hall RCW: The 1995 Kikwit Ebola outbreak Model of virus properties on system capacity and function: A lesson for future viral epidemics. American Journal of Disaster Medicine, 2(5):270-276, 2007 +- 26. Hall RCW, Hall RCW, Chapman MJ: Central Serotonin Syndrome: Part [— Causative Agents, Presentation, and Differential Diagnosis. Clinical Geriatrics, 15(12):18-25, 2007. +- 27. Hall RCW, Hall RCW, Chapman MJ: Central Serotonin Syndrome: Part II Pathophysiology, Drug Interactions, and Treatment. Clinical Geriatrics, 16(1):24-28, 2008 +- 28. Hall RCW, Resnick PJ: Psychotherapy Malpractice: New Pitfalls. Journal of Psychiatric Practice, 14(2):119-121, 2008 +- 29. Hall RCW, Hall RCW, Chapman MJ: Violence in Older Persons: Part I Occurrence in Forensic/Criminal Situations, Partner Relationships, and Sexual Offenses. Clinical Geriatrics, 16(5):27-32, 2008 +- 30. Hall RCW, Hall RCW, Chapman MJ: Violence in Older Persons: Part II Occurrence in Hospitals and Pharmacological/Behavioral Treatment of Agitation, Aggression and Violence. Clinical Geriatrics, 16(6):28-32, 2008. +- 31. Hall RCW, Hall RCW, Chapman MJ. The 1995 Kikwit Ebola outbreak: lessons hospitals and physicians can apply to future viral epidemics. Gen Hosp Psychiatry. 2008 Sep-Oct;30(5):446-52. Epub 2008 Jul 23 +- 32. Hall RCW, Friedman SH: Drug Diversion Program Rights. Legal Digest. The Journal of the American Academy of Psychiatry and the Law, 36(4):579-580, 2008 + +- 33. Hall RCW, Hall RCW, Chapman MJ: Nursing Home Violence: Occurrence, Risks, and Interventions. Annals of Long-Term Care, 17(1):25-31, 2009 +- 34. Paul RK, Lockey C, Hall RCW, Bursztajn H: Practice Management: Managing Risks When Practicing in Three-Party Care Settings. Psychiatrictimes.com, 26(2), Feb. 3, 2009. +- 35. Hall RCW, Hall RCW, Chapman MJ: Letter to the Editor response re: Nursing Home Violence: Occurrence, Risks, and Interventions) Annals of Long-Term Care, 17(1):25-31, 2009), Annals of Long-Term Care, 17(4):17-21, 2009. +- 36. Hall RCW, Hall RCW, Myers W, Chapman M: Testamentary Capacity: History, Physicians' Role, Requirements, and Why Wills are Challenged. Clinical Geriatrics, 17(6):18-24, 2009. +- 37. Hall RCW, Hall RCW, Chapman M: Anticholinergic Syndrome: Presentations, Etiological Agents, Differential Diagnosis, and Treatment. Clinical Geriatrics, 17(11):22-28, 2009. +- 38. Hall RCW: Somatoform Disorders. In First Aid for the Neurology Boards: An Insider's Guide. Rafii MS; Cochrane TI; and Le T (eds), McGraw-Hill Medical:New York, Chapter 17, Pps 451-460, 2010. +- 39. Hall RCW: Somatoform Disorders. In First Aid for the Psychiatry Boards: An Insider's Guide. Azzam A, Yanofski J, Kaftarian E, Le T (eds), McGraw-Hill Medical:New York, Chapter 10, Pps 122-135, 2010. +- 40. Day TR, Hall RCW: Déjà vu: From Comic Books to Video Games: Legislative Reliance on "Soft Science" to Protect Against Uncertain Societal Harm Linked to Violence v. the First Amendment. Oregon Law Review, 89(2):415-452, 2010. +- 41. Appleby BS, Appleby KK, Hall RCW, Wallin MT: D178N, 129Val and N171S, 129Val Genotype in a Family with Creutzfeldt-Jakob Disease. Dement Geriatr Cogn Disord, 30:424-431, 2010. +- 42. Hall RCW, Day T, Hall RCW: A Plea for Caution: Violent Video Games, the Supreme Court, and the Role of Science. Mayo Clin Proc, 86(4):315-321, 2011. +- 43. Paul RK, Lockey C, Hall RCW, Bursztajn HJ: Managing Risks When Practicing in Three-Party Care Settings. Psychiatric Times, 28(4):18-22, 2011. +- 44. Gould NF, McKibben JB, Hall R, Corry NH, Amoyal NA, Mason ST, McCann UD, Fauerbach JA. Peritraumatic Heart Rate and Posttraumatic Stress Disorder in Patients with Severe Burns. Psychiatrist.com, Oct 19, 2010 [Epub ahead of print] and J Clin Psychiatry, 72(4):539-547, 2011. +- 45. Hall RCW, Day T, Hall RCW: Reply to A Plea for Concern Regarding Violent Video Games. Letter to the Editor, Mayo Clin Proc, 86(8):821-823. 2011. + +- 46. Hall RCW, Hall RCW: Plaintiffs Who Malinger: Impact of Litigation on Fake Testimony. In New Perspectives on Faking in Personality Assessment. Ziegler M, MacCann C, Roberts R (eds), Oxford:New York, Chapter 16, Pps 255-281, 2012. +- 47. Nucifora FC, Hall RCW, Everly G: Reexamining the Role of the Traumatic Stressor and the Trajectory of Posttraumatic Distress in the Wake of Disaster. Editorial, Disaster Medicine and Public Health Preparedness, 5:suppl 2:S172-175, 2011 +- 48. Hall RCW, Hall RCW: Compensation Neurosis: A Too Quickly Forgotten Concept? J Amer Acad Psychiatry Law, 40(3):390-398, 2012. +- 49. Hall RCW: Civil War. In Encyclopedia of immigrant Health, Loue S and Sajotovic M (eds.) Springer, Pps 445-447, 2012. +- 50. Hall RCW: Radicalization. In Encyclopedia of immigrant Health, Loue S and Sajotovic M (eds.) Springer, Pps 1264-1266, 2012. +- 51. Hall RCW: Terrorism. In Encyclopedia of Immigrant Health, Loue S and Sajotovic M (eds.) Springer, Pps 1413-1416, 2012. +- 52. Myers WC, Hall RCW, Tolou-Shams M: Prevalence and Assessment of Malingering in Homicide Defendants Using the Mini-Mental State Examination and the Rey 15- Item Memory Test. Homicide Studies, 17(3):314-328, August 2012. +- 53. Hatters Friedman S, Hall RCW: Antidepressant Use During Pregnancy: How to Avoid Clinical and Legal Pitfalls. Current Psychiatry, 12(2):10-16, 2013 +- 54. Hall RCW, Hall RCW: Biological and Pharmacological Treatment of Post-traumatic Stress Disorder in Older Adults. Clinical Geriatrics, 21(8), 2013. Published online August 22, 2013 at www.clinicalgeriatrics.com. +- 55. Hall RCW, Hall RCW: Psychotherapeutic Interventions for Post-traumatic Stress Disorder. Clinical Geriatrics, 21(9), 2013. Published online September 24, 2013 at www.clinicalgeriatrics.com. +- 56. Hall RCW, Hatters Friedman S: Guns, Schools, and Mental Illness: Potential Concerns for Physicians and Mental Health Professionals. Mayo Clinic Proceedings, 88(11):1272-1283, November 2013 +- 57. Hatters Friedman S, Hall RCW, Sorrentino R: Commentary: Women, Violence and Insanity. J Am Acad Psychiatry Law, 41(4):523-528, 2013 +- 58. Hatters Friedman S, Hall RCW: Teaching Psychopathology in a Galaxy Far, Far Away: The Light Side of the Force. Academic Psychiatry. 2015 Dec;39(6):719-25. Epub 2015 May 2. +- 59. Hall RCW, Hatters Friedman S: Psychopathology in a Galaxy Far, Far Away: The Use of Star Wars' Dark Side in Teaching. Academic Psychiatry. 2015 Dec;39(6):726- + +32. Epub 2015 May 6. + +- 60. Hall RCW: Somatic Symptom and Related Disorders (formerly Somatoform Disorders). In First Aid for the Neurology Boards. Second Edition. Rafii MS; Cochrane TI; and Le T (eds), McGraw-Hill Medical:New York, Chapter 17, Pps 439-447, 2015. +- 61. Hall RCW: Mental Status Examination. In Wiley Encyclopedia of Forensic Science. Jamieson A and Moenssens AA (eds), John Wiley: Chichester. DOI: 10.1002/9780470061589.fsa287.pub2. (online), June 2015. http://onlinelibrary.wiley.com/doi/10.1002/9780470061589.fsa287.pub2/full +- 62. Hall RCW, Soliman S: Elderly and Pharmacological Treatment of PTSD. In: Comprehensive Guide to Post-Traumatic Stress Disorder. Martin C, Preedy V, Patel V (eds), Springer International: Switzerland, ISBN: 978-3-319-08613-2 (Online), March 2015. +- 63. Day TR, Hall RCW: PTSD and Tort Law. Comprehensive Guide to Post-Traumatic Stress Disorder. Martin C, Preedy V, Patel V (eds), Springer International: Switzerland, ISBN: 978-3-319-08613-2 (Online), March 2015. +- 64. Hatters Friedman S, Collier S, Hall RCW: PTSD Behind Bars: Incarcerated Women and PTSD. Comprehensive Guide to Post-Traumatic Stress Disorder. Martin C, Preedy V, Patel V (eds), Springer International: Switzerland, ISBN: 978-3-319-08613-2 (Online), March 2015. +- 65. Hatters Friedman S, Hall RCW: Using Star Wars' Supporting Characters to Teach about Psychopathology. Australasian Psychiatry, Epub June 23, 2015; print Aug 2015; 23(4):432-4. +- 66. Soliman S, Hall RCW: Forensic Issues in Medical Evaluation: Competency and End of Life Issues. In Balon R, Wise TN (eds): Clinical Challenges in the Biopsychosocial Interface. Update on Psychosomatics for the 21st Century. Adv Psychosom Med. Basel, Karger, 2015, vol 34, pp 36-48. +- 67. Hall RCW, Hatters Friedman S, Jain A: Pregnant Women and the Use of Corrections Restraints and Substance Use Commitment. J Am Acad Psychiatry Law, 43(3):359-68, 2015. +- 68. Shand J, Hall RCW: Consent in Psychiatric Emergencies: What Clinicians Need to Know. Psychiatric Times, 32(11):17-20, 2015. +- 69. Myers W, Hall RCW, Marshall R, Tolou-Shams M, Wooten K: Frequency and Detection of Malingering in Homicide Defendants Undergoing Criminal Responsibility Evaluations Using the Schedule for Nonadaptive and Adaptive Personality: A Feasibility Study. SAGE Open, April-June 2016, vol 6:1-8. http://sgo.sagepub.com/contentispsgo/6/2/2158244016638131.full.pdf +- 70. Hall RCW, Myers WC: Challenges and Limitations to Treat ADHD in Incarcerated Populations. Commentary. J Am Acad Psychiatry Law, 44(2):164-170, 2016 + +- 71. Sorrentino R, Hatters Friedman S, Hall RCW: Gender Consideration in Violence. In. Knoll JL (ed): Violence. Psychiatric Clinics of North America. Elsevier, NY; 39(4):701- 10, 2016. +- 72. Hatters-Friedman S, Hall RCW: Star Wars: The Force Awakens Forensic Teaching About Patricide. J Am Acad Psychiatry Law, 45(1):128-130, 2017 +- 73. Hall RCW, Hall RCW: Torture and Psychiatric Abuse: Definition, Ethics, and Assessment. In: Rosner R, Scott C (eds): Principles and Practice of Forensic Psychiatry, 3rd Edition. CRC Press. Taylor & Francis Group:Boca Raton, FL; 2017, Cpt 82, pp 845-854. +- 74. Lee J, Hall RCW: The Death Penalty and Mental Illness: An Evolving Standard? Psychiatric Times. 36(6):16C-16E, 2017 +- 75. Hatters Friedman S, Hall RCW: Competencies in Civil Law. In: Gold L, Frierson R (eds): Textbook of Forensic Psychiatry, 3rd Edition. American Psychiatric Association Publishing: Arlington, VA; 2017, Cpt 13, pp 185-200 +- 76. Friedman S, Hall RCW, Appel JM: The Last Jedi Takes His Own Life: Rational Suicide and Homicide-Suicide in Star Wars. Acad Psychiatry; published online May 24, 2018; https://doi.org/10.1007/s40596-018-0938-y; August 2018. Volume 42 (4): 503- 509 +- 77. Hatters-Friedman S, Hall RCW, Sorrentino R: Involuntary Treatment of Psychosis in Pregnancy. J Am Acad Psychiatry Law, 46(2):217-223, 2018 +- 78. Cooke B, Hall RCW, Hatters Friedman S, Jain A, Wagoner R: Professional Boundaries in Corrections. J Am Acad Psychiatry Law, 47(1):91-98, 2019 +- 79. Lee J. Hall RCW: The Impact of Gliomas on Cognition and Capacity. J Am Acad Psychiatry Law, 47(3):350-359, 2019 +- 80. Hall RCW, Friedman SH, Sorrentino R, Lapchenko M, Marcus A, Ellis R: The myth of school shooters and psychotropic medications. Behav Sci Law, 1-19, 2019. https://doi.org/10.1002/bsl.2429 +- 81. Hatters Friedman S, Tamburello A, Kaemph A, Hall RCW: Prescribing for Women in Corrections. J Am Acad Psychiatry Law, 47(4): 476-85, 2019. +- 82. Hall RCW, Hatters Friedman S: I'm [Virtual] Batman: Violence and Video Games. In: Packer S and Fredrick D (eds): Welcome to Arkham Asylum: Essays on Psychiatry and the Gotham City Institution. McFarland & Company:Jefferson, NC; 2020, pps 55-64 +- 83. Hatters Friedman S, Hall RCW: Deadly and Dysfunctional Family Dynamics: When Fiction Mirrors Fact. In: Packer S and Fredrick D (eds): Welcome to Arkham Asylum: Essays on Psychiatry and the Gotham City Institution. McFarland & Company:Jefferson, NC; 2020, pps 65-75 + +- 84. Hall RCW, Hatters Friedman S: Don't Laugh at the Comics: A Modern Take. Academic Psychiatry,44(4) 476-482, 2020, DOI 10.10071s40596-020-01257-2 +- 85. Hall RCW, Hatters Friedman S: Comic Books, Dr. Wertham, and the Villains of Forensic Psychiatry. J Am Acad Psychiatry Law, 48(4) 563-544, 2020 +- 86. Hall RCW, Tardif I: Florida Law Enforcement Policies for and Experience with Tarasoff-Like Reporting. J Am Acad Psychiatry Law, 49(1):77-86, and online, 2021. DOI:10.29158/JAAPL.200065-20. +- 87. Hatters Friedman S, Hall RCW: Avoiding malpractice while treating depression in pregnant women. Current Psychiatry, 20(8):30-36; 2021 August; doi:10.12788/cp.0154 +- 88. Hall RCW: Suicide Risk Assessment for Individuals Involved in the Legal System. In: Kelley E and Flood F (eds): Suicide and Its Impact on the Criminal Justice System. American Bar Association's ABA Publishing: Chicago, IL; Cpt 11: pps 155-172, 2021. + +\* Boldface indicates Ryan C. W. Hall, MD + +# NEWSLETTERS: + +- 1. Hall RCW, Hall RCW: Fee-Splitting: Ethical Implications and Principles for Practice Management. Florida Psychiatric Society's Transference, (2)14, 1999. +- 2. Phillips RTM, Wall B, Frisher K. Hall RCW, Zonana H: American Medical Association 2010 Interim Meeting Highlights. American Academy of Psychiatry and the Law Newsletter, 36(1):27-29, 2011. +- 3. Friedman S, Yang S, Hall RCW: Why Research Matters in Expert Testimony. American Academy of Psychiatry and the Law Newsletter, 36(2):1-21, 2011. +- 4. Hall RCW, Davidson C, Levine H: Serotonin Syndrome in Children: A Potentially Toxic Clinical and Legal Entity. American Academy of Psychiatry and the Law Newsletter, 36(2):18-26, 2011. +- 5. Phillips RTM, Wall B, Frisher K. Hall RCW, Zonana H: American Medical Association 2011 Annual Meeting Highlights. American Academy of Psychiatry and the Law Newsletter, 37(1):25, 2012. +- 6. Hatters Friedman S, Hall RCW: Treatment of Mental Illness in Pregnancy and Malpractice Concerns. American Academy of Psychiatry and the Law Newsletter, 37(2):21-22, 2012 +- 7. Hatters Friedman S, Hall RCW, Kenedi C, Knoll IV J: "Your Drugs Made Me Do It." American Academy of Psychiatry and the Law Newsletter, 39(3): 24-29, 2014 + +- 8. Hall RCW, Hatters Friedman S, Jain A, Sorrentino R: Guns and Mental Illness. American Academy of Psychiatry and the Law Newsletter, 39(3): 26-29, 2014 +- 9. Wall B, Hall RCW, Piel J: American Medical Association 2014 Interim Meeting Highlights. American Academy of Psychiatry and the Law Newsletter, 39(1):18, 2015 +- 10. Hatters Friedman S, Hall RCW, Glezer A, Jain A, Wisner K: Ethical and Legal Issues in Treatment of Mental Illness in Pregnancy. American Academy of Psychiatry and the Law Newsletter, 39(1):23, 28, 2015 +- 11. Wall B, Hall RCW, Piel J: American Medical Association 2015 Annual Meeting Highlights. American Academy of Psychiatry and the Law Newsletter, 40(3):1, 2, 27, 2015 +- 12. Hall RCW: Where is Board Certification going? Southlands, Newsletter of the Southern Psychiatric Association, Volume 2(1), Dec 2015 +- 13. Hall RCW: AAPL at the APA Awards. American Academy of Psychiatry and the Law Newsletter, 41(3):1-2, 2016 +- 14. Cheng J, Hall RCW: What Toxicology Screens May Miss: Dextromethorphan. American Academy of Psychiatry and the Law Newsletter, 41(3):23, 28, 2016 +- 15. Cheng J, Hall RCW: A Primer on Kratom. American Academy of Psychiatry and the Law Newsletter, 42(2):24, 32, 2017 +- 16. Hatters Friedman S, Hall RCW, Cooke B, Jain A, Wagoner R, Sorrentino R: Boundary Violations in Correctional Psychiatry. American Academy of Psychiatry and the Law Newsletter, 42(3):16, 2017 +- 17. Ellis R, Cheng J, Hall RCW: What was Old is New Again: Ketamine in 21" Century. American Academy of Psychiatry and the Law Newsletter, 42(3):23, 31, 2017 +- 18. Hall RCW: Mr. Anthony Graves: Graves Injustice. American Academy of Psychiatry and the Law Newsletter, 43(1):7, 2018. +- 19. Hall RCW, Levine H: Updating the Marijuana Use History: "Doc, I treat my depression with Incredible Hulk." American Academy of Psychiatry and the Law Newsletter, 43(2):18, 24, 2018 +- 20. Hall RCW: Brief review of Gabapentin Abuse Potential. American Academy of Psychiatry and the Law Newsletter, 44(2):14, 23, 2019 +- 21. Hall RCW, Hatters Friedman S, Sorentino R: Evolving Policy Topics of Interest for Institutions of Higher Learning. American Academy of Psychiatry and the Law Newsletter, 44(2):16, 25, 2019 +- 22. Hall RCW: Is Your "Fat Burner" Dietary Supplement Really Fertilizer? American + +Academy of Psychiatry and the Law Newsletter, 44(3):9, 27, 2019 + +- 23. Tardif I, Hall RCW: Moon Rocks: The Caviar of the Cannabis Industry? American Academy of Psychiatry and the Law Newsletter, 44(3):19. 28, 2019 +- 24. Liu C, Romeus L, Hall RCW: 13 Reasons Why and Media's Interest in Suicide. American Academy of Psychiatry and the Law Newsletter, 45(1): 11, 25, 2020. +- 25. Hall RCW: Update on the Parkland Shooting Civil Cases. American Academy of Psychiatry and the Law Newsletter, 45(3): 21, 25, 2020. +- 26. Sarmiento B, Hall RCW: Georgia County Sheriff's Attempt to Protect Trick-or-Treaters. American Academy of Psychiatry and the Law Newsletter, 45(3): 30, 32, 2020. +- 27. Hall RCW: All Rise, the Judge has Entered the Zoom Call. American Academy of Psychiatry and the Law Newsletter, 46(1): 13, 30, 2021. + +\* Boldface indicates Ryan C. W. Hall, MD + +## ABSTRACTS/POSTERS: + +- 1. Hall RCW, Hazard SC. Hall RCW, Pacheco CA, Blakey RE, Abraham J: Thyroid Disease in Eating Disordered and Depressed Patients. -146th Annual Meeting, American Psychiatric Association, May 25, 1993, San Francisco, CA, P.1.57 (Poster Session). +- 2. Hall RCW, Platt DE, Hall RCW: Suicide Risk Assessment: A Review of Risk Factors for Suicide in 100 Patients Who Made Severe Suicide Attempts: Evaluation of Suicide Risk in a Time of Managed Care. + - Psychiatric Practice and Managed Care, American Psychiatric Association, Vol. 5, No. 5, P 12, Sept-Oct 1999. +- 3. Hall RCW, Gould N, McCann U, McKibben J: The Role of Morphine in the Development of Acute Stress Disorder and Posttraumatic Stress Disorder in Patients with Severe Burn Injury. + - 41s,Annual Meeting, American Burn Association. San Antonio, TX, Mar 25, 2009. +- 4. Gould N, McCann U, McKibben J, Hall RCW: Peri-traumatic Heart Rate as a Predictor of Acute Stress Disorder and Post-traumatic Stress Disorder in Patients with Burn Injury. + - 4P' Annual Meeting, American Burn Association. San Antonio, TX, Mar 25, 2009. +- 5. Marriner B, Tseng T, Rich W, Hall RCW: Investigating the Factors Influencing the + +#### Prescription of Antidepressants with No FDA-Approved Indication in the United States Between 2006 — 2009. + +- Annual Meeting, American College of Clinical Pharmacy, Hollywood, FL, Oct 22, 2012. +- 6. Marriner B, Rich W, Matthews A, Hall RCW, Tseng T: Provider Characteristics Influencing the Prescription of Antidepressants without a Psychiatric Diagnosis in the United States, 2006-2009. + - 140th Annual Meeting & Expo, American Public Health Association, San Francisco, CA, Oct 29, 2012. +- 7. Padalia K, Hall RCW: Change in Use of Suicidality Assessment Tools Since the 2004 FDA Suicidality Black Box Warning on Antidepressants in Children and Adolescents. -FIRE Module, University of Central Florida College of Medicine, Feb 23, 2017 +- 8. Kiguradze T, Hall RCW: Glucocorticosteriods, Psychosis, and Legal Culpability + - The Mickey Finn Defense? A Cross-sectional Retrospective Analysis of the FDA-FAERS Database. -FIRE Module, University of Central Florida College of Medicine, Feb 22, 2018 +- 9. Mayet M, Hall RCW: The Balance of Free Speech in Medicine: A Literature Review. -FIRE Module, University of Central Florida College of Medicine, March 5, 2021 +- 10. Sarmiento B, Hall RCW: Cannabis Use and Mental Health Status in Florida College Students: A 5-Year Survey Analysis. -FIRE Module, University of Central Florida College of Medicine, March 5, 2021 + +\* Boldface indicates Ryan C. W. Hall, MD + +#### PRESENTATIONS AT NATIONAL AND INTERNATIONAL MEETINGS AND INVITATIONAL ACADEMIC LECTURES: + +- 1. Hall RCW, Hazard SC, Dunlap PK, Hall RCW, Pacheco CA, Blakey RE, Abraham J: Thyroid disease and abnormal function tests in patients with eating disorders and depression. Poster Session - American Psychiatric Association Annual Meeting, San Francisco, CA, May 25, 1993 + +- 2. Hall RCW, Hall RCW: Management of Hostage Situations. Psychiatric Responses to Trauma, U.S. State Department Conference on International Terrorism, hosted by Uniformed Services University of Health Sciences, Washington, D.C., April 28, 1999 +- 3. Hall RCW, Hall RCW: Terrorism: Its Aftermath and Long-term Effects on Survivors - A Consultation-Liaison Perspective -- Part I. Psychiatric Responses to Trauma, U.S. State Department Conference on International Terrorism, hosted by Uniformed Services University of Health Sciences, Washington, D.C., April 28, 1999 +- 4. Hall RCW, Hall RCW: Terrorism: Its Aftermath and Long-term Effects on Survivors - A Consultation-Liaison Perspective - Part II. Psychiatric Responses to Trauma, U.S. State Department Conference on International Terrorism, hosted by Uniformed Services University of Health Sciences, Washington, D.C., April 28, 1999 +- 5. Hall RCW, Hall RCW, Platt DE: Impact of Managed Care on Suicide Risk Assessment. American Academy of Psychiatry and the Law, 1999 Annual Meeting, Baltimore, MD, October 15, 1999 +- 6. Hall RCW, Hall RCW: Ethical Issues in Managed Care. American Psychiatric Association, 1999 Ethics Workshop, Washington, DC, November 3, 1999 +- 7. Hall RCW, Hall RCW: Terrorism, Bioterrorism and Disaster Aftermath and Long-term Effects on Survivors. Cycle of Violence: Assessment and Management of Aggression - A Mardi Gras Symposium, Tulane University, New Orleans, LA, February 26, 2000 +- 8. Hall RCW, Hall RCW: Bioterrorism Dealing with Medical and Psychiatric Consequences of Victims and Responders. Cycle of Violence: Assessment and Management of Aggression - A Mardi Gras Symposium, Tulane University, New Orleans, LA, February 26, 2000 +- 9. Hall RCW, Hall RCW: Psychiatric Consequences of Terrorism, Bioterrorism and Disaster. Rocky Mountain Emotional Trauma Symposium, Pathways Treatment Center. Kalispell, MT, June 29, 2000 +- 10. Hall RCW, Hall RCW: Suicide in an Era of HMO's and Managed Care. Rocky Mountain Emotional Trauma Symposium, Pathways Treatment Center, Kalispell, MT, June 30, 2000 +- 11. Hall RCW, Hall RCW: Psychological Response to Disasters and Terrorism. International Society of Political Psychology, 23rd Annual Scientific Meeting, Seattle, WA, July 4, 2000 +- 12. Hall RCW, Hall RCW: Biological Warfare Attack Scenarios, Response to Terrorist Attacks, and Sources of Conflict. American Academy of Psychiatry and the Law, Pre-AAPL meeting, Ireland, September 16-26, 2000 +- 13. Hall RCW, Hall RCW, Chapman M: Workplace Violence. American Academy of Psychiatry and the Law, Pre-AAPL meeting, Ireland, September 16-26, 2000 + +- 14. Hall RCW, Hall RCW: Biological Warfare: Attack Scenarios and Public Health Issues. Grand Rounds, Hennepin County Medical Center, Minneapolis, MN, December 8, 2000 +- 15. Hall RCW, Hall RCW: Bioterrorism: A Short History of Biowarfare & Analysis of the Threat. Grand Rounds, Mayo Clinic, Jacksonville, FL, August 15, 2001 +- 16. Hall RCW, Hall RCW: Situational Suicide. Halifax Medical Center, Daytona Beach, FL, September 13, 2001 +- 17. Hall RCW, Hall RCW: Domestic Violence: The Physician's Role. Halifax Medical Center, Daytona Beach, FL, September 14, 2001 +- 18. Hall RCW, Hall RCW: Terrorism, Bioterrorism and Assault with Anthrax as a Biological Weapon. -Florida Psychiatric Society, Fall Meeting, Coconut Grove, FL, November 4, 2001 -Grand Rounds, Louisiana State University Health Sciences Center, Shreveport, LA, January 30, 2002 +- 19. Hall RCW, Hall RCW: Smallpox. Grand Rounds, Louisiana State University Health Sciences Center, Shreveport, LA, January 30, 2002 +- 20. Hall RCW, Hall RCW: Psychopharmacology Forensic Risk and Clinical Practice: Things the clinician must know. Apopka Community Health Center, Apopka, FL, March 13, 2002 +- 21. Hall RCW, Hall RCW: Overview of Terrorism and Bioterrorism. Orlando Police Academy, Orlando Police Department, Orlando, FL, August 2, 2002 +- 22. Hall RCW, Hall RCW: Workplace Violence, School Shootings and Occupations at Risk: Analysis of current data and psychological profiles. Orlando Police Academy, Orlando Police Department, Orlando, FL, August 2, 2002 +- 23. Hall RCW, Hall RCW: Smallpox as a Biological Weapon. Orlando Police Academy, Orlando Police Department, Orlando, FL, August 2, 2002 +- 24. Hall RCW, Hall RCW: Smallpox as an Agent for Biological Warfare. Southern Psychiatric Association Annual Meeting, Loews Ventana Canyon Resort, Tucson, AZ, October 3, 2002 +- 25. Hall RCW, Hall RCW: Domestic Violence: The Physician's Role. Mandatory Madness, Halifax Medical Center, Daytona USA, Daytona Beach, FL, December 14, 2002 +- 26. Hall RCW, Hall RCW, Chapman MJ: Workplace Violence, School Shootings and Occupations at Risk: Analysis of current data and psychological profiles. Orlando Police Department, Orlando, FL, February 11, 2003 + +- 27. Hall RCW, Hall RCW: Medical and Psychological Sequelae of Bombings: Implications for First Responders and Critical Government Staff. Orlando Police Department, Orlando, FL, February 11, 2003 +- 28. Hall RCW, Hall RCW: Domestic Violence: The Physician's Role. Florida Psychiatric Society Spring Meeting, Orlando, FL, April 5, 2003 +- 29. Hall RCW, Hall RCW: Terrorist Bombings: Medical and Psychiatric Impact. Southern Psychiatric Association's Annual Meeting, Nashville, TN, October 11, 2003 +- 30. Hall RCW, Hall RCW: Terrorism, Bombings, and Psychiatric Casualties. University of Florida, Department of Psychiatry, Visiting Professor Program, November 7, 2003 +- 31. Hall RCW, Hall RCW: Domestic Violence: The Physician's Role. Tampa Bay Psychiatric Society, Tampa, FL, sponsored by Pfizer. January 29, 2004 +- 32. Hall RCW, Hall RCW: Smallpox as an Agent for Biological Warfare. Orlando Police Academy, Orlando Police Department, Orlando, FL, August 13, 2004 +- 33. Hall RCW, Hall RCW: Medical and Psychiatric Casualties of Terrorist Bombings. Orlando Police Academy, Orlando Police Department, Orlando, FL, August 13, 2004 +- 34. Hall RCW, Hall RCW: Medical and Psychological Consequences of Bombings. Grand Rounds, Tulane University, Department of Psychiatry, New Orleans, LA, January 28, 2005 +- 35. Hall RCW, Hall RCW: Psychological Sequelae of Weapons of Mass Destruction on First Responders. South Central Center for Public Health Preparedness/Alabama Department of Public Health, Montgomery, AL, Satellite Conference, May 6, 2005 +- 36. Hall RCW, Hall RCW: Medical and Psychological Aspects of Terrorist Bombings. Grand Rounds, Sinai Hospital, Department of Medicine, Baltimore, MD, June 2, 2005 +- 37. Hall RCW, Hall RCW: Managed Care Disrupting the Physician-Patient Relationship: The New Realities. (Abbreviated version) Forensic Psychiatry Fellows and Residents, University of Florida, Gainesville, FL, January 24, 2006 +- 38. Hall RCW, Hall RCW, Chapman MJ: Managed Care Disrupting the Physician-Patient Relationship: The New Realities. Presidential Address. Southern Psychiatric Association, Baltimore, MD, September 30, 2006. +- 39. Hall RCW, Hall RCW: When the System is Overwhelmed: Protecting the Provider during Biodisaster. Satellite Conference, University of Alabama Birmingham South Central Center for Public Health Preparedness/Alabama Department of Public Health/Tulane University School of Public Health, Montgomery, AL, February 27, 2007. + +- 40. Hall RCW: Testamentary Capacity from Isaac Ray to Anna Nicole Smith. Grand Rounds, Case Western Reserve School of Medicine, Cleveland, OH, March 28, 2008 +- 41. Hall RCW, Hall RCW, Rundell JR, Winstead DK: Psychiatrists' Role in Disaster Management: Lessons Learned. Course 14, American Psychiatric Association, Annual Meeting, Washington, DC, May 3, 2008. +- 42. Hall RCW: Violence in the Elderly: Forensic and Treatment Concerns. Forensic Forum, Florida Psychiatric Society, ChampionsGate, FL, September 20, 2008. +- 43. Hall RCW: Testamentary Capacity: From Isaac Ray to Anna Nicole Smith. Southern Psychiatric Association, September 25, 2008. +- 44. Hall RCW: Testamentary Capacity: From Isaac Ray to Anna Nicole Smith. Forensic Psychiatry Program, University of South Florida, Tampa, FL, January 29, 2009. +- 45. Hall RCW, Hall RCW: Domestic Violence as Portrayed in Film A Realistic Appraisal? Florida Psychiatric Society, St. Petersburg Beach, FL, March 20, 2009. +- 46. Hall RCW, Silberman E, Preven D, Weissman S (chairperson): Indications for the Use of Combined Talking Therapy and Pharmacotherapy and How to Teach in Residency. Corresponding Committee on Graduate Education, CW16, American Psychiatric Association, San Francisco, CA, May 19, 2009. +- 47. Hall RCW, Hall RCW: Serotonin Syndrome. Southern Psychiatric Association, Destin, FL, September 24, 2009 +- 48. Hall RCW: Testamentary Capacity: From Isaac Ray to Anna Nicole Smith. Florida Psychiatric Society, Orlando, FL, October 11, 2009. +- 49. Hall RCW, Hall RCW: Avoiding Psychiatric Malpractice in a Litigious Environment. Florida Psychiatric Society, Orlando, FL, October 11, 2009. +- 50. Hall RCW, Appleby B: Research on Young-Onset Dementia and Forensic Implications. Workshop, American Academy of Psychiatry and the Law, Baltimore, MD, October 29, 2009 +- 51. Hall RCW, Hall RCW: Terrorist Bombings: Medical and Psychiatric Impact. Alabama Psychiatric Society meeting, Montgomery, AL, April 24, 2010. +- 52. Hall RCW, Hall RCW: Serotonin Syndrome. Alabama Psychiatric Society meeting, Montgomery, AL, April 24, 2010. +- 53. Hall RCW, Hall RCW: Geneva Conventions and Foreign Intelligence Surveillance Act, Florida Psychiatric Society's Forensic Psychiatry Committee meeting, Tampa, FL, April, 30, 2010 + +- 54. Hall RCW, Hall RCW: Epidemics Bureaucracy and Why Governments Fail in Times of Crisis, Southern Psychiatric Association, Asheville, NC, September 30, 2010 +- 55. Levine H, Bradford, J, Hall RCW, Kaye N, Levin A: Do Practice Guidelines Belong In Court? Where Do They Belong? American Academy of Psychiatry and the Law, Annual Meeting, Tucson, AZ, October 21, 2010 +- 56. Dinwiddie SH, Hall RCW, Harlow M, Friedman S, Yang S: Why Research Matters: Applying Science to Cases. American Academy of Psychiatry and the Law, Annual Meeting, Tucson, AZ, October 21, 2010 +- 57. Hall RCW, Hall RCW: Terrorist Bombings: Medical and Psychiatric Impact-Implications for Law Enforcement. Orange County Sheriffs Office senior leadership team, Orlando, FL, November 4, 2010 +- 58. Hall RCW, Hall RCW: Head Trauma: Psychiatric Sequelae and Malingering. Bell & Roper, PA, Law Seminar, Orlando, FL, November 5, 2010 +- 59. Hall RCW: Pedophiles: Definition, Characteristics, Patterns, and Technology. Internet Crimes Against Children Task Force Conference (Investigation unit), Orlando, FL, December 2, 2010 +- 60. Hall RCW: Pedophiles: Definition, Recidivism, Technology, and Treatment Options. Internet Crimes Against Children Task Force Conference (Prosecution unit), Orlando, FL, December 2, 2010 +- 61. Hall RCW: Serotonin Syndrome: Diagnosis, Treatments and Societal Impact. Grand Rounds, University of South Florida Department of Psychiatry, Tampa, FL, December 16, 2010 +- 62. Hall RCW: The Psychology of Aging. Newcomers Group. Lake Mary, FL, January 20, 2011 +- 63. Hall RCW, Hall RCW: The Culture of Domestic Violence? Florida Psychiatric Society, Spring Meeting, Sarasota, FL, April 8, 2011 +- 64. Pasternack S, Schmidt C, Barnett D, Hall RCW: Guns and Medical Practice: Why does a physician need to inquire? Panel, Florida Psychiatric Society, Spring Meeting, Sarasota, FL, April 9, 2011 +- 65. Hall RCW: Compensation Neurosis. Hot Topics in Forensic Psychiatry. Tulane University, New Orleans, LA, April 17, 2011 +- 66. Hall RCW: Offender Behavior. National District Attorneys Association, National Center for Prosecution of Child Abuse, Unsafe Havens I: Investigation and Prosecution of Technology-Facilitated Child Sexual Exploitation, Portland, OR, June 23, 2011 + +- 67. Hall RCW, Hall RCW: The Evaluation and Future of Posttraumatic Stress Disorder. Southern Psychiatric Association Annual Meeting, Annapolis, MD, September 17, 2011 +- 68. Hall RCW, Hall RCW: Assessment of Violence Potential: Are there any neural factors? Florida Psychiatric Society, Orlando, FL, September 24, 2011 +- 69. Levine H, Hall RCW, Kaye N: Black Box or Pandora's Box How Black Boxes Affect our Field. American Academy of Psychiatry and the Law, Annual Meeting, Boston, MA, October 27, 2011 +- 70. Myers W, Hall RCW, Tolou-Shams M: Malingering in Homicide Defendants: Use of the MMSE and FIT. American Academy of Psychiatry and the Law, Annual Meeting, Boston, MA, October 27, 2011 +- 71. Hall RCW: Compensation Neurosis. Florida Psychiatric Society, Orlando, FL, April 14, 2012 +- 72. Hall RCW, Hall RCW: Hostage Crises: A Psychiatric and Geopolitical Analysis. Southern Psychiatric Association, White Sulphur Springs, WV, October 5, 2012 +- 73. Kaufman A, Mossman D, Hall RCW, Trestman R: Beyond a Reasonable Doubt: Evidence-Based Expert Opinions. American Academy of Psychiatry and the Law, Annual Meeting, Montreal, Quebec, Canada, October 25, 2012 +- 74. Kaye N, Hatters Friedman S, Hall RCW, Janvier A: Legal, Ethical, and Risk Implications of Psychotropic Treatment in the Pregnancy/Perinatal Period. American Academy of Psychiatry and the Law, Annual Meeting, Montreal, Quebec, Canada, October 26, 2012 +- 75. Hall RCW, Day T: Landmark Cases and Supreme Court's Decision on Healthcare. American Academy of Psychiatry and the Law, Annual Meeting, Montreal, Quebec, Canada, October 26, 2012 +- 76. Hall RCW, Day T: Violent Video Games and the Battle of the Social Science Experts. American Academy of Psychiatry and the Law, Annual Meeting, Montreal, Quebec, Canada, October 26, 2012 +- 77. Hall RCW, Hall RCW: Chechen Terrorists: Quick Overview. Meridian Club, Maitland, FL, May 8, 2013 +- 78. Sorrentino R, Hatters-Friedman S, Jain A, Hall RCW: The Mentally III and Guns: A Perfect Target? American Psychiatric Association, Annual Meeting, Workshop 134, San Francisco, CA, May 22, 2013 +- 79. Hall RCW: Offender Characteristics. Safety Net: Multidisciplinary Investigation and Prosecution of Technology-Facilitated Crimes Against Children. National Center for + +Prosecution of Child Abuse, National District Attorneys Association, Alexandria, VA, June 5, 2013 + +- 80. Hall RCW: Sanity. Defender Summer School, sponsored by Robert Wesley, Public Defender, 9th Judicial Circuit, Orlando, FL, August 6, 2013 +- 81. Hall RCW: Violent Video Games: Brown vs. Entertainment Merchants Association: A Precursor to the Current Debate. Southern Psychiatric Association, Destin, FL, August 19, 2013 +- 82. Myers W, Hall RCW, Scott C: 10 Reasons Why Psychiatrists Should Do Their Own Psychometric Testing. American Academy of Psychiatry and the Law, San Diego, CA, October 24, 2013 +- 83. Kaufman A, Candilis P, Hall RCW, Kolla N, Mossman D: What Should Forensic Fellows Learn About Research? American Academy of Psychiatry and the Law, San Diego, CA, October 26, 2013 +- 84. Hatters Friedman S, Hall RCW, Kenedi C, Knoll J: Not Guilty by Reason of Medication: Your Drugs Made Me Do It. American Academy of Psychiatry and the Law, San Diego, CA, October 27, 2013 +- 85. Hall RCW: What Psychiatrists Need to be Careful of with the Gun Violence Debate. Florida Psychiatric Society, March 29, 2014 +- 86. Hall RCW: Video Game Violence and the Supreme Court. Forensic Psychiatry Conference, Tulane University, New Orleans, LA, April 12, 2014 +- 87. Jain A (chair), Hall RCW, Hatters-Friedman S, Sorrentino R: Mental Illness, Guns, and Public Policy in Symposium 7: Taking Aim at a Loaded Issue: Guns, Mental Illness, and Risk Assessment. American Psychiatric Association, New York, NY, May 3, 2014 +- 88. Hall RCW: Death Penalty Ramifications of Hall v. Florida. Southern Psychiatric Association, New Orleans, LA, September 12, 2014 +- 89. Hatters Friedman S, Wisner K, Jain A, Glezer A, Hall RCW: Ethics and Forensics in the Treatment of Pregnant Women. Workshop, American Academy of Psychiatry and the Law, Chicago, IL, October 26, 2014 +- 90. Hall RCW: Competency. University of Central Florida's Learning Institute for Elders (LIFE) program, Orlando, FL, January 13, 2015 +- 91. Hall RCW: Death Penalty: Hall v. Florida. Florida Psychiatric Society's Forensic Luncheon, Orlando, FL, April 18, 2015 +- 92. Hall RCW: What Psychiatrists need to know about Ebola. Alabama Psychiatric Physicians Association, Montgomery, AL, April 24, 2015 + +- 93. Hall RCW: Presidential Address: What We as Psychiatrists Need to be Careful of with the Gun Violence Debate: An Update. Southern Psychiatric Association, Chattanooga, TN, October 3, 2015 +- 94. Hall RCW, Cooke B, Johnston L, Strauss A: Forensics in Florida: Hot Topics for the Sunshine State. Panel. American Academy of Psychiatry and the Law, Ft. Lauderdale, FL, October 23, 2015 +- 95. Hall RCW, Piel J, Wall B: AMA Resolutions which Focused on Corrections. Panel. American Academy of Psychiatry and the Law, Ft. Lauderdale, FL, October 24, 2015 +- 96. Hall RCW, Hatters Friedman S: Using Star Wars to Teach Psychopathology. American Psychiatric Association, Atlanta, GA, May 16, 2016 +- 97. Jain A, Hall RCW, Hatters Friedman S, Sorrentino: Sex Ed: A Psychiatric Primer on Managing Patients' Sexual Behaviors. American Psychiatric Association, Atlanta, GA, May 17, 2016 +- 98. Hall RCW. When the Toxicology Screen is Not Enough. Panel. American Academy of Psychiatry and the Law, Portland, OR, October 30, 2016 +- 99. Hall RCW. Physician Wellness. Seminole County Medical Society, Longwood, FL, October 15, 2016 +- 100. Hall RCW. Florida Political & Legislative Update. Seminole County Medical Society, Altamonte Springs, FL, February 21, 2017 +- 101. Hall RCW. Competency. Barry Law School's Health Law Society, Orlando, FL, March 30, 2017 +- 102. Hall RCW. Divorce and Domestic Violence. Florida Psychiatric Society, Orlando, FL, March 31, 2017 +- 103. Hall RCW. Posttraumatic Stress Disorder: Diagnosis and Application in Criminal Court. 2017 Federal Criminal Practice Seminar, Orlando, FL, April 6, 2017 +- 104. Hall RCW (chair), Hatters Friedman S (co-chair), Wagoner R, Sorrentino R, Jain A, Cooke B. Boundary Violations in Correctional Settings. American Psychiatric Association's Annual Meeting, San Diego, CA, May 22, 2017 +- 105. Hall RCW. Video Game Violence. Gang Intervention and Prevention Summit. Florida Gang Investigators Association, Daytona Beach, FL, June 12, 2017 +- 106. Hall RCW. Forensic Issues at Universities. Florida Psychiatric Society, Sarasota, FL, October 7, 2017 + +- 107. Hall RCW (chair), Hatters-Friedman S, Sorrentino R, Jain A: Outpatient Violence Risk Assessment — What Clinicians Need to Know. American Psychiatric Association, New York, NY, May 5, 2018 +- 108. Hall RCW: Marijuana Issues at Universities. The Maitland Men's Club, Maitland, FL, June 29, 2018 +- 109. Hall RCW: Guns, Schools and Mental Illness. Orange County Health Department, Public Health Grand Rounds, August 14, 2018 +- 110. Hall RCW, Hatters-Friedman S, Jain, A, Sorrentino R, Landess J: Current Policy Topics on University Campuses. American Academy of Psychiatry and the Law, Austin, TX, October 27, 2018 +- 111. Greenspan M, Cooke B, Levin A, Hall RCW, Gage B: Forensic Considerations of Treatment When You Haven't Seen the Patient. American Academy of Psychiatry and the Law, Austin, TX, October 28, 2018 +- 112. Hall RCW: Guns, Schools and Mental Health. Florida Department of Health, Cross City, Florida, November 29, 2018 +- 113. Hall RCW: Sanity. Spring Training Mental Health Panel, hosted by Robert Wesley, Public Defender, 9th Judicial Circuit, Barry University Dwayne O. Andreas School of Law, Orlando, FL, March 5, 2019 +- 114. Hall RCW, Sorrentino R, Jain A, Cooke B, Waggoner R: Burnout: Doctors and Lawyers and Other Professionals...Oh My. American Psychiatric Association's Annual Meeting, San Francisco, CA, May 19, 2019 +- 115. Packer S, Hall RCW, Forcen F, Hatters-Friedman S: The Profound and Long-Term Impact of Arkham Asylum on Psychiatry. American Psychiatric Association's Annual Meeting, San Francisco, CA, May 21, 2019 +- 116. Hall RCW: New Controversies or Just a Repeat? Featuring Batman. Indienomicon, Melrose Center, Orlando, June 6, 2019 +- 117. Hall RCW: Retail E-Prescribing is Coming. Florida Psychiatric Society's Leadership Conference, Jensen Beach, FL, June 22, 2019 +- 118. Hall RCW, Kass E: Comic superheroes: A Mental Health Crisis. Florida Psychiatric Society's Annual Meeting, September 20, 2019 +- 119. Kolla N, Candilis P, Parker G. Hall RCW: What Forensic Psychiatrists Need to Know: Recent Research Findings. Workshop. American Academy of Psychiatry and the Law, Baltimore, MD, October 25, 3019 +- 120. Tamburello A. Hatters Friedman S, Hall RCW: Prescribing for Women in Corrections. Panel Discussion. American Academy of Psychiatry and the Law, Baltimore, MD, October 26, 3019 + +- 121. Hall RCW: Parricide: Why Kids Kill Their Parents. Broward County Crime Commission's 51h Annual Juvenile Crime Conference, Delray Beach, November 22, 2019 +- 122. Hall RCW: Trauma in Depth. (PTSD). Ninth Circuit Public Defender's Spring Schedule, Orlando, FL March 2, 2020 +- 123. Hall RCW: PTSD. University of South Florida Department of Psychiatry, Division of Forensic Psychiatry, Tampa, FL, March 20, 2020 (done via online platform due to coronavirus social distancing) +- 124. Hall RCW: Testamentary Capacity. University of South Florida Department of Psychiatry, Division of Forensic Psychiatry, Tampa, FL, March 20, 2020 (done via online platform due to coronavirus social distancing) +- 125. Kass E, Hall RCW, Strauss A. Insanity by Malpractice: A Mock Trial exploring issues of Mental Health in the Justice System. Presenters, Florida Psychiatric Society annual meeting (via online platform due to coronavirus social distancing), September 25, 2020. +- 126. Hall RCW. Battered Women That Kill. Broward County Crime Commission's 4th Annual Societal Violence Webinar, September 30, 2020 +- 127. Hall RCW. The Myth of School Shooters and Psychotropic Medications. Loyola University School of Medicine Grand Rounds, via Zoom, February 11, 2021 +- 128. Hall RCW. Background and Basics of the Official MeToo Movement and Its General Impact. APA virtual Annual Meeting, taped on 03/17/21 +- 129. Hall RCW. The Need For Competency. University of Central Florida College of Medicine, by Zoom, 03/30/21 +- 130. Hall RCW. Panel I Domestic Violence: Why Men Torture Animals to Hurt Spouses and Partners. Broward County Crime Commission's Animal Cruelty Webinar, April 8, 2021 +- 131. Hall RCW: Risk Assessment. University of Central Florida College of Medicine, by Zoom, 04/13/21 +- 132. Hall RCW: PTSD. University of South Florida Department of Psychiatry, Division of Forensic Psychiatry, Tampa, FL, April 22, 2021 (done via online platform due to coronavirus social distancing) +- 133. Hall RCW: Testamentary Capacity. University of South Florida Department of Psychiatry, Division of Forensic Psychiatry, Tampa, FL, April 22, 2021 (done via online platform due to coronavirus social distancing) + +- 134. Hall RCW: Don't Laugh At the Comics: a modern take regarding mental health. Loyola University School of Medicine Grand Rounds, via Zoom. September 2, 2021 + +\* Boldface indicates Ryan C. W. Hall, MD + +#### VIRTUAL LECTURES: + +USMLERX.COM First Aid Step 1 Express Video Review Courses, May 2012 + +- 1. Types of studies +- 2. Clinical trial +- 3. Meta-analysis +- 4. Evaluation of diagnostic tests +- 5. Prevalence vs. incidence +- 6. Odds ratio vs. relative risk +- 7. Precision vs. accuracy +- 8. Bias +- 9. Statistical distribution +- 10. Statistical hypotheses +- 11. Error types +- 12. Power (1 —(3) +- 13. Standard deviation vs. standard error +- 14. Confidence interval +- 15. t-test vs. ANOVA vs. X2 +- 16. Correlation coefficient (r) +- 17. Disease prevention +- 18. Reportable diseases +- 19. Leading causes of death in the United States by age + +- 20. Health care payment +- 21. Core ethical principles +- 22. Informed consent +- 23. Exceptions to informed consent +- 24. Consent for minors +- 25. Decision-making capacity +- 26. Written advance directive +- 27. Confidentiality +- 28. Exceptions to confidentiality +- 29. Malpractice +- 30. Good Samaritan law +- 31. Ethical situations +- 32. Apgar score +- 33. Low birth weight +- 34. Early developmental milestones +- 35. Piaget's stages of cognitive development +- 36. Tanner stages of sexual development +- 37. Changes in the elderly +- 38. Grief +- 39. Kiibler-Ross grief stages +- 40. Stress effects +- 41. Sexual dysfunction +- 42. Body-mass index (BMI) +- 43. Sleep stages + +- 44. REM sleep +- 45. Narcolepsy +- 46. Circadian rhythm +- 47. Intelligence quotient +- 48. Simple learning +- 49. Classical conditioning +- 50. Operant conditioning +- 51. Reinforcement schedules +- 52. Transference and countertransference +- 53. Freud's structural theory of the mind +- 54. Oedipus complex +- 55. Social learning +- 56. Erikson's Stages of Psychosocial development +- 57. Ego defenses +- 58. Infant deprivation effects +- 59. Child abuse +- 60. Child neglect +- 61. Anaclitic depression (hospitalism) +- 62. Regression in children +- 63. Childhood and early-onset disorders +- 64. Pervasive developmental disorders +- 65. Neurotransmitter changes with disease +- 66. Orientation +- 67. Amnesia types + +- 68. Delirium +- 69. Dementia +- 70. Hallucination vs. illusion vs. delusion vs. loose association +- 71. Hallucination types +- 72. Schizophrenia +- 73. Delusional disorder +- 74. Dissociative disorders +- 75. Manic episode +- 76. Hypomanic episode +- 77. Bipolar disorder +- 78. Major depressive episode +- 79. Sleep patterns of depressed patients +- 80. Atypical depression +- 81. Electroconvulsive therapy (ECT) +- 82. Risk factors for suicide completion +- 83. Panic disorder +- 84. Specific phobia +- 85. Obsessive-compulsive disorder (OCD) +- 86. Post-traumatic stress disorder +- 87. Generalized anxiety disorder +- 88. Malingering +- 89. Factitious disorder +- 90. Somatoform disorders +- 91. Personality + +- 92. Cluster A personality disorders +- 93. Cluster B personality disorders +- 94. Cluster C personality disorders +- 95. Keeping "schizo" straight +- 96. Eating disorders +- 97. Gender identity disorder +- 98. Substance dependence +- 99. Substance abuse +- 100. Substance withdrawal +- 101. Signs and symptoms of substance abuse +- 102. Heroin addiction +- 103. Alcoholism +- 104. Delirium tremens (DTs) + +APA On Demand, March 30, 2020 + +- 1. The Good, the Bad, and the Ugly: Anabolic Androgenic Steroid (AAS) Use Depicted in Comics/Using Comics to Teach: Workshop Exercise + +MEDIA: + +- 1. Time Magazine, Definition, Diagnosis, and Forensic Implications of Postconcussional Syndrome, May 16, 2005 +- 2. Reach MD XM Radio, Pedophilia (Types and Classifications, Profile of Victims of Pedophilia, Treatment for Pedophiles and their Victims, and Pedophilia Research), May 14, 2007 +- 3. MD Consult. Doug Kaufman. Joint telephone interview with Richard C. W. Hall, MD, Pedophilia. May 2, 2007 +- 4. The Korean Broadcasting System, KBS Special, Pedophilia. March 11, 2008. +- 5. Tony Pipitone, WKMG-TV Channel 6, Mothers Who Kill Their Children. October 28, + +2008. + +- 6. J. L. Webb. Orlando Medical News. Cyberchondriacs. November 13, 2008. +- 7. Fox 35 News, Orlando. Forensic Implications of Casey Anthony case. December 11, 2008. +- 8. Fox 35 News, Orlando. The Casey Anthony Case: DNA Evidence. December 12, 2008. +- 9. Jessica Sanchez, WKMG-TV Channel 6. The Casey Anthony Case: Baker Act and Stressors. January 23, 2009. +- 10. Nam Nae Won and Jihyun Song. Korea Educational Broadcasting System. Pedophilia. March 30, 2009. +- 11. Keith Landry, Fox 35 News, Orlando. Effects of Stress and Financial Strain. June 15, 2009. +- 12. Heidi Hatch, Fox 35 News, Orlando. Effects of Stress on Families. June 16, 2009. +- 13. Zac Anderson, Sarasota Herald-Tribune. Child pornography. January 8, 2010. +- 14. Florida Psychiatric Society. Brief Conversations with Experts, Public Service Announcement. Legal Competency. January 23, 2010. +- 15. Canadian Broadcasting Corporation, CBC Radio, Up To Speed, with host Margaux Watt, Pedophilia. April 5, 2010. +- 16. Chilean newspaper, Third Voice, phone interview. Pedophiles. April 13, 2010. +- 17. Roberto Schiattino, Caras Magazine, Santiago, Chile: Pedophilia, April 19, 2010 +- 18. Cris Barrish, Delaware News Journal, Pedophiles, June 5, 2010 +- 19. Steve Blow, The Dallas Morning News. Pedophiles. September 2, 2010 +- 20. Karen Lusky, MSN, RN, EliHealthcare.com. Serotonin Syndrome vs. Anticholinergic Syndrome. September 7, 2010 +- 21. http://www.katenagroup.org/expertsspeak/RYAN\_HALL\_MD\_DOMESTIC\_VIOLENC E SEPT2011.mp3 +- 22. Donna Leinwand Leger, USA Today. Misconceptions make sex abuse offenders difficult to detect. November 16, 2011 +- 23. http://www.katenagroup.org/expertsspeak/RYAN\_HALL\_MD\_CHILD\_SEX\_ABUSE\_ NOVEMBER2011.mp3 + +- 24. Renee Stoll. WFTV Channel 9 News. Psychosis/Affect in Potential Violent Crimes. March 30, 2012 +- 25. The Discovery Channel. Wills: Etta James. April 26, 2012 +- 26. Marisol Bello, USA Today. Sandusky child sex abuse case offers important lessons. June 23, 2012 +- 27. Channel 13, Orlando. Stop the Bullying. Town hall symposium. September 18, 2012 +- 28. Brandon Keim, NOVA. Videogames and Violence. January 9, 2013 +- 29. Jo Ciavaglia, Bucks County Courier Times (PA). Anabolic Steroids Withdrawal. January 18, 2013 +- 30. http://www.katenagroup.org/expertsspeak/RYAN\_HALL\_MD\_VIDEO\_GAME\_VIOLE NCE JAN2013.mp3 +- 31. Gwen Knapp, www.sportsonearth.com. General comments on Anabolic Steroids for "Did Oscar Pistorius Have 'Roid Rage?" February 21, 2013 +- 32. Maia Szalavitz, TIME.com. Video games and behavior. July 2, 2013 +- 33. Erin Brodwin, Scientific American. Guns, Schools, and Mental Illness. October 25, 2013 +- 34. Andrew Pollock, New York Times. Ebola (as a bioweapon). August 15, 2014 +- 35. Abigail Ohlheiser, Washington Post. Ebola. October 2, 2014 +- 36. Kelley Beaucar Vlahos, Foxnews.com. Ebola (as a bioterrorist threat). October 3, 2014 +- 37. Rich Zeoli, Talk Radio 1210 WPHT, Philadelphia. Ebola as bioterrorist threat. October 3, 2014 +- 38. Naseem Miller, Internal Medicine News. Ebola. October 3, 2014 +- 39. Amy Ohoheiser. The Washington Post. It's highly unlikely you'll become infected with Ebola, So what are you afraid of? October 5, 2014 +- 40. Laura Evans, WTTG-FOX5 Washington, DC. Ebola. via Skype. October 8, 2014 +- 41. Sue Ambrose, Dallas Morning News. Ebola. October 14, 2014 +- 42. Mackenzie Carpenter, Pittsburgh Post-Gazette. Ebola (Public discussions of). October 15, 2014 + +- 43. Andy Newman, New York Times. Pedophilia. May 6, 2015 +- 44. Wes Judd, Pacific Standard. Teaching Psychopathology in a Galaxy Far, Far Away: The Light Side of the Force. May 27, 2015 +- 45. Tori Walker, The Ledger. Local movie theaters respond to recent attacks with more security. August 18, 2015 +- 46. Michael Greshko, National Geographic. The Real Science Inspired By Star Wars. http://news.nationalgeog raphic.com/2015/12/151209 -star-wars-science-movie-film/ December 9, 2015 +- 47. Adam Hochron, MD Magazine. Using Star Wars to Teach Psychopathology 3. May 16, 2016 +- 48. Elizabeth Bachmann, Catholic News Service. Video games and mass shootings. August 5, 2019 +- 49. Joel Solomon. Tampa Bay Times. Psychiatrists acting in dual roles (forensic expert/treater). January 6, 2020 +- 50. Danielle Prieur, 90.7 WMFE Orlando. COVID-19 testing. March 5, 2020 +- 51. Fox 35 Orlando. On-air medical panel regarding the Coronavirus. March 6, 2020 +- 52. Panelist for Physicians Society of Central Florida's COVID-19 Virtual Town Hall, April 9, 2020 +- 53. Naseem Miller, Orlando Sentinel. Pressure mounts on doctors as COVID-19 hospitalizations climb again. 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b/marker2/ds9/EFTA00090186/EFTA00090186.md @@ -0,0 +1,191 @@ +![](_page_0_Picture_0.jpeg) + +November 1, 2021 + +VIA EMAIL + +![](_page_0_Picture_5.jpeg) + +United States Attorney's Office Southern District of New York 1 St. Andrew's Plaza New York, NY 10007 + +Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) + +Dear Counsel: + +> 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 FX 303.832.2628 www.hmflaw.com JPagliuca@hmflaw.com + +Defendant Ghislaine Maxwell through counsel, submit the following summary pursuant to Fed. R. Crim. P. 16(b)(1)(C). + +### I. EXPERT DISCLOSURE BY THE DEFENSE + +A. Dr. Elizabeth Loftus + +Dr. Loftus is the Distinguished Professor of Psychological Science and Law at the University of California, Irvine School of Law. Dr. Loftus is one of the nation's leading experts on the science of memory. In addition to her experience as an academic and clinical researcher, she has been an expert witness or consultant in hundreds of cases. Her extensive experience and credentials are recited in her curriculum vitae. Exhibit A. + +It is expected that Dr. Loftus, a psychologist who specializes in the study of memory, will focus on the memory aspects of this case. Based on her education, training, experience, and research, her testimony will concern the workings of human memory, the effects of suggestion on memory, the mechanism of creation of false memories, the characteristics of false memories, how memory fades and weakens over time, and how memory becomes more vulnerable to contamination. She will describe scientific research showing that false memories can be + +described with confidence, detail, and emotion, just like true memories. This can occur when people come to believe in these experiences and are not deliberately lying. Dr. Loftus would identify some of the suggestive activities that occurred in the current case. + +Suggestive activities can explain how it is that a person might go from having no memory of sexual abuse, and even denying sexual abuse, to later having "memories" for numerous abusive acts, if the memories are false. She will explain the mechanism by which false and/or distorted memories can be created as a result of post-event information and occurrences, suggestion, influence or the like. She will also testify about the characteristics of false and/or distorted memories. In particular "memories" can be described with confidence, detail and emotion, even when they are false. She will point out some of the suggestive activities that occurred in this case. She will explain how media coverage and other publications (including but not limited to newspaper and magazine articles, news reports, television shows, documentaries, books, podcasts, websites, etc.) and discussions/ conversations with others, can be sources of suggestion. She will explain how, in a case like this one, suggestion can lead individuals to the construction of distorted memories. + +# B. Park Dietz, M.D., M.P.H., PH.D. + +Dr. Park Dietz is a psychiatrist specializing in forensic psychiatry with over 40 years of experience. He has been previously qualified as an expert in psychiatry and forensic psychiatry. + +Dr. Dietz received a bachelor's degree in psychology and biology from the Cornell University College of Arts and Sciences (1970), an M.D. degree from the Johns Hopkins University School of Medicine (1975), a Master's degree in Public Health from the Johns Hopkins School of Hygiene and Public Health (1975), and a Ph.D. in sociology from the Johns Hopkins University (1984). He completed psychiatric residency at the Johns Hopkins Hospital (1975-77) and the Hospital of the University of Pennsylvania (1977-78), where he was Chief Fellow in Forensic Psychiatry. He has been board certified in psychiatry by the American Board of Psychiatry and Neurology since 1979. + +He is a Clinical Professor of Psychiatry and Biobehavioral Sciences at the UCLA School of Medicine. From 1986 to 1989, he was a Professor of Law at the University of Virginia School of Law and a Professor of Behavioral Medicine and Psychiatry at the University of Virginia School of Medicine. From 1982 to 1986, he was an Associate Professor of Law and of Behavioral Medicine and Psychiatry at the University of Virginia Schools of Law and Medicine. From 1978 to 1982, he was an Assistant Professor of Psychiatry at Harvard Medical School. In those positions he taught and lectured on forensic psychiatry for diverse audiences, including law students, practicing attorneys, law enforcement officers, psychiatry residents, forensic psychiatry fellows, and practicing forensic psychiatrists and psychologists. + +He is a Past President of the American Academy of Psychiatry and the Law, a Distinguished Life Fellow of the American Psychiatric Association, and a Fellow of the American Academy of Forensic Sciences. He has served on the editorial boards of the Bulletin of the American Academy of Psychiatry and the Law, the Journal of Forensic Sciences, Behavioral Sciences and the Law, the Journal of Threat Assessment and Management, and other professional publications. He has authored more than 100 articles and book chapters, primarily on forensic psychiatry. + +He has conducted more than 1,000 evaluations of persons charged with crime and, in his role as President of Park Dietz & Associates, Inc., has evaluated or supervised over 1,000 evaluations of allegations of sexual victimization. He has testified as an expert witness in forensic psychiatry on hundreds of occasions, including testimony in criminal matters in federal courts throughout the U.S. and the trial courts of nearly every state. + +Dr. Dietz will be qualified as an expert in the areas of psychiatry and behavioral science. Dr. Dietz's curriculum vitae is attached as Exhibit B. Attached as Exhibit C is a list of material reviewed by Dr. Dietz. + +His testimony may include, but will not be limited to, the following: + +### a. Opinions about Dr. Rocchio's Disclosed Opinions + +The first use of the word "grooming" to refer to strategies that sometimes enable nonforceful, nonthreatening, and nonviolent sexual victimization of minors was the proposition that "the perpetrator involves children in sexual abuse through a grooming process in which a combination of kindness, attention, material enticement, special privilege, and coercion are expertly applied" (Conte, 1984, p. 558). Since then, this usage has been widely adopted by social scientists, clinicians, journalists, and others. But this usage has some unintended consequences that threaten the integrity of the adjudicative process, including these: + +- (1) Because use of the term "grooming" commonly assumes that the grooming party is intentionally using these strategies to gain sexual access to children, to abuse them, and to prevent them from disclosing the abuse, the word "grooming" has acquired meaning beyond an objective description of behaviors; it imputes motive and intent without adequate evidence of either. +- (2) In the litigation context, "when `grooming' is applied to such common and desirable behaviors as being kind or attentive or helpful or caring, there is considerable risk of misleading the fact finder into believing that these latter behaviors are well established predictors of child sexual abuse," when they are not. Park Dietz, Grooming and Seduction, 33 J. Interpersonal Violence, 28, 31 (2018). Dr. Rocchio characterizes "grooming" as "a strategic pattern of behavior[] ... that can take a variety of forms and function to render the victims vulnerable to abuse, to obscure the nature of the abuse, and to build trust and attachment with their abuser." This vague opinion about "grooming" carries the risk of imputing motive and intent to the Defendant, when the determination of motive and intent is a task for the fact finder charged with determining the credibility of witnesses, the weight of the evidence, and the ultimate issues. Moreover, this opinion carries the risk of implying that innocuous and even desirable behaviors are associated with nefarious or criminal conduct. + +Moreover, grooming has no consistent definition, and concerns have been raised that "there is no valid method to assess whether grooming has occurred or is occurring." Natalie Bennett & William O'Donohue, The Construct of Grooming in Child Sexual Abuse, 23 J. Child Sexual Abuse 957, 974 (2014). + +In any particular population of alleged victims, patients, or plaintiffs—including those whom Dr. Rocchio has treated or evaluated—the determination of whether grooming has occurred is a subjective judgment hinging largely on the credibility of the individuals. Such judgments have no known error rate and cannot be tested, verified, or reproduced. + +Although the Government's Expert Notice regarding Dr. Rocchio's proposed testimony is silent as to whether she is expected to impute a theory of "grooming-by-proxy" to the Defendant, it is important to note that there is no generally accepted theory of grooming by third parties or empirical evidence regarding the prevalence, characteristics, or mechanisms of such a phenomenon. Ms. Maxwell is not accused of soliciting or enticing sexualized massages for herself. Instead, the claim appears to be that Ms. Maxwell recruited and groomed minors to provide sexualized massages for Mr. Epstein, which would amount to grooming-by-proxy. + +Dr. Dietz is aware of no authority—no journal articles, no studies, no tests, nothing—to support a theory of grooming-by-proxy. Such a theory has not gained any acceptance (let alone general acceptance) in the relevant community; it has not been peer-reviewed; it has not and cannot be tested; and there is no known or potential rate of error. + +Dr. Rocchio's opinion that "[i]ndividuals with particular vulnerabilities are often targeted by perpetrators of sexual abuse" is a commonly accepted bit of clinical lore derived from the frequent observation of highly vulnerable children among those children who allege sexual abuse, but it is not based on empirical data regarding the likelihood of abuse among children with varying degrees of vulnerability. To the extent that less vulnerable children, such as those with intact families, attentive parents, good social support, little psychopathology, less prior trauma, no substance use, and higher resilience are less likely to allege abuse than the more vulnerable, the generalization could be proved weak or false, if only there were such empirical data. And even if there were such data, it would be important to devise a means of verifying that abuse did occur to those who allege it, which is a difficult task at best because of the pains so many abusers take to avoid confession, witnesses, or physical evidence. The clinical, criminal justice, and forensic populations from which the observation of prevalent vulnerabilities is derived—including those clients whom Dr. Rocchio has treated or evaluated—rarely represent groups in which all allegations of abuse have been verified by confession, witnesses, physical evidence, or other means. + +Other opinions put forth in the disclosure of Dr. Rocchio's proposed testimony also rest on assertions that are untestable, cannot be reproduced, and have no known error rate. + +# b. Opinions About Hindsight Bias + +Hindsight bias must be considered when evaluating sex abuse allegations and or "grooming behavior." Many claims of sexual abuse of minors involve behaviors that are, in + +hindsight, labeled "grooming" or otherwise imputed as knowledge to onlookers. Hindsight bias refers to the tendency to overestimate how predictable or foreseeable an event is after being informed about the outcome of an event. Simply put, knowledge of the outcome of the event, i.e. Epstein pleaded guilty to having sexual contact with post-pubescent minors, makes the importance of pre-conviction behaviors obvious. Retrospective judgments about the predictability or foreseeability of the outcome are systemically inflated or biased compared to judgments made without information about the outcome. Hindsight bias refers to the tendency to overestimate how predictable an event is after learning the outcome of the event (Fischhoff, 1975). For example, after a political election, people believe their pre-election estimates of the outcome were closer to the outcome than they actually were (Blank, Fischer, & Erdfelder, 2003). Hindsight bias has been discussed in over 800 scholarly articles across a variety of different domains including medicine, financial decision making, consumer satisfaction, and within the legal domain (see Roese & Vohs, 2012; Arkes, 2013; Strohmaier et al., 2021) and using a variety of different experimental designs (Pohl & Erdfelder, 2016) and a variety of different stimuli such as written vignettes, visual stimuli (e.g., Bernstein & Harley, 2007), and auditory stimuli (e.g., Bernstein, Wilson, Pernat, & Meilleur, 2012). Even individuals with specialized training and expertise succumb to hindsight bias (Musch & Wagner, 2007). One notable study detected hindsight bias among actual judges making civil liability decisions, in which judges with outcome knowledge perceived the harm to be significantly more foreseeable than judges who did not receive outcome information and were thus more likely to render a finding of negligence (Oeberst & Goeckenjan, 2016). Another notable study detected hindsight bias in a sample of mental health professionals who gauged the dangerousness of a psychiatric patient; again, outcome knowledge affected the reported dangerousness and predictably of harm posed by the patient (Beltrani et al., 2018). + +Hindsight bias affects legal judgments. Civil or criminal prosecutions related to events occurring decades ago may be compromised by this bias in many ways, from the investigation either ignoring evidence or attributing significance in hindsight—through the presentation of evidence, to the deliberation of any factfinder. Awareness of the impact of the hindsight bias should temper any claims that so called "grooming" behaviors should have been noticed and either reported or avoided and that failing to do so constitutes knowledge or intent. + +### c. Opinions Related to the Halo Effect + +The term "Halo effect" was coined by Thomdike (1920) a century ago. The Halo effect is a cognitive bias in impression formation whereby the positive evaluation of one characteristic has a radiating effect on how other, non-related characteristics of the individual are evaluated. For example, one classic study found that physical attractiveness influenced evaluations of the target's personality, life satisfaction, and expected future personal and occupational success despite the fact that no information about any of these attributes was provided (Dion et al., 1972). Physical attractiveness has also been found to influence culpability judgments, with attractive individuals being held less-responsible than unattractive individuals (Dion, 1972; Efran, 1974). Halo effects have been found to be cued by factors other than attractiveness, such as the described status of the target (Wilson, 1968), the name of the target (Harari & McDavid, 1973), and even one's mood when evaluating the target (Forgas, 2011). Studies have documented halo effects when making diagnoses of psychopathology, such that symptoms of one mental disorder influence the interpretation of other symptoms indicative of other mental disorders and vice versa (see e.g., DeVries, Hartung, & Golden, 2017). + +Halo effects are a means to achieving cognitive consistency, which roughly refers to a state in which attitudes, perceptions, beliefs, predictions, and thoughts are aligned. Cognitive consistency serves many important goals. As noted by Read and Simon (2012), cognitive consistency is "essential for reasons of parsimony and economy of effort, as well as to allow for the predictability of, and hence adaptability to, subsequent encounters" (p. 67). Indeed, the noted psychologist Leon Festinger "was convinced that the psychological need for cognitive consistency is as basic as hunger and thirst" (Gawronski, 2012, p. 652). But because the world is often not so neat, orderly, or unequivocal, humans engage in complicated reasoning processes to impose consistency. These processes involve bi-directional reasoning in which "decisions follow from evidence, and evaluations of the evidence shift toward coherence with the emerging decision" (Simon, Snow, & Read, 2004, p. 814; Greenspan & Scurich, 2016). As a result, perceptions and decisions become highly skewed toward one interpretation while alternatives are neglected or dismissed, hence consistency is achieved. This reasoning process occurs unconsciously, i.e., outside conscious awareness, and is not intentional self-deception. + +Halo effects can have serious practical consequences. As noted by Forgas and Laham (2016): + +Once unjustified initial expectations are formed about a person, they can easily become self-perpetuating with serious implications for how a target is treated. If we expect a person to have positive characteristics, we may selectively look for and find such features from the rich array of information available (a self-fulfilling prophecy), and positive impressions may in turn lead to preferential treatment in a range of domains: + +interpersonal relations, the work place, the health and legal systems, and even for decision making and consumer choices. (p. 286) + +Like many people who achieve great power and wealth, Jeffery Epstein exploited the Halo effect to surround himself with people who would serve his needs. At the most primitive level, his wealth attracted those seeking for themselves some of what he had. At the most sophisticated level, others with halos of their own—through any combination of power, influence, fame, brilliance, attractiveness, social standing, or other positive characteristics—mingled with Epstein for reasons of their own, and being seen in their company empowered him and made him look above suspicion. In a videotaped interview with Steve Bannon, Epstein differentiated between different kinds of power—such as Bill Clinton's political power, wrestlers' and weight lifters' physical power, and Gerry Edelman's intellectual power—and acknowledged that he gravitated to people of power. [CONFIDENTIAL] SDNY\_GM\_SUPP\_00219000.mov. + +The materials reviewed reflect that Jeffrey Epstein was a brilliant man who was flawed by enduring personality traits familiar to psychiatrists as "Cluster B personality traits," found among those with antisocial, narcissistic, borderline, and histrionic personality disorders. + +American Psychiatric Association, Diagnostic and Statistical Manual of Mental Disorders, 5th Ed., Arlington, VA: American Psychiatric Association (2013), pp. 659-672. These flaws allowed him to use his brilliance to manipulate people to do his bidding and to compartmentalize people into isolated cells in which none had complete information about his activities. These were not his only flaws, and Dr. Dietz is also prepared to address Jeffrey Epstein's sexual behavior should it prove relevant. + +#### d. Opinions Related to the Multiple Pathways to False Sex Assault Allegations + +Studies concerning the accurate reporting of alleged sexual assaults undermine the assertions made by Dr. Rocchio to the extent they are based on uncorroborated allegations and are also otherwise relevant here. False allegations of sexual assault do occur, and there are multiple pathways to these false allegations of sexual assault. + +Not all allegations of sexual assault are true. Unfortunately, there has been little work on understanding the prevalence of false allegations or pathways to these, particularly in a sample most relevant to a jury—currently adjudicated cases. A peer reviewed journal article has proposed 11 pathways to false allegations of sexual assault: (a) lying, (b) implied consent, (c) false memories, (d) intoxication, (e) antisocial personality disorder, (t) borderline personality disorder, (g) histrionic personality disorder, (h) delirium, (i) psychotic disorders, (j) dissociation, and (k) intellectual disability. Jessica Engle and William O'Donohue, Pathways to False Allegations of Sexual Assault, 12 J. Forensic Psychology Practice, 97. These pathways originate in the psychological proclivities or state of the individual making these false allegations. The descriptions of these pathways that follow include material drawn nearly verbatim from the article by Engle and O'Donohue (2012), which was published before the latest edition of the Diagnostic and Statistical Manual of Mental Disorders but nonetheless remains accurate in characterizing certain personality disorders. + +Ly\_int : Lying involves the alleged victim knowingly making a false claim of sexual assault. Humans do lie, and their lies can be difficult to detect. Often, humans lie because of what they perceive as the favorable consequences for lying; for sexual assault these consequences could be: + +- I. the severe negative consequences that the alleged perpetrator experiences, +- 2. secondary gain from victim status, +- 3. excusing behaviors or characteristics of the alleged victim (e.g., sexual activity, pregnancy, sexually transmitted diseases) +- 4. financial gain. + +Implied Consent: A fact finder's determination of whether consent was competently given is often problematic, and some allegations are regarded as unfounded or false based on determinations regarding consent before cases reach the stage of adjudication. A false allegation can arise when it was reasonable to believe consent was given but the alleged victim falsely believes that it was not. + +False Memory: The existence and prevalence of repressed memories is a source of controversy, and yet research does exist demonstrating the successful implantation of fabricated memories. In one of the first studies on the implantation of false memories, participants were given short narratives of childhood experiences, purportedly obtained from relatives, and asked to try to remember these experiences. Research by Elizabeth Loftus has revealed how subtle information introduced after an event may alter the memory of that event. Loftus and her students have conducted more than 200 studies with more than 20,000 participants demonstrating how misinformation introduced after an event can induce people into creating false memories. + +Intoxication: Intoxication can substantially increase the likelihood of a false allegation of sexual assault. Alcohol and other intoxicants pose a significant problem in sorting out the validity of a sexual assault allegation. The information-processing errors induced by intoxicating substances may cause confusion surrounding events that occurred while a person was intoxicated. A person who does not accurately recall events that occurred while he or she was under the influence or while experiencing the side effects of withdrawal from a substance may attempt to make sense out of the disjointed and seemingly incoherent memories of events that occurred while intoxicated. In an effort to make sense of and organize what memories are intact, a person may confabulate or fill in the memory lapses with events that seem probable or which for some reason they come to believe "must have" taken place. + +Antisocial Personality Disorder: The essential feature of antisocial personality disorder is a pervasive pattern of behavior that disregards and violates of the rights of others. It often begins in early childhood or early adolescence and continues into adulthood. If an individual with antisocial personality disorder is likely to lie to achieve power and pleasure, a false allegation of sexual assault might be the means by which he or she attempts to achieve power over the falsely accused. Falsely claiming someone sexually assaulted you can be an aggressive act and a lack of remorse could allow the individual to file an allegation of sexual assault and maintain this allegation with few, if any, conflicts of conscience. Thus, a pathway to a false allegation of sexual assault can occur when an individual with antisocial personality disorder makes a false claim of assault. + +Borderline Personality Disorder: Borderline personality disorder (BPD) is a serious mental condition characterized by affective dysregulation, impulsiveness, difficulties in interpersonal relationships, and difficulties with self-image. Of particular note is the rapid switching from idealization to devaluation, impulsivity, and manipulative features of borderline personality disorder. The instability of relationships experienced by an individual with BPD may be rooted in the tendency to quickly switch from idealizing significant others or lovers to devaluing them. This sudden change in conceptualization of a partner is often caused by feeling that the partner is not caring enough or giving enough or by suspicion of abandonment. The rapid shifting between idealizing and demonization may bring about a change in perspective such that a relationship that was viewed idealistically in the past is now seen through the devalued lens of abuse or mistreatment. Past events then may become construed as "abuse" and may lead a person with BPD to believe he or she is a victim of sexual assault. Previous research has found that two of the three major motivations to file a false allegation of rape were attention-seeking and revenge. The switch from idealization to devaluation of the relationship and/or relationship partner may spur a desire for revenge for any past behaviors that are, in the devaluation phase, newly construed as mistreatment. Also, there is some evidence that individuals with BPD engage in behaviors that are viewed as "manipulative." Manipulative behaviors are often outside the conscious awareness of the individual and are learned through positive reinforcement, as manipulation frequently results in positive outcomes for the manipulator. Thus, an individual with BPD may use a sexual assault allegation as a way of impacting a third party for some desired outcome. + +Histrionic Personality Disorder: Diagnostic criteria for histrionic personality disorder include: 1) feeling uncomfortable in situations in which he or she is not the center of attention; 2) interactions with others are often characterized by inappropriate sexually seductive or provocative behavior; 3) displaying rapidly shifting and shallow expressions; 4) consistently uses physical appearance to draw attention to the self; 5) has a style of speech that is excessively impressionistic and lacking in detail; 6) shows self-dramatization, theatricality, and exaggerated expression of emotion; 7) is suggestible (i.e., easily influenced by others or circumstances), and 8) considers relationships to be more intimate than they actually are. Other relevant behaviors include the tendency to play out stereotyped roles in their relationships with others; an intense desire for novelty and excitement; and the upset and depression that may follow periods in which they received little attention. Filing a false allegation of sexual assault may serve to benefit individuals with histrionic personality disorder in several important ways. The sexualized behavior of individuals with histrionic personality disorder can lead to sexual relationships that may be used to seek attention (e.g., having sex with a person and telling all of their friends about it). Filing a false sexual assault claim may regain lost attention, either from the desired partner or from other individuals, providing a novel and exciting environment that may be stimulating to a person who is histrionic. They may enjoy the large amounts of attention received for filing a sexual assault charge and for the "victim" role that can be played out in other relationships (a dynamic also common in false allegations by those with borderline personality disorder). In times when attention is not being received to the desired level, a false allegation of sexual assault may help to pull individuals with histrionic personality disorder out of their depressed state. + +Delirium: Delirium is a disturbance of consciousness that is accompanied by a change in cognition that cannot be better accounted for by a preexisting or evolving dementia. Relevant to this pathway are the perceptual disturbances that may be present, including misinterpretations, illusions, or even hallucinations. Many substances induce delirium, particularly in excessive doses. + +Psychotic Disorders: The term psychotic generally refers to conditions that are marked by delusions, hallucinations, or markedly illogical thinking. Such conditions cause gross impairments in functioning. Studies investigating the content of delusions have found delusions that are sexual in nature are not uncommon and occur more often in women than in men. Some cases of sexual delusions have been documented. These delusions may lead a person to claim adamantly that sexual relations or events occurred that may be impossible or highly improbable. + +Dissociation: Dissociation is `the lack of the normal integration of thoughts, feelings, and experiences into the stream of consciousness and memory. Dissociation involves a disruption or splitting off of memory, personality, identity, consciousness, or general perceptions of the self and surroundings; it can be recurring, gradual, or transient. It is likely associated with memory distortions. Thus, it is possible that in the event of a sexual assault, dissociation may cause a person to fill in the parts of the experience that are not clearly remembered with events that for them feasibly could have occurred. Of course, memory lapses will not necessarily be filled in with a confabulated event, let alone a sexual one. However, individuals who dissociate at a high frequency may seek to make their stories more coherent by adding details to an incomplete memory that would make sense to them when considered in the context of the event. Thus, these confabulations may lead to erroneous claims that have forensic relevance, including who the perpetrator was, what happened, where, and how many times. + +Intellectual Disability: Intellectual disability, is characterized by below average IQ and adaptive functioning. Limitations in functioning include deficits in the acquisition of social, occupational, academic, and general self-care skills. Intellectual disability has several etiologies that often are related to biological or pathological processes affecting the central nervous system. Many of the specific vulnerabilities that arise from intellectual disability overlap to some extent with other disorders (e.g., autism spectrum disorders, cerebral palsy, fetal alcohol syndrome) and individuals with other developmental disabilities may also have intellectual disability. Intellectually disabled individuals, compared to individuals without ID, have vulnerabilities related to memory and communication that the legal system may not be equipped to handle adequately. Individuals with moderate-to-profound ID may have significant difficulty communicating about the events that occurred because of language skills deficits or other communication-interfering conditions (e.g., related neurological conditions). Research findings indicate that communications skills are essential in filing a sexual assault charge; alleged victims with mild ID were more likely than individuals with moderate or severe ID not only to file sexual assault charges but to have their allegations confirmed. Difficulties with memory may also complicate the investigation process for individuals with ID. + +Changes in the core details of the allegation are often used by professionals as indices in determining the credibility of a victim's claims. Peace and colleagues (2015) conducted a narrative analysis of 147 sets of allegations of sexual assault across short (3 month) and long (6 month) intervals since the alleged event took place. In reviewing the existing literature, Peace and colleagues found that genuine traumatic experiences have a demonstrable resiliency to drastic impairments in recall. However, some inconsistencies especially in less core matters are to be expected due to some less important details fading or varying over time. In examining their sample of 147 allegations, the researchers discovered that truthful allegations contained more detail relative to false allegations at each of the assessment intervals. Specifically, the researchers found that fabricated allegations of traumatic experiences contained more inconsistent details both at 3 months and 6 months. The total amount of detail for each type of allegation (true or false) does tend to decrease over time. Additionally, as these figures suggest, the researchers found that the number of details present in genuine reports continued to decrease over time whereas fabricated stories `levelled off in detail. + +Hunt and Bull (2012) reviewed signs that can be used to differentiate true allegations of sexual assault from false ones and concluded that the literature did not support the hypothesis that emotional distress was predictive of the truthfulness of the allegation. This is consistent across the literature, and emotional distress (e.g., crying) is not regarded as a reliable predictor of the accuracy or truthfulness of an allegation. Additional research is needed, but at this point there is little empirical support to indicate that being emotionally upset, distressed, or crying while reporting an assault indicates that the report is more likely to be true. This is likely due to the fact that such reactions can also occur in false allegations for various reasons, including a false memory or an attempt to mislead by those who know this sort of reaction would be expected of a true allegation. + +Individuals who have been sexually assaulted have higher rates of mental disorders than individuals who have not been sexually assaulted, and this includes significantly higher rates of post-traumatic stress disorder, depression, bipolar disorder, drug use disorders, and alcohol use disorders. Emily R. Dworkin, Risk for Mental Disorders Associated with Sexual Assault: A Meta-Analysis, 21 Trauma, Violence, & Abuse (2020), pp. 1011-1028. Any of these mental disorders that occur more frequently among those who have been sexually assaulted can affect memory and recall, requiring assessment on a case-by-case basis. + +Varying degrees of post-traumatic stress symptomatology occur in significant proportions of victims following sexual assault and last for varying durations. Emily R. Dworkin, Anna E. Jaffe, Michele Bedard-Gilligan, and Skye Fitzpatrick, PTSD in the Year Following Sexual Assault: A Meta-Analysis of Prospective Studies, Trauma, Violence, & Abuse (2021) https://doi.org/I0.1177/15248380211032213. A substantial number of people never fully remit from their PTSD even after many years, and variables associated with a longer time to remit from an episode of chronic PTSD include a history of alcohol abuse and a history of childhood trauma. Caron Zlotnick, Meredith Warshaw, et al., Chronicity in Posttraumatic Stress Disorder (PTSD) and Predictors of Course of Comorbid PTSD in Patients with Anxiety Disorders,12 J. Traumatic Stress (1999), 89-100. + +Symptoms of PTSD include distressing memories of the event; intense or prolonged psychological distress at exposure to cues that symbolize or resemble an aspect of the traumatic event; marked physiological reactions to cues that symbolize or resemble an aspect of the traumatic event; avoidance or efforts to avoid distressing memories, thoughts, or feelings about or closely associated with the traumatic event(s); and avoidance of or efforts to avoid external reminders (people, places, conversations, activities, objects, situations) that arouse distressing memories, thoughts, or feelings about or closely associated with the traumatic event(s). American Psychiatric Association, Diagnostic and Statistical Manual of Mental Disorders, 5th Ed., Arlington, VA: American Psychiatric Association (2013), pp. 271-272. Individuals with any of these symptoms are particularly unlikely to engage in continued communication or friendly gestures with an alleged perpetrator, to wear clothing provided by an alleged perpetrator, or to unnecessarily recreate a sexual assault event, any of which would be expected to elicit intense distress. + +C. Dr. Ryan Hall + +Dr. Hall's curriculum vitae is attached as Exhibit D. His report is attached as Exhibit E. Attached as Exhibit F is a list of material reviewed by Dr. Hall. + +Dr. Hall is an expert in the field of forensic psychiatry and will offer opinions as such. He will offer the opinions and diagnoses contained in his report. the bases for those opinions, and the significance of the diagnoses and opinions. + +D. Bennett Gershman + +Professor Gershman is a Distinguished Professor of Law at the Elisabeth Haub School of Law of Pace University since its founding as the Pace Law School in 1976. He has also taught as a visiting professor at Cornell Law School and Syracuse Law School. Prior to coming to Pace, he was a prosecutor in the Manhattan District Attorney's Office and the New York State Anti-Corruption Office. Professor Gershman's extensive scholarship has had an essential role in establishing the study of prosecutorial misconduct, a subject at the intersection of criminal procedure and professional ethics. He is a leading authority on prosecutorial misconduct and the author of the treatise, Prosecutorial Misconduct, a preeminent resource for scholars and practitioners. + +We expect Professor Gershman to provide testimony on best practices to ensure the integrity of any prosecution, focusing on investigation, witness preparation, media contact, neutrality, obligations to provide accurate information, and relationship with crime victims, their counsel, and case-related civil litigation. His extensive experience and credentials are recited in his curriculum vitae, annexed as Exhibit G. + +E. Robert Kelso + +Mr. Kelso is CEO of Forensic Pursuit. He has over 25 years of experience in computer forensics, engineering and software technology. He holds Bachelor's and Master's degrees from University of Colorado at Boulder in aerospace engineering and astrodynamics, respectively. He is currently an adjunct professor at University of Denver teaching computer forensics at the Master's level. He holds multiple computer forensics certifications including EnCE, CHFI, ACE and AME. His curriculum vitae is attached. Exhibit H. Mr. Kelso has previously testified in federal and state courts as an expert witness in computer forensics and has been appointed a "special master" by the court on multiple occasions. + +We anticipate that Mr. Kelso will testify about the user data associated with certain devices seized and searched by the government's team in this case, documents and photographs extracted from certain of those devices, and the metadata associated with certain documents and photographs. He may also testify generally about computer forensic principles associated with the creation of documents, storage and retrieval of digital documents and photographs, including November 1, 2021 + +Page 13 + +the limits to the information that can be gleaned from the metadata. Mr. Kelso may testify in rebuttal to any testimony offered by the government through M=. As trial preparation proceeds, the defense will update the topics for Mr. Kelso if any arise. + +F. + +was a Special Agent with the United States Department of the Treasury, Internal Revenue ServiceCriminal Investigation ("IRS-CI") for over twenty-five years. During his tenure at IRS-CI, led the New York Asset Forfeiture Task Force and participated in numerous criminal investigations involving complex fraud, corruption, bribe evasion, money laundering, and asset forfeiture. Since retiring from the IRS in 2013, has worked as a financial investigator and consultant for several private investigation companies and government enforcement agencies. He current) runs his own private financial investigation and consulting company called JDL Services, Inc. holds a bachelor's degree in Business Administration, Accounting and Finance from Pace University. His curriculum vitae is attached as Exhibit I. + +It is expected that will testify about his review of certain financial records provided by the government in discovery. Specifically, will discuss various transfers of funds that are reflected in the financial records and explain the information contained in the financial records regarding those transfers.' + +G. Gerald LaPorte + +Mr. LaPorte is a Forensic Chemist and Document Dating Specialist with the firm Riley Welch LaPorte &Associates Forensic Laboratories. He currently is the Director of Research Innovation for Florida International University, Global Forensic and Justice Center. Prior to that, he was the Director of the U.S. Department of Justice, National Institute of Justice, Office of Investigative and Forensic Sciences. He has testified as an expert witness in numerous cases and has multiple professional honors in this field. His curriculum vitae is attached. Exhibit J + +Defendant anticipates the receipt of documents produced by the government and documents received ursuant to defense subpoena included but not limited to . These documents may require analysis regarding the dates of creation, completeness, alteration and manipulation. When these documents are disclosed, Defendant will seek to have them analyzed and present testimony on the analysis as needed. + +&#x27; The defense does not believe that the Court needs to ualif as an expert to offer the proposed testimony. Nevertheless, we hereby notice as a potential expert witness in an abundance of caution. + +#### H. Jennifer Naso + +Ms. Naso is a Forensic Document Examiner who worked for and received specialized training from the United States Secret Service as a Document Analyst. Ms. Naso has a Master's of Science in Forensic Science and a Bachelor of Arts in Psychology. She has over 15 years of experience examining and determining authorship and authentication of documents. Her curriculum vitae is attached as Exhibit K. + +Defendant anticipates the receipt of documents roduced b the overnment and pursuant to defense subpoena included but not limited t These documents may require analysis regarding the dates of creation, completeness, alteration and manipulation. When these documents are disclosed, Defendant will seek to have them analyzed and present testimony on the analysis as needed. + +# II. RESERVATION OF RIGHTS + +The defense reserves the right to amplify the disclosures contained herein based on testimony and other evidence presented during the government's case-in-chief. The defense also reserves the right to call additional expert witnesses and will promptly provide additional disclosure notice. + +# III. RIGHT TO SUPPLEMENT + +Ms. Maxwell reserves the right to supplement these opinions depending on the evidence produced at trial. To the extent that any accuser claims to have been "groomed" or otherwise testifies to the challenged opinions of Dr. Rocchio or other opinions properly rebutted by expert testimony Ms. Maxwell reserves the right to identify and rebut this testimony after the close of the government's case in chief. + +Very Truly Yours, + +![](_page_13_Picture_10.jpeg) + +Jeffrey S. Pagliuca + +Enclosures \ No newline at end of file diff --git a/marker2/ds9/EFTA00090186/EFTA00090186.metadata.json b/marker2/ds9/EFTA00090186/EFTA00090186.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..99db5a096a19a90656bad7ac51c2d7169a28bac7 --- /dev/null +++ b/marker2/ds9/EFTA00090186/EFTA00090186.metadata.json @@ -0,0 +1,768 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090186.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 14, + "chars": 43378, + "elapsed_seconds": 2.24, + "image_assets": [ + "_page_0_Picture_0.jpeg", + "_page_0_Picture_5.jpeg", + "_page_13_Picture_10.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "I. 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+MEMORANDUM OPINION & ORDER + +ALISON J. NATHAN, District Judge: + +Before the Court is the Defendant's fourth motion in limine to "exclude evidence related to Accuser-3," to whom the Court refers as Witness-3, on the grounds that the testimony is not direct evidence of the charged conspiracies and is inadmissible under Federal Rules of Evidence 404(b) and 403. Dkt. Nos. 387, 444. The Court has twice heard argument related to this motion, including argument at the November 10, 2021 in camera hearing that was sealed pursuant to Federal Rule of Evidence 412. See generally Nov. 1, 2021 Transcript; Nov. 10, 2021 Transcript. At the November I, 2021 hearing, the Court provided a brief explanation of its current position based on the information then before it, but the Court ultimately reserved ruling pending additional briefing. The Court is now in receipt of the parties' additional briefing and accordingly is prepared to resolve the motion.' + +The Government now proffers that the anticipated testimony of Witness-3 will describe how she met the Defendant and her relationship with the Defendant and Mr. Epstein. In particular, Witness-3 is anticipated to testify how Defendant introduced her to Mr. Epstein, how + +I This Memorandum Opinion & Order is filed temporarily under seal to permit the parties the opportunity to propose sealing or limited redactions pursuant to Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006), and Federal Rule of Evidence 412(cX2). + +massages progressed to involve sexual activity, and Ms. Maxwell's role in facilitating those massages. Based on all of the information now before the Court, including a substantially more detailed proffer by the Government as to the anticipated testimony, see Gov. Supp. Ltr. at 2-3 (Nov. 5, 2021); see also Dkt. No. 452 at 42-43, the Court concludes that some of the anticipated testimony may serve as direct evidence of the Mann Act counts. + +The Government rightly acknowledged at the November 1 pretrial conference that Ms. Maxwell cannot be found guilty on this witness's testimony alone for any of the crimes charged in the Indictment. Nov. 1, 2021 Tr. at 67:12-25, 68:13-19, 69:4-9, 70:23-71:2, 72:22-25. As the Government acknowledged, with respect to the jury's determination in this case, this witness is not a victim of any of the crimes charged in the Indictment. See id. at 69:4-9; Nov. 10, 2021 Tr. at 164:19-165:3.2 However, evidence of legal conduct can of course be relevant evidence of illegality. And conduct that cannot itself form the basis of a conviction can serve as direct evidence of the crimes charged. See, e.g., United States v. Robinson, 702 F.3d 22, 37 (2d Cir. 2012) (affirming admission of defendant pimp's relationship with and control over women who worked as prostitutes as direct evidence of 18 U.S.C. § 1591(a) charge). Thus some of the anticipated testimony described above can serve as direct evidence, notwithstanding the fact that the alleged conduct as to Witness-3 was not illegal for the purpose of the charges in this case. + +Portions of the anticipated testimony may also serve permissible purposes under Rule 404(b), namely proving motive, intent, and knowledge. See Fed. R. Evid. 404(b)(2). The witness is expected to testify about certain statements by Ms. Maxwell. For example, the + +2 At the November I conference, the Court denied the Defendant's motion to preclude the Government from referring to alleged victims as "victims" and "minor victims." Nov. I, 2021 Tr. at 4. In contrast to the other alleged victim witnesses, it is not (nor could it be) the Government's litigating position that this witness is a victim of the crimes charged in the Indictment. Given this, the Government may not refer to this witness as a "victim" or a "minor victim" in front of the jury. Doing so would constitute prejudicial error for the reasons explained in this Memorandum Opinion & Order. + +Government expects the witness to testify: + +Gov. Supp. Ltr, at 2-3 (Nov. 5, 2021). These statements are relevant because the jury may conclude that they tend to establish that the Defendant knew the alleged massages were sexualized and the Defendant's motive for facilitating the encounters. + +Id. at 3, 9. This testimony is relevant because the jury may conclude that it tends to establish the Defendant's intent to recruit girls for sexualized massages. + +Id. at 3. Although it is not the only available interpretation of this evidence, the jury could conclude that + +. Such knowledge and intent are of course proper purposes under Rule 404(b).3 + +3 Defendant argues that this witness's testimony is impermissible propensity evidence as to Mr. Epstein under Rule 404(b). Def. Supp. Resp. at 5.7 (Nov. II, 2021). The Court is unpersuaded. The testimony is not offered to show that Mr. Epstein acted in accordance with a certain character trait on a particular occasion. Rather, it is probative of whether Ms. Maxwell knew of or at least believed he had a sexual interest in which a jury may find tends to establish the Defendant's intent and motive as to the charged crimes. See Roe v. Howard, 917 F.3d 229, 245-46 (4th Cir. 2019) (rejecting argument that husband's assault of a non-party housekeeper was improper character evidence under Rule 404(b) in a Trafficking Victims Protection Act action against the wife for facilitating husband's assaults of live-in housekeeper). + +The probative value of the anticipated testimony must of course be balanced with any potential prejudice under Rule 403. As the Court noted at the November 1 conference, there is a risk that the jury may confuse the issues and think that the sexual conduct this witness is describing itself constitutes the illegality charged in the Indictment due to the closeness in age of this witness to the age of consent. Nov. 1, 2021 Tr. at 89-90. There is also the risk that the jury may convict Ms. Maxwell due to feelings of immorality or sympathy for the witness despite the lack of illegality with regard to the crimes charged in the Indictment. However, the Court concludes that this risk of prejudice can be sufficiently minimized through two avenues. First, the testimony must be carefully limited. Second, there must be a clear limiting instruction. + +As to the first, the witness is limited to stating that sexual activity occurred but is precluded from providing detailed descriptions of the sexual activity. There is little to no probative value of a witness describing sexual activity when that witness's testimony regarding the sexual activity cannot form the basis for the conviction of the crimes charged. For example, any prejudice from described above is substantially diminished by limiting the proffered testimony to the Defendant's interaction with the witness and testimony indicating that sexual activity allegedly took place without describing the details of that sexual activity. Unlike the details of the sexual conduct itself, this anticipated testimony would not be unduly prejudicial. In contrast, the minimal probative value of the details of sexual conduct would be substantially outweighed by the risk of the jury convicting Ms. Maxwell on an improper basis. The same is true of the witness's subjective experience of the sexual conduct and any emotional or other impact the sexual conduct had on the witness because such testimony cannot form the basis of a conviction in this case. Accordingly, the witness is limited, as the Government phrased it, to describing her "factual experience" as to the lines of testimony + +described above. See Gov. Supp. Ltr. at 12 (Nov. 5, 2021). For example, in a recent murder trial, the Court permitted the nephew of the victim to describe his uncle's wounds because the nephew, who had served as a caretaker, had some information that was not cumulative of the medical records. The Court expressly cautioned the Government that it would not permit emotional testimony, or the probative value would be outweighed by the prejudice: + +[I]t's clearly a 403 line here. You have cumulativeness with the medical testimony, you have graphic descriptions from a relative who cared for the victim which could very well produce sympathies and prejudice that would interfere with and overcome the medical facts that you need for purposes of proving causation.... I am certainly going to cut off the line at any graphic descriptions. To the extent that walking this person through questions regarding the medical condition is emotional testimony, I think we are — it will have to be stopped. + +United States v. Berry, No. 20 Cr. 84 (AJN), Dkt. No. 138 at 13; see also id. at 15. In that case, the Government agreed that the line had to be carefully guarded. Id. at 13-14. The transcript of that ruling is attached for counsel's reference. See Exhibit A. The Court cautions the Government to proceed carefully because the Court will not allow testimony that steps over this 403 line. The Court will allow some leading questions for this portion of the testimony to help ensure that it does not. + +Finally, the Court concludes that this witness's anticipated testimony as to the sex trafficking counts is inadmissible. Although the Government's letter points to some relevant direct evidence that this witness could provide regarding these counts, see Gov. Supp. Ltr. at 6-7, any minimal probative value of this evidence is diminished by its remoteness in time to the charged sex trafficking conspiracy, which is alleged to have run from 2001 to 2004. This evidence does not face the same problem as it relates to the Mann Act conspiracies, which are alleged to have begun in 1994 (and when the Defendant allegedly began her relationship with this witness.). Because the risk of unfair prejudice substantially outweighs the probative value of this evidence as to the sex trafficking counts, the witness is precluded from testifying that + +The Court thus draws the line described above for limiting Witness-3's testimony. Permitting the entirety of the proffered testimony carries a risk that the jury may convict Ms. Maxwell due to conduct that cannot form the basis of a conviction for the charged crimes. But by limiting the testimony to the few categories of relevant testimony outlined above, the prejudice is substantially minimized. + +Moreover, whether as direct evidence of the Mann Act counts or offered for a proper purpose under 404(b), this testimony must be paired with a proper limiting instruction to guard against potential juror confusion. The Defense has submitted proposed limiting instructions, and the Government agrees that some sort of instruction is appropriate, although it disagrees with the basis for the instruction. Dkt. No. 452 at 50 n.12; Gov. Supp. Ltr. at 12 (Nov. 5, 2021). In accordance with this ruling, the Court proposes the following instruction before this anticipated witness testifies: + +You will hear testimony from the next witness about interactions that she says she had with the Defendant and Mr. Epstein. I instruct you that because the witness was over the relevant age of consent at the relevant time period, any sexual conduct she says occurred with Mr. Epstein was not "illegal sexual activity" as the Government has charged in the Indictment. I instruct you that this witness is not a victim of the crimes charged in the Indictment. To the extent you conclude that her testimony is relevant to the issues before you, you may consider it. However, you may not convict the Defendant on the basis of the testimony regarding the sexual conduct between this witness and Mr. Epstein. Nor may you consider this testimony as any kind of reflection on Mr. Epstein's nor Ms. Maxwell's character or propensity to commit any of the crimes charged in the Indictment. + +The Court also proposes the following instruction before any testimony by other witnesses regarding sexual activity that occurred after the relevant age of consent: + +I anticipate that you will hear testimony from the next witness about sexual conduct that she says she had with Mr. Epstein in [insert relevant jurisdiction, e.g. New Mexico]. I instruct you that because the witness was over the age of consent in [insert relevant + +jurisdiction, e.g. New Mexico] at the relevant time period, the sexual conduct she says occurred with Mr. Epstein was not "illegal sexual activity" as the Government has charged in the Indictment. However, to the extent you conclude that her testimony is relevant to the issues before you, you may consider it. However, you may not consider this testimony as any kind of reflection on Mr. Epstein's nor Ms. Maxwell's character or propensity to commit any of the crimes charged in the Indictment. + +The parties may submit any requested edits to the proposed limiting instructions that are consistent with the Court's ruling or indicate that they have none on or before November 21, 2021. + +This resolves Dkt. Nos. 387, 444. + +SO ORDERED. + +Dated: November 19, 2021 New York, New York )44 + +ALISON J. NATHAN United States District Judge + +UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x + +UNITED STATES OF AMERICA, New York, N.Y. + +4 v. 20 Cr. 84 (AJN) + +5 RALPH BERRY, + +6 Defendant. + +7 x + +8 September 21, 2021 9:45 a.m. + +9 + +10 Before: + +11 HON. ALISON J. NATHAN, + +12 U.S. District Judge And A Jury + +13 + +14 + +## APPEARANCES + +15 + +AUDREY STRAUSS + +United States Attorney for the Southern District of New York + +16 BY: + +17 + +18 + +Assistant United States Attorneys + +19 + +LAW OFFICE OF MARK S. DEMARCO Attorneys for Defendant + +20 + +BY: MARK DeMARCO -AND- + +21 + +LAW OFFICES OF EZRA SPILKE, PLLC + +BY: EZRA SPILKE + +22 + +23 + +24 + +25 + +4 5 MR. : Good morning, your Honor. , and for the government. + +6 THE COURT: Good morning. + +7 For the defendant? + +8 9 10 MR. DeMARCO: Good morning. For Mr. Berry, Mark DeMarco and Ezra Spilke, Ms. Mayerlin Ulerio, and of course Mr. Berry. + +11 THE COURT: Good morning, counsel. + +12 Good morning, Mr. Berry. + +13 THE DEFENDANT: Good morning. + +14 15 16 17 THE COURT: I had hoped to start at 9:00 but Mr. Berry wasn't brought until now. Hopefully that won't repeat going forward. We will make sure that things are in place to prevent that so we can timely get started each day. + +18 19 20 21 22 23 24 25 I thank everyone as a matter of procedure, for being here on time. Let me ask, we will wait for the jury department to let us know when the panel is checked in and assembled and in their seats, and then can head over to 500 Pearl to commence jury selection. My purpose for today is to confirm the receipt of the voir dire questionnaire that I sent yesterday with the noted change, make sure everybody got that. The second is to confirm that there have been no additional plea offers. And + +(Case called) + +THE DEPUTY CLERK: Counsel, please state your name for the record, starting with the government. + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +lastly, I made the note, make sure there are no questions regarding jury selection now that you have been to the walk-through in the jury selection room where selection will take place. + +So, let me ask, everybody received the voir dire with the noted changes? + +MR. : Yes, your Honor. We did. + +THE COURT: Nothing additional, Mr. + +MR. : Nothing additional. + +MR. DeMARCO: Yes, your Honor; and nothing additional. + +THE COURT: Thank you. + +Any additional plea offers that I need to allocute on? + +MR. : No additional plea offers have been extended, your Honor. + +THE COURT: OK. And then let me confirm if anybody has any questions about jury selections. To repeat the basic process, I will qualify 33 potential jurors that represents 12 jurors and three alternates, 10 peremptories as to the main panel for the defense, six peremptories for the government, one peremptory per side with respect to the alternates. And the way that we are operating under the COVID protocols, the jury department will, after the jury panel members are checked in, they'll be randomly assigned a number consistent with a list that the jury department generates, they will be seated in that numerical order in the jury selection room. I understand 1 + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +through 42 will be in the main jury selection room and then 43 through, I believe 82 -- we will get the final number once we see what the return on the summons is -- will be seated in courtroom 9C also at 500 Pearl, with a live feed to 9C of everything taking place in the jury assembly room. + +I will make preliminary instructions which you have seen after you and I enter the courtroom. The panel members will be seated at that point. I will make my preliminary remarks, the written questionnaire that the jurors can read along with will be handed out at that point, both in the jury assembly room and in 9C simultaneously through court staff. will instruct the jurors not to write anything on the questionnaire with the exception of circling a number if they have a "yes" response to that question as I read through the questionnaire. + +So, at that point I will turn to panel member juror no. 1 and go through and read the questionnaire getting "yes" or "no" response to each question. If the answer is "yes" following up as appropriate. To the extent that the matters touched upon could influence other jurors or are of a sensitive nature, we will bring that juror over to the plexiglass area to my right in the jury assembly room, there is markings on the floor where folks stand and the noise machine will be on so that others cannot hear, and I will inquire with the juror as to any necessary follow-up. + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +Once we get through, assuming we get through juror no. 1 without any for-cause issues, I will turn to juror no. 2 and say do you have any "yes" responses? And then we will take those in order as they come. + +If any juror needs to be dismissed for cause, let's say juror no. 2 needs to be dismissed for cause, then we will proceed with the same process with juror no. 3. Any "yes" questions, taking those 33 qualified jurors. one at a time, continuing until we have + +Once we have 33 qualified jurors you will exercise your peremptory strikes by list and simultaneously, that is, each side will produce a list with the government's six strikes as to the main panel and one strike as to the alternate panel, and the defense will write its list with 10 strikes as to the main panel and one strike as to the alternate panel. + +Obviously, before anyone is dismissed, I will hear from counsel if any applications or issues need to be raised if you are satisfied with our jury. Once we get there we will read the names of the selected jurors, dismiss to the jury department the unused jurors, and then proceed over back across the street over here. I believe what we will do is have Ms. Williams take the jurors to the jury room, which is an outfitted courtroom so they can put their belongings down, she can give them notebook and pen, bring them back in. At that point she will swear the jury and I will give preliminary instructions and opening + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +statements. Whether that happens today or tomorrow we will see. Hopefully today. + +Any questions or issues to raise with the process I have described? Mr. + +MR. : Your Honor, no. One small thing on the voir dire. We submitted a list of names for the Court to read. One thing I wanted to flag for the Court is one of the witnesses' names we asked you to include is Jesus Ortiz, and that's how he pronounces his name, with a hard J. I want to flag that for the Court so that his name is read accurately to the jury. + +THE COURT: Let me see if there are any other pronunciation issues. + +Mr. DeMarco, while I am pulling that up, any other questions or issues with respect to the process? + +MR. DeMARCO: No, your Honor. + +THE COURT: And, Mr. DeMarco, you are going to keep your mask on so I don't have to keep coming at you about it? + +MR. DeMARCO: I will do my best. + +THE COURT: OK. Don't take it off to talk. + +MR. DeMARCO: Sorry? + +THE COURT: Don't take it off to talk. + +MR. DeMARCO: OK. I took it off to listen the last time. + +THE COURT: That's an anatomical anomaly. + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +I should say, of course, once we are in the courtroom then counsel in the plexiglass box with the HEPA filter will be able to remove their mask for questioning, and to the extent outside of the jury we have argument or the like, we can do that in there to aid that that process. + +It's Ms. Ulerio, Mayerlin, am I saying that correctly? + +MS. ULERIO: Yes. + +THE COURT: And you have another paralegal Dylan Schneider who may be here? + +MR. DeMARCO: Yes, your Honor, but he won't be with us in court. + +THE COURT: And what about Jeremy Schneider? Mr. Schneider. + +MR. DeMARCO: He is unable to be with us. + +THE COURT: He won't be at trial at any point? + +MR. DeMARCO: No. I don't expect him to be here. + +THE COURT: Should I include him in the voir dire just in case. + +MR. DeMARCO: I think you should, Judge, because his name might come up and I just can't see how or where or under what scenario. But, just to be safe. + +MR. : His name is on the stipulations, so maybe to be safe. + +THE COURT: Just to note, when I do introduce counsel for purposes of the voir dire, and Mr. Berry, and the + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +paralegals, I will ask each of you to stand as I say your name so that the jurors can see you, the panelists can see you. So, I will note Mr. Schneider is part of the team but not present today and may not be present every day of the trial. + +Appropriate, Mr. DeMarco? + +MR. DeMARCO: Yes, Judge. + +THE COURT: OK. So Jesus Ortiz is the pronunciation. + +How about, Mr. how do I pronounce no. Q? + +MR. : I believe, your Honor, it is Vyacheslav, and the last name is Polosin. + +THE COURT: Vyacheslav Polosin. OK. + +Special Agent Stefano Braccini? + +MR. : And he is in the courtroom. + +THE COURT: OK. I think that's it. Other issues to take up? + +MR. : I don't think so, your Honor. + +THE COURT: Mr. DeMarco? + +MR. DeMARCO: No, your Honor. Not now. + +Judge, how much time do we have before we walk over? Maybe we could use this time efficiently, because I do have I raised with the government an issue I was going to raise with their first witness so you tell me. + +THE COURT: I was told around between 10:00 and 10:30 but we won't know until they actually call over so I'm happy to use the time and if we get the call, we will pause. + +4 5 6 MR. DeMARCO: I did consult with the government. I was unpersuasive. I was hoping to be more successful with your Honor. + +7 THE COURT: OK. And the first witness is? + +8 MR. DeMARCO: Mr. Rasheen Vega. + +9 10 THE COURT: Go ahead. And if you could speak into the mic, please? + +11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. DeMARCO: It seems to me, your Honor, from my reading of the 3500 material, that we can expect Mr. Vega to testify to something like this: That he was the nephew of Mr. Jones, that he was 11 years old at the time that Mr. Jones was shot in June of 2000, that he witnessed a portion of that shooting or the aftermath of that shooting which I am OK with. The problem that I have with his prospective testimony is this: It also appears from reading the 3500 that the government will seek to elicit from Mr. Vega testimony about the horrific, horrific bedsores or compression sores that Mr. Jones was suffering from at the time of his death. I believe there is at least notes that Mr. Vega observed the sores to be oozing, observed Mr. Jones to be in terrible, terrible pain and suffering at or near the time of his death, and my concern is that, A, in light of the fact that two doctors are being called + +MR. DeMARCO: OK. + +THE COURT: Was it an issue you wanted to speak to the government about first? + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +by the government and, even apart from that, Mr. Vega is not qualified to testify about the injuries that he observed; and B, that this type of testimony serves no purpose but to elicit or garner sympathy from the jury and will be unduly prejudicial to Mr. Berry. + +So, that's the basis of my objection to Mr. Vega, should he be asked those types of questions. + +THE COURT: Understood. + +Mr. + +MR. : Your Honor, there are two large topics that Mr. Vega is anticipated to testify about. I think it is consistent with what Mr. DeMarco says is, one, he was a percipient witness to the shooting itself; and two, he observed the victim's injuries after the shooting and was involved in the victim's care in the 10 years between the shooting and the victim's death. I take it it is the second category that the defendant is objecting to. But here, cause of death is obviously a big issue in this case and it is something that it is our burden to prove, that the injuries from the shooting lead to his death. And we expect the evidence to show that, as a result of the shooting, the victim became paralyzed from the waist down and that meant that he was confined to a wheelchair -- whereas he was not in a wheelchair before -- and developed serious complications as a result of that including serious sores which later led to infection and the victim's + +death. + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +We will not be eliciting expert medical testimony or opinion from this witness, he will be simply testifying to what he observed with respect to the victim's physical condition during the 10 intervening years between the shooting and the death and that's important evidence, it's evidence that will then be consistent with things that medical experts to be qualified as experts will be called to testify about, but those experts did not observe these injuries during the 10 intervening years. They also did not observe Mr. Jones prior to the shooting. For instance, they wouldn't be able to tell you whether he was in a wheelchair before the shooting or after the shooting. They wouldn't be able to tell you if he developed those bedsores before the shooting or after the shooting. It is Mr. Vega's observations that will allow the jury to connect those dots. Given how important causation is in this case, we think it is important that the jury understand those injuries. + +THE COURT: Will medical records, that will be introduced, describe the bedsores? + +MR. : They will describe the bedsores at the time of the autopsy which was in November of 2010. + +THE COURT: What is the connection between bedsores and cause of death? Infection? + +MR. : Your Honor, essentially what I expect the + +testimony will be from the medical experts is that as a result of the gunshot wound, that caused paralysis and paraplegia in the victim. Paraplegia commonly leads to things such as bedsores or pressure sores from not being able to move one's body; also other conditions such as a colostomy bag, a collapsed rectum, a permanent catheter, all of which can lead to infections and that in this particular case it was the complications of the paraplegia that led into infections or sepsis and that it was the sepsis that ultimately, in 2010, killed Mr. Jones. + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +MR. DeMARCO: Your Honor, if I may? + +THE COURT: Sure. + +MR. DeMARCO: In my reading of the 3500 notes that were disclosed it's more than that. He describes oozing-type wounds, he describes a horrific odor, I think he described it as the smell of death in Mr. Jones' apartment at or near the time of his death. It's facts like these that I am focusing on. + +THE COURT: Yes. + +MR. DeMARCO: The paraplegia, the medical testimony from the medical examiners will establish that Mr. Jones was paraplegic and he was in a wheelchair. But, my concern is about the graphic description of the bedsores, the compression sores, and also the horrific odor witnessed by Mr. Vega. + +MR. : Your Honor, we are certainly cognizant of + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +not crossing the 403 line here. We think it is important that the jury understand the nature of these injuries and how they could lead to his death and what the injuries were during the intervening time between the shooting and the autopsy. We are not looking to be gratuitous or to pile on here. + +THE COURT: Yes. Well, it's clearly a 403 line here. + +You have cumulativeness with the medical testimony, you have graphic descriptions from a relative who cared for the victim which could very well produce sympathies and prejudice that would interfere with and overcome the medical facts that you need for purposes of proving causation. So, because this witness is testifying first it's difficult for me to know exactly what additional facts you need to extract from the witness but I am certainly going to cut off the line at any graphic descriptions. To the extent that walking this person through questions regarding the medical condition is emotional testimony, I think we are -- it will have to be stopped. + +So, I think what you need to think about is what and I'm going to allow a little bit of leading to ask the specific factual questions you believe that you need and that are not cumulative with the medical testimony, but I'm going to guard this line very carefully, and you should too. + +MR. : Your Honor, I understand that. I will say that in meeting with this witness we have tried to follow that line and I am -- with the ability to maybe construct some + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +of my questions in a leading way, I will hope to enforce that line. It is, again, certainly not our intention to be gratuitous but to simply get in the nature of the injuries and their relationship. + +THE COURT: You don't have pre-autopsy medical records that you are putting in that describes these injuries? + +MR. : No, your Honor. + +MR. DeMARCO: I'm sorry. What was that? Pre? + +THE COURT: No. I asked if there were -- + +MR. DeMARCO: I misunderstood your question, Judge. I'm sorry. + +THE COURT: I asked if there were pre-autopsy medical records that describes these infections and injuries and the answer is no. + +MR. DeMARCO: The government has disclosed, pursuant to Rule 16, some of these records that your Honor references, so. + +MR. : Your Honor's question was I think if we are introducing them. There are voluminous medical records that are almost incomprehensive to a layperson. We are not introducing those records. + +THE COURT: But you have a medical expert. + +MR. : We do have a medical expert. + +MR. DeMARCO: Your Honor, if I just might add another fact to this? Based on the exhibit list and the exhibits + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +provided to us by the government, the government intends to introduce, through the medical examiner, photographs of these bedsores. So, I think that expert testimony, by itself, sufficiently will describe the bedsores that Mr. Jones was suffering at the time of his death. + +MR. : To be clear of what photographs we are introducing, we are not introducing the most graphic pictures of the bedsores. In fact, we were concerned in introducing some of the pictures that they wouldn't fully show how serious the bedsores were but we are not going to be putting in the most graphic pictures. + +THE COURT: What I am going to allow is you will have some permission to lead with respect to the description of the injuries and sores. It's going to be brief and extraction of facts that you need that is not cumulative with medical testimony and evidence that's coming in. We will see how it goes but I am -- I intend to be extremely cautious given that this is non-expert medical testimony coming from a relative. So, the prospect of prejudice and emotion and sympathy is real and I'm not going to let it happen. + +MR. : Yes, your Honor. We understand. + +THE COURT: Anything else? + +MR. DeMARCO: No thank you, your Honor. + +THE COURT: OK. Any word, Ms. Williams? + +(Discussion off record) + +4 + +5 + +6 + +7 + +8 + +9 + +10 + +11 + +12 + +13 + +14 + +15 + +16 + +17 + +18 + +19 + +20 + +21 + +22 + +23 + +24 + +25 + +THE COURT: They said 15 to 20 minutes so I imagine the marshals need time to get Mr. Berry across the street. So, unless anyone has anything further, we will break and re-assemble across the street at 500 Pearl. Thank you. + +So, one question. Mr. is the government ready to commence trial? + +MR. : Yes, your Honor. + +THE COURT: Mr. DeMarco? + +MR. DeMARCO: Yes, Judge. + +THE COURT: Thank you. + +MR. DeMARCO: Your Honor, we are going to meet over at the jury room? + +THE COURT: We will meet in the alcove outside the jury assembly room. 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a/marker2/ds9/EFTA00090223/EFTA00090223.md b/marker2/ds9/EFTA00090223/EFTA00090223.md new file mode 100644 index 0000000000000000000000000000000000000000..ab6d9f5cbd82c87597e65067ac08d3c87637428c --- /dev/null +++ b/marker2/ds9/EFTA00090223/EFTA00090223.md @@ -0,0 +1,95 @@ +![](_page_0_Picture_0.jpeg) + +United States Attorney Southern District of New York + +The SihioJ. Mollo Building One Saint Andrew's Plaza New York. New York 10007 + +November 18, 2021 + +#### BY E-MAIL + +The Honorable Alison J. Nathan United States District Judge Southern District of New York 40 Foley Square New York, New York 10007 + +Re: United States v. Ghislaine Maxwell, S2 20 Cr. 330 (MN) + +Dear Judge Nathan: + +The Government respectfully submits this letter motion to quash the defendant's Rule 17(c)(3) subpoena to-the administrator of the Epstein Victims' Compensation Program (EVCP). For the reasons set forth below, the subpoena should be quashed.' + +#### I. Applicable Law + +As the defendant acknowledges, she bears the burden of satisfying the standard in United States v. Nixon, 418 U.S. 683 (1974). (Def. Mot. at 1). Pursuant to that standard, the "party seeking issuance of [a Rule 17(c)] subpoena must clear three hurdles: (1) relevancy; (2) admissibility; (3) specificity." United States v. Cole, 2021 WL 912425, at \*3 (S.D.N.Y. Mar. 10, 2021) (internal quotation marks omitted). The proponent must also establish that the records sought "are not otherwise procurable." Id. (quoting Nixon, 418 U.S. at 699-700). + +&#x27; For sake of simplicity, the Government uses the term "Minor Victims" to include Witness-3. The Government acknowledges the Court's order that Witness-3 should not be referenced at trial as a victim. + +The Nixon test is enforced strictly. As the Supreme Court has explained, "[lit was not intended by Rule 16 to give a limited right of discovery, and then by Rule 17 to give a right of discovery in the broadest terms." Bowman Dairy Co. v. United States, 341 U.S. 214, 220 (1951); see also United States v. Purin, 486 F.2d 1363, 1368 (2d Cir. 1973) ("A subpoena duces tecum in a criminal case is not intended as a means of discovery."). It is not sufficient for a party to show only that the subpoenaed documents "are potentially relevant or admissible." United States v. Wey, 252 F. Supp. 3d 237, 254 (S.D.N.Y. 2017) (internal quotation marks omitted); see United States v. Skelos, No. 15 Cr. 317, 2018 WL 2254538, at \*2 ("The materials sought under Rule 17 must themselves be admissible at trial; it is not enough that they contain information which could be admissible." (alterations and internal quotation marks omitted)); United States v. RW Prof? Leasing Servs. Corp., 228 F.R.D. 158, 162 (E.D.N.Y 2005) (explaining that it is "insufficient" for a party to show only that the subpoenaed documents "are potentially relevant or may be admissible"). Similarly, the party requesting the subpoena must also show that the "the application is made in good faith and is not intended as a general fishing expedition." United States v. Ulbricht, 858 F.3d 71, 109 (2d Cir. 2017) (quoting Nixon, 418 U.S. at 699-700) (internal quotation marks omitted), abrogated on other grounds as recognized by United States v. Chambers, 751 F. App'x 44, 46 & n.1 (2d Cir. 2018) (summary order).2 + +## II. Discussion + +The defendant has subpoenaed four categories of information: (1) copies of any payments to the Minor Victims and their counsel, and (2) "[lily and [a]ll [r]eleases executed by the [Minor + +2 Although generally "production of impeaching evidence pursuant to Rule 17(c) is not required until after the witness testifies," Skelos, 2018 WL 2254538, at \*2, in this case the Government expects each of the Minor Victims named in the subpoena to testify at trial. Accordingly, if the Court permits enforcement of the subpoena, the Government does not object to production of the records to the Court before the Minor Victims actually testify for the sake of efficiency. + +Victims];" (3) "[a]ny and all" material "submitted by each [Minor Victim]" to the EVCP; and (4) "communications" between the EVCP and the Minor Victims or their counsel. (Def. Mot. Attachment A). The subpoena should be quashed as to each of these categories.; + +## A. Payment Records + +The first category—copies of payments made to the Minor Victims—concerns information already in the defendant's possession. Indeed, the defendant's motion cites the amounts received by the Minor Victims, which is reflected in their 3500 material (Def. Mot. at 3), and the Government expects the Minor Victims to testify to those amounts at trial. + +Accordingly, this information is "otherwise procurable." United States v. Pena, No. 15 Cr. 551 (AJN), 2016 WL 8735699, at \*2 (S.D.N.Y. Feb. 12, 2016). The subpoena should therefore be quashed. At most, the Court should order production of that information to the Court so that it may be provided to the defense in the unlikely event that the Minor Victims testify inconsistently with their prior statements at trial. + +# B. Claim Release Forms + +The defendant makes no argument for the relevance of the release forms executed by the Minor Victims, and none is apparent to the Government. The Court should therefore quash the subpoena insofar as it calls for that category of information, at least until the defendant explains what relevant and admissible evidence is contained in the release forms. + +3 The Government has standing to challenge the subpoena because it targets information about anticipated Government witnesses, "based on the Government's 'interest in preventing any undue lengthening of the trial, any undue harassment of the witness and [her] family, and any prejudicial over-emphasis on the witness's credibility."' United States v. Ray, 337 F.R.D. 561, 571 (S.D.N.Y. Nov. 25, 2020) (quoting United States v. Giampa, No. 92 Cr. 437 (PKL), 1992 WL 296440, at \*1 (S.D.N.Y. Oct. 7, 1992)). The Government has provided notice of this subpoena to the Minor Victims and is informed that at least two victims expect to file submissions regarding the subpoena. + +### C. Any and All Material Submitted to the EVCP + +The defendant makes a further request for any and all submissions by the Minor Victims to the EVCP. This request would not generate relevant, admissible evidence for two reasons. + +First, the defendant has not identified a theory by which these materials are relevant and admissible. The defendant argues primarily that the materials contain relevant impeachment information because "[f]ull and complete cross-examination is impossible without understanding the complete terms of the agreement with the Epstein Fund, including the claims concerning Maxwell, as well as others." (Def. Mot. at 6). Materials are not relevant and admissible at trial, as required by Nixon, simply because they aid the defendant's "understanding." And the defendant articulates only one theory by which EVCP materials may be admitted to show bias. According to the defendant, the May 2020 Protocol governing the EVCP states that claims are evaluated depending on whether "there exists any information and/or pertinent findings offered by the appropriate .. . United States Attorneys' Office or other law enforcement agency." (Def. Mot. at 5). If this "prosecution against [the defendant] went forward," the argument goes, the Minor Victims and their lawyers would "benefit." (Id.) + +The defendant already has the information relevant to this argument. She has the protocol for the EVCP. The Government has "offered" no "information" or "findings" to the EVCP about the Minor Victims; to the extent the EVCP relied on publicly available information about this case to make its determination, such as the charging instruments in this case, that information is in the public record. And the Government has already disclosed to the defendant the settlement amounts—which the defendant cites in her motion. (Def. Mot. at 5). Thus, if these records are relevant at all, they are "otherwise procurable." Pena, 2016 WL 8735699, at \*2.4 + +The defendant also argues that the subpoenaed records contain prior statements of the Minor Victims, presumably suggesting that they may be admissible as prior inconsistent statements. (Def. Mot. at 4). This argument misses the mark. Any statements in the EVCP's files are unlikely to be inconsistent in light of the context in which they were made. See United States v. Barrow, 400 F.3d 109, 123 (2d Cir. 2005) (citing United States v. Strother, 49 F.3d 869, 875 (2d Cir. 1995) for the proposition that an omission in a prior statement "should have been admitted as an inconsistent statement because it would have been natural for the witness to include the fact" (internal quotation marks and alterations omitted)). In order to initiate a proceeding with the Epstein Victims Compensation Fund, a victim must articulate a claim "directed against Epstein." (Indep. Epstein Victims' Compensation Program Protocol, Def. Mot. Ex. 1 Attachment A Ex. 1 at 3 (emphasis added)). And in that context, it would be wholly unsurprising if victims spoke at times about their experience with Epstein without discussing the defendant.5 Further, if it were true (as the defendant argues above) that EVCP funds will reveal the Minor Victims' bias because their recovery from the EVCP was aided by the Government's continued case against the defendant, one would expect that any statements by the Minor Victims to the EVCP regarding the defendant would be consistent with their statements to the Government and at trial. If the Minor + +4 Indeed, because all four Minor Victims identified in the subpoena have resolved their claims with the EVCP, there is no reason to think their trial testimony will be biased in order to advance their claims in a now-completed settlement process. + +5 Consider, for instance, if a victim met Epstein and the defendant together on a certain date. It would be entirely consistent for the victim to testify as much on the stand, and to tell the EVCP that she "met Epstein"—without mentioning the defendant—on that date. + +Victims' submissions to the EVCP did not discuss the defendant, a criminal case against the defendant would not advance their claims. + +Second, even if these subpoenas yielded marginally relevant impeachment material or marginally inconsistent statements notwithstanding their context, such evidence would not be admissible under Rule 403. At the November 1,2021 conference, the defendant sought to preclude the Government from arguing that the Minor Victims' settlements with the EVCP reflects an endorsement of their claims, which "would be confusing to the jury" and "open the door to an explanation from the defense about what really happened in those proceedings," a request to which the Court and Government agreed. (11/01/21 Tr. at 43:7-46:3). It remains the Government's position that cross-examination highlighting the fact that the Minor Victims received large settlements for their claims would not open the door to a broader discussion of the Epstein Victims Compensation Program. + +If, however, the defendant engages in significant cross-examination about what Minor Victims did and did not say to the EVCP, and the reasons for those statements, it would create just that confusion and open just that door. If the defendant argues that a Minor Victim should have, but did not, make statements about the defendant to the EVCP, the Government will have to explain to the jury the purpose of the EVCP and its adjudicative process in order to contextualize that omission. Similarly, if the defendant argues that the Minor Victims' testimony was biased by some interrelationship between the EVCP and this case, the Government will have to explain to the jury the absence of such an interrelationship, including the timeline of the Minor Victims' statements relative to the timeline of the EVCP. Indeed, it appears that the defendant anticipates arguing that some Minor Victims' bias is shown by the fact that their counsel was involved in structuring the EVCP, which would require further response from the Government about the + +operations of the EVCP. (Def. Mot. at 5 ("Lawyers for Accuser-2 and Witness-3 were instrumental in creating and structuring the terms of the Protocol.")). The risk of confusing the issues and wasting time at trial substantially outweigh any probative value in the evidence the defendant might obtain. + +This is not a trial about the scope and adjudicative process of the EVCP. All of this should be precluded, and therefore none of it is admissible under Nixon. The defendant is able to make arguments about bias and consistency without issuing a subpoena that is unlikely to yield relevant information—information that would be precluded at trial in any event.' + +# D. Communications + +Finally, the subpoena calls for communications between EVCP and the Minor Victims and their counsel. The term "communications" is defined broadly, covering "all forms of correspondence, including regular mail, email, text messages, memorandum, or other written communication of information of any kind." + +This subpoena request is a classic fishing expedition that the Court should quash. There is no reason to believe that the Minor Victim or their counsel would make substantive statements, which might be inconsistent, in emails and text messages. The defendant offers no reason why their theory of bias would find support in correspondence. Nor is one supported by logic: the theory is that the Minor Victims told false stories to the Government to advance the prosecution, not that they did or said biased things to the EVCP. This subpoena does not seek to "obtain identified evidence" but rather to engage in "a general `fishing expedition' that attempts to use the + +6 The defendant defines "EVCP Material" to include information regarding compensation received by Minor Victims and releases signed by them. (Def. Mot. Ex. I Attachment A). Those items should be treated identically to the specific requests for them, as discussed above. + +rule as a discovery device." United States v. Cuthbertson, 630 F.2d 139, 144 (3d Cir. 1980); see Ulbricht, 858 F.3d at 109. Such an expedition is precluded by Nixon. 418 U.S. at 700. + +## III. Conclusion + +For the foregoing reasons, the Court should quash the defendant's subpoena.? + +Respectfully submitted, + +DAMIAN WILLIAMS United States Attorney + +by: as/ + +Assistant United States Attorneys + +cc: Counsel of Record (by email) + +7 In the event the Court does not quash the subpoena, the Government notes that it is returnable to the Court for in camera review. (Def. Mot. at 1). To the extent the Court releases any records from the EVCP to the defendant, it should only release those records that comply with the Nixon standard. See Skelos, 2018 WL 2254538, at \*2 ("To avoid delay in trial, courts sometimes require production of impeaching material to the court (but not to counsel), with the court reviewing these documents in camera and then disclosing any admissible documents only after the witness testifies."). For instance, if the Court identifies a prior inconsistent statement in only one document, no other records should be released to the defendant. And, in addition to evaluating whether any statement is relevant to show bias or as a prior inconsistent statement, the Court should consider whether it is precluded under Rule 403, for the reasons described above. See supra pp. 6-7. \ No newline at end of file diff --git a/marker2/ds9/EFTA00090223/EFTA00090223.metadata.json b/marker2/ds9/EFTA00090223/EFTA00090223.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..3f93c86d373c623849d8179efa4cd5cc08953307 --- /dev/null +++ b/marker2/ds9/EFTA00090223/EFTA00090223.metadata.json @@ -0,0 +1,554 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090223.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 8, + "chars": 15217, + "elapsed_seconds": 1.2, + "image_assets": [ + "_page_0_Picture_0.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "U.S. Department of Justice", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 319.464, + 25.92 + ], + [ + 463.70361328125, + 25.92 + ], + [ + 463.70361328125, + 40.353515625 + ], + [ + 319.464, + 40.353515625 + ] + ] + }, + { + "title": "BY E-MAIL", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 169.29 + ], + [ + 139.0744171142578, + 169.29 + ], + [ + 139.0744171142578, + 182.853515625 + ], + [ + 68.544, + 182.853515625 + ] + ] + }, + { + "title": "I. 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But that said, their proposed answers are attached. + +From: (PAO) < + +Sent: Monday, November 22, 2021 2:52 PM + +To: (USANYS) < > + +Subject: RE: when does Maxwell's trial start? + +Hey, + +Attached are the proposed answers to the NY Times questions re the documents released in July. + +Let me know if any issues/concerns/edits. Their deadline is 5pm today. + +And if you want any Qs other than this referred to you guys, let me know. + +I need to get back to ODAG before going back to the reporter, so if you can get back to me ASAP that would be a huge help. + +Thank you! + +Spokesperson, Office of Public Affairs + +Department of Justice \ No newline at end of file diff --git a/marker2/ds9/EFTA00090231/EFTA00090231.metadata.json b/marker2/ds9/EFTA00090231/EFTA00090231.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..22e6d7433d4ddcc92a464d45960aebbc26c43fd7 --- /dev/null +++ b/marker2/ds9/EFTA00090231/EFTA00090231.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090231.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 941, + "elapsed_seconds": 0.89, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 49 + ], + [ + "Line", + 23 + ], + [ + "Text", + 20 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00090231" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00090232/EFTA00090232.md b/marker2/ds9/EFTA00090232/EFTA00090232.md new file mode 100644 index 0000000000000000000000000000000000000000..165551f5c266afbf68272ced9b65efb95cfb8008 --- /dev/null +++ b/marker2/ds9/EFTA00090232/EFTA00090232.md @@ -0,0 +1,57 @@ +We also would like to offer BOP a chance to respond to what the documents reveal and any remedial steps that have been taken. + +1. Most centrally, the documents paint a picture of mistakes, sloppiness and even incompetence by some BOP employees in their dealings with Epstein -- such as failing to log/monitor/record social calls, delays in getting him requested psych exams and assessments, multiple inaccuracies in Epstein's intake forms and of not responding to directives to provide him with a cellmate on the night he died. + +The BOP records show Epstein repeatedly assured one or more jail psychologists that he was not suicidal and had a lot to live for. But the records also show BOP officials later concluded that they did not appreciate as quickly as they could have the risk factors for suicide that Epstein's case presented (for example, after his admission and later after he was denied bail.) + +A. Has BOP addressed the problems identified in the BOP records, through policy changes or corrective measures or the training of employees? + +The safe, secure, and humane housing of inmates is BOP's highest priority. While we decline to comment specifically as to any inmate, as a general matter, BOP has launched a task force that will address mental health implications of housing individuals alone in a cell, and is committed to improving its suicide prevention program. In addition, BOP is increasing the number of beds available as secure mental health units, which will support moving inmates with serious mental illness out of restrictive housing and into secure treatment programs. BOP is also taking a number of other steps to address mental health issues, including enhancing peer support programs, and continuing to train BOP staff on suicide prevention, risk assessment, and emergency responses. + +B. Does BOP have any other comment on Epstein's period in its custody and/or his suicide? + +We decline to comment + +In addition, we have listed below 9 specific questions that were prompted by references in the documents. (Please see below) + +## SPECIFIC QUESTIONS + +1. INMATE COMPANIONS: The records show MCC utilized "inmate companions" to observe Mr. Epstein when he was on psychological observation and suicide watch, and to write down what he did or said. Are such "inmate companions" specially trained for this task? And how did they monitor Epstein: watching through a window in his cell door? Entering the cell and sitting with him? + +As found in Program Statement 5324.08 "Suicide Prevention Program" here https://www.bop.gov/policv/progstat/5324 008.pdf and BOP Program Statement 531017 "Psychology Services Manual" here httos://www.boD.gov/Dolicy/Drogstat/5310 017.odf the BOP has an extensive suicide prevention program that begins upon an inmate's arrival at each BOP facility, including pretrial facilities. When inmates report suicidal ideation, or are suspected of being at elevated risk of suicide, a suicide risk assessment is completed consistent with the Bureau suicide prevention policy. + +While we decline to comment specifically as to any inmate, as a general matter, the BOP utilizes inmate companions consistent with the policy Suicide Prevention Program. In some circumstances, inmate companions monitor inmates on suicide watch and provide peer support. They do not have direct + +contact with the inmates they monitor. They are able to observe them and communicate through a window. + +2. DISCIPLINARY ACTION REGARDING HIS SUICIDE ATTEMPT: There are suggestions in the records that Mr. Epstein was subjected to a disciplinary process for his attempted suicide. Is that correct? Was he disciplined in any way? If so, why? Did jail officials not believe his attempt was genuine? Is disciplinary action common after a suicide attempt? BOP provided us with a redacted copy of the incident report, which said Epstein was read his rights with regards to the incident. Does that signify that he underwent a disciplinary hearing? There also are references to the incident as "mutilation." Is discipline a common procedure after a suicide attempt? + +While we decline to comment specifically as to any inmate, as a general matter, the BOP's inmate discipline program is authorized by 18 U.S.C. 4042(a)(3), and can be found on our public website here https://www.bop.gov/policv/progstat/5270.90 cnl.pdf. The provisions outlined in the BOP's inmate discipline program helps ensure the safety, security, and orderly operation of correctional facilities, and the protection of the public. Under Chapter 3 of the policy, inmates are referred to a mental health professional for examination if it appears that an inmate is mentally ill. + +3. BOP produced a record that said the incident report for Jeffrey Epstein's attempted suicide was expunged without explanation. Can you explain what this means or why that was done? + +## Option 1. Decline to comment + +4. THE MCC STRUCTURE: BOP produced a record that quoted Jeffrey Epstein as asking an inmatecompanion: "Who's the best cook on 11 North?" Was there a kitchen on 11 North in the MCC? Press accounts describe the MCC as 12 stories tall -- is that correct? + +MCC New York is a 12-story administrative facility. There is a kitchenette on the 11th floor where inmates are able to prepare and consume items from the commissary. + +5. THE SIGN: BOP produced to us one document, labeled "sign", which appears to have been posted somewhere in the jail. We have attached it as a PDF to this email and we would like to know the circumstances of its creation and posting. Was it posted in the jail, where was it put up, and by whom? Do you know who created it and posted it? And do you know the circumstances of the handwritten graffiti on it (the word "mandator( is underlined and there is a question mark after it. The sign refers to "GOD: Does BOP know who, in the context of the sign, GOD refers to? + +We cannot speak to the validity or origination of the signage. + +6. PHONE CALLS: The BOP records conflict in stating the number of social calls Epstein was known to have made. Some records indicate he made 2 and another suggests he made 3. Does BOP know how many social calls Epstein made? Were any of the social calls monitored or recorded by BOP? + +We respectfully decline to comment + +7. PHOTOS OF EPSTEIN WHILE ON SUICIDE WATCH - The inmate companion logs provided by BOP reflected that on two occasions, a jail officer took a photo of Epstein at in his cell. Is it common or proper for inmates on suicide watch to be photographed? Did this violate any rule? + +While we decline to comment specifically as to any inmate, as a general matter, inmate photography is not prohibited in all instances, but there may be circumstances where photography is needed to document events or actions. + +8. CLOSURE OF MCC: Did the irregularities and errors by BOP employees in the lead-up to Epstein's death play any part in the decision to close the MCC earlier this fall? If so, please explain. + +The Department of Justice is committed to ensuring that every facility in the federal prison system is not only safe and secure, but also provides people in custody with the resources and programs they need to make a successful return to society after they have served their time. As part of this effort, the Bureau of Prisons has assessed steps necessary to improve conditions at the Metropolitan Correctional Center (MCC) in New York City. In an effort to address the issues at MCC NY as quickly and efficiently as possible, the Department decided to close the MCC, at least temporarily, until those issues have been resolved. + +9. PSYCH EVALUATIONS: The records show that when Epstein arrived at the MCC, a BOP employee recommended he be evaluated by the psychology department. That was delayed until the following day. Soon after, on July 8, there was another recommendation that he be evaluated for suicide risk. That assessment was delayed until July 9. Are these delays normal? + +While we decline to comment specifically as to any inmate, as a general matter, individuals are commonly referred to Psychology Services upon their arrival. The nature of the referral may affect the timing and steps taken thereafter. \ No newline at end of file diff --git a/marker2/ds9/EFTA00090232/EFTA00090232.metadata.json b/marker2/ds9/EFTA00090232/EFTA00090232.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..7d8061a23d80b06e221e1e7e6841ad117a4c7e1b --- /dev/null +++ b/marker2/ds9/EFTA00090232/EFTA00090232.metadata.json @@ -0,0 +1,169 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090232.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 8158, + "elapsed_seconds": 0.86, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "SPECIFIC QUESTIONS", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 479.52 + ], + [ + 169.0792236328125, + 479.52 + ], + [ + 169.0792236328125, + 493.5840759277344 + ], + [ + 68.544, + 493.5840759277344 + ] + ] + }, + { + "title": "Option 1. 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NATHAN, District Judge: + +The Court is in receipt of the Government's, Administrator Feldman's, and two anticipated witnesses' motions to quash the Defendant's Rule 17(c)(3) subpoena. Dkt. No. 486. The motions to quash are DENIED.' + +The Court hereby ORDERS the Administrator of the Epstein Victims' Compensation Program to produce to the Court via electronic thumb drive any materials responsive to the subpoena as soon as possible, but no later than 12:00 p.m. on November 24, 2021. + +Upon receipt, the Court will determine whether the parties may "inspect all or part" of the materials. Fed. R. Crim. P. 17(c)(1). In that event, the Court may determine that an appropriate protective order is necessary for the parties' review of some or all of the materials. Review under a protective order may better facilitate the review process of the narrow, specific, and targeted materials and may better ensure no trial delay, as compared to a review process solely by the Court. Accordingly, the parties shall negotiate a protective order and submit the proposal for approval by the Court no later than 12:00 p.m. on November 24, 2021. + +SO ORDERED. • + +I Administrator Feldman's request for oral argument is accordingly denied. + +Dated: November 22, 2021 +New York, New York + +![]() + +--- + +ALISON J. NATHAN +United States District Judge \ No newline at end of file diff --git a/marker2/ds9/EFTA00090235/EFTA00090235.metadata.json b/marker2/ds9/EFTA00090235/EFTA00090235.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..9c495c4434cfd32f0fc9479cbb718b37191a2228 --- /dev/null +++ b/marker2/ds9/EFTA00090235/EFTA00090235.metadata.json @@ -0,0 +1,120 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090235.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 1557, + "elapsed_seconds": 1.67, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 72.08999999999999 + ], + [ + 281.019775390625, + 72.08999999999999 + ], + [ + 281.019775390625, + 99.603515625 + ], + [ + 68.544, + 99.603515625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 61 + ], + [ + "Line", + 30 + ], + [ + "Text", + 12 + ], + [ + "PageFooter", + 2 + ], + [ + "SectionHeader", + 1 + ], + [ + "Footnote", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 9 + ], + [ + "Line", + 5 + ], + [ + "Text", + 4 + ], + [ + "PageFooter", + 4 + ], + [ + "Caption", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00090235" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00090237/EFTA00090237.md b/marker2/ds9/EFTA00090237/EFTA00090237.md new file mode 100644 index 0000000000000000000000000000000000000000..f6a66d396be09c59c7ffb248f016394192450863 --- /dev/null +++ b/marker2/ds9/EFTA00090237/EFTA00090237.md @@ -0,0 +1,84 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +United States of America + +v. + +Tova Noel, + +Defendant. + +TO: TOVA NOEL + +DOCUMENT ELECTRONICALLY FILED DOC #: DATE FILED: 5/25/2021 + +## Deferred Prosecution Agreement + +19 Cr. 830 (AT) + +On November 19, 2019, a grand jury sitting in this District returned a six-count indictment (the "Indictment"), which charged Tova Noel ("you") with committing offenses against the United States, to wit, conspiring to knowingly defraud the United States and to knowingly make and use a false writing or document, in violation of 18 U.S.C. § 371, and five counts of knowingly making and using a false writing or document, in violation of 18 U.S.C. § 1001. However, after a thorough investigation, and based on the facts of this case and your personal circumstances, the U.S. Attorney's Office for the Southern District of New York ("USAO-SDNY") has determined that the interests of justice will best be served by deferring prosecution in this District. Upon your acceptance of responsibility for your behavior and by your signature on this deferred prosecution agreement (the "Agreement"), prosecution will be deferred during the term of your behavior and satisfactory compliance with the terms of this Agreement for the period of six months from the date of this Agreement. + +The terms and conditions constituting your good behavior and satisfactory compliance are as follows: + +- (1) You shall refrain from violating any federal, state, or local law. You shall immediately contact your U.S. Pretrial Services Officer if arrested or questioned by a lawenforcement officer. +- (2) You shall associate only with law-abiding persons. +- (3) You shall work regularly at a lawful occupation, regularly attend school, and/or support or care for your legal dependents, if any, to the best of your ability, as approved by your U.S. Pretrial Services Officer. You shall notify your supervising U.S. Pretrial Services Officer prior to any work or school changes. +- (4) You shall not leave the contiguous United States without permission of your supervising U.S. Pretrial Services Officer. In accordance with this condition, the U.S. Pretrial Services Office shall return your passport upon the Court's entering this Agreement, and shall do so indefinitely unless this Agreement is violated. + +- (5) You shall notify your supervising U.S. Pretrial Services Officer immediately of any change in your place of residence. +- (6) You shall follow your supervising U.S. Pretrial Services Officer's instructions and advice. +- (7) You shall report to your supervising U.S. Pretrial Services Officer as directed. + +As a further condition you hereby consent to disclosure, by any federal, state, or local government agency, or by any medical or substance abuse treatment provider, to the U.S. Pretrial Services Officer supervising your case, of such medical and treatment records as may be requested by the Pretrial Services Officer to evaluate deferral of prosecution in this case You further agree that you will execute any additional consent forms that any such agency or provider may require to release such information. + +Special conditions are as follows: + +You shall truthfully and completely disclose all information with respect to the activities of yourself and others related to your employment by the Bureau of Prisons ("BOP"), which information can be used for any purpose. You shall agree to meet with and be interviewed by the USAO-SDNY, the Federal Bureau of Investigation, the Department of Justice, Office of the Inspector General ("DOJ-OlG"), and any other law enforcement agency designated by this Office. + +You shall complete 100 documented hours of community service, preferably related to the criminal justice system, including working with recently released inmates. The specific type of community service to be performed must be approved by your Pretrial Services Officer. + +The USAO-SDNY may at any time revoke or modify any condition of this provisional release or change the period of such supervision, which shall in no case exceed six months. The USAO-SDNY may discharge you from supervision at any time. The USAO-SDNY may at any time proceed with the prosecution for this offense should the USAO-SDNY, in its sole discretion, deem such action advisable. + +If upon completion of your supervision a written report from your supervising U.S. Pretrial Services Officer is received to the effect that you have complied with all the rules, regulations and conditions and special conditions applicable to your deferred prosecution, no further prosecution will be instituted in this District for the above offenses. + +Nothing in this Agreement shall be interpreted to preclude the BOP or the DOJ-OIG from taking any administrative action against you, including suspension or termination of employment, based on the facts alleged in the Indictment, the facts identified in the course of the investigation that led to the Indictment, or your own statements to the Dal-OIG or any other law enforcement entity. Nothing in this Agreement shall be interpreted to require the BOP or the DOJ-OIG to delay + +any administrative action until after the expiration of the period of deferment contemplated by this Agreement. You agree that a copy of this Agreement, including your admission and acceptance of responsibility, shall be provided to the BOP. + +\* s + +If you successfully complete the term of supervision and fulfills all the terms and conditions of this Agreement, the Government will move the Court to dismiss the Indictment as to the defendant. + +It is further understood that this Agreement and the terms and conditions set forth herein are limited to the facts and circumstances of this case and lack precedential value. + +Dated: New York, New York May 20, 2021 + +> AUDREY STRUASS United States Attorney for the Southern District of New York + +By: + +Assistant United States Attorneys + +The undersigned hereby consents to the foregoing. The undersigned hereby further admits that she willfully and knowingly completed materially false count and round slips regarding required counts and rounds in the Special Housing Unit of the Metropolitan Correctional Center ("MCC") on August 9, 2019 and August 10, 2019. The undersigned expressly waives any and all rights to a speedy trial pursuant to the Sixth Amendment to the United States Constitution, the Speedy Trial Act, §§ 3161 et seq., and any other pertinent provisions, and consents to the adjournment of all pending proceedings in this case. The undersigned further waives the applicable statute of limitations with respect to any prosecution that is not time-barred on the date that this agreement is signed. It is the intent of this provision to toll the applicable statute of limitations during the pendency of the deferred prosecution. + +The undersigned understands that pursuant to Title 18, United States Code, Section 3161(h)(2), this Agreement is subject to approval by the Court. Should the Court refuse to approve, and thereby reject, this Agreement, neither party shall be bound to any term of this Agreement, and no admissions in this Agreement may be used against the undersigned. + +Finally, the undersigned acknowledges that she has read this Agreement and has carefully reviewed each provision with her attorney. The undersigned and her attorney acknowledge that no threats, promises, or representations have been made, nor agreements reached, other than those set forth in this Agreement. The undersigned further acknowledges that she understands and voluntarily accepts each and every term and condition of this Agreement. + +Dated: New York, New York May2O, 2021 + +Jason y, Esq. Atto ey for Defend + +Tova Noel Defendant + +Pursuant to 18 U.S.C. §3161(h)(2), exclusion under the Speedy Trial Act of the period of time during which the prosecution of the defendant is deferred pursuant to this Agreement is hereby approved. + +Dated: New York, New York May 25, 2021 + +Honorable Analisa Torres United States District Judge + +The undersigned hereby consents to the foregoing and will accept supervision of the above-named defendant on the conditions set forth herein. + +Dated: New York, New York Maya 2021 + +> 4.4.44 nited Stattfs Prlitrial Services Officer \ No newline at end of file diff --git a/marker2/ds9/EFTA00090237/EFTA00090237.metadata.json b/marker2/ds9/EFTA00090237/EFTA00090237.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..fb51eb51d57199dd9d27ed62c7f6509f4d78f257 --- /dev/null +++ b/marker2/ds9/EFTA00090237/EFTA00090237.metadata.json @@ -0,0 +1,265 @@ +{ + "source_pdf": 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"block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00090237" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00090242/EFTA00090242.md b/marker2/ds9/EFTA00090242/EFTA00090242.md new file mode 100644 index 0000000000000000000000000000000000000000..df62c9e890b38d1750610fc7d56f08e886c5be5f --- /dev/null +++ b/marker2/ds9/EFTA00090242/EFTA00090242.md @@ -0,0 +1,84 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +United States of America + +v. + +Michael Thomas, + +Defendant. + +TO: MICHAEL THOMAS + +DOCUMENT ELECTRONICALLY FILED DOC #: DATE FILED: 5/25/2021 + +## Deferred Prosecution Agreement + +19 Cr. 830 (AT) + +On November 19, 2019, a grand jury sitting in this District returned a six-count indictment (the "Indictment"), which charged Michael Thomas ("you") with committing offenses against the United States, to wit, conspiring to knowingly defraud the United States and to knowingly make and use a false writing or document, in violation of 18 U.S.C. § 371, and three counts of knowingly making and using a false writing or document, in violation of 18 U.S.C. § 1001. However, after a thorough investigation, and based on the facts of this case and your personal circumstances, the U.S. Attorney's Office for the Southern District of New York ("USAO-SDNY") has determined that the interests of justice will best be served by deferring prosecution in this District. Upon your acceptance of responsibility for your behavior and by your signature on this deferred prosecution agreement (the "Agreement"), prosecution will be deferred during the term of your behavior and satisfactory compliance with the terms of this Agreement for the period of six months from the date of this Agreement. + +The terms and conditions constituting your good behavior and satisfactory compliance are as follows: + +- (1) You shall refrain from violating any federal, state, or local law. You shall immediately contact your U.S. Pretrial Services Officer if arrested or questioned by a lawenforcement officer. +- (2) You shall associate only with law-abiding persons. +- (3) You shall work regularly at a lawful occupation, regularly attend school, and/or support or care for your legal dependents, if any, to the best of your ability, as approved by your U.S. Pretrial Services Officer. You shall notify your supervising U.S. Pretrial Services Officer prior to any work or school changes. +- (4) You shall not leave the contiguous United States without permission of your supervising U.S. Pretrial Services Officer. In accordance with this condition, the U.S. Pretrial Services Office shall return your passport upon the Court's entering this Agreement, and shall do so indefinitely unless this Agreement is violated. + +- (5) You shall notify your supervising U.S. Pretrial Services Officer immediately of any change in your place of residence. +- (6) You shall follow your supervising U.S. Pretrial Services Officer's instructions and advice. +- (7) You shall report to your supervising U.S. Pretrial Services Officer as directed. + +As a further condition you hereby consent to disclosure, by any federal, state, or local government agency, or by any medical or substance abuse treatment provider, to the U.S. Pretrial Services Officer supervising your case, of such medical and treatment records as may be requested by the Pretrial Services Officer to evaluate deferral of prosecution in this case. You further agree that you will execute any additional consent forms that any such agency or provider may require to release such information. + +Special conditions are as follows: + +You shall truthfully and completely disclose all information with respect to the activities of yourself and others related to your employment by the Bureau of Prisons ("BOP"), which information can be used for any purpose. You shall agree to meet with and be interviewed by the USAO-SDNY, the Federal Bureau of Investigation, the Department of Justice, Office of the Inspector General ("DOJ-OIG"), and any other law enforcement agency designated by this Office. + +You shall complete 100 documented hours of community service, preferably related to the criminal justice system, including working with recently released inmates. The specific type of community service to be performed must be approved by your Pretrial Services Officer. + +The USAO-SDNY may at any time revoke or modify any condition of this provisional release or change the period of such supervision, which shall in no case exceed six months. The USAO-SDNY may discharge you from supervision at any time. The USAO-SDNY may at any time proceed with the prosecution for this offense should the USAO-SDNY, in its sole discretion, deem such action advisable. + +If upon completion of your supervision a written report from your supervising U.S. Pretrial Services Officer is received to the effect that you have complied with all the rules, regulations and conditions and special conditions applicable to your deferred prosecution, no further prosecution will be instituted in this District for the above offenses. + +Nothing in this Agreement shall be interpreted to preclude the BOP or the DOJ-OIG from taking any administrative action against you, including suspension or termination of employment, based on the facts alleged in the Indictment, the facts identified in the course of the investigation that led to the Indictment, or your own statements to the DOJ-OIG or any other law enforcement entity. Nothing in this Agreement shall be interpreted to require the BOP or the DOJ-OIG to delay any administrative action until after the expiration of the period of deferment contemplated by this Agreement. You agree that a copy of this Agreement, including your admission and acceptance of responsibility, shall be provided to the BOP. + +If you successfully complete the term of supervision and fulfills all the terms and conditions of this Agreement, the Government will move the Court to dismiss the Indictment as to the defendant. + +It is further understood that this Agreement and the terms and conditions set forth herein are limited to the facts and circumstances of this case and lack precedential value. + +Dated: New York, New York May 20, 2021 + +> AUDREY STRUASS United States Attorney for the Southern District of New York + +By: + +meys + +The undersigned hereby consents to the foregoing. The undersigned hereby further admits that he willfully and knowingly completed materially false count and round slips regarding required counts and rounds in the Special Housing Unit of the Metropolitan Correctional Center ("MCC") on August 9, 2019 and August 10, 2019. The undersigned expressly waives any and all rights to a speedy trial pursuant to the Sixth Amendment to the United States Constitution, the Speedy Trial Act, §§ 3161 et seq., and any other pertinent provisions, and consents to the adjournment of all pending proceedings in this case. The undersigned further waives the applicable statute of limitations with respect to any prosecution that is not time-barred on the date that this agreement is signed. It is the intent of this provision to toll the applicable statute of limitations during the pendency of the deferred prosecution. + +The undersigned understands that pursuant to Title 18, United States Code, Section 3161(h)(2), this Agreement is subject to approval by the Court. Should the Court refuse to approve, and thereby reject, this Agreement, neither party shall be bound to any term of this Agreement, and no admissions in this Agreement may be used against the undersigned. + +Finally, the undersigned acknowledges that he has read this Agreement and has carefully reviewed each provision with his attorney. The undersigned and his attorney acknowledge that no threats, promises, or representations have been made, nor agreements reached, other than those set forth in this Agreement. The undersigned further acknowledges that he understands and voluntarily accepts each and every term and condition of this Agreement. + +Dated: New York, New York + +May " 2021 + +frialteil Mantel' Figgins (May , 021 15:49 EDT) + +Montell Figgins, Esq. Attorney for Defendant MICh. . 4 .202116.04 EDT) + +Michael Thomas Defendant + +Pursuant to 18 U.S.C. §3161(hX2), exclusion under the Speedy Trial Act of the period of time during which the prosecution of the defendant is deferred pursuant to this Agreement is hereby approved. + +Dated: New York, New York May 25 2021 + +> Honorable Analisa Torres United States District Judge + +The undersigned hereby consents to the foregoing and will accept supervision of the above-named defendant on the conditions set forth herein. + +Dated: New York, New York May , 2021 + +> Digitally signed by Francesca Francesca Piperato Pi perato Date W2021.05.24 10:32:36 -04 United States Pretrial Services Officer \ No newline at end of file diff --git a/marker2/ds9/EFTA00090242/EFTA00090242.metadata.json b/marker2/ds9/EFTA00090242/EFTA00090242.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..dcd660c5c0732a96e1074923de5d7a9dcff62629 --- /dev/null +++ b/marker2/ds9/EFTA00090242/EFTA00090242.metadata.json @@ -0,0 +1,261 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090242.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 5, + "chars": 8388, + "elapsed_seconds": 1.07, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 72.08999999999999 + ], + [ + 281.3897705078125, + 72.08999999999999 + ], + [ + 281.3897705078125, + 99.603515625 + ], + [ + 68.544, + 99.603515625 + ] + ] + }, + { + "title": "Deferred Prosecution Agreement", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 361.08, + 126.35999999999999 + ], + [ + 537.5643920898438, + 126.35999999999999 + ], + [ + 537.5643920898438, + 141.603515625 + ], + [ + 361.08, + 141.603515625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 82 + ], + [ + "Line", + 42 + ], + [ + "Text", + 9 + ], + [ + "ListItem", + 4 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "ListGroup", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 74 + ], + [ + "Line", + 37 + ], + [ + "Text", + 7 + ], + [ + "ListItem", + 3 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "ListGroup", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 35 + ], + [ + "Line", + 18 + ], + [ + "Text", + 8 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 3, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 62 + ], + [ + "Line", + 31 + ], + [ + "Text", + 9 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 4, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 38 + ], + [ + "Line", + 18 + ], + [ + "Text", + 6 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00090242" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00090247/EFTA00090247.md b/marker2/ds9/EFTA00090247/EFTA00090247.md new file mode 100644 index 0000000000000000000000000000000000000000..e774062576f9973a42d2278d56c5301c1219b1b3 --- /dev/null +++ b/marker2/ds9/EFTA00090247/EFTA00090247.md @@ -0,0 +1,887 @@ +**About This Form** +FEES ("w" in computer) + +Please answer all questions below. The application deadline for first priority review is **February 15**. Applications made after this date are welcome and will be reviewed on a rolling admission basis. See the "Admissions" section of the Camp Extra (page 2) for complete application and scholarship/financial aid information. Sorry, but we cannot process an incomplete application. + +## Applicant Information + + Yes No Are you applying for Scholarship/Financial Aid? Yes No Are you applying for The Governor's Scholar Program? + +What Division are you applying for? Junior Session A Junior Session B Junior A & B Intermediate High School + +*Ready* + +International students: When providing telephone number, include the country code and the city code *before* the local telephone number. + +First Name \_\_\_\_\_ Second \_\_\_\_\_ First Name \_\_\_\_\_ Second \_\_\_\_\_ (Nickname?) \_\_\_\_\_ Date of Application \_\_\_\_\_ + +District Street Address \_\_\_\_\_ Home Telephone: Area Code + Number (Fax available?) \_\_\_\_\_ + +City \_\_\_\_\_ State \_\_\_\_\_ Zip \_\_\_\_\_ Boulevard (prevailing agency) \_\_\_\_\_ Address \_\_\_\_\_ + +Names of brothers and their ages \_\_\_\_\_ Names of sisters and their ages \_\_\_\_\_ + +F \_\_\_\_\_ Height \_\_\_\_\_ Weight \_\_\_\_\_ Grade you will complete by June. + +Name of your school. \_\_\_\_\_ Street Address \_\_\_\_\_ + + Yes No Have you previously attended \_\_\_\_\_ Write dates attended: + + Yes No Is a parent an alumni of Interlochen? Father Mother / Maiden name: \_\_\_\_\_ Year(s) of attendance: \_\_\_\_\_ + +## Additional International Applicant Information + + Yes No Are you a U.S. Citizen? If not a U.S. Citizen, indicate citizenship held: + +Is English the primary language spoken at home? \_\_\_\_\_ If not, what is the primary language? \_\_\_\_\_ + +Full Name of a contact person in the United States \_\_\_\_\_ Home Telephone: Area Code + Number (Fax available?) \_\_\_\_\_ + +## Parent or Guardian Information + +Applicant normally lives with: Father Mother Stepfather Stepmother Legal Guardian Other: + +If parent(s), what is current marital status? Single Matried Divorced Separated + +\_\_\_\_\_ + +Mother or Guardian (note relationship) Name \_\_\_\_\_ Occupation \_\_\_\_\_ + +\_\_\_\_\_ State \_\_\_\_\_ Zip \_\_\_\_\_ + +Name of your school \_\_\_\_\_ Office Telephone: Area Code \_\_\_\_\_ + +Father or Guardian (note relationship) Name \_\_\_\_\_ Occupation \_\_\_\_\_ + +Home Street Address \_\_\_\_\_ City \_\_\_\_\_ State \_\_\_\_\_ Zip \_\_\_\_\_ + +Name of Employer \_\_\_\_\_ Office Telephone: Area Code + Number \_\_\_\_\_ Office Fax: Area Code + Number \_\_\_\_\_ + +## Personal Information + +Note any physical, psychological, medical or other condition requiring special attention or care (such as sleepwalking, fear of storms, bed wetting, etc.) + +How do you rate your child in terms of personal adjustment, such as his or her sense of self worth, ability, independence, etc.? + +\_\_\_\_\_ + +Please give any information that might be helpful in guiding the educational and personal development of your child. + +## For Internal Use + +Sch/FA \_\_\_\_\_ Rec C \_\_\_\_\_ Tape # \_\_\_\_\_ MAJ \_\_\_\_\_ +Amt \_\_\_\_\_ Rec D \_\_\_\_\_ Video # \_\_\_\_\_ Re \_\_\_\_\_ +Work \_\_\_\_\_ FA E \_\_\_\_\_ Post # \_\_\_\_\_ I-20 + +DO NOT USE LETTERS MEDICAL INTERNATIONAL FORM THROUGH APPLICATION FORM. + +VOIC +5/16 + +Please list Course Names in order of preference. +**Camp session A** at left. +**Camp session B** at right. + +Private Lessons? + +Students in the Junior Division will be assigned three periods of arts activities, including private lessons. Students who complete grade 6 have the option of selecting an additional arts class in place of land recreation. Please refer to the "Junior Division" section in the Camp Extra for a complete discussion of arts activities, daily class scheduling and prerequisites. + +1. Session A + +1. Session B + +2. Session A + +2. Session B + +3. Session A + +3. Session B + +4. Session A + +4. Session B + +5. Session A + +5. Session B + + 4 - 30-min. lessons. Instrument: + + 4 - 30-min. lessons. Instrument: + + 4 - 60-min. lessons. Instrument: + + 4 - 60-min. lessons. Instrument: + +**Intermediate & High School Arts Activities** + +Students in the Intermediate Division will be assigned four periods of arts activities, including private lessons. Students who complete grade 9 have the option of selecting an additional class in place of recreation. High School students will be assigned four periods of arts activities, including private lessons. Please refer to your division's section in the Camp Extra for a complete discussion of arts activities, daily class scheduling and prerequisites. **Note:** the Camp does not include prerequisites and audition requirements. + +Major Activity: + At left; list Course Names in order of preference. + +Minor Activities: + At right; list Course Names in order of preference. + +1. First Choice Major Course Name / Instrument (if applicable) + +1. THEATRE ARTS / MUSICAL + +2. Second Choice Major Course Name / Instrument (if applicable) + +2. MUSIC / VOCAL + +3. Third Choice Major Course Name / Instrument (if applicable) + +2. Minor Course Name + +2. BEGINNING INSTRUMENT + +3. Minor Course Name + +3. CLASSES / FLUTE + +3. MODERN DANCE + +4. Minor Course Name + +4. Minor Course Name + +Private Lessons? + + 8-30-min. private lessons. Instrument: + + 8-60-min. private lessons with one period of practice daily. Instrument: + + 8-60-min. private lessons with two periods of practice daily. Instrument: + +Music Students -, + Please Answer: + +![](_page_1_Picture_80.jpeg) + +Previous experience in Orchestra: Number of Years / Position + +Previous experience in Band: Number of Years / Position + +List **two** difficult works performed in orchestra, band or in ensemble within the past year. + +List the **two** most difficult solos you have mastered on your primary instrument or sung. + +**THEATRE / MUSICAL THEATRE = Training at** + +What is your primary interest? Describe previous training and experience in this area. +**for stage craft, costuming, acting, improvisation, musical theatre, etc. Plays, performances, movies.** + +Dance, Theatre, Visual Art + Students - Please Answer + +**Additional References given to whom?** + +![](_page_1_Picture_89.jpeg) + +Optional. Applicant please indicate: + + Asian American + + Black/African American + + Chicano/Mexican American + + Puerto Rican + + Native American/American Indian + + White/Caucasian + + Other, please specify: + +No application can be processed without the signatures of Applicant and Parent/Guardian. + +![](_page_1_Picture_100.jpeg) + +**Please enclose the required \$225 with your application.** See page 2 of the Camp Extra for a complete discussion of Camp cost and refund policy. Your check is payable to [redacted]. You may use a credit card: VISA, MasterCard, Discover and American Express. + +## Part I Applicant + +*Address* + +Please complete the following items and request that the person to whom you are giving this form fill out Part II and return it by **February 15** to the [redacted] Admissions Office. This recommendation should be completed by a teacher, instructor or director who is very familiar with your abilities in your particular arts area. + +![](_page_2_Picture_27.jpeg) + +In what capacity have you known the person completing this form? + +*now congo* + +**THEATRE ARTS / MUSICAL THEATRE** + +What is your primary area of interest? If music, list instrument. + +## Part II Instructor + +The above student is making application for admission to the Interlochen Arts Camp and is asking that you complete this confidential recommendation form. **By returning this form by February 15**, you will insure a prompt review of his or her application. All information given will be treated in a strictly confidential and professional manner by the Camp. **Please return the completed form promptly to:** Admissions Office [redacted] + +If you have questions, please call the Admissions Office at [redacted] + + Please check if you would like to receive more information about Interlochen Center for the Arts and its year-round educational programs. + +### Estimate of applicant's success: + + Will probably be a superior student. Will probably be an above average student. Will probably be an average student. + + May have some difficulty and should have special guidance (please explain below). + +In relation to others in the candidate's age group whom you have known, please check the appropriate box for each item: + +| Artistic Potential | Outstanding | Very Good | Average | Below Average | +|------------------------|-------------------------------------------------|-----------------------------------------------|----------------------------------|----------------------------------------| +| Artistic Achievement | Outstanding | Very Good | Average | Below Average | +| Work/Practice Habits | Outstanding | Very Good | Average | Below Average | +| Initiative | Outstanding | Very Good | Average | Below Average | +| Creativity | Outstanding | Very Good | Average | Below Average | +| Common Sense | Outstanding | Very Good | Average | Below Average | +| Seriousness of Purpose | Outstanding | Very Good | Average | Below Average | +| Reaction to Criticism | Outstanding | Very Good | Average | Below Average | +| Self Discipline | Outstanding | Very Good | Average | Below Average | +| Peer Compatibility | Outstanding | Very Good | Average | Below Average | +| Conduct | Outstanding | Very Good | Average | Below Average | +| Integrity | Outstanding | Very Good | Average | Below Average | + +Additional comments, positive or otherwise, which the Camp should review when considering the applicant's acceptance. The Camp wishes to receive all information which will lead to a better understanding of the applicant and his or her experience to date. + +![](_page_3_Picture_24.jpeg) + +ALL COMMENTS I COULD MAKE FOR [REDACTED] WOULD BE MOST POSITIVE. SHE IS SINGULARLY GIFTED IN MUSIC AND BRAMA AND HAS MANY FACETS OF HER TALENT AND INTEREST INCLUDING PRAYING FLUTE, PIANO and HARP, SINGING IN A LOVELY VOICE AND AN AMAZINGLY WIDE RANGE OF NOTES, IN FOUR OR FIVE LANGUAGES, AND TAKING MUSICAL DIRECTION LIKE A PROFESSIONAL, THOUGH SHE IS LARGELY UNTRAINED TO DATE. SHE ALSO ADDS THE PROUNCY OF HER OWN CHARMING PERSONALITY TO ALL THESE SKILLS. HER DICTION IS PARTICULARLY GOOD, AND SHE IS MOST VERSATILE IN PRESENTING CHARACTERS. I RECOMMEND HER VERY HIGHLY AND AN SURE SHE WILL MAKE OPTIMAL USE OF HER TIME AT [REDACTED] + +Signature + +[REDACTED Signature] + +July 27, 1994 + +FIRMERLY A DIRECTOR OF [REDACTED] + +AUTHOR-LYRIST +S School + +Name of School (if applicable) + +[REDACTED Name and School information] + +City + +State + +FL + +Zip + +Please send admission materials to: + +Admissions + +[REDACTED Admissions information] + +By returning this form by **February 15** you will insure a prompt review of this student's application. The application is not considered complete until this information is received. + +## Part I Applicant + +Please complete the following items and request that the person to whom you are giving this form fill out Part II and return it by **February 15** to the [REDACTED] Admissions Office. This recommendation should be completed by a teacher in your school who knows you well and is working with you in an academic classroom setting. + +![](_page_4_Picture_191.jpeg) + +GEOGRAPHY TEACHER + +1 year + +In what capacity have you known the person completing this form? + +How Long? + +THEATREARTS/MUSICAL THEATRE + +What is your primary area of interest? If music, list instrument + +## Part II Teacher + +The above student is making application for admission to the Interlochen Arts Camp and is asking that you complete this confidential recommendation form. **By returning this form by February 15**, you will insure a prompt review of his or her application. All information given will be treated in a strictly confidential and professional manner by the Camp. **Please return the completed form promptly to:** Admissions Office [REDACTED] + +If you have questions, please call the Admissions Office at [REDACTED] + + Please check if you would like to receive more information about Interlochen Center for the Arts and its year-round educational programs. + +### Estimate of applicant's success: + + Will probably be a superior student. Will probably be an above average student. Will probably be an average student. + + May have some difficulty and should have special guidance (please explain below). + +In relation to others in the candidate's age group whom you have known, please check the appropriate box for each item: + +| Academic Potential | Outstanding | Very Good | Average | Below Average | +|------------------------|-------------------------------------------------|------------------------------------|----------------------------------|----------------------------------------| +| Academic Achievement | Outstanding | Very Good | Average | Below Average | +| Work/Practice Habits | Outstanding | Very Good | Average | Below Average | +| Initiative | Outstanding | Very Good | Average | Below Average | +| Concern for Others | Outstanding | Very Good | Average | Below Average | +| Common Sense | Outstanding | Very Good | Average | Below Average | +| Seriousness of Purpose | Outstanding | Very Good | Average | Below Average | +| Reaction to Criticism | Outstanding | Very Good | Average | Below Average | +| Self Discipline | Outstanding | Very Good | Average | Below Average | +| Peer Compatibility | Outstanding | Very Good | Average | Below Average | +| Conduct | Outstanding | Very Good | Average | Below Average | +| Integrity | Outstanding | Very Good | Average | Below Average | + +**D** + +Additional comments, positive or otherwise, which the Camp should review when considering the applicant's acceptance. The Camp wishes to receive all information which will lead to a better understanding of the applicant and his or her ability to fit in [redacted] during situation. + +*is a very intelligent student. She is a delight to have in class. She maintains a superior rank among her peers. She is creative, sensitive, and witty in all her donatment. Please consider [redacted] for any position she seeks.* + +![](_page_5_Picture_22.jpeg) + +Signature + +A 269839 + +![](_page_5_Picture_25.jpeg) + +4-27-94 + +Date + +Print Name Above + +Code Back + +![](_page_5_Picture_30.jpeg) + +Circle + +*K.* + +State + +Zip + +Office Fax: Area Code + Number + +**Please send admission materials to:** + +Admissions + +![](_page_5_Picture_38.jpeg) + +By returning this form by **February 15** you will insure a prompt review of this student's application. The application is not considered complete until this information is received. + +![](_page_6_Picture_0.jpeg) + +3XS + NOV 18 REC'D +**About This Form** + +# Application for Admission + +IG- BOTH + S# 269116 M# A269850 F# 4/A IN 4/10/95 + +Answer all questions below. The application deadline for **first priority review is February 15**. Applications made after this date are welcome and will be reviewed on a rolling admission basis. See the "Admissions" section of the Camp Extra (page 2) for complete application and financial aid information. Sorry, but we cannot process an incomplete application. + +**Applicant Information** + +Are you applying for Financial Aid? Yes No Have you applied for The Governor's Scholar Program? Yes No + What Division are you applying for? Junior Service A Junior Service B International Service A International Service B High School + +[Redacted Name and State information] + +International students: When providing telephone number, include the country code and the city code *before* the local telephone number. + +[Redacted Name and State information] + +Names of brothers and their ages. + +Names of sisters and their ages. + +Have you previously attended Interlochen Arts Camp (excluding All-State)? + + Yes No Year(s) attended: *1 year/1994* + +**International Applicants Only** + +Country of birth + Secondary language (if any) spoken at home + Full name of a contact person in the United States Home Telephone: Area Code + Number (Fax available?) + +**Parent or Guardian Information** + +[Redacted Name and State information] + +Father or Guardian (note relationship) Name + +Occupation + +Home Street Address + +City + +State + +Zip + +Name of Employer + +Office Telephone: Area Code + Number + +Office Fax: Area Code + Number + +**Personal Information** + +Note any physical, psychological, medical or other condition requiring special attention or care (such as sleepwalking, fear of storms, bed wetting, etc.) +*She adjusts extremely well and quickly, good self-worth and ability and is How do you rate your child in terms of personal adjustment, such as his or her sense of self worth, ability, independence, etc.?* +*very independent.* + How do you rate your child in terms of social adjustment? Has many friends Has few friends Has one or two close friends + Has had close association with older children Younger children Children his or her own age + +NO + +Is there any phase of personal or social adjustment which you hope Camp will aid? + +Please give any information that might be helpful in guiding the educational and personal development of your child. + +*Ready* + +*Ck. #269 + Ack. #269/3x + 18 KB* + +| Sch/FA | Rec C | Tape # | MAJ | +|--------|---------|---------|---------| +| Amt | Rec D | Video # | Res | +| Work | EAF N/A | Port # | I-20 NO | + +Piano + +3 years + +What is your secondary instrument or interest? + +Number of Years Studied + +Previous experience in Orchestra: Number of Years / Position + +Previous experience in Band: Number of Years / Position + +List **two** difficult works performed in orchestra, band or in ensemble within the past year. + +*Nothing has been very difficult for me. (I am at high level of reading music)* + +List the **two** most difficult solos you have mastered on your primary instrument or sung. + +**MUSICAL THEATRE.** I have had fairly mount of acting experience. I go to the + +What is your primary interest? Describe previous training and experience in this area. + +School of Arts for music and theatre. I've done commercials, many performances singing, plays, skits, etc. I've been in New York Broadway + +**Junior and Intermediate Class Schedule** + +Students in the Junior Division will be assigned three periods of classes, including private lessons. Students who complete grade 6 have the option of selecting an additional class in place of land recreation. Intermediate Division students will be assigned four periods of classes, including private lessons. Students who complete grade 9 have the option of selecting an additional class in place of recreation. Please refer to your division's section in the Camp Extra for a complete discussion of classes, scheduling, prerequisites and audition requirements. + +**CHORUS** + +1. Session A (Intermediate: First Choice Major) + +**MUSICAL THEATRE** + +2. Session A (Intermediate: Second Choice Major) + +**OPERETTA** + +3. Session A + +**VOCAL TECHNIQUES** + +4. Session A + +**MODERN DANCE (minor)** + +5. Session A **BEGINNING WIND CLASS-FLUTE** + + 4 - 30-min. lessons. Instrument: + + 4 - 60-min. lessons. Instrument: + +*It doesn't matter which Session !!!* + +**CHORUS** + +1. Session B (Intermediate: First Choice Major) + +**MUSICAL THEATRE ENTRE** + +2. Session B (Intermediate: Second Choice Major) + +**MUSIC THEORY (ADVANCED)** + +3. Session B + +**VOCAL TECHNIQUES** + +4. Session B + +**MODERN DANCE (minor)** + +5. Session B **BEGINNING WIND CLASS-FLUTE** + + 4 - 30-min. lessons. Instrument: + + 4 - 60-min. lessons. Instrument: + +Please list Class Names in order of preference. + +**Camp session A** at left. + +**Camp session B** at right. + +Private Lessons? + +**High School Class Schedule** + +High School students will be assigned five periods of classes, including private lessons. Please refer to your division's section in the Camp Extra for a complete discussion of classes, scheduling, prerequisites and audition requirements. **Note:** the Camp does not guarantee participation in more than one major activity. + +Major Courses: + +At left; list Class Names in order of preference. + +Minor Courses: + +At right; list Class Names in order of preference. + +1. First Choice Major Course Name / Instrument (if applicable) + +2. Second Choice Major Course Name / Instrument (if applicable) + +3. Third Choice Major Course Name / Instrument (if applicable) + +1. Minor Course Name + +2. Minor Course Name + +3. Minor Course Name + +4. Minor Course Name + +5. Minor Course Name + +Private Lessons? + + 8-30-min. private lessons. Instrument: + + 8-60-min. private lessons. Instrument: + +**Additional** + +References given to whom? + +Name of person in receipt of Artistic Recommendation form "C." + +Home Telephone: Area Code + Number + +Name of person in receipt of Academic Recommendation form "D." + +Home Telephone: Area Code + Number + +How did you first learn about Interlochen? + +**Optional.** Applicant please indicate: + + Asian American + + Black/African American + + Chicano/Mexican American + + Puerto Rican + +*No application can be processed without the signatures of Applicant and Parent or Guardian.* + +**Please enclose the required \$225 with your application.** See page 2 of the Camp Extra for a complete discussion of Camp cost and refund policy. Your check is payable to [redacted]. You may use a credit card: VISA, MasterCard, Discover and American Express. + +## About This Form + +Please answer all questions below. Refer to the "Admissions" section of the Camp Extra (page 2) for complete application and financial aid information. The application deadline for first priority review is **February 15**. Applications made after this date are welcome and will be reviewed on a rolling admission basis. **Send all materials to:** Admissions Office [REDACTED] + +Complete address and phone information are on the back of this form. + +**Sorry, but we cannot process an incomplete application.** + +## Application Checklist + +- Completed Application and Course Selection Form +- Application Form Signatures +- \$225. Application Fee +- Audition Materials Enclosed if Required (see your division's Course Descriptions in the Camp Extra). + +## Camp Application Fee + +Please enclose the required \$225. with your application. Make checks payable to [REDACTED] If you wish, you may charge the application fee to VISA, MasterCard, Discover or American Express. + +Credit Card Name and Number Expiration Date Print Card Holder Name Card Holder Signature + +![](_page_10_Picture_268.jpeg) + +## Signatures + +*We cannot process your application without the signatures of Applicant and Parent/Guardian.* + +*Signature and sent my answers are true and correct.* + +*Coverage: I hope you know applicant is not intermediate sent only.* + +## Applicant Information + +What Division are you applying for? Junior Session A Junior Session B Intermediate Session A Intermediate Session B + + High School Advanced String Quartet Institute (Session A-High School only) Creative Writing Institute (Session B-High School only) + +![](_page_10_Picture_275.jpeg) + +Non-U.S. students: When providing telephone number, include the country code and the city code before the local telephone number. + +Date of this Application + +State 9 Zip + +Area Code + Number Grade completed by June. + +Social Security Number + +![](_page_10_Picture_281.jpeg) + + Yes No Have you previously attended Interlochen Arts Camp (excluding All-State)? Write years attended: 2 (1994, 1995) + +*Friend* + +How did you first learn about Interlochen? + +**Optional.** Applicant please indicate: Asian American African American Mexican American Puerto Rican Asian + + Native American Caucasian Other, please specify: + +## Citizenship Information + +If you are **not** a U.S. Citizen, please complete this section. + +Country of Birth Country issuing the passport you will use to travel + +Full name of a contact person in the United States + +Home Street Address City State Zip + +Home Telephone: Area Code + Number Fax Number: Area Code + Number + +*3/7 CLW* + +## Teacher Information + +Name of current primary instructor in your arts area: [REDACTED] CHORUS/VOICE INSTRUCTOR + +Title/Position: FL- [REDACTED] + +Home Street Address City State Zip + +Home Telephone: Area Code + Number Fax Number: Area Code + Number Office Telephone: Area Code + Number + +Sch/FA N Audition # INT000048 I-20 MAJ TMUCL ACCEPT + +# 111494 \$256 TMUCL (3) Part Camp Mistacle + +### Parent or Guardian Information + +![](_page_11_Picture_1.jpeg) + +Home Street Address + +\tint Employer and address + +City Stare Zap + +Off Telephone: Area Code • Number Office Faa: Area Cade • Number + +### Financial Information + +If you are applying for aid. please fill our this section. + +Mother or Guardian Please Answer + +Father or Guardian PleasCAnswer + +Please attach a copy of your most recent Federal Tax Form 1040 to this form. + +At< yk, ..pplying for financial aid%O Yes IWNo Arc ycra Apr,:y:ng for The Governor's Scholar Program? O Yes ZKo + +Dora the student applying expect to be the recipient of any funds (scholarship. Bane. award or pnze) from any country. stare, organization or individual specifically for attendance at the Interlochen Arts Camp% ❑ Yes Er No + +If yes. name the title of award. source of award and amoont. What i + +Earnings this pear. + +Value of real estate. + +Earnings this year. + +Value of real estate. + +Please note unusual expenses or circumstances you would like taken into + +Choosing a Major All Juniors (grades 5-6) are designated as General Arts below. Intermediate Division (grades 6-9) and High Scl only minor courses, your designated major will be Gent programs in the Intermediate and High School Divisiol The information below must be completed it + +Junior Please refer to the "Junior Division- section in the Camp requisites and audition requirements. + +1. Session A: Band or Siring Orchestra Imtrument 1. Session B: Band or Stnng Orchestra Instrument + +### Intermediate + +Please enter the Major Code from the Camp Extra (i.e. DMODN or BCLAR-INET) + +Please refer to the "Intermediate Division- section in the Camp Extra for a complete discussion of major arts activities, course codes, class scheduling, prerequisites and audition requirements. + +I. Session A: (first choke major codennstnunent) S. &nil= B: (first choice major code/instrument) + +2. Session A: (second choke major codeinstrument) 2. Session B: (second choice major tedefinstrurnent) + +### High School + +Please enter the Major and Code from the Camp Extra. (i.e. TMUCL OR OVIOLIN) Please refer to the "High School Division- section in the Camp Extra for a complete discussion of major arts activities, daily class scheduling, prerequisites and audition requirements. + +7W6arge PgioWcriew ) music& -rinuct\_ + +L Fast Choice Major Course Name and Code Instrument (if applicable) saer ertenZ Moen. + +2. Second Choke Major Course Name and Code Instrument (if applicable) + +### About This Form + +### Applicant Name + +This part of the application will be used for class registration. Your major will he determined through the Admissions process. You do not need to indicate your major on this page. Please complete the appropriate section to indicate classes that you would like in addition to your major. + +First Name Middle Lug + +### Junior + +Please list class names in order of preference. Do not list according to time. ' Remember to include all classes since there are no majors in this division. + +Students in the Junior Division will be assigned three periods of arts activities, including private lessons. Students who complete grade 6 have the option of selecting an additional arts class in place of land recreation. Please refer to the "Junior Division" section in the Camp Extra for a complete discussion of classes, scheduling and prerequisites. + +1..Saston A: (first choice area of interns) I -Session B. (lint choke stn of insane) + +Session A: (second choice arm cruxes's.) 2. Session B: (second Omer area al inteiels) + +&Session A: (third choice) 3-Session B: (third choice) + +4. Session A: (fourth choice) 4- Samuel B: (fourth choice) + +5. Session A: (alternate choice) 0.Session B: (alternate choice) + +Private Lessons 0 4- 30 minuet lemons. (Instrument) 0 4 30 minute lessons. (Inumunem) + +0 4 . 60 minute lemons. (Instrument) 0 4 . 60 minute lessons. (Sacrament) + +Poitnet Campers Only: Teacher preference for private lessons. Former (simpers Only Teaches preference for pr. lessons. + +### Internals!. + +Please list only minor class names in order of preference. Do not list according to time. Please note that most majors will count as two periods of classes. + +Private Lessons + +Students in the Intermediate Division will be assigned four periods of arts activities, including private lessons. Students who complete grade 9 have the option of selecting an additional class in place of recreation. Please refer to the "Intermediate Division" section in the Camp Extra for a complete discussion of classes, scheduling, prerequisites and audition requirements. + +1. Setae A: (fiat choice) 1. Session B. (line chart) + +2. Session A: (attend choice) 2. Seams B: (mad choice) + +3. Session A: (third choice) 3. Session B: (third choice) + +4. Session A. (alternate choice) 4. Session B: (alternate choice) + +O 4 30 minute lessons. (Inutomms) 0 4.30 minute lessons. (Instrument) + +O 4.60 minute lessons. (Instrument) 0 4 - 60 minute Irma fimuument) + +O 4 .60 minute lessons with 2 ponds wage. (Instrumem) 0 4 - 60 minute lessons with 2 periods pactire.Onunienent) + +Forme, Campers Only: Trochee prefennce for minor leuom. Fan\*. Campers Only Teacher preference for ptivase know.. + +### High School + +Please list only minor class names in order of preference. Do artist according to time. Please note that most majors will count as two periods of classes. + +High School students will be assigned five periods of arts activities, including private lessons. Please refer to the "flesh School Division" section in the Camp Extra for a complete discussion of classes, scheduling, prerequisites and audition requirements. + +0 eereitit L110 r KS hr) L Fi /Choice 1. First Altetnste + +2. Second Choice 2. Second Alternate + +3. Third enure + +4. Founts Choice + +.4., Voice soprano + +Describe previous training and experience in this area. + +CHECK LAST YEARS' RECORDS OF GREAT ACHEIVEMENTS! + +What is your secondary instrument or interest? + +Number of Years Studied + +Describe previous training and experience in this area. + +**Music Students:** + +Previous experience in Orchestra: Number of Years / Position + +Previous experience in Band: Number of Years / Position + +List **two** difficult works performed in orchestra, band or in ensemble within the past year. + +Nothing's too difficult! + +List the **two** most difficult solos you have mastered on your primary instrument or sung. + +**Personal Information** + +![](_page_13_Picture_50.jpeg) + +Note any physical, psychological, medical or other condition requiring special attention or care (such as sleepwalking, fear of storms, bed wetting, etc.). + +None + +How do you rate your child in terms of personal adjustment, such as his or her sense of self worth, ability, independence, etc.? + +See records and awards from last year + +How do you rate your child in terms of social adjustment? Has many friends Has few friends Has one or two close friends + + Has had close association with older children Younger children Children his or her own age + +No + +Is there any phase of personal or social adjustment which you hope Camp will aid? + +Please give any information that might be helpful in guiding the educational and personal development of your child. + +**Send all materials and direct inquiries to:** + +When using U.S. Postal Service send to: + +When using Federal Express, UPS and Airborne Express send to: + +Telephone: + +[Redacted] \ No newline at end of file diff --git a/marker2/ds9/EFTA00090247/EFTA00090247.metadata.json b/marker2/ds9/EFTA00090247/EFTA00090247.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..23c3e66dfaaeef61b694dbd1c95a1b601b05e556 --- /dev/null +++ b/marker2/ds9/EFTA00090247/EFTA00090247.metadata.json @@ -0,0 +1,1791 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090247.pdf", + "engine": 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sha256:502ac9588490096b323914a72936eae3fc5d8f60208336d8dee7a473fc2654a0 +size 1820 diff --git a/marker2/ds9/EFTA00090247/_page_6_Picture_0.jpeg b/marker2/ds9/EFTA00090247/_page_6_Picture_0.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..a0350439aee0e27dbe9307eeb81b3fc7022eb62d --- /dev/null +++ b/marker2/ds9/EFTA00090247/_page_6_Picture_0.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:2a4710ad910b79f4c713b8915ccf249f63388fa8bbfeb21665654780086fe8f1 +size 44354 diff --git a/marker2/ds9/EFTA00090261/EFTA00090261.md b/marker2/ds9/EFTA00090261/EFTA00090261.md new file mode 100644 index 0000000000000000000000000000000000000000..f38d07688caf1a6e0484bd5b3853a7b91df21ab9 --- /dev/null +++ b/marker2/ds9/EFTA00090261/EFTA00090261.md @@ -0,0 +1,345 @@ +![](_page_0_Picture_1.jpeg) + +## Memorandum + +To: ein From: Interlochen Center for the Arts Re: c o ars ip Lodge Information Date: 8/26/93 + +Ihave instructed Town and Country Log Homes to send you the blueprints for the proposed scholarship lodges we anticipate building on campus. Karen Sargent, anoted architect and Interlochen Alumni from New Jersey, is in the process of modifying the plans to incorporate wheel chair and handicap accessibility. She will forward the plans to me upon completion. + +The basic plan for one-half of the lodge is priced in the neighborhood of \$125,000 to \$150,000, depending on the options selected. Karen is also working on the cost for modifying the structure. I will send them on to you upon my return from Colorado in mid-September. + +Ihave spoken with Dean Boal and our Buildings and Grounds Director. We believe the area next to Frohlich lodge is the optimal spot for placement due to its location on the water and accessibility for handicapped vehicles in the winter. + +If you are interested in proceeding with the concept, I will be happy to send aformal proposal upon my return. + +All is well here, but abit muggy. + +Best wishes, + +![](_page_0_Picture_11.jpeg) + +Inteitchen .arts Academy Mierlochen Arts Camp Interlochen Public Radio 88.7 FM/10P 9 FAl + +GOVERNMENT EXHIBIT 741 + +52 20 Cr 330 (AJN) + +![](_page_1_Picture_1.jpeg) + +February 9, 1994 + +Mr. Jeffrey Epstein J. Epstein and Company, Inc. The Villard House 457 Madison Avenue New York, NY 10022 + +Dear Jeffrey: + +Ihave talked to you and Ghislaine on several occasions to say thank you. But, I wanted to express in writing my personal and professional gratitude for the very generous gift \$20 0 for a new scholarship lodge. It is truly an extraordinary sture. + +Ithought an update would be appropriate at this time. + +- 1. The contract with Town and Country has been executed and they have scheduled construction of the lodge. +- 2. We are waiting for the temperature to rise above 10-15 degrees so that we can move the existing buildings and set the foundation. (The June target date remains at this time.) Design and construction of the exterior walls is underway. +- 3. You have approved the latest set of drawings with the basement entrance as indicated and approved the green roof which works for us as well. +- 4. We are requesting furniture packages from local vendors that will be both aesthetic and functional for a rental lodge. When we receive the packages and corresponding quotes, we will send them on to Ghislaine for her comments and suggestions. +- 5. We anticipate setting aside all lodge income in the 1994 Camp season and placing the net income in an endowment fund so that subsequent repairs, maintenance and furniture replacement are funded through the endowment. All succeeding income will be placed into the Jeffrey Epstein Scholarship + +Mr. Jeffrey Epstein +Page 2 +February 9, 1994 + +Fund for deserving and talented students. When awards are made, Interlochen will notify you, with respect to the recipients. The recipient will also be asked to communicate with the donor. If you would like to met the students, we will help arrange a meeting on campus as well. + +1. 6. At present we are calling the lodge the "Jeffrey E. Epstein Scholarship Lodge." If you would like it named in another manner, please contact me with the appropriate name or wording. +2. 7. Under the charitable contribution act, you are permitted use of the lodge for two weeks each year, without any negative implications in respect to the full tax deductibility of your gift. Naturally, we would like you to visit the new lodge this summer. So that we might begin to book the lodge, I would ask you to consider what two weeks you would like reserved for your use. Perlman will be giving his concert on August 7, 1994. I have enclosed the appropriate tax code for your file. + +We have much to discuss as we move towards completion, but I thought this might be helpful. + +Jeffrey, we really appreciate all that you do for Interlochen. Somehow thank you seems inadequate for your continued commitment and generosity. We are most grateful. + +Warmest regards, + +![](_page_2_Picture_318.jpeg) + +Vice President +Institutional Advancement + +Enclosure + +February 22, 1994 + +Mr. Jeffrey Epstein J. Epstein and Company, Inc. The Villard House 457 Madison Avenue New York, NY 10022 + +Dear Jeffrey: + +![](_page_3_Picture_2.jpeg) + +On behalf of the Interlochen Board of Trustees, I have been asked to convey our sincere and heartfelt appreciation for your very generous crift of \$200,000,for a scholarship lodge. As you have requested, this soon to be constructed lodge will be handicapped accessible and designed to meet the ADA requirements. This is the first such facility on our campus. + +We are pleased to accept and acknowledge your significant commitment to Interlochen and to the students, parents and guests who visit our campus each year. + +You have set the standard for others in creating an aesthetically pleasing and accessible new scholarship lodge here among the pines of northern Michigan. + +Warmest regards, + +James L. Tolley Chair, Board of Trustees + +![](_page_3_Picture_10.jpeg) + +![](_page_4_Picture_1.jpeg) + +December 23, 1994 + +Ghislaine Maxwell ,7. FostrIp & rnmnanm Inc. cite 1 i1 lard Rbuse 457 Madison Avenue New York, NY 10022 + +Dear Ghislaine: + +Enclosed is the envelope we recently found in cleaning the Epstein Lodge. Apparently it lodged between the wall and the dresser. It was not discovered until the unit was moved for cleaning. + +As we discussed, the final week of Camp is August 14 through the 20th. I have reserved the lodge for Jeffrey's use. In addition, he has one more week that he can reserve for himself or guests he may wish to have use it. Attached is a list of the dry goods that are in storage as part of Jeffrey's personal inventory. Please advise if we are missing any items you are aware of being sent here. + +Please convey to Jeffrey how pleased we are to have such a facility on our campus. In fact, the President Elect will be staying in the lodge until his family's furniture arrives. It is a remarkable place. We are grateful. + +Best wishes for a wonderful holiday season. + +Sincerely + +Vice President Institutional Advancement + +Enclosures: Inventory listing Lost envelope + +## INTEROFFICE MEMORANDUM + +Date: 20-Dec-1994 01:57pm EST From: + +Dept: Operations Tel No: + +TO: + +CC: + +Subject: Epstein inventory linens + +The following items of linens have been inventoried for the Epstein Lodge. + +1 ea. Duvet down bed pillow (white) 1 ea. Down comforter (white) 1 ea. Indiana Blanket 1 ea. King size blanket (white) 2 ea. Bean bag standard pillows 4 sets Navy Blue towels (includes hand towel and wash cloth each set) 6 large white bathsheets 6 sets White towels (includes hand towel and wash cloth each set) 3 sets White King size sheets (includes flat and fitted sheet) 3 sets White pillow shams (2 shams each set) + +*Copy* + +February 21, 1995 + +![](_page_6_Picture_148.jpeg) + +Mr. Jeffrey Epstein +The Villard House +457 Madison Avenue +New York, NY 10022 + +Dear Jeffrey: + +It is not difficult to say thank you for your recent gift of \$25,000, or to express our gratitude for your continuing generosity (for tax purposes, it should be noted that your contribution was received by Interlochen Center for the Arts in support of general operations. Interlochen has not provided any goods or services to you in exchange for your gift). But, it is difficult to adequately express our deep sense of appreciation for all that you have done in furthering the mission of Interlochen over the past four years. In addition to your personal and significant annual contributions, you have opened up and hosted several alumni meetings and receptions (our New York alumni group is now one of the strongest in the nation). It all began with our first meeting at the Villard House. Dr. Tuckerman's recent endowed gift in your honor speaks to your support and commitment to Interlochen. + +Last year we built the Epstein Lodge, Interlochen's first scholarship lodge in many years. It is our premier guest accommodation and the first handicapped accessible facility. Most recently you gave your strong endorsement of Interlochen to the [REDACTED] family as they investigated the Academy offerings for their daughter, [REDACTED]. + +You have done much in the name of Interlochen. We thank you. If I might borrow from my colleague Dr. Luby, you are a mensch! + +Best wishes for a successful 1995. + +Sincerely, + +![](_page_6_Picture_156.jpeg) + +Vice President +Institutional Advancement + +![](_page_7_Picture_1.jpeg) + +January 19, 1995 + +Mr. Jeffrey Epstein Epstein Foundation 457 Madison Avenue New York, NY 10022 + +Dear Jeff: + +On behalf of the students, faculty, and staff at the Interlochen Center for the Arts, I want to thank you for your generous contribution of \$25,000. + +4 As you know, the support dollars received each year through the efforts of many individuals add up to a wealth of opportunities for those young students who come to make Interlochen their artistic home. + +Your gift enables us to continue to provide quality educational opportunities, enhance our tradition of excellence, and assist in the development of tomorrow's leaders. + +You have made a difference. For that irreplaceable gift, we thank you. + +With warm regards, + +Dean Boal President + +arecat terns jertrisr÷seari ssrf- + +March 20, 1996 + +![](_page_8_Picture_2.jpeg) + +Mr. Jeffrey E. Epstein J. Epstein Foundation The Villard House 4576 Madison Avenue New York, NY 10022 + +Dear Jeffrey: + +Thank you for the gift of \$20,000 received on 3/18/96 designated for the Olympics Fund. Your gift is the motivation or at Interlochen, because it is the springboard for the many things that are happening here. + +As we've already shared with you, we are in great need of assistance this year, since the World Youth Symphony Orchestra will be traveling to Atlanta to perform in Symphony Hall on July 21 as a part of the opening weekend celebration in the Cultural Olympiad. Your gift will help provide support for this project. THANK YOU! + +Another piece of good news--Interlochen has been announced as one of the "10 Best Camps in America" as published in the March/April edition of Family Life magazine. The Today Show on NBC expects to air a piece on the 10 best camps, with emphasis on choosing the correct one, what to consider, and what to expect. And, Interlochen will be included. So, the tradition of nurturing young talent to its fullest potential goes on... + +Again, thank you for your generosity in selecting Interlochen as the recipient of your philanthropic endeavors. + +![](_page_8_Picture_10.jpeg) + +Vice President Institutional Advancement + +For tax purposes it should be noted that your contribution received by Interlochen Center for the Arts is in support of scholarships. Interlochen has not provided any goods or services for your gift. + +![](_page_9_Picture_1.jpeg) + +March 20, 1996 + +Mr. Jeffrey Epstein Epstein Foundation 457 Madison Avenue New York, NY 10022 + +Dear Jeffrey: + +It is with great pleasure that I acknowledge your recent contribution to the Interlochen Annual Campaign. Please accept my personal thanks for your gift of \$20,000 designated for the Olympic Project. + +While we are still struggling through snow and cold days, summer is never far from our minds. This year, we have added 2 new programs: we will now offer a creative writing program and a chamber music program. However, our big news is that the World Youth Symphony Orchestra will be going to Atlanta to perform in the opening weekend of the Olympics. + +Again, Ed Downing has been working his magic to present another record-setting Summer Festival Concert Series. I hope you will be able to visit our campus and attend these events. + +Thank you again for including Interlochen in your annual philanthropy. Your gift will go directly toward helping talented and deserving students through our scholarship program. + +Since + +Richard F. Odell President + +![](_page_10_Picture_17.jpeg) + +August 29, 1996 + +Mr. Jeffrey E. Epstein +J. Epstein Foundation +The Villard House +457 Madison Avenue +New York, NY 10022 + +Dear Jeffrey: + +We gratefully accept and acknowledge your gift of \$10,000 received 8/26/96. Your gift allows students to explore their potential as musicians, artists, and actors. Equipping students with the "Interlochen experience" provides self-discovery through self-discipline and challenge. + +As you well know, camp is an intense, emotional 8 weeks for students. But, it is wonderful to listen as row after row of tiny practice rooms vibrate with the sounds of instrumentalists warming up in preparation of the day's audition, performance, or weekly challenge. It is our hope that as campers go home they will carry a little piece of Interlochen back to their communities with them. + +Jeffrey, let me give my personal and professional thanks for all you do here at Interlochen. Your caring and thoughtful input in preserving Interlochen's physical environment is very much appreciated. The remaining amount of your gift will be directed to the Annual Fund. Thank you. + +Sincerely, + +![](_page_10_Picture_25.jpeg) + +Vice President +Institutional Advancement + +For tax purposes, please note that this gift is a charitable contribution and no goods or services were exchanged. + +August 29, 1996 + +Mr. Jeffrey E. Epstein J. Epstein Foundation The Villard House 457 Madison Avenue New York, NY 10022 + +Dear Jeffrey: + +![](_page_11_Picture_2.jpeg) + +On behalf of the students, faculty, and staff of the Interlochen Center for the Arts, I would like to thank you for your contribution oL\$1a.,-04341. to our scholarship fund. The generosity of you and fellow donors enables us to offer artistic and academic opportunities to students from all nations, backgrounds, and cultural heritage. + +The final camper concert, "Les Preludes," marks the conclusion of our 69th summer camp season. During the summer, over 1,800 campers participated in 4 and 8-week sessions with scholarship support totaling more than \$800,000. Over 500 events during the 1996 Summer Arts Festival brought thousands of visitors to the campus. Just a few of the outstanding student performances during August include the high-schoolers' presentation of the operetta "Princess Ida" and the intermediate students' presentation of "Romeo and Juliet." + +During the second weekend of August, concerto winners are recognized for their achievements by performing solos with the World Youth Symphony Orchestra. As you may have heard, WYSO was an outstanding representation for Interlochen at the Olympics through their highly-praised performance in Atlanta's Symphony Hall on July 21. + +Thank you for joining us on campus and experiencing the magic of Interlochen first hand. + +Sincerely, ' • + +Richard F. Odell President + +P.S. For tax purposes, please note that this gift was solely philanthropic. No goods or services were exchanged in return for this gift. + +ri nk awe( r, se. ; Av.' ,4,4d- + +InterInthot Arts Academy • lmeriorhen Arts Camp • Interlochen Public. Radio SS] PM/100.9 FM interlochen Center for the Arts • P.O. Mn 199 • Interlchen, Michigan 49643.0199 + +## J. EPSTEIN & COMPANY, INC. + +THE VILI.ARD HOUSE + +NEW YORK. NEW YORK /0022 + +TELEPHO, tal TELEF + +![](_page_12_Picture_4.jpeg) + +August 26. 1997 + +![](_page_12_Picture_6.jpeg) + +iiiler for The Art + +![](_page_12_Picture_8.jpeg) + +Dear.. + +Please find a check for \$50.000 enclosed for Interlochen. This summer was really fun even though it was only a weekend. + +Please use \$5,000 of the \$50,000 for the scholarship for + +Again, thanks for your help. + +Sinc y. + +Jeffr Epstein + +![](_page_13_Picture_1.jpeg) + +September 18, 1997 + +Mr. Jeffrey Epstein 457 Madison Avenue New York, NY 10022-6809 + +Dear Jeffrey: + +Thank you, you are very generous! It's difficult to express how pleased I was to fmd a check for \$50,000 in the Federal Express envelope from The Jesse Philips Foundation. + +Per your instructions, \$45,000 will be used for operations and scholarship support-- \$5,000 will be held in a reserve account for a South Africa Sctolarship Fund (\$3,990 will be used for Camp tuition and \$1,010 for travel expense. With your permission, I will also designate \$5,000 for the Presidential Discretionary Fund (from the \$45,000 operations monies), which will be used by the President for emergency needs or to fund a project vital to Interlochen but not anticipated in the regular budget process. + +It's difficult to get a sense of this place and see the accomplishments of the students in a short time; but, I am pleased that you have made some time in your busy schedule. Please know that I personally and professionally appreciate your generosity and all that you do for a place that is special to those of us interested in the arts and young people. + +Have a great autumn! + +![](_page_13_Picture_10.jpeg) + +ice President Institutional Advancement + +For tax purposes, please note that this gift is a charitable contribution and no goods or services were exchanged. + +![](_page_14_Picture_16.jpeg) + +![](_page_14_Picture_18.jpeg) + +September 18, 1997 + +Mr. Jeffrey Epstein +9 E. 71st Street +New York, NY 10021-4118 + +Dear Jeffrey: + +I did not mention the student from South Africa, since tax deductible contributions cannot be directed to an individual. As I indicated, we have set aside \$5,000 for ██████████ for the 1998 Camp year. She is aware of your generosity, as I have spoken with her father. Enclosed is a letter confirming the fund and notification of your gift. + +You clearly have made one young lady extremely happy. 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Refer to the Admissions Section of the Camp Schedule (page 1) for complete application and financial aid information. The application deadline for first priority review is **February 15**. Applications made after this date are welcome but will be reviewed on a rolling admission basis. **Send all materials to:** Admissions Office, Interlochen Arts Camp, P.O. Box 199, Interlochen, MI 49642-0199. Complete address and phone information are on the back of this form. **Sorry, but we cannot process your application without the following materials:** + +**Application Checklist** + +- Completed Application and Class Selection Form +- Application Form Signatures +- Audition materials enclosed if replaced (see audition requirements in the Camp Schedule) +- Tex forms of applying for financial aid + +**Camp Application Fee** + +Please enclose the required \$35. with your application. Make check payable to "Interlochen Arts Camp." If you wish, you may charge the application fee to VISA, MasterCard, Discover or American Express. + +*SCHOLARSHIP from J Epstein & Ly Marcuell* Card Holder Signature + +**Signatures** + +We cannot process your application without signatures. + +I have answered the questions on this application to the best of my ability and believe my answers are true and correct. + +I have sent this application to the Express and I support the student's correct to the best of my knowledge. I support the student's application to the Interlochen Arts Camp. + +**Applicant Information** + +What division are you applying for? + +- High School +- Advanced String Quarter Institute (Session A - High School Only) +- Creative, Writing Institute (Session B - High School Only) + +- Tuplor Session A +- Junior Session B +- Intermediate Session A +- Intermediate Session B +- If my first session choice is full, I would be interested in an alternative session. + +Sorry, your Interlochen Arts Camp is located on your cover letter + +AP000438147 + +International students: When providing telephone number, include the country code before the local telephone number. + +Nickname (If any) + +Applicant Social Security Number + + Yes No Have you previously attended Interlochen Arts Camp (excluding All-State)? Write years attended: 1997 + +How did you first learn about Interlochen? *from South African Society of Music Teachers* + +**Optional:** Applicant please indicate: Asian American African American Mexican American Porto Rican Asian + + Native American Cucusian Other, please specify: + +**Citizenship Information** + +If you are not a U.S. Citizen, please complete this section. + +[Redacted block] + +Home Telephone: Area Code + Number + +Fax Number: Area Code + Number + +**Teacher Information** + +[Redacted block] + +*PROF of Music* + +Email Address + +City + +State + +Zip + +Fax Number: Area Code + Number + +Office Telephone: Area Code + Number + +*Danken* +*R to* + +Parent or Guardian Information + +**Financial Aid Information** + +**Emerson Electric Co. Scholarship** + +Note: Applications for the Emerson Electric Co. Scholars program must be postmarked by January 12, 1998. + +The Emerson Electric Co. Scholars program provides full aution grants for one student from each state, the District of Columbia and Puerto Rico. Students currently in grades 9-12 with a high proficiency in any of the following instruments: any apply: violin, viela, cello, buss, wint and percussion instruments or harp. Please see page 7 of the Camp Schedule for the suggested repartoire flat for an Emerson Electric Co. scholars audition. + +SCHOLARSHIP FROM J. EOSTEIN + G. MAXWELL +Note you applying for the Emerson Electric Co. Scholars program? Yes No I have enclosed the required audition materials. + +If not an Emerson Electric Co. Scholars winner would you still like to apply to the Arts Camp? Yes No + +If you are not an Emerson Electric Co. Scholars winner and would like to be considered for financial aid for the Arts Camp, please fill out the financial information below and attach a copy of your most recent 1040 Federal Tax Form. + +If you are applying for aid, please fill out this section. + +Are you applying for financial aid? Yes No I have enclosed the required audition materials. +Does the student applying expect to be the receipient of any funds (scholarship, grant, award or prize) from any country, state, organization or individual specifically for attendance at the Intertochen Arts Camp? Yes No + +Mother or Guardian +Please Answer + +Table with 2 columns: If yes, name of the tax of award and amount. Row 1: Earnings last year NA. Row 2: Navigate accounts NA. Row 3: Navigate last year NA. Row 4: Springs accounts NA. + +Father or Guardian +Please Answer + +Please now universal expenses or circumstances you would like taken into consideration (either additional sheet if necessary). + +**Please attach a copy of your most recent Federal Tax Form 1040 to this form** + +**Choosing Your Classes** +The information below must be completed in order to process your application. + +All Juniors (grades 5-9) are attended based on the date of their completed application and the enrollment needs of the Camp. Juniors do not need to audition enclose applying for financial aid. Intermediate (grades 6-9) and High School (grades 9-12) applicants must apply for audition-based or non-audition-based majors. The remainder of their schedules should be filled with non-audition-based major classes. Students selecting audition-based majors are attended based on their level of ability and the enrollment needs of the camp. Those selecting non-audition-based majors are attended based on the date of their completed application and the enrollment needs of the Camp. The applicant post is competitive and finished space is available therefore your early application is strongly recommended. Please note: very few spaces are available for the non-audition-based general arts major in the Intermediate division. + +**Audition-Based and Non-Audition-Based Majors** + +**Intermediate** +Please enter the Class Code from the Camp Schedule (i.e. DMODN or CLARB) + +Please refer to the "Intermediate Division" section in the Camp Schedule for a complete discussion of classes, scheduling, prerequisites and audition requirements. Please fulfill audition requirements for each audition-based major entered below. + +Table with 2 columns: 1. Session A: first choice major class code/instrument (NA), 2. Session B: first choice major class code/instrument (NA), 3. Session C: alternative choice major class code/instrument (NA). + +**High School** +Please enter the Class Code from the Camp Schedule (ie TMUCI or VIOLO) + +Please refer to the "High School Threshold" section in the Camp Schedule for a complete discussion of classes, scheduling, prerequisites and audition requirements. Please fulfill audition requirements for each audition-based major entered below. + +Table with 2 columns: 1. First choice major class code (ORCHESTRA (O)), 2. Alternate choice major class code, 3. Second alternate classes major class code. + +# Non-Audition-Based Minor Class Selection Form + +be sure to indicate that class on the preceding page. You do not need to indicate it on this page. Use this form only to select your non-audition-based minor classes. Please complete the appropriate section to indicate classes that you would like in addition to a minor class if applicable. + +**Applicant Name** + +(Please Print) + +**Junior** + +Please list class names in order of preference, rather than in order of time. Remember to include all classes since there are no major classes in this division. + +Students in the Junior Division will be assigned three periods of classes, including private lessons. Students who complete grade 6 have the option of selecting an additional attendant class in place of land recreation. Please refer to the 'Junior Division' section in the Camp Schedule for a complete discussion of classes, scheduling and prerequisites. Do not schedule recreation classes on this form. They will be determined at the beginning of Camp. If interested in land or archeology, please list instrument and ensemble on the first line below. + +1. Session A: (first choice class) + +1. Session B: (first choice class) + +2. Session A: (second choice class) + +2. Session B: (second choice class) + +3. Session A: (third choice class) + +3. Session B: (third choice class) + +4. Session A: (fourth choice class) + +4. Session B: (fourth choice class) + +5. Session A: (fifth choice class) + +5. Session B: (fifth choice class) + +**Private Lessons** + + 4-30 minute lessons (Instrument) + 4-60 minute lessons (Instrument) + + 4-30 minute lessons (Instrument) + 4-60 minute lessons (Instrument) + +Former Campers Only: Indicate Teacher preference for private lessons. + +Former Campers Only: Indicate Teacher preference for private lessons. + +**Intermediate** + +Please list non-audition-based minor classes in order of preference rather than in order of time. Do not list major classes, if applicable. + +Students in the Intermediate Division will be assigned four periods of classes, including private lessons. Students who complete grade 9 have the option of selecting an additional class in place of recreation. Please refer to the "Intermediate Division" section in the Camp Schedule for a complete discussion of classes, scheduling, prerequisites and audition requirements. Do not schedule recreation classes on this form. They will be determined at the beginning of camp. + +1. Session A: (first choice class) + +1. Session B: (first choice class) + +2. Session A: (second choice class) + +2. Session B: (second choice class) + +3. Session A: (third choice class) + +3. Session B: (third choice class) + +4. Session A: (fourth choice class) + +4. Session B: (fourth choice class) + +**Private Lessons** + + 4-30 minute lessons (Instrument) + 4-60 minute lessons (Instrument) + 4-60 minute lessons with 2 periods practice (Instrument) + + 4-30 minute lessons (Instrument) + 4-60 minute lessons (Instrument) + 4-60 minute lessons with 2 periods practice (Instrument) + +Former Campers Only: Indicate Teacher preference for private lessons. + +Former Campers Only: Indicate Teacher preference for private lessons. + +**High School** + +Please list non-audition-based minor classes in order of preference rather than in order of time. Do not list major classes, if applicable. + +High School students will be assigned five periods of classes, including private lessons. Please refer to the "High School Division" section in the Camp Schedule for a complete discussion of classes, scheduling, prerequisites and audition requirements. + +1. ALEXANDER TECHNIQUE + +4. Fourth Choice + +2. CHARLOTTE MUSIC FOR STRINGS + +5. Fifth Choice + +3. CONDUCTING + +6. Sixth Choice + + 8-30 minute lessons (Instrument) + + 8-60 minute lessons (Instrument) + +**Artistic Information** +All students please answer: + +What is your primary instrument or interest? Number of years of private study + +CELLO 10 + +Describe your primary instrument and experience in this area + +Play in a symphony orchestra + +While is your personal art instrument or interest? + +Number of years of private study + +Describe previous training and experience in this area + +4 years + +Music Students: + +Previous experience in Orchestra: Number of Years/Position Previous experience in Band/Number of Years/Position + +Reader of Section Reader of Section + +List two difficult works referenced in orchestra, friend or in ensemble within the past year: + +Be Tchaikowsky for Symphony +Stravinsky Fireborn + +List the two most difficult solos you have plastered on your primary instrument or song: + +Haydon C may Cello Con. Saunt Saers Cello Concer + +**Personal Information** + +[REDACTED] + +at home + +How do you rate your child in terms of personal adjustment, such as his or her sense of self worth, ability, independence, etc. + +VERY FINE, IN EVERY RESPECT + +How do you rate your child in terms of social adjustment? has many friends has few friends has one or two close friends + has had close association with richer children younger children children his or her own age + +Is there any phase of personal or social adjustment which you hope Camp will add? + +Please give any information that might be helpful in guiding the educational and personal development of your child. + +**Send all materials and direct inquiries to:** + +When using U.S. Private Service send to: + +When using Federal Express, UPS and Airborne Express send to: + +Telephone: 616-276-7472 +E-mail: + +[REDACTED] \ No newline at end of file diff --git a/marker2/ds9/EFTA00090276/EFTA00090276.metadata.json b/marker2/ds9/EFTA00090276/EFTA00090276.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..57947d4cef219b94e467794ed44632ede9c4dcf3 --- /dev/null +++ b/marker2/ds9/EFTA00090276/EFTA00090276.metadata.json @@ -0,0 +1,705 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090276.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 4, + "chars": 12444, + "elapsed_seconds": 17.71, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Instructions", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 29.375999999999998, + 95.58 + ], + [ + 77.724, + 95.58 + ], + [ + 77.724, + 104.49 + ], + [ + 29.375999999999998, + 104.49 + ] + ] + }, + { + "title": "Application Checklist", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 31.823999999999998, + 144.99 + ], + [ + 116.892, + 144.99 + ], + [ + 116.892, + 155.52 + ], + [ + 31.823999999999998, + 155.52 + ] + ] + }, + { + "title": "Camp Application Fee", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 32.436, + 177.39000000000001 + ], + [ + 119.952, + 177.39000000000001 + ], + [ + 119.952, + 187.92000000000002 + ], + [ + 32.436, + 187.92000000000002 + ] + ] + }, + { + "title": "Signatures", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 34.272, + 241.38 + ], + [ + 77.724, + 241.38 + ], + [ + 77.724, + 251.10000000000002 + ], + [ + 34.272, + 251.10000000000002 + ] + ] + }, + { + "title": "Applicant Information", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 35.496, + 287.54999999999995 + ], + [ + 122.4, + 287.54999999999995 + ], + [ + 122.4, + 298.08 + ], + [ + 35.496, + 298.08 + ] + ] + }, + { + "title": "Citizenship Information", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 39.78, + 541.08 + ], + [ + 131.57999999999998, + 541.08 + ], + [ + 131.57999999999998, + 550.8000000000001 + ], + [ + 39.78, + 550.8000000000001 + ] + ] + }, + { + "title": "Teacher Information", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 39.78, + 652.0500000000001 + ], + [ + 122.4, + 652.0500000000001 + ], + [ + 122.4, + 662.5799999999999 + ], + [ + 39.78, + 662.5799999999999 + ] + ] + }, + { + "title": "For Internal Use", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 39.78, + 733.05 + ], + [ + 110.16, + 733.05 + ], + [ + 110.16, + 745.2 + ], + [ + 39.78, + 745.2 + ] + ] + }, + { + "title": "Financial Aid Information", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 45.9, + 237.32999999999998 + ], + [ + 165.24, + 237.32999999999998 + ], + [ + 165.24, + 249.48 + ], + [ + 45.9, + 249.48 + ] + ] + }, + { + "title": "Emerson Electric Co. 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Southern District of New York + +The Si!lo J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 + +November 24, 2021 + +## BY ELECTRONIC MAIL + +Christian Everdell, Esq. Cohen & Gresser LLP 800 Third Avenue New York, NY 10022 + +Laura Menninger, Esq. Jeffrey Pagliuca, Esq. Haddon, Morgan and Foreman, P.C. 150 East Tenth Avenue Denver, CO 80203 + +Bobbi Stemheim, Esq. Law Offices of Bobbi C. Stemheim 33 West 19th Street-4th Fl. New York, NY 10007 + +Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) + +Dear Counsel: + +Today the Government is producing additional materials, including Jencks Act and Giglio material, regarding witnesses who may be called to testify at trial in the above-referenced case. Enclosed please find an index detailing the materials included in today's production. + +The Government is also producing today certain materials relating to individuals the Government does not currently intend to call as witnesses at trial in the above-referenced case. These materials do not contain a comprehensive set of Jencks Act and Giglio materials, as the Government does not expect to call these individuals to testify at trial. Instead, these materials contain, among other things, certain witness statements. Enclosed please find an index detailing these materials. This production should not be taken to indicate that the Government believes it has any obligation to provide all of these materials; rather, we make this production as a courtesy. Moreover, although the Government presently does not intend to call the individuals listed in the enclosed index, we reserve the right to do so and will notify you should the Government determine that it intends to call any of these individuals at trial. + +Please note that this letter, the enclosed index, and the enclosed materials are governed by the July 31, 2020 Protective Order in this case. **In particular, the materials are designated as “confidential” under the Protective Order. The index is itself designated as “confidential,” because it includes information regarding records designated as “confidential” under the Protective Order.** The Department of Justice directed this office to cease the dissemination of materials marked with the word “confidential” in order to avoid potential confusion with markings reserved for classified documents. Accordingly, in order to note the appropriate designation of this production under the operative Protective Order in this case, the materials being produced today are marked with the following label: “SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17.” This marking directly refers to the specific paragraphs of the Protective Order that govern today’s production. + +Very truly yours, + +DAMIAN WILLIAMS +United States Attorney + +by: s/ + +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] + +Assistant United States Attorneys \ No newline at end of file diff --git a/marker2/ds9/EFTA00090280/EFTA00090280.metadata.json b/marker2/ds9/EFTA00090280/EFTA00090280.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..b7d2cddc2c8975b21c850b0df4b1d91f17ca218f --- /dev/null +++ b/marker2/ds9/EFTA00090280/EFTA00090280.metadata.json @@ -0,0 +1,145 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090280.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2912, + "elapsed_seconds": 4.39, + "image_assets": [ + "_page_0_Picture_0.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "U.S. Department of Justice", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 319.464, + 25.11 + ], + [ + 463.93951416015625, + 25.11 + ], + [ + 463.93951416015625, + 40.5 + ], + [ + 319.464, + 40.5 + ] + ] + }, + { + "title": "BY ELECTRONIC MAIL", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 182.25 + ], + [ + 211.1153564453125, + 182.25 + ], + [ + 211.1153564453125, + 196.4830322265625 + ], + [ + 68.544, + 196.4830322265625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 77 + ], + [ + "Line", + 37 + ], + [ + "Text", + 10 + ], + [ + "SectionHeader", + 2 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 37 + ], + [ + "Line", + 18 + ], + [ + "Text", + 12 + ], + [ + "PageHeader", + 2 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00090280" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00090280/_page_0_Picture_0.jpeg b/marker2/ds9/EFTA00090280/_page_0_Picture_0.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..99e8b574107eb66d40364c7519a345440634774c --- /dev/null +++ b/marker2/ds9/EFTA00090280/_page_0_Picture_0.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:80c7c0f51f1d8cd2eff02bcdc09463948795225afef32f1099b9da9746b344a5 +size 3526 diff --git a/marker2/ds9/EFTA00090282/EFTA00090282.md b/marker2/ds9/EFTA00090282/EFTA00090282.md new file mode 100644 index 0000000000000000000000000000000000000000..c6dc911fe3ddc68b410b5272709031798216a535 --- /dev/null +++ b/marker2/ds9/EFTA00090282/EFTA00090282.md @@ -0,0 +1,19 @@ +T + +Subject: RE: Quick Epstein FOIA check in + +Date: Thu, 14 Jan 2021 15:48:09 +0000 + +Thanks, No issues on our end if his name is not on it (and probably don't even need to see it). + +From + +Sent: Thursday, January 14, 2021 10:47 AM + +To (USANYS) + +Subject: Quick Epstein FOIA check in + +Quick check-in on the Epstein FOIA: there's an attorney visit room inventory log (with inmate names on it) that we previously withheld under 7(A) that the Noel team now thinks we can release with privacy redactions. It's one page, and there's no mention of Tartaglione there. I'm assuming (1) I could send this to you and (2) this can be released with no Tartoglione concerns because he's not on the document. But checking before I send it to you and/or it gets released. + +Thanks, \ No newline at end of file diff --git a/marker2/ds9/EFTA00090282/EFTA00090282.metadata.json b/marker2/ds9/EFTA00090282/EFTA00090282.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..1aa47f02a4faaf824793673bd87583920003c44b --- /dev/null +++ b/marker2/ds9/EFTA00090282/EFTA00090282.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090282.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 761, + "elapsed_seconds": 0.66, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 31 + ], + [ + "Line", + 15 + ], + [ + "Text", + 13 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00090282" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00090283/EFTA00090283.md b/marker2/ds9/EFTA00090283/EFTA00090283.md new file mode 100644 index 0000000000000000000000000000000000000000..bfb1e4c1cae6f622059b17e6b0988e882d99ab75 --- /dev/null +++ b/marker2/ds9/EFTA00090283/EFTA00090283.md @@ -0,0 +1,18 @@ +To: "S" + +Cc: ' lANYS)" + +Subject: US v. Epstein + +Date: Thu, 14 Jan 2021 19:07:34 +0000 + +Hello + +The vendor has told me that there are issues with the data for SDFL data that was scanned. Here are the issues: + +- 1. The vendor sent us all color tiff images. Anything that color images these need to be in jpg format. The images need to be single page tiff (black and white) or single page jpg (color images) +- 2. The image load file that was sent to us (.opt) is incomplete. The opt file contains 108,582 images, but the image folder only contains 58,468 files. + +There was nothing wrong with the data file (.dat file) that we received, and the data from .dat file was loaded to the database. Can you please have the vendor send us a new image files along with a new .opt file so we can make this data available for review. Please let me know if there are any questions. + +Thank you. \ No newline at end of file diff --git a/marker2/ds9/EFTA00090283/EFTA00090283.metadata.json b/marker2/ds9/EFTA00090283/EFTA00090283.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..bf0f8283ad096ec7673d664eb8e7746dc8b78f81 --- /dev/null +++ b/marker2/ds9/EFTA00090283/EFTA00090283.metadata.json @@ -0,0 +1,62 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090283.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 877, + "elapsed_seconds": 0.58, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 33 + ], + [ + "Line", + 17 + ], + [ + "Text", + 10 + ], + [ + "ListItem", + 2 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00090283" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00090284/EFTA00090284.md b/marker2/ds9/EFTA00090284/EFTA00090284.md new file mode 100644 index 0000000000000000000000000000000000000000..136a2317f309134fdff46161b88d1e7f6673f415 --- /dev/null +++ b/marker2/ds9/EFTA00090284/EFTA00090284.md @@ -0,0 +1,44 @@ +From: ' (USANYS) [Contractor]" To:" )" Cc: ' il ANYS)" >, '1 1 ' + +Subject: RE: US v. Epstein + +Date: Thu, 14 Jan 2021 19:12:33 +0000 + +I will include all of you on the e-mail I send to You will see this e-mail shortly. + +Thank you. + +From: + +Sent: Thursday, January 14, 2021 2:10 PM + +To: (USANYS) [Contractor] + +Cc: (USANYS); + +Subject: RE: US v. Epstein + +Thank you for letting me know. Would you please coordinate directly with the vendor is the point of contact you've spoken with in the past, I believe) to explain these issues? I think it would be best to minimize the number of messengers in getting this fixed. + +Thanks, + +From: (USANYS) [Contractor] + +Sent: Thursday, January 14, 2021 2:08 PM + +To: > + +Cc: (USANYS) < + +Subject: US v. Epstein + +Hello + +The vendor has told me that there are issues with the data for SDFL data that was scanned. Here are the issues: + +- 1. The vendor sent us all color tiff images. Anything that color images these need to be in jpg format. The images need to be single page tiff (black and white) or single page jpg (color images) +- 2. The image load file that was sent to us (.opt) is incomplete. The opt file contains 108,582 images, but the image folder only contains 58,468 files. + +There was nothing wrong with the data file (.dat file) that we received, and the data from .dat file was loaded to the database. Can you please have the vendor send us a new image files along with a new .opt file so we can make this data available for review. Please let me know if there are any questions. + +Thank you. \ No newline at end of file diff --git a/marker2/ds9/EFTA00090284/EFTA00090284.metadata.json b/marker2/ds9/EFTA00090284/EFTA00090284.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..6b48e1f265b14067af1abb16c12cb4e7ff4facca --- /dev/null +++ b/marker2/ds9/EFTA00090284/EFTA00090284.metadata.json @@ -0,0 +1,62 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090284.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1528, + "elapsed_seconds": 1.15, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 73 + ], + [ + "Line", + 34 + ], + [ + "Text", + 25 + ], + [ + "ListItem", + 2 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00090284" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00090285/EFTA00090285.md b/marker2/ds9/EFTA00090285/EFTA00090285.md new file mode 100644 index 0000000000000000000000000000000000000000..aefe3cbe27ac410b541818f5619f646b0fc2dd54 --- /dev/null +++ b/marker2/ds9/EFTA00090285/EFTA00090285.md @@ -0,0 +1,129 @@ +![](_page_0_Picture_0.jpeg) + +United States Attorney Southern District of New York + +The Silvio J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 + +November 18, 2020 + +## BY ELECTRONIC MAIL + +Christian Everdell, Esq. Mark Cohen, Esq. Cohen & Gresser LLP 800 Third Avenue New York, NY 10022 + +Laura Menninger, Esq. Jeffrey Pagliuca, Esq. Haddon, Morgan and Foreman, P.C. 150 East Tenth Avenue Denver, CO 80203 + +Bobbi Stemheim, Esq. Law Offices of Bobbi C. Stemheim 33 West 19th Street-4th Fl. New York, NY 10007 + +Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) + +Dear Counsel: + +In recognition of the Government's ongoing discovery obligations, today we are producing one hard drive and one CD, which contain copies of the materials listed in the below index. These discovery materials are stamped with control numbers SDNY\_GM\_00536837 through SDNY GM 02742043. The password for the drive is "WO-6291\_20201104" and the password for the CD is "USAOsdny 1 !". The drive and CD are both available for pickup at the U.S. Attorney's Office in Manhattan. + +Please note that both this letter and the enclosed materials are governed by the July 31, 2020 Protective Order in this case.' This letter is itself designated as "confidential," because it includes information regarding records designated as "confidential" under the Protective Order. An index of the materials contained in this production is below: + +Files in PDF format designated as "confidential" under the protective order have been stamped "confidential." However, certain files cannot be individually labeled as confidential on the documents themselves due to their file format. + +| Bates Stan | Bates End | Summary Description | Confidential | +|-------------------|-------------------|---------------------------------------|--------------| +| SDNY_GM_00536837 | SDNY_GM_00869725 | | | +| | | Warrant Returns) | Confidential | +| SDNY_GM 00869726 | SDNY_GM_012 16165 | | | +| | | Warrant Returns) | Confidential | +| SDNY GM 01216166 | SDNY GM 01546512 | | | +| | | Warrant Returns) | Confidential | +| SDNY_GM_0 1546513 | SDNY_GM_0 1964992 | | | +| | | Warrant Returns) | Confidential | +| SDNY_GM_0 1964993 | SDNY_GM_02292245 | | | +| | | Warrant Returns) | Confidential | +| SDNY_GM_02292246 | SDNY_GM_02678243 | | | +| | | Warrant Returns) | Confidential | +| SDNY_GM_02678244 | SDNY_GM_02735320 | | | +| | | Warrant Returns) | Confidential | +| SDNY_GM_02735321 | SDNY_GM_02742042 | SDNY_PROD016 (Search Warrant Returns) | Confidential | +| SDNY_GM_02742043 | SDNY_GM_02742043 | NYC024318 1B71 (iPhone, images pt. 2) | Confidential | + +Please note that the item identified with bates number SDNY\_GM\_02742043 consists of the final portion of images identified responsive from Subject Device-2, which is an iPhone that law enforcement seized from Jeffrey Epstein at the time of his arrest in 2019. The remainder of the responsive materials from that same device were previously produced to you on November 9, 2020. Due to technical difficulties, we were unable to complete the responsiveness review of images from this device until November 17, 2020. + +Additionally, as a courtesy, attached to this letter please find a chart of the Subject Devices searched pursuant to warrants in this case. The chart includes the FBI identifiers associated with each device and the date(s) on which the Government produced responsive material from each device to the defense. As noted in the chart, in some instances, the Government determined that there was no responsive material from certain devices and accordingly did not produce any data from those particular devices. + +The Government recognizes that its discovery obligations are ongoing and will promptly produce any additional discoverable material of which it becomes aware. Please do not hesitate to reach out if you have any difficulty accessing these materials or if you wish to arrange a time to review physical items in the FBI's custody. + +Very truly yours, + +AUDREY STRAUSS + +Acting United States Attorney + +tim " States Attorneys + +Enclosure + +| I n —Device Number | 1B Number | FBI Barcode | CART Evidence Number(s) | Responsive Material Produced | +|--------------------|-----------|-------------|---------------------------------|---------------------------------| +| Subject Device-01 | 1B72 | E6516107 | NYCO24319 | Produced 11/09/2020 | +| Subject Device-02 | 1B71 | E6516106 | NYCO24318 | Produced 11/09/2020, 11/18/2020 | +| Subject Device-03 | 1B73 | E6516108 | NYCO24354 | Produced 11/09/2020, 11/18/2020 | +| Subject Device-03 | 1B74 | E6516109 | NYCO24355 | Produced 11/09/2020, 11/18/2020 | +| Subject Device-04 | 1B70 | E65 15034 | NYCO24332 | Produced 11/09/2020, 11/18/2020 | +| Subject Device-05 | 1B69 | E65 15033 | NYCO24359 | Produced 11/09/2020 | +| Subject Device-06 | 1B68 | E65 15032 | NYCO24358 | Produced 11/09/2020 | +| Subject Device-07 | 1B67 | E6515031 | NYCO24357 | Produced 11/09/2020 | +| Subject Device-08 | 1B62 | E65 15026 | NYCO24335, NYCO24336, NYCO24337 | Produced 11/09/2020, 11/18/2020 | +| Subject Device-09 | 1B61 | E6515025 | NYCO24320, NYCO24321 | Produced 11/09/2020, 11/18/2020 | +| Subject Device-10 | 1B60 | E6515024 | NYCO24342 | None | +| Subject Device-11 | 1B59 | E6515023 | NYCO24333, NYCO24334 | Produced 11/18/2020 | +| Subject Device-12 | 1B58 | E6515022 | NYCO24351 | Produced 11/09/2020 | +| Subject Device-13 | 1B57 | E65 15021 | NYCO24328, NYCO24329 | Produced 11/09/2020, 11/18/2020 | +| Subject Device-14 | 1B56 | E6515020 | NYCO24338 | None | +| Subject Device-15 | 1B55 | E6515019 | N/A (FBI unable to access) | None | +| Subject Device-16 | 1B54 | E6515018 | NYCO24353 | Produced 11/09/2020, 11/18/2020 | +| Subject Device-17 | 1B53 | E6515017 | NYCO24329 | Produced 11/09/2020, 11/18/2020 | +| Subject Device-18 | 1B52 | E6515016 | NYCO24340 | Produced 11/09/2020 | +| Subject Device-19 | 1B51 | E6515015 | NYCO24345 | None | +| Subject Device-20 | 1B50 | E6515014 | NYCO24346 | None | +| Subject Device-21 | 1B49 | E6515013 | NYCO24347 | None | +| Subject Device-22 | 1B48 | E6515012 | NYCO24344 | None | +| Subject Device-23 | 1B47 | E65 15011 | NYCO24343 | Produced 11/09/2020, 11/18/2020 | +| Subject Device-24 | 1B46 | E6515010 | NYCO24341 | Produced 11/09/2020, 11/18/2020 | +| Subject Device-25 | 1B44 | E6515008 | NYCO24339 | None | +| Subject Device-26 | 1B43 | E6515007 | NYCO24323, NYCO24324 | Produced 11/09/2020, 11/18/2020 | +| Subject Device-27 | 1B42 | E6515006 | NYCO24330, NYCO24331 | None | +| Subject Device-28 | 1B41 | E6515005 | NYCO24325, NYCO24326, NYCO27913 | Produced 11/09/2020, 11/18/2020 | +| Subject Device-29 | 1B40 | E6515004 | NYCO27913 | Produced 11/18/2020 | +| Subject Device-30 | 1B39 | E65 15003 | NYCO27911 | None | +| Subject Device-31 | 1B38 | E6515002 | NYCO27912 | None | + +| Corrected Subject Device-32 IB30 | | E6433822 | NYCO24348 | Produced 11/09/2020, 11/18/2020 | +|----------------------------------|-------|-----------|----------------------|---------------------------------| +| Corrected Subject Device-33 IB32 | | E6433824 | NYCO24350 | Produced 11/09/2020, 11/18/2020 | +| Corrected Subject Device-34 IB29 | | E6433821 | NYCO24349 | Produced 11/09/2020, 11/18/2020 | +| Subject Device-35 | IB28 | E6433828 | NYCO24327 | Produced 11/09/2020, 11/18/2020 | +| Subject Device-36 | IB80 | E65 16259 | NYCO24362 | Produced 11/09/2020, 11/18/2020 | +| Subject Device-37 | IB81 | E65 16260 | NYCO24363 | Produced 11/09/2020, 11/18/2020 | +| Subject Device-38 | 1B82 | E65 16261 | NYCO24364 | Produced 11/09/2020, 11/18/2020 | +| Subject Device-39 | 1B83 | E65 16262 | NYCO27905 | Produced 11/09/2020 | +| Subject Device-40 | IB84 | E65 16263 | NYCO27904 | Produced 11/09/2020 | +| Subject Device-41 | 1B85 | E65 16264 | NYCO24365 | Produced 11/09/2020, 11/18/2020 | +| Subject Device-42 | 1B87 | E65 16266 | NYCO24366 | Produced 11/09/2020, 11/18/2020 | +| Subject Device-43 | 1B96 | E6516275 | NYCO24367, NYCO27908 | Produced 11/18/2020 | +| Subject Device-44 | IB97 | E65 16276 | NYCO24368 | Produced 11/09/2020, 11/18/2020 | +| Subject Device-45 | IB98 | E65 16277 | NYCO24369 | Produced 11/09/2020, 11/18/2020 | +| Subject Device-46 | IB102 | E6516281 | NYCO24371 | Produced 11/09/2020, 11/18/2020 | +| Subject Device-47 | IB106 | E6516285 | NYCO27909, NYCO27910 | Produced 11/09/2020, 11/18/2020 | +| Subject Device-48 | IB107 | E65 16286 | NYCO24372 | Produced 11/09/2020, 11/18/2020 | +| Subject Device-49 | IB111 | E65 16290 | NYCO247903 | None | +| Subject Device-50 | IB112 | E6516291 | NYCO24373 | None | +| Subject Device-5I | IB115 | E6516294 | | | +| | | | NYCO24379, NYCO24380 | None | +| Subject Device-52 | IB116 | E65 16306 | NYCO24381 | None | +| Subject Device-53 | IB117 | E65 16296 | NYCO24395 | None | +| 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U.S. Department of Justice + +#### Criminal Division + +VAA:WHG:TNB:AF:ss DOJ No. CRM-182-[number] Office ofInternational Affairs Washington, D.C. + +FROM: The Central Authority of the United States TO: The Central Authority of France SUBJECT: Request for Assistance in the Prosecution of Ghislaine Maxwell DATE: January 8, 2021 + +#### INTRODUCTION + +The Central Authority of the United States requests the assistance of the appropriate authorities in France pursuant to the 1998 U.S.-France Mutual Legal Assistance Treaty, as supplemented by the 2004 U.S.-France Mutual Legal Assistance Instrument (collectively, "the Treaty"). The United States Attorney for the Southern District of New York ("the prosecutor") and the Federal Bureau of Investigation (collectively, the "U.S. authorities") are prosecuting charges of violations of United States criminal law concerning Ghislaine Maxwell and her role in the sexual exploitation and abuse of multiple minor girls by Jeffrey Epstein from at least in or about 1994, up to and including at least in or about 1997. + +The U.S. authorities request to conduct a voluntary interview of French citizen ("Ml=" or the "Witness") and request the assistance of French authorities in arranging for such an interview. The U.S. authorities understand that was a witness to certain events, conduct, or conversations relevant to its prosecution of Maxwell and, in particular, that was sexually abused by Epstein + +in New York after meeting Epstein and Maxwell in in approximately In addition, the U.S. authorities seek the assistance of French authorities to obtain records of prior interviews of the witness by French law enforcement, as well as certain materials seized from the Parisian residence of Jeffrey Epstein in September 2019, including documents relating to Maxwell and photographs of women, including of the witness. + +A trial date of July 12, 2020 has been set in United States v. Ghislaine Maxwell. In light of the trial date, the U.S. authorities would like to interview the witness as soon as possible in order to evaluate if additional charges may be brought against Maxwell. The U.S. authorities believe that may be a critical witness and the subject of additional charges against Maxwell. Accordingly, we request that the execution of this request be carried out on an expedited basis, and that for the United States (contact information below) be notified in order to facilitate rapid execution of the request and transmission of the evidence sought. + +# REQUEST FOR CONFIDENTIALITY + +This request is sensitive in that it recounts specifics and evidentiary detail that may not be known, the exposure of which could impede the prosecution of Maxwell and the U.S. authorities' ongoing investigation with regard to the integrity of evidence and witness accounts. Premature notification of this request could seriously jeopardize the investigation or compromise the trial of Maxwell, by prompting a witness to alter or prepare his/her answers to specific questions, by prompting others to destroy or tamper with evidence; change patterns of behavior; intimidate potential witnesses; or alert others who could do the same. Indeed, the parties' disclosure of information produced in + +discovery in the prosecution of Maxwell is governed by a protective order which is attached as Attachment B. Accordingly, pursuant to Article 14 of the Treaty, please keep this request confidential in all respects, and do not share its contents, its subject matter, or the fact that the request has been made with any private persons (including the subject(s) of the investigation), or any government officials whose knowledge is not absolutely necessary for purposes of executing this request. In addition, please advise all who must be made aware of this request for assistance that the request, its contents and its subject matter are to be kept confidential and should not be shared except as described above. In order to avoid disclosure to third parties (including parties civiles), if a related criminal investigation exists in France, please ensure that this mutual legal assistance request is NOT placed in the French criminal dossier without the express authorization of the United States; instead, we ask that this request for assistance be placed in a separate mutual legal assistance dossier. If this request cannot be executed without breaching confidentiality, please notify for the United States, whose contact information is listed below. + +# THE FACTS + +U.S. citizen Jeffrey Epstein is alleged to have engaged in the sexual abuse of minor girls during the period of approximately 1994 through 2005. On or about July 2, 2019, a grand jury in the Southern District of New York returned an indictment charging Epstein with violations of U.S. criminal laws in connection with his sexual abuse of minors, including with engaging in a conspiracy to sexually traffic in minors. Epstein was arrested pursuant to the indictment on or about July 6, 2019, and had been detained pending trial in New York. On or about August 10, 2019, Epstein committed suicide in his cell. Notwithstanding Epstein's death, the investigation that led to his indictment remains ongoing. That investigation has revealed evidence of additional criminal conduct by Epstein and his associates, including Ghislaine Maxwell. + +On or about June 29, 2020, a grand jury in the Southern District of New York returned an Indictment charging Maxwell with violations of U.S. criminal laws in connection with her role in assisting, facilitating, and contributing to Epstein's sexual abuse of minors by, among other things, helping Epstein to recruit, groom, and ultimately abuse victims known to Maxwell and Epstein to be under the age of 18. The Indictment alleges that from at least in or about 1994, up to and including at least in or about 1997, Maxwell enticed and conspired with Epstein to entice and cause minor victims to travel to New York, which Maxwell knew and intended would result in their grooming and subjection to sexual abuse by Epstein. Maxwell was arrested pursuant to the Indictment on or about July 2, 2020, and has been detained pending trial in New York since that date. Finally, the Indictment also alleges that Maxwell provided false and perjurious statements, under oath, regarding, among other subjects, her role in facilitating the abuse of minor victims by Epstein. + +The U.S. authorities have learned that may have been a witness to certain events of relevance to its prosecution. In particular, the U.S. authorities understand that met Epstein and Maxwell in when she was .year old in approximately ■ **that subsequently traveled with Epstein and Maxwell to the United States; and that Maxwell invited to New York, where Epstein sexually abused her.** + +# **THE OFFENSES** + +**Title 18, United States Code, Section 371 Conspiracy** + +If two or more persons conspire ... to commit any offense against the United States ... and one or more of such persons do any act to effect the object of the conspiracy, each shall [have committed a crime and be] imprisoned not more than five years. + +## Title 18, United States Code, Section 2423 Transportation of Minors + +- (a) Transportation with intent to engage in criminal sexual activity + - (1) A person who knowingly transports an individual who has not attained the age of 18 years in interstate or foreign commerce, or in any commonwealth, territory or possession of the United States, with intent that the individual engage in prostitution, or in any sexual activity for which any person can be charged with a criminal offense, shall [have committed a crime and be] imprisoned not less than 10 years or for life. + +# Title 18, United States Code, Section 2422 Coercion and Enticement + +- (1) (b) Whoever, using the mail or any facility or means of interstate or foreign commerce, or within the special maritime and territorial jurisdiction of the United States knowingly persuades, induces, entices, or coerces any individual who has not attained the age of 18 years, to engage in prostitution or any sexual activity for which any person can be charged with a criminal offense, or attempts to do so, shall [have committed a crime and be] imprisoned not less than 10 years or for life.2 + +# Title 18, United States Code, Section 1623 Perjury + +- (a) Whoever under oath (or in any declaration, certificate, verification, or statement under penalty of perjury as permitted under section 1746 of title 28, United States Code) in any proceeding before or ancillary to any court or grand jury of the United States knowingly makes any false material declaration or makes or uses any other information, including any book, paper, document, record, recording, or other material, knowing the same to contain any false material declaration, shall be fined under this title or imprisoned not more than five years, or both. + +## RELEVANT ENTITIES AND INDIVIDUALS + +Name: + +Date of birth: + +Place of birth: + +Citizenship: + +France + +French + +The penalties stated herein apply to conduct that occurred after July 27, 2006. that occurred prior to that time, the penalties would be lower and may mandatory minimum sentences. For conduct not include + +2The penalties stated herein apply to conduct that occurred after July 27, 2006. that occurred prior to that time, the penalties would be lower and may mandatory minimum sentences. For conduct not include + +Name: Ghislaine Maxwell Date of Birth: Place of Birth: Maison-Laffitte, France Citizenship: U.S., UK, France + +# ASSISTANCE NEEDED + +### Testimony + +U.S. authorities seek to conduct an investigative interview of the witness identified above. The specific subject matters of questioning are set forth in Attachment A. + +# Records + +The U.S. authorities also seek certain records which are relevant to the prosecution of Maxwell. The U.S. authorities learned of certain of these records from the July 8, 2020 request for international legal assistance from the French Ministry of Justice. In particular, the U.S. authorities request that an appropriate custodian of official records produce true and correct copies of the following documents: + +- a. Any notes, memoranda, or recordings of interviews of conducted by French law enforcement. +- b. Materials seized from Jeffrey Epstein's Parisian residence located at Paris 16th district, which was searched on September 23, 2019; in particular: + - i. Photographs of and other females found at Epstein's residence and on seized devices; + - ii. Any and all documents, records, recordings, and photographs relating to Ghislaine Maxwell; + - iii. Contents of a CD Rom with the inscription "CONFIDENTIAL + - COMPREHENSIVE CHART" + - iv. Photographs of both the interior and exterior of Epstein's Parisian residence located at , Paris 16th district + +# PROCEDURES TO BE FOLLOWED + +### Testimony + +The U.S. authorities specifically request to conduct the questioning themselves in the presence of French authorities to ensure that all necessary lines of inquiry are completed in the most efficient fashion. The U.S. authorities—who have significant experience conducting interviews of victims—request to conduct a voluntary interview of the witness that is sensitive to the difficult nature of the subject matter and guided by the witness's comfort level. The U.S. authorities believe to be an important witness whose experience falls squarely within the conspiracy charge pending against Maxwell and who may be the subject of additional charges against Maxwell. As a result, the U.S. authorities respectfully submit that it is important that they conduct the questioning themselves in the presence of French authorities to assess the viability of additional charges. The U.S. authorities also request that they be permitted to conduct the interview by video, should that be deemed necessary, in light of the COVID-19 pandemic and travel restrictions and difficulties. + +The U.S. authorities request that the following individuals be permitted to conduct the interview: + +- a. +- b. +- c. +- d. Assistant U.S. Attorney, Southern District of New York Assistant U.S. Attorney, Southern District of New York Assistant U.S. Attorney, Southern District of New York + +S ial A ent, Federal Bureau of Investigation + +e. Detective, New York City Police Department; + +IMMIM + +#### Official Records + +Please ask the French authority executing this request to do the following: + +- 1. secure certified copies of the official records pursuant to article 20; +- 2. have the official providing the documents attach an attestation that the documents are official records provided in his official capacity pursuant to French law, by completing an Attestation of Authenticity of Official Records (form enclosed); and, +- 3. present the records with certificate to the Central Authority for France for transmittal to the Office of the Justice Attaché, U.S. Embassy Paris. + +### COORDINATION WITH U.S. LIAISON MAGISTRATE IN FRANCE + +Please coordinate the general execution of this request for assistance with for the United States, at the U.S. Embassy in Paris at or via email at + +Thank you in advance for your assistance with the prosecution of Ghislaine Maxwell. + +Date + +Associate Director Office of International Affairs Criminal Division + +3 NYPD detective serving on the FBI task force, and assisting in the federal investigation. + +#### ATTACHMENT A + +The U.S. authorities would seek to question regarding the following topics during a voluntary interview: + +- I. The history and nature of relationship with Jeffrey Epstein. +- 2. The history and nature of relationship with Ghislaine Maxwell. +- 3. The details of time spent with Epstein and/or Maxwell in France, the United States, and any other locations. +- 4. The details regarding any trips took with and/or to visit Maxwell and/or Epstein. +- 5. The details regarding any trips Maxwell and/or Epstein took to visit +- 6. The details regarding any payments madeigiein, Maxwell, or any female associated with Maxwell and/or Epstein to +- 7. The details of any conversations participated in or witnessed during which anyone discussed Epstein's sexual preferences, practices or history; Maxwell's sexual preferences, practices, or history; and/or Maxwell's role assisting Epstein or other men in locating females with whom to engage in sexual activity. +- 8. Communications, including email correspondence, between and Maxwell and/or Epstein. +- 9. Photographs of with Epstein and/or Maxwell or of she met Epstein and Maxwell. at the time +- 10. involvement, if any, in any sexual contact and/or relationship with Epstein and/or Maxwell. +- 11. Any knowledge had or may have had of inappropriate relationships, including improper or unlawful sexual contact, involving Epstein, Maxwell, and/or their associates with any minor. + +**ATTACHMENT B** + +### ATTESTATION OF AUTHENTICITY OF OFFICIAL RECORDS + +, attest that my position with the (Name) Government of France is and that in that (Official Title) position I am authorized by French law to attest that the + +documents attached hereto and described below: + +- (1) are true copies of official records which are authorized by the laws of France to be recorded or filed in (Name of Public Office or Agency) which is a government office or agency. +- (2) set forth matters which are required by the laws of France to be reported and recorded or filed. + +Description of Documents: + +(Signature) + +(Official Seal) + +(Date) \ No newline at end of file diff --git a/marker2/ds9/EFTA00090290/EFTA00090290.metadata.json b/marker2/ds9/EFTA00090290/EFTA00090290.metadata.json new file mode 100644 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0000000000000000000000000000000000000000..5ce4f86a394a23964ef5ccda4e69848cfd249bda --- /dev/null +++ b/marker2/ds9/EFTA00090290/_page_0_Picture_0.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:ec16c5e73dbeee2bddf96a7c68997d950cbabd9683c394408588e8488b2eecaa +size 3803 diff --git a/marker2/ds9/EFTA00090301/EFTA00090301.md b/marker2/ds9/EFTA00090301/EFTA00090301.md new file mode 100644 index 0000000000000000000000000000000000000000..826ed8ee1ac230bc938ba09d4d57a07cc25a9b2e --- /dev/null +++ b/marker2/ds9/EFTA00090301/EFTA00090301.md @@ -0,0 +1,37 @@ +From: (USANYS)" < To: " Illjr> (USANYS)" Cc:' "< + +Subject: RE: GM - MLAT Request to France + +Date: Fri, 08 Jan 2021 17:09:05 +0000 + +Attachments: MLAT France vlalocx + +Some light comments on this. Thanks + +From: (USANYS) + +Sent: Thursday, January 7, 2021 9:31 PM + +To: (USANYS) (USANYS) + +Cc: ) °c > + +Subject: GM - MLAT Request to France + +MI= + +Attached for your review is a draft MLAT to France regarding the witness we mentioned earlier this week, The DOJ Attaché met with the Paris Prosecutor's Office about Brunel today. We understand that they indicated a willingness to assist on the basis of an MLAT request, and that more generally, they seemed willing to help us as long as the sharing is reciprocal. Happy to discuss. + +Thanks, + +Assistant United States Attorney + +United States Attorney's Office + +Southern District of New York + +One St. Andrew's Plaza + +New York, New York 10007 + +Tel: \ No newline at end of file diff --git a/marker2/ds9/EFTA00090301/EFTA00090301.metadata.json b/marker2/ds9/EFTA00090301/EFTA00090301.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..05d86fefa4c349f9995b955b0a4c15838432febe --- /dev/null +++ b/marker2/ds9/EFTA00090301/EFTA00090301.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090301.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 882, + "elapsed_seconds": 1.12, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 57 + ], + [ + "Line", + 26 + ], + [ + "Text", + 21 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00090301" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00090302/EFTA00090302.md b/marker2/ds9/EFTA00090302/EFTA00090302.md new file mode 100644 index 0000000000000000000000000000000000000000..ee1b5169abedf4df1c27bf576fe97bdc65c89a93 --- /dev/null +++ b/marker2/ds9/EFTA00090302/EFTA00090302.md @@ -0,0 +1,58 @@ +From: To: Cc: + +Subject: RE: Following up re outstanding GM items + +Date: Fri. 08 Jan 2021 22:06:36 +0000 + +Thanks very much for these, MI. Following up: + +- Would you be able to please send us the 302s (including the 302 documenting the image review)? +- would you please send us the notes from the interviews you handled? +- Any update from CART on those videos? +- Any word from + +From: ,=< + +Sent: Tuesday, December 22, 2020 5:22 PM + +To Cc + +Sulec : • e• o owing up re outstan.ing • items + +Hey guys, + +is on vacation for the rest of the week but I'll be in for today and tomorrow if you need anything please let me know. To answer your questions + +- These 302's are still in process and hopefully completed by next week if not in the new year. +- See attached copies of the notes I have since July of this year. will be able to follow up with the rest of the notes next week after her vacation. +- I spoke with CART and these video files are still in process. They expect to be completed in the new year. +- Today we made indirect contact with who is aware that we need to speak with her about this case going to trial. She is busy with the holiday season but agreed to call us after the new year at which time we will set a time and date for a phone call with you guys. + +Detective + +NYPD / FBI + +Child Exploitation Human Trafficking Task Force + +Office: + +Cell: + +Fax: + +From: + +Sent: Tuesday, December 22, 2020 11:32 AM + +To: Cc: + +Just wanted to check in on the status of the below items for Maxwell. When you have a chance, would you please update us on these? + +- 302 documenting the number of highly confidential items identified responsive during the searches of Epstein's devices and documenting where those images/videos are being stored; +- Providing AUSAs with copies of all outstanding notes and 302s from interviews; +- FBI CART attempts to get the video files from the +- Setting up a call with materials to play; and + +Thanks very much, + +Assistant United States Attorney Southern District of New York \ No newline at end of file diff --git a/marker2/ds9/EFTA00090302/EFTA00090302.metadata.json b/marker2/ds9/EFTA00090302/EFTA00090302.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..30d825df7dd175b0b7f81c8b142799412e0c602f --- /dev/null +++ b/marker2/ds9/EFTA00090302/EFTA00090302.metadata.json @@ -0,0 +1,100 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090302.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 1990, + "elapsed_seconds": 1.03, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 73 + ], + [ + "Line", + 37 + ], + [ + "Text", + 20 + ], + [ + "ListItem", + 8 + ], + [ + "ListGroup", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 26 + ], + [ + "Line", + 13 + ], + [ + "Text", + 6 + ], + [ + "ListItem", + 4 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00090302" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00090304/EFTA00090304.md b/marker2/ds9/EFTA00090304/EFTA00090304.md new file mode 100644 index 0000000000000000000000000000000000000000..3f8720a4b52a318f97c27e11796d82a074ff31cb --- /dev/null +++ b/marker2/ds9/EFTA00090304/EFTA00090304.md @@ -0,0 +1,80 @@ +To: + +Subject: Re: Ghislaine Maxwell 02879-509 + +Date: Sat, 09 Jan 2021 21:09:32 +0000 + +Good afternoon- + +Thank you for the response. + +To avoid repeated, inappropriate touching of Ms. Maxwell's breasts during numerous daily pat-down searches, we are requesting the guards avoid touching and brushing over her breasts while she is wearing a thin tee shirt. + +We request that Ms. Maxwell be permitted to wear her khaki v-neck top during pat searches. + +The v points directly to the area where Ms. Maxwell should be searched and minimizes unnecessary exposure and feeling of vulnerability occurring several times per day. Eniov the weekend. + +Law Offices of + +- 4th Floor + +New York, NY 10011 + +Main: + +Cell: + +Fax: + +"Covid-19 Notice: The office is currently closed but we continue to work remotely. + +Please use entail or fax, instead of regular mail, for all correspondence during this time. + +We continue to work regular business hours throughout this situation. + +Thank you for your consideration. Our best wishes for your good health and well being. + +This message and any attached documents contain information from the Law Offices o + +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 Jan 8, 2021, at 1:15 PM, > wrote: + +Good afternoorM: + +As you noted Ms. Maxwell has continuously been produced in advance of 12:30 PM. In addition, I would like to note that while Ms. Maxwell was produced after the scheduled time (twice), the additional time was provided to compensate for the delay. Please understand that while we + +are working to ensure all inmates are produced for their court and legal calls, there are institutional emergencies that require additional assistance, causing staff to slightly deviate from time frames. + +Should you request a copy of the incident report, Ms. Maxwell may provide you with it, however I cannot. I can further assure you that the daily searches are consistent with BOP Program Statement § 552.06, Searches of Housing Units, Inmates, and Inmate Work Areas. It is my understanding that gloves and masks were recently brought to the unit. Any further concerns you have indicated will be reviewed and addressed accordingly if need be. + +Thank you for your time and patience in this matter, +██████████ + +██████████ > 1/7/2021 9:50 PM >>> + +For the past two days, Ms. Maxwell has not been on time for the daily 12:30 VTCs. Yesterday, she arrived at 12:59; today she arrived at 12:47. Until yesterday, Ms. Maxwell appeared in advance of 12:30. We appreciate ██████████'s assistance in facilitating Ms. Maxwell's appearance, but no explanation has been provided for these delays.. Each delay limits the time Ms. Maxwell can confer with counsel. We hope this will not be repeated and is not retribution for complaints made by counsel. + +We learned today that the complaint report issued to Ms. Maxwell earlier this week has now been revised. I renew my request for the original report and request a copy of the updated report. + +This morning at 6:40 am, the team leader ordered Ms. Maxwell to clean a toilet, providing a few paper towels, but no gloves, sending a clear message that Ms. Maxwell should clean the toilet bare handed, despite having cleaned the toilet the night before. Gloves were provided only upon request by Ms. Maxwell. Per the A&O Handbook, sanitation duties commence at 7:30 am for pretrial inmates (See A&O, p.4). We request that Ms. Maxwell be permitted to perform sanitation duties in the evening when returned to her isolation cell. + +Further, the team leader ordered Ms. Maxwell to clean crumbs from her bed. Lest she face another charge of being untidy, Ms. Maxwell attempted to comply but there were no crumbs - just stains on the blanket issued to her. This is another example of the petty officiousness displayed by the present team. + +The ear searches continue. Routinely, in connection with open mouth searches, guards run fingers through Ms. Maxwell's hair and behind her ears, at times before she gets a chance to put on her face mask. These searches - conducted within 6 inches of Ms. Maxwell's face- continue to + +increase her risk of exposure to COVID. The number of daily searches of Ms. Maxwell, an isolated inmate under constant surveillance by multiple guards, seems excessive and unnecessarily violative.. + +Law Offices o - 4th Floor New York, NY 10011 + +Main: Cell: Fax: + +This message and any attached documents contain information from the Law Offices of + +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. \ No newline at end of file diff --git a/marker2/ds9/EFTA00090304/EFTA00090304.metadata.json b/marker2/ds9/EFTA00090304/EFTA00090304.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..af8f1c90e95fa29b3b0d237f1e38ac5d32de421f --- /dev/null +++ b/marker2/ds9/EFTA00090304/EFTA00090304.metadata.json @@ -0,0 +1,106 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090304.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 4932, + "elapsed_seconds": 9.59, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 70 + ], + [ + "Line", + 36 + ], + [ + "Text", + 27 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 18 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 35 + ], + [ + "Line", + 18 + ], + [ + "Text", + 7 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00090304" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00090307/EFTA00090307.md b/marker2/ds9/EFTA00090307/EFTA00090307.md new file mode 100644 index 0000000000000000000000000000000000000000..67af4f9e499d4f6d84fdcbbdda6eee4b2f83afa8 --- /dev/null +++ b/marker2/ds9/EFTA00090307/EFTA00090307.md @@ -0,0 +1,17 @@ +From: (USANYS)" I > + +To (USANYS)" -ffi + +Cc: iaVslYS" ffi , ' (USANYS)" + +Subject: Non-public matters for transition + +Date: Mon, 11 Jan 2021 22:32:40 +0000 + +Attachments: Non-public\_investigations docx + +— attached is a draft response to the transition's request for a description of non-public investigations and matters. Although EOUSA said it was not necessary to include cases for which we have previously sent a UMR, I did not draw that distinction, though we can discuss if you think we should. There is one additional description from which I am recused will send that separately to you. + +if you think there are any other cases that should be in this memo, let me know. + +Counsel to the Acting U.S. Attorney United States Attorney's Office Southern District of New York \ No newline at end of file diff --git a/marker2/ds9/EFTA00090307/EFTA00090307.metadata.json b/marker2/ds9/EFTA00090307/EFTA00090307.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..841d0255019b52271420ddfdcc13ed37e00c8bca --- /dev/null +++ b/marker2/ds9/EFTA00090307/EFTA00090307.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090307.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 772, + "elapsed_seconds": 0.49, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 35 + ], + [ + "Line", + 16 + ], + [ + "Text", + 9 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00090307" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00090308/EFTA00090308.md b/marker2/ds9/EFTA00090308/EFTA00090308.md new file mode 100644 index 0000000000000000000000000000000000000000..abceb40d711d0d436acd14f1b4c1769b1b3d013a --- /dev/null +++ b/marker2/ds9/EFTA00090308/EFTA00090308.md @@ -0,0 +1,13 @@ +From: (NY) (FBI)" a + +To: , a (USANYS)" + +Cc: (NYPD)" ct > + +Subject: Other documentation + +> Date: The, 12 Jan 2021 17:43:21 +0000 + +Attachments: (U)\_Documentation\_of\_services.pdf; + +(U)\_Documentation\_of\_Services\_by (U)\_S-00099701-A-011.pdf.pdf; (U)\_Victim\_Services\_ Division\_- \_Case\_Support\_Unit\_Assistance.pdf 04\_01\_2020-06\_30\_2020.pdf; \ No newline at end of file diff --git a/marker2/ds9/EFTA00090308/EFTA00090308.metadata.json b/marker2/ds9/EFTA00090308/EFTA00090308.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..ab1887945971de7aecadedd0bc1fe23a1e1b1f98 --- /dev/null +++ b/marker2/ds9/EFTA00090308/EFTA00090308.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090308.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 353, + "elapsed_seconds": 0.42, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 37 + ], + [ + "Line", + 18 + ], + [ + "Text", + 7 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00090308" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00090309/EFTA00090309.md b/marker2/ds9/EFTA00090309/EFTA00090309.md new file mode 100644 index 0000000000000000000000000000000000000000..f250bc287e1d4fb7cf0eb96aec9ecdd853a71d7b --- /dev/null +++ b/marker2/ds9/EFTA00090309/EFTA00090309.md @@ -0,0 +1,21 @@ +## FEDERAL BUREAU OF INVESTIGATION Import Form + +Form Type: OTHER - Other + +Title: f: Documentation of services + +Approved By: A/SSR, + +Drafted By: + +Case ID #: 50D-NY-3027571 (U) EPSTEIN, JEFFREY; CHILD SEX TRAFFICKING + +Synopsis: (U) To document the provision of victim services. + +♦♦ + +**UNCLASSIFIED** + +![](_page_0_Picture_2.jpeg) + +Date: 38/14/2020 \ No newline at end of file diff --git a/marker2/ds9/EFTA00090309/EFTA00090309.metadata.json b/marker2/ds9/EFTA00090309/EFTA00090309.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..f1e3564cc9bdf7b11d62468ee2300a5ece6bff67 --- /dev/null +++ b/marker2/ds9/EFTA00090309/EFTA00090309.metadata.json @@ -0,0 +1,92 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090309.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 345, + "elapsed_seconds": 0.66, + "image_assets": [ + "_page_0_Picture_2.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "FEDERAL BUREAU OF INVESTIGATION \nImport Form", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 129.744, + 58.31999999999999 + ], + [ + 476.64947509765625, + 58.31999999999999 + ], + [ + 476.64947509765625, + 87.60113525390625 + ], + [ + 129.744, + 87.60113525390625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 31 + ], + [ + "Line", + 16 + ], + [ + "Text", + 10 + ], + [ + "PageHeader", + 1 + ], + [ + "Picture", + 1 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00090309" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00090309/_page_0_Picture_2.jpeg b/marker2/ds9/EFTA00090309/_page_0_Picture_2.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..c61958da39bcce98b2f9218181511c8c5f3acac8 --- /dev/null +++ b/marker2/ds9/EFTA00090309/_page_0_Picture_2.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:fcb0d9fb52f17f247a1a6336e0479ea92b5227ac056d30ea02307a64b50a9d62 +size 4218 diff --git a/marker2/ds9/EFTA00090310/EFTA00090310.md b/marker2/ds9/EFTA00090310/EFTA00090310.md new file mode 100644 index 0000000000000000000000000000000000000000..14f6c75340b571f001362e99aa1afb742c888b2c --- /dev/null +++ b/marker2/ds9/EFTA00090310/EFTA00090310.md @@ -0,0 +1,23 @@ +![](_page_0_Picture_2.jpeg) + +## FEDERAL BUREAU OF INVESTIGATION Import Form + +Form Type: FD-1023 - Confidential Human Source Date: 10/19/2020 Reporting Document + +Title:(j) S-00099701-A-011.pdf + +Approved By: + +Drafted By: + +Case ID #: 8041-LA-3315657- (U//FOUO) 2020 Election Influence Threat INTELPRODS Assessment; FBI Los Angeles Area of Responsibility; Type 3 Assessment; Intelligence Products 50D-NY-3027571 (U) EPSTEIN, JEFFREY; CHILD SEX TRAFFICKING + +Synopsis: (U) Foreign influence on. U.S. officials by Israel, Russia, and + +Enclosure(s): Enclosed are the following items: + +- 1. Imported Attachment +- 2. A Imported Attachment +- 3. 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Please limit comments to logistical or service referral information. 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CHS learned that Dershowitz influenced many students from wealthy families. For example. Josh Kushner (Josh) and Jared Kushner (Jared) were both his students. Dershowitz told CHS that if he were young again, he would be holding a stun gun as an Israeli Intelligence (Mossad) agent. CHS believed Dershowitz was co-opted by Mossad and subscribed to their mission. CHS still continues to communicate occasionally for Dershowitz [See previous reporting]. + +(U)Jeffrey Epstein (Epstein) was represented by Dershowitz. CHS remembered Dershowitz tell Alex Ocasta (U.S. Attorney of Southern District of Florida at the time) that Epstein belonged to both U.S. and allied intelligence services. CHS shared phone calls between Dershowitz and Epstein during which he/she took notes. After these calls, Mossad would then call Dershowitz to debrief. Epstein was close to the former Prime Minister of Israel, Ehud Barak (Barak) and trained as a spy under him. Barak believed Netanyahu was a criminal. Saudi Arabia, Israel and the United Arab Emirates (UAE) are allied against Qatar, Turkey, Iran and Syria. One of CHS' (who presumably worke asked CHS a lot of questions about Epstein. CHS became convinced t t pstein was a co-opted Mossad Agent see previous reporting). + +(U)Masha Drokova (Drokova), telephone number [REDACTED], is based in Silicon Valley. She has been running a firm called Day One Ventures, which is supposedly an early stage investment company. She used to be Russian President Vladimir Putin's main contact in the Russian Youth movement. CHS and Drokova spoke, but Drokova did not talk at all about technology; instead, she looked at CHS and said, "You knew Epstein, didn't you." She said Epstein was a "wonderful man" and that it was a crying shame what had been done to him. CHS concluded Day One Ventures was in Silicon Valley to steal technology. + +(U)CHS advised Chabad is doing everything they can to co-opt the Trump presidency. Chabad is basically state-sanctioned Judaism. It is used by Putin to keep tabs on all the Russo-Jewish oligarchs. On the day Trump was elected President, Ivanka Trump (Ivanka) and Jared were at the gravesite of Rabbi Scheersom, who was the most powerful Rabbi in the Chabad network. Jared didn't disclose his stake in Cadre, because of its ties to the Russian state (NFI). CHS believed this was/is the "real" Russian collusion story. Kushner has moved a lot of Russian investment money around. The FBI should investigate Kushner's family charities to find evidence of corruption and money laundering. Chabad routinely uses charities to launder money. + +(U)CHS provided the attached article entitled "Jim McGreevey and His Main Man By Craig Horowitz," published 09/10/2004. While the article is old and centered on Charles Kushner (Charles), it highlights and documents the deep ties the Kushner family has with Israel and their history of corrupt business practices and alleged violations of election laws. CHS stated that if the FBI is serious about investigating the Kushners and their relationships with Middle East, they should look closely at Ken Kurson, who "knows everything" (NFI). CHS advised Henry Kissinger introduced Charles to Cui Tiankai, the Chinese ambassador to the U.S., a relationship that could have been helpful; at around the same time of the introduction, Anbang was entering negotiations with the Kushners over 666 Fifth Avenue. + +(U)Hary Tanoesoedinbjo (Hary) has been involved has developed Trump's hotels and is a billionaire. Hary [REDACTED] introduced him/her to the Indonesian CIA [REDACTED] Hary [REDACTED] speak Indonesian. Hary bought his Beverly Hills home from Trump at an inflated price (NFI). On [REDACTED] [REDACTED] was at Hary's house when Hary [REDACTED] that Trump told him that he was going to "fuck Amazon" over their military contracts. CHS advised that this was a real collusion story - Trump has been compromised by Israel, and Kushner is the real brains behind his organization and his Presidency. + +(U)Igor Korbatov (Igor) brokered the sale of a Beverly Hills mansion Trump acquired for \$800,000 less than the market value. CHS referenced the attached article that summarized the matter - "A small-time scam artist gave Trump a mansion for \$0. Why?" published April 12 2018 by Lance Williams and Matt Smith in "Reveal from The Center for Investigative Reporting." Ross Delston, a Washington, D.C.-based attorney and consultant on financial crimes to the International Monetary Fund, said the deal included "many facets that don't add up" and that the deal warrants further scrutiny and investigators should follow up on the "numerous oddities and red flags that this series of transactions raises." + +(U)The Fisches (NFI) signed the deed transferring the Beverly Hills home. The Fisches are prominent Los Angeles real estate investors and political donors. They have given more than \$250,000 to GOP candidates and causes, records show. They were guests at the White House when George W. Bush was president and accompanied him on a trip to Israel, Selma Fisch said in a phone interview. Their daughter and wife of the sales broker, Lisa Korbatov (Lisa), is a GOP activist and president of the Beverly Hills Unified school board; Lisa is an active member of the Jewish community in Beverly Hills. After one season on the West Coast, "The Apprentice" moved back to New York. Trump never lived in the Beverly Hills mansion. In the summer of 2009, he sold the home for \$9.5 million - \$800,000 less than the previous year's price - to a Swiss entity associated with the family of Eka Widjaja, an Indonesian billionaire financier. The sale was in cash. Trump's former lawyer, Michael Cohen, filed the legal papers for the shell company involved in the mansion's purchase, and he notarized the deed when Trump sold the property, records show. He didn't respond to multiple requests for comment. + +![](_page_2_Picture_4.jpeg) + +(U)CHS statecl l Renda Tillerson (Renda), telephone numbe . Renda is the wife of Rex Tillerson (Rex), former Secretary of State for Trump. Renda told CHS about smears in the New York Post and how Jared was running a rival State Department operation. Rex affirmed Renda's claim. Renda was introduced to CHS by Daren Blanton (Blanton). Renda and Rex both told CHS they had been under intense surveillance. Renda told CHS she can't wait for the FBI to call her, so that she can tell them everything she knows. + +(U)According to Jed Shugerman and Whitney Webb, Leon Black (Black) owns the mercenary firm formerly known as Blackwater, now Constellis, which has been accused of being involved in several arms and human trafficking scandals. Black is also the CEO of Apollo. "@NYTimes" noted that Black "inexplicably stood by Jeffrey Epstein. recently giving him \$50M." Apollo also lent the Kushners \$184 million (USD) while Kushner was facing his 666 5th Avenue disaster. (see attached screenshots for references] + +(U)Elliott Broidy (Broidy) recently plead to charges related to money laundering unregistered lobbying for the UAE. Broidy previously paid a former Playboy Model over \$1 million to stay quiet about an affair he had with her. Broidy allegedly successfully lobbied to increase U.S. sanctions on the Government of Qatar. CHS advised since Broidy was purportedly the largest fund raiser for Trump, supporting esidential election, he apparently used his access to Trump to lobby. Joel Mowbray (Mowbray). telephone has been in Broidy's inner circle. CHS believed Mowbray was an unregistered lobbyist. Mowbray was one of the "shiftiest" people CHS had ever encountered. Mowbray was a convert to Judaism. CHS stated Mowbray would flip on Broidy because he's a "flipper." Congressman Ed Royce (Royce) was close to Broidy and has been trying to do shady things (NFI). Royce's wife may be a lobbyist who works with Broidy. + +(U)CHS emphasized the importance for the FBI to investigate Gawker for its involvement in pushing Russian propaganda. 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12\_28\_p.m.\_Eastern\_Time, an\_anonymous\_tipster\_(Anonymous) , IP.pdf; +(U) On 08\_05\_2020, at 5\_48\_p.m.\_Eastern\_Time, [REDACTED], [REDACTED]; (U) On 08\_06\_2020, at 02\_27\_PM, [REDACTED] - [REDACTED], Called the FBI.pdf; +(U) On 08\_06\_2020, at 10\_12\_a.m.\_Eastern\_Time, [REDACTED], [REDACTED].pdf; +(U) On 08\_10\_2020, at 08\_10\_2020\_p.m.\_Eastern\_Time, an\_anonymous\_female\_caller\_(Anonymous.pdf; +(U) On 08\_11\_2020, at 7\_26\_a.m.\_Eastern\_Time, [REDACTED] ) , email.pdf; +(U) On 08\_17\_2020, at 3\_03\_PM\_Eastern\_Time, [REDACTED], [REDACTED].pdf; +(U) On 08\_17\_2020, at 3\_32\_p.m.\_Eastern\_Time, [REDACTED], [REDACTED].pdf; +(U) On 08\_20\_2020, at 10\_31\_12\_AM\_Eastern\_Time, [REDACTED], [REDACTED].pdf; +(U) On 08\_24\_2020, at 4\_31\_p.m.\_Eastern\_Time, [REDACTED], [REDACTED].pdf; +(U) On 08\_24\_2020, at 11\_34\_48\_AM\_Eastern\_Time, [REDACTED], Home\_telephone\_number.pdf; +(U) On 08\_24\_2020, [REDACTED], [REDACTED].pdf; +NU), date\_of.pdf; +(U) On 09\_08\_2020, at 10\_29\_p.m.\_Eastern\_Time, [REDACTED], [REDACTED].pdf; +(U) On 09\_14\_2020, at 12\_12\_p.m.\_Eastern\_Time, [REDACTED], [REDACTED].pdf; +(U) On 10\_09\_2020, at 7\_22\_58\_PM\_Eastern\_Time, [REDACTED], [REDACTED].pdf; +(U) On 10\_12\_2020, at 3\_14\_p.m.\_Eastern\_Time, [REDACTED], [REDACTED].pdf; +(U) On 10\_19\_2020, at 2\_00\_p.m.\_Eastern\_Time, [REDACTED], [REDACTED].pdf; +(U) On 10\_19\_2020, at 11\_43\_AM\_Eastern\_Time, [REDACTED], [REDACTED].pdf; +(U) On 10\_27\_2020, at 3\_20\_p.m.\_Eastern\_Time, [REDACTED], [REDACTED].pdf; +(U) On 11\_02\_2020 at 5\_58\_AM\_Eastern\_Time, [REDACTED] ), date\_of\_birth [REDACTED]; + +(U) On 11\_09\_2020, at 5\_16\_p.m. Eastern\_time, [REDACTED], date\_of\_birth\_[REDACTED].pdf; + +(U) On 12\_06\_2020, [REDACTED]. 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The main house I was taken to is located behind Thorpe Green, at the end of a private road. Hurst Farm Livery Stables is next door. In the driveway of this house, I was hit by a dark blue car with a personalised license plate ending in "DOY", driven by Prince Andrew. I was not taken to hospital, but I suffered permanent injuries to my ribs, hip and leg on my right side. The car's hood figurine broke off in my hand on impact and I later buried it near my home, so it could still be recoverable as evidence. After I was hit by the car, I woke up to Prince Andrew forcing his He me. In that house, I was also . I have medical records of the resulting infection. I once ran away from the house naked, and made it to the Irish Traveller community down the road (GPS: 51.405369, - 0.546576). I remember seeing and speaking to a man, so I think that there may be Irish Travellers living in the area who could corroborate what goes on there. I was also taken to another house that I later recognised as Frogmore Cottage when its refurbishment was in the news in 2018. There, I was restrained on a table and tortured with electrical shocks by Ghislaine Maxwell and surrounded by watching men. I remember seeing Prince Andrew's face. After being by another man there, I tried to sneak out. Maxwell caught me and beat me with the bristle end of a broom. She . She also threatened me, saying that I "deserved to die" and hit me in the face with the broom, breaking my nose. I was only taken to the hospital for the broken nose after a rugby match, so that the injury could be blamed on that. + +Re: 50D-NY-3027571, 08/15/2020 + +Violation: Other + +## Violation Questions + +What was the exact crime that occurred?: Human trafficking and sexual assault against minors + +When did the crime/incident occur? (Please provide an approximate date and time): 1994-1996 + +Where did the crime/incident occur? (Please provide the specific location/address if possible): Frogmore Cottage, Windsor SL4 2JG, United Kingdom / Egham, TW20 8QL GPS Coordinates: 51.403800, -0.551690 / Palm Beach, Florida + +# Complainant Information + +First Name: + +Middle Name: + +Last Name: + +Age: + +DOB: + +Additional Info: + +Type: Cell + +Phone: + +Extension: n/a + +Account: + +Type: Residential + +Address: + +City: Newhall + +State: California + +Zip: 91321 + +Re: 50D-NY-3027571, 08/15/2020 + +Country: United States + +Subject Information + +First Name: Ghislaine + +Middle Name: + +Last Name: Maxwell + +Age: 58 + +DOB: + +Additional Info: During this time frame, I also went on yearly vacations with my family to Florida, staying at my grandparent's house in I remember on one occasion being driven by my father over an hour away to a mansion with a gated driveway and a large rectangular swimming pool. I was by a man that I later recognised as Epstein when he was in the news. He also attempted to rape me ( . He took pornographic photographs of me in a skirt. + +Around late 2012, I had not yet fully processed all these memories, but I reported my father to the police after seeing a text from G. Maxwell on his phone saying: " ", and being triggered by it. I believe it's possible that my father may have been involved in procurement for the pedophile ring even then, because he made visits to several local schools and a disabled children's home (the White Lodge Centre). In the end, he was not arrested and the case was not investigated. As a result, he was able to destroy a lot of evidence, such as photographs. Releasing Ghislaine Maxwell on bail would lead to the same outcome. + +I am willing to testify, and provide evidence and/or more detailed descriptions of events. + +Other ring members - + +Re: 50D-NY-3027571, 08/15/2020 + +My father's best friend - + +My father's 'secret accountant' - he lives in the house between Fanshaw Cottage and the Royal Marine Pub on Lyne Lane. GPS Coordinates: I heard my rapist from Frogmore Cottage at his house during a "party" on a Saturday in the Summer of 2018. + +How is Contact Known: I was a victim of human trafficking by her pedophile ring. + +Type: Other + +Address: + +City: + +Zip: + +Witness Information + +First Name: + +Middle Name: + +Last Name: + +Age: • + +DOB: + +Additional Info: I also remember another victim being + +She is a year younger than me, so she may have been as young as 5 years-old at the time. Afterwards, she was taken out of an affluent private primary school and sent to the worst school in the area, where my mother worked. That was where I first recognised her, even though we had supposedly never met. She was put in a class two years ahead, and then went to the same Secondary School as me patron the Queen) a year before I did. We have never once spoken. + +How is Contact Known: is the daughter of and my childhood friend. I remember was at some of the parties with me, and I remember us once hiding behind a drape together. 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Anonymous stated she and her five siblings were "sold" throughout their entire childhood and Anonymous stated she met Epstein when she was four years old, around the time Ghislaine was around. Anonymous was given mental health problems while growing up in order to make her appear less credible. Anonymous stated her father forced men to . Anonymous reported she is now 28 years old and she cannot do it anymore. + +While growing up, assigned all of the siblings with "pimps." Anonymous stated her "pimp" was only a year older and they were expected to marry one another. Anonymous noted she is still with her "pimp" and they have a four year old child together. is currently attempting to get full custody of Anonymous' child, but Anonymous fears he will be trafficked as well. Anonymous' child has already made reference to " " and "I don't want monsters to come in my room." + +UNCLASSIFIED + +Re: 50D-NY-3027571, 08/11/2020 + +Anonymous reported her siblings would never come forward with the information and would never bring it up. Anonymous stated she is still "under the thumb" of an unknown man that sells her, and Anonymous receives no money for it. Anonymous often blacked-out as a child and stated some of her memories are unclear. + +Anonymous is potentially willing to provide additional information in person. Anonymous noted she was the one to take the photograph of Prince Andrew and in 2001. Anonymous formally went by the name + +.• \ No newline at end of file diff --git a/marker2/ds9/EFTA00090324/EFTA00090324.metadata.json b/marker2/ds9/EFTA00090324/EFTA00090324.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..e64e755299f81a286896b1aa3d47fefc2ba9081b --- /dev/null +++ b/marker2/ds9/EFTA00090324/EFTA00090324.metadata.json @@ -0,0 +1,172 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090324.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2062, + "elapsed_seconds": 0.81, + "image_assets": [ + "_page_0_Picture_2.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "FEDERAL BUREAU OF INVESTIGATION", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 129.744, + 58.31999999999999 + ], + [ + 477.0376281738281, + 58.31999999999999 + ], + [ + 477.0376281738281, + 75.032958984375 + ], + [ + 129.744, + 75.032958984375 + ] + ] + }, + { + "title": "Details:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 59.976, + 270.54 + ], + [ + 122.48091888427734, + 270.54 + ], + [ + 122.48091888427734, + 284.0752258300781 + ], + [ + 59.976, + 284.0752258300781 + ] + ] + }, + { + "title": "UNCLASSIFIED", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 259.488, + 40.5 + ], + [ + 348.6435241699219, + 40.5 + ], + [ + 348.6435241699219, + 52.57623291015625 + ], + [ + 259.488, + 52.57623291015625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 70 + ], + [ + "Line", + 34 + ], + [ + "Text", + 11 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 27 + ], + [ + "Line", + 14 + ], + [ + "Text", + 4 + ], + [ + "PageFooter", + 3 + ], + [ + "SectionHeader", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00090324" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00090324/_page_0_Picture_2.jpeg b/marker2/ds9/EFTA00090324/_page_0_Picture_2.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..878f22e2ba2063af22fc12ff963e1bbf31d8d6ae --- /dev/null +++ b/marker2/ds9/EFTA00090324/_page_0_Picture_2.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:6de70f6effb0969cbfeb565b4124f1261714ff640d11988afa2a00c1be2d91e7 +size 8867 diff --git a/marker2/ds9/EFTA00090326/EFTA00090326.md b/marker2/ds9/EFTA00090326/EFTA00090326.md new file mode 100644 index 0000000000000000000000000000000000000000..f648b0ae0afb2efa59b28da7a87c1abf3bdc3f42 --- /dev/null +++ b/marker2/ds9/EFTA00090326/EFTA00090326.md @@ -0,0 +1,155 @@ +![](_page_0_Picture_2.jpeg) + +# FEDERAL BUREAU OF INVESTIGATION + +Intake + +Date: 08/11/2020 + +Case ID #: 50D-NY-3027571 (U) EPSTEIN, JEFFREY; CHILD SEX TRAFFICKING + +Drafted Sy: + +Date/Time Received: 08/11/2020 07:26 AM EDT + +# Details: + +On 08/11/2020, at 7:26 a.m. Eastern Time, Last Name Unknown (LNU), email address , who resides in Virginia Beach, VA, Internet Protocol (IP) address , which resolves to Virginia Beach, VA 23464, submitted an online tip to the FBI National Threat Operations Center (NTOC) via tips.fbi.gov, to report a sexual encounter with Jeffrey Epstein when she was 15 years old. + +Date Submitted: 08/11/2020 07:26:56 AM ET + +Transaction Number: 0B153A14-9B5A-425F-ACAB-46CC624AD735 + +Threat To Life: False + +Submitted Text: + +Hi, my name is I think I may have been a victim by jeffrey epstein. I was about 15 at the time. My friend said we could make some quick money just by giving a massage. So we met with her friend who his name was Andy. When we went I sat down while she went inside the bedroom. She came out & Andy said he wanted me to come in. When I walked in there was another man sitting on I don't know who I need to talk to about this but + +Re: 50D-NY-3027571, 08/11/2023 + +the bed which made me even made hesitate to go in but I went quick massage to a man who looks very much like him. Then he . All I remember is in. I gave a proceeded to getting . After it was all done he gave us money & we left. I'm really trying to remember if it was him or not since I've blocked absolutely so much of those years out of my head. But he looks so familiar & that voice of his as well.Not only that but months later Andy drives by the place I stayed at & asked me was there anyone in the government or law enforcement looking for him. He said that he was part of a thing with a powerful man & he has to get out of town if they were looking for him. I told him they weren't which it was the case. I know Andy & other men he knew would give girls but mostly Russian girls places to stay & help them with work. Much of that work was prostitution for rich men that Andy pimped them out to. So I am hoping you can help me figure out if I was Epstein victims by answering some questions so I can piece it together. Such as could you please tell me if you have proof that jeffrey epstein was in Virginia Beach,Virginia in the 2000's? Did Epstein have Russian girls in Virginia Beach, Virginia? Do you have a Virginia Beach home address on file for him that I could verify back to you? Finally has the name Andy ever come up in ur files that's related to Epstein in anyway? If you would be so kind to email me back it would be greatly appreciated. Thank you. + +Violation: Other + +#### Violation Questions + +What was the exact crime that occurred?: It's about Jeffery Epstein + +When did the crime/incident occur? (Please provide an approximate date and time): 2000's + +Where did the crime/incident occur? (Please provide the specific location/address if possible): Virginia Beach, VA + +Re: 50D-NY-3027571, 08/11/2020 + +# Complainant Information + +First Name: + +Middle Name: + +Last Name: + +Age: + +DOB: + +Additional Info: + +Account: + +Type: Other + +Address: + +City: Virginia Beach + +State: Virginia + +Zip: + +Country: United States + +## Subject Information + +First Name: Jeffery + +Middle Name: + +Last Name: Epstein + +Age: N/A + +Re: 50D-NY-3027571, 08/11/2020 + +DOB: + +Additional Info: No + +How is Contact Known: Written above + +Type: Other + +Address: + +City: + +Zip: + +Witness Information + +First Name: + +Middle Name: + +Last Name: + +Age: + +DOB: + +Additional Info: N/A + +How is Contact Known: N/A + +Type: Other + +Address: + +City: + +Zip: + +Re: 50O-NY-3027571, 08/11/2020 + +Remote IP: + +Remote Host: api.fbi.gov + +Http Referrer: https://www.fbi.gov/tips + +User Browser: Mozilla/5.0 (iPhone; CPU iPhone OS 13\_6 like Mac OS X) AppleWebKit/605.1.15 (KHTML, like Gecko) Version/13.1.2 Mobile/15E148 Safari/604.1 + +Latitude: + +Longitude: -- + +Country: US + +Region: Virginia + +City: Virginia Beach + +Postal Code: 23464 + +Timezone: -04:00 + +Domain Awareness Caveat: When collected, this information was determined to be of no current lead value and did not provide a basis to investigate further. 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Time, number called the FBI National Threat Operations Center (NTOC) to report information regarding a Jeffrey Epstein party. date of birth cellular telephone + +provided the following information: + +met Lisa Villeneuve at a hospital where they were roommates in 2000. Villeneuve now goes by Ghislaine Lisa Villeneuve and sells real estate in Irving California. + +After and Villeneuve left the hospital they remained friends. Later that year in 2000 around Christmas time Villeneuve invited to a party on Palm Beach Island, FL. believes the house belong to Epstein. Before the part Villeneuve took to meet Bobby Cox. Cox was a young man and introduced himself as a model scout. Villeneuve laughed in response to Cox's introduction and said "No, you're a pimp." Villeneuve, Cox and then went to the party. They entered the property through the back yard and Villeneuve said she would go inside to speak with the hostess which believes was Ghislaine Maxwell. When Villeneuve took inside Villeneuve told to stay close and not go into any of the rooms. Villeneuve took to meet a man named Curt Schmidt, who is currently the CEO of Blue Buffalo. When Villeneuve and approached Schmidt he asked Villeneuve if was cool. stated she was cool. Villeneuve said no, he means cool to have sex. Schmidt said no he meant cocaine. Villeneuve took back inside and someone told the party that Donald Trump had invited them all to a party at Mar a Lago. told Villeneuve she wanted to go, but Villeneuve told it wasn't that kind of party, it was for prostitutes. + +♦♦ + +**hasn't spoken to Villeneuve since 2002.** + +**UNCLASSIFIED** \ No newline at end of file diff --git a/marker2/ds9/EFTA00090332/EFTA00090332.metadata.json b/marker2/ds9/EFTA00090332/EFTA00090332.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..d18bd824dfe3ad6feb0f19ae221b6b8f016fb11d --- /dev/null +++ b/marker2/ds9/EFTA00090332/EFTA00090332.metadata.json @@ -0,0 +1,115 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090332.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1876, + "elapsed_seconds": 0.85, + "image_assets": [ + "_page_0_Picture_2.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "FEDERAL BUREAU OF INVESTIGATION", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 129.744, + 58.31999999999999 + ], + [ + 477.0376281738281, + 58.31999999999999 + ], + [ + 477.0376281738281, + 75.032958984375 + ], + [ + 129.744, + 75.032958984375 + ] + ] + }, + { + "title": "Details:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 59.976, + 270.54 + ], + [ + 122.47794342041016, + 270.54 + ], + [ + 122.47794342041016, + 283.83416748046875 + ], + [ + 59.976, + 283.83416748046875 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 66 + ], + [ + "Line", + 33 + ], + [ + "Text", + 13 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00090332" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00090332/_page_0_Picture_2.jpeg b/marker2/ds9/EFTA00090332/_page_0_Picture_2.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..331eb6b21da239025b80434c442ed3a9a0cf19e0 --- /dev/null +++ b/marker2/ds9/EFTA00090332/_page_0_Picture_2.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:73605bfd710e8c04a3fbf25243d778dc2e00da26828dc52f85d2de3136a4e0de +size 8869 diff --git a/marker2/ds9/EFTA00090333/EFTA00090333.md b/marker2/ds9/EFTA00090333/EFTA00090333.md new file mode 100644 index 0000000000000000000000000000000000000000..f7030ff407bfa34d8475e34c80c68126c49b0de3 --- /dev/null +++ b/marker2/ds9/EFTA00090333/EFTA00090333.md @@ -0,0 +1,135 @@ +# FEDERAL BUREAU OF INVESTIGATION + +Intake + +Case ID \*: 50D-NY-3027571 (U) EPSTEIN, JEFFREY; CHILD SEX TRAFFICKING + +Drafted Sy: + +![](_page_0_Picture_2.jpeg) + +Date: 11/02/2020 + +Date/Time Received: 11/02/2020 05:58 AM EST + +# Details: + +On 11/02/2020 at 5:58 AM Eastern Time, • birth , email address international cellular telephone number + Stavanger, Norway 04010, internet protrocol (IP) address -• which resolves to Stavanger, Rogaland, Norway, submitted an online tip at tips.fbi.gov regarding Human Trafficking involving Jeffrey Epstein. , date of , residential address + +Date Submitted: 11/02/2020 05:58:41 AM ET Transaction Number: F1F04018-40CB-45CE-A08A-CC97021E3E10 + +Threat To Life: False + +## Submitted Text: + +I have suffered massive humantrafficking. It started as a young child. I was sold to russia. I have been molested by lawyers, judges, royalties, politicians and presidents, policemen and others. I was sold to Jeffrey Epstein several times. My family and relatives recieved money for me. I have been molested and raped several years. They made porn of me. They made me a sexslave in every nation. They tried to kill my brain. The royalties in Norway, Rokke, others tried to put was a billionaire and people stole this fortune and tried to disqualify me. There is no help to get, I need help. I have been involved with Joe Eiden and Hillary Clinton. Gunnhild Stordalen, Petter Stordalen, Kjell Inge , Jens Stoltenberg, Jonas Gahr Store, Stian and me into coma and they wanted to make me disabled. I + +UNCLASSIFIED + +Re: 50D-NY-3027571, 11/02/2020 + +Violation: Human Trafficking + +# Violation Questions + +Please provide details about the specific location where the victim is being held.: no specific location + +How do you know the victim?: I am the victim. + +Who has control of the victim's identification and travel documents?: victim + +## Complainant Information + +First Name: + +Middle Name: + +Last Name: + +Age: + +DOB: + +Additional Info: + +Type: Cell + +Phone: + + +Extension: +47 + +Account: + +Type: Residential + +Address: + +City: Stavanger + +Zip: 04010 + +Country: Norway + +#### Trafficker Information + +First Name: + +Middle Name: + +Last Name: + +Age: + +DOB: + +Additional Info: They sterilised me. + +I once gave birth to a child and I wake up from coma because of the birth. + +How is Contact Known: some of the traffickers are relatives and family + +#### UNCLASSIFIED + +Re: 50D-NY-3027571, 11/02/2020 + +members, Odd Gunnar bjørstad. Jorunn Jaunsen. + +Einar Ossletten, Ove Arnt Breen. Arnt Ossletten. Bjørn Ossletten. Roger Oss letten. + +Rose Ossletten. Sigurd ossletten. Aud Ossletten. + +Type: Other + +Address: + +City: + +Zip: + +Remote IP: + +Remote Host: api.fbi.gov + +Http Referrer: https://www.fbi.gov/tips + +User Browser: Mozilla/5.0 (Windows NT 10.0; Win64; x64; rv:72.0) + +Gecko/20100101 Firefox/72.0 + +Latitude: + +Longitude: + +Country: NO + +Region: Rogaland + +City: Stavanger + +Postal Code: + +Timezone: 01:00 + +\*\* + +UNCLASSIFIED \ No newline at end of file diff --git a/marker2/ds9/EFTA00090333/EFTA00090333.metadata.json b/marker2/ds9/EFTA00090333/EFTA00090333.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..73ca7fb376691b8e0c2a6e234460b6e28767e9f2 --- /dev/null +++ b/marker2/ds9/EFTA00090333/EFTA00090333.metadata.json @@ -0,0 +1,344 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090333.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", 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b/marker2/ds9/EFTA00090333/_page_0_Picture_2.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..793f1df4f33c5b1da63e65721772c8816ec6523a --- /dev/null +++ b/marker2/ds9/EFTA00090333/_page_0_Picture_2.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:283bbbf79509eecca1f9aafbba9c5e8699552f99bb5c404d4b904b2784d1a0bf +size 4552 diff --git a/marker2/ds9/EFTA00090336/EFTA00090336.md b/marker2/ds9/EFTA00090336/EFTA00090336.md new file mode 100644 index 0000000000000000000000000000000000000000..e8704c9b50030f5efc3d287cc833978ab7f1c6ed --- /dev/null +++ b/marker2/ds9/EFTA00090336/EFTA00090336.md @@ -0,0 +1,25 @@ +![](_page_0_Picture_2.jpeg) + +## FEDERAL BUREAU OF INVESTIGATION + +Intake + +Date: 11/10/2020 + +Case ID #: 50D-NY-3027571 (U) EPSTEIN, JEFFREY; CHILD SEX TRAFFICKING + +Drafted By: + +Date/Time Received: 11/09/2020 05:16 PM EST + +## Details: + +On 11/09/2020, at 5:16 p.m. Eastern time, birth , home telephone number National Threat Operations Center (NTOC)to report her Epstein in New York City, NY. , date of called the FBI assault by Jeffrey + +provided the following information, + +When she was sixteen years old, vacation with her grandfather. She often with her grandfather. One day, Ghislaine a dog-walking job. went with Epstein was present. She was offered a drink which she says made her tired and she fell asleep. When she woke up she went to the bathroom and claims she was . She claims to remember Epstein pinning her down at some point. When she woke up, the only person in the office was a housekeeper or something. She did not report this to anyone until this year. has filed a report with the NYPD regarding the assault. 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Ms. Waggner was (SA ) and (Det. 1 . + +On August 4, 2020, SA was provided with Maricopa Police Department Officer Report for D. summarized the interview. a copy of the City of R. 200722037, which + +UNCLASSIFIED//FOUO + +Date of entry 08/05/2020 + +Investigation on 07/27/2020 at Maricopa, Arizona, United States (In Person) + +This document contains neither recommendations nor conclusions of the FBI. 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Present for the interview was attorneys Brad Edwards and Brittany Henderson. Also present for the interview was Assistant United States Attorney-III and Special Agent-. After being advised of the identities of the above listed individuals and the nature of the interview, provided the following information: + +grew up in Astoria with her family; was the youngest of five children. has a European background and grew up in a strict household. has a big family. went to school in Astoria. When was 15 years old, her mother passed away and she was pretty much left on her own being the youngest child. aunts and uncles went their own way. + +met (known to law enforcement as and her life took a different turn. worked for JEFFREY EPSTEIN. still has trouble dealing with it; she normalized it in her mind for so long. knew meeting EPSTEIN was wrong but he was smart and he felt like her friend. EPSTEIN would hug and made her feel like he was the only person she had. wanted to feel mad about it but EPSTEIN was all she had for so many years; did not completely know how to feel about it. Saying it all out loud, realized how messed up it was and it took a long time for to get to that point. has seen movies and always wondered why people did not leave when in similar situations. has asked herself why she continued to have the relationship with EPSTEIN. still talks to III (known to law enforcement as ) and (known to law enforcement as has also talked to her sister and a therapist no longer speaks with + +Investiptionon 11/04/2020 at New York, New York, United States (In Person) + +This document contains neither recommendations nor conclusions of the FBI. It is the moµ" ty of the FBI and is loaned to your agency; it and its contents arc not to be distributed outside your agency. + +Comthuation of FD-302 of (U) Interview of .On 11/04/2020 ,page 2 of 9 + +When was 15 years old, her mother was in the hospital for four months before she passed away. and her sister had no guardian. When met they smoked weed together. was independent and also 15 years old. was living with her mother and a "go getter". mom was strict while was not. A month after mother passed away, about a guy her friend problems. (EPSTEIN) who saw EPSTEIN. would pay for worked at a Greek restaurant tried to get a job like that. met EPSTEIN. talked about like he talked to food that had had told was a god. ■ **about her always had money. Greek music. and** + +**was angry with her family after her mother's passing. agreed to meet EPSTEIN. had told to massage EPSTEIN and that he liked pretty girls and she may have to massage him in her bathing suit. EPSTEIN was nice, comforting, and EPSTEIN's house as hug and like a when she would go there. welcoming to dream. described stated it felt like a high** + +**The first time met EPSTEIN he knew everything about her. EPSTEIN listened, hugged her, and comforted her. EPSTEIN came at the right time in life as he seemed like a savior. There was no thought process as just went with it. EPSTEIN reassured that he would always be there if she ever needed anything. recalled the feeling that EPSTEIN loved and cared about her. The first time she went to EPSTEIN's home in Manhattan, was nervous and recalled fixing her makeup and wanting to look older. recalled walking up to EPSTEIN's front door because it was so massive. took to meet EPSTEIN. They walked into his Manhattan mansion as people let them in, then they waited in the office. EPSTEIN came in and showed around. recalled walking by his office and seeing leopard print chairs and thinking it was so cool because she loved leopard print. recalled going to different floors before going to the massage room.** + +**recalled the massage room as having a table with a little desk by it. The room had a full cabinet with so many lotions, including Bath and Body Works products. recalled orange scented products and stress relief products. felt cool because it felt like she was a real masseuse. described there being paintings on the walls.** + +continuation of FD-302 of (U) Interview of 11/04/2020 .page 3 of 9 + +recalled seeing a painting of a "fat lady" that was naked but look depressed. would joke because she "had a butt" and would say that was her while the skinny one was recalled she would never forget the ceiling as it was not flat and there were clouds all over. Ninety percent of the time, EPSTEIN would be on the phone while he was getting a massage, then he would get off of the phone then flip over. EPSTEIN would brag about who he was talking to on the phone, saying he was on with the president or be on the phone with models. The president went on a trip with EPSTEIN on EPSTEIN's private jet. felt that EPSTEIN would brag about these calls on purpose. + +EPSTEIN was always talking to someone in power. was very intimidated by him. EPSTEIN was very powerful and had a very strong presence. EPSTEIN would come in wearing "stupid sweaters" that had "JE" on them. stated EPSTEIN "was so extra". EPSTEIN had towels that had his initials on them. described that EPSTEIN was funny and had a good sense of humor and would make them laugh. wanted to be a superstar; her screen name at the time was " '. EPSTEIN told that he had all these connections with models, and he knew the head of Victoria's Secret. EPSTEIN made a lot of promises. + +A few times, EPSTEIN drove home with a driver. recalled they were in a black pickup suburban. EPSTEIN tried to ask to do stuff. EPSTEIN told he could take her places and she could fly with him. mother was in a car accident and was scared to be in cars and flying. EPSTEIN bought things including Victoria's Secret lingerie. EPSTEIN really liked EPSTEIN did not care if had someone; he just wanted to see her. and told that EPSTEIN really liked her and she should go with him. did not like flying so she did not travel with EPSTEIN. + +would call the office and talk to girls. EPSTEIN always had LESLEY (known to law enforcement as LESLEY GROFF) call then he would come on the phone. EPSTEIN never called direct. Eventually EPSTEIN started asking for friends. brought to meet EPSTEIN. estimated saw EPSTEIN 3 to 4 times. EPSTEIN would get tired of the same girls. knew EPSTEIN saw III; he wanted to see her. + +Continuation of FD-302 of (U) Interview of .On 11/04/2020 ,page 4 of 9 + +If ever needed anything she would call because she was a girl and felt comfortable talking to her. would rarely call EPSTEIN personally. would ask for money or Broadway show tickets, then would usually go to the office to pick up the money or tickets. If needed something and it was after office hours she would call EPSTEIN. recalled giving her identification when she went to the office for tickets. checked her ID before giving her the tickets. was picking up approximately six tickets. just looked at her ID and gave it back to her. thought she was looking at it to maybe just make sure it was her. This was in the beginning during one of her first encounters with thought this was around 2003. The first time had gone to the office was a few months after she started seeing EPSTEIN. thought the office was in Midtown. Sometimes, went with some of the girls, including or , to the office. did not go to the office with III as III and EPSTEIN formed their own relationship and he saw III on his own. Most of the times went in a cab to the office by herself. + +EPSTEIN was straight to the point, asking when he would see or if she had anyone new. EPSTEIN would tell her she could come at a certain time. Sometimes, went to EPSTEIN's residence 2 to 3 times a day to give him a massage. They did not speak over the phone about it. + +would massage EPSTEIN Then about six months later, EPSTEIN took to a different room, which was an open room that included a jacuzzi and a lot of shower heads. This was EPSTEIN's bedroom. EPSTEIN did not always every time he saw her. Sometimes, EPSTEIN just wanted Other times, EPSTEIN wanted to in different rooms of the house, including one time in the room that had a stuffed dog and a tiger in it. + +Seeing EPSTEIN became more personable to as it felt like EPSTEIN was her boyfriend. EPSTEIN would spend time with her and drive her home. knew he was not her boyfriend because he was still seeing her friends. + +Comthwdion of FD-302 of (U) Interview of .On 11/04/2020 .page 5 of 9 + +knew the massages were sexual because had told her. told that she met EPSTEIN through her friendtold that EPSTEIN was rich, he would help her, and give her money. told that she would have to massage EPSTEIN and it would lead to a "happy ending" and that EPSTEIN sometimes "jerked himself off". told her she would get \$300 each time. The massages turned sexual right away when started seeing EPSTEIN. EPSTEIN always gave her \$300, sometimes he gave her \$400. If went with someone, sometimes it was would get \$300 and or another girl would get \$300. EPSTEIN paid himself. If EPSTEIN gave the full amount, sometimes only gave \$200 and kept the rest for herself. + +asked LESLEY if she could borrow \$1000 and EPSTEIN said she could. went to the office to pick it up. described as blonde and nice. would tell LESLEY to tell EPSTEIN that her friend could not make it and asked if he wanted to see instead. would mention different girls' names to LESLEY. felt it was pretty obvious LESLEY knew what was going on. When was 17/18 years old she found out she was pregnant. called the office to talk to LESLEY, saying she needed to speak to EPSTEIN as soon as possible because she needed money to get an abortion. said the procedure would cost her \$400. LESLEY was able to get EPSTEIN on the phone right away and EPSTEIN gave \$1000 in an envelope. then went to Planned Parenthood. EPSTEIN would send to his dentist and medical care providers if she needed it. + +was supposed to go to school in 9th grade but with her mother passing away and her family not around, she could not focus. With "selling her body to an older man" she felt she was "fucked up". + +would rather call LESLEY than EPSTEIN when she needed money. LESLEY knew she was staying in hotels. was too young to get an apartment in her name as she was 16 years old at the time, so she stayed in hotels, including Super 8. would call LESLEY, who knew she was living in hotels, and tell her she needed money for hotels. said to LESLEY that she could not sign a lease because she was not 18 years old. remembered the conversation she had with LESLEY because it was when she first booked a hotel. was staying with III for approximately 2 to 3 days when mother started "bitching" about her staying there. She + +Continuation of FD-302 of (U) Interview of o, 11/04/2020 m g, 6 of 9 + +and III stormed out and they slept on the roof that night. then called the office and talked to LESLEY. told LESLEY that she could not get an apartment because she was not 18. told LESLEY that it was \$100 night and if she stayed for the week then she could get a better rate. It was a hotel near house. LESLEY said she would relay the message to EPSTEIN. ended up staying with for a while. + +would take girls out, get their nails done, get a girl to be her friend then convince her to go to see EPSTEIN. would tell this to LESLEY and ask her if EPSTEIN could give her money to do so. Key words she would say to LESLEY was, "I have a new friend and I was going to take her to dinner and get her nails done". LESLEY would tell her "ok", put her on hold, and get EPSTEIN on the line. had a deeper conversation with LESLEY in person. There was a time when had to wait because the money was not ready when she went to pick it up from the office - usually the money was ready but that time it was not and she and LESLEY talked. felt it was clear her relationship with EPSTEIN was based on money and she felt it was clear she was underage. + +said things stopped when EPSTEIN was arrested in Florida. EPSTEIN had gone to Florida and she did not see him for a while and did not know what had happened. just thought that he went away. had gotten a notice when EPSTEIN was arrested. told EPSTEIN and remembered being scared about it. EPSTEIN said he got in trouble in Florida. remembered being mad for him. EPSTEIN said that if she saw or heard anything, she did not know anything and to ignore it. said EPSTEIN was still in Florida. did not think she knew what was going on and did not mention it. + +When EPSTEIN came back to New York, there were rules. One of the rules was that girls had to bring ID and had to be 18 years old. This was for a few months. When was around 21 years old, things with EPSTEIN "died off". There were times where told EPSTEIN she had a girl who was 21 years old and he told that was too old. It became challenging for to find girls that EPSTEIN liked. Sometimes lied to EPSTEIN and told him the girl was younger than she was if she looked young, but EPSTEIN would catch her in the lie. + +Continuation of FD-302 of (U) Interview of .On 11/04/2020 ,page 7 of 9 + +conversations about why she could not get an apartment. EPSTEIN knew age because he asked right away, also asking where she was from and what was her birthday. told him she was a Cancer and EPSTEIN told her he was an Aquarius. + +Two to three months after meeting EPSTEIN, brought was best friend at the time, before had met EPSTEIN would ask questions about her day and she would talk about , so EPSTEIN told her that she should bring her. Sometimes, lied to EPSTEIN that she did not have anyone. would try to find a girl to go with her if he was not seeing her as much. EPSTEIN wanted a certain age group, even 20 was too old for him. EPSTEIN liked 15 to 18 years old girls and liked them on the "slim side". When was 16 years old, she started training and her "butt got bigger" and EPSTEIN told her that she her to bring needed to girls, he lose said the slim side?". After the ten pounds. When EPSTEIN first started asking something like, "Do you have any friends, but on first few conversations with him he did not have to tell her anymore. EPSTEIN would settle if he had to if the girl looked young but would tell never to bring her again. EPSTEIN did not like aggressive or experienced girls. EPSTEIN hated one girl because she tried to do more with him and initiated more. EPSTEIN liked shy and timid girls. EPSTEIN did not want anyone over 18 years old. and III talked about it once and they brought a girl just to shut him up and EPSTEIN replied "really". EPSTEIN would turn them down. There would be certain girls knew would be willing to go. To the money she received at the time felt like a lot of money. would tell girls that they would massage EPSTEIN and sometimes he would masturbate. made it seem like it was normal. normalized it in her own brain. When would take a girl the first time, she would stay with the other girl. Sometimes EPSTEIN would want her to stay in the room with the girl she brought and sometimes he would want her to leave the room. EPSTEIN would give a vibrator and tell her to go wait in the other room. When would bring a girl, she would bring them one or two times then would filter through friends and bring different girls. friendships at the time were based on who was working with her to see EPSTEIN. + +continuation of FD-302 of (U) Interview of a 11/04/2020 ,page 8 of 9 + +EPSTEIN's go to person. was one of the girls who also worked in the office. mostly dealt with but then later dealt with someone else, but did not recall the person's name. recalled someone with brown hair who worked out of the office at the house sometimes; was not sure if this was she was recalling or someone else. recalled talking to the last time and she said she would speak to EPSTEIN but EPSTEIN never called + +met CHRIS TUCKER in EPSTEIN's house and just said hi to him. interaction with TUCKER was brief and just said it was nice to meet him - they did not really talk and nothing happened with him. EPSTEIN always told he was going to get her into Victoria's Secret, telling her he knew NAOMI CAMPBELL. There was one time where EPSTEIN introduced to CAMPBELL while they were in EPSTEIN's office with the stuffed tiger. recalled something about MIKE TYSON but did not remember what it was. EPSTEIN may have been talking to TYSON on speaker phone and heard. EPSTEIN was always on the phone with others including, BILL CLINTON and DONALD TRUMP. + +EPSTEIN and talked via phone call but never through email or text. EPSTEIN gave her lingerie. still has the first bra EPSTEIN gave her; it was a white lace Victoria's Secret bra. had picked the lingerie up from the office; LESLEY gave it to her in a Victoria's Secret bag. EPSTEIN also gave earrings, but she gave those away. + +When was not around EPSTEIN she did not want to go see him, but when she was around him she wondered why she was beating herself up about seeing him. EPSTEIN was only source of income for a while. was able to get a job with " " for a while. + +felt that LESLEY knew the massage appointments were sexual. would talk with LESLEY about different girls and LESLEY was always connecting her with EPSTEIN. LESLEY would get back on the call with when EPSTEIN was done talking to him, so did not know if LESLEY was on the whole time. never said anything to LESLEY about the massages. + +recalled a time when she and III were underage drinking and were arrested. thought they were on 77th and York and went to a police + +Continuation of FD-302 of (U) Interview of .On 11/04/2020 .Page 9 of 9 + +station downtown. called LESLEY and EPSTEIN bailed them out. They went to court and and III had to do community service. Was around 17 year sold and thought III would have been 16 years old when this happened. thought this happened in or around 2004 probably around the end of summer. + +The last time saw EPSTEIN was when she was 21 years old. thought she spoke with EPSTEIN sometime afterwards because she had a bill from EPSTEIN's dentist DR KAPLAN and had called LESLEY. EPSTEIN had returned her call while she was in Walmart with her boyfriend. thought she was around 23/24 years old at the time of this call. EPSTEIN told her not to worry about the bill. thought the bill was around \$5000. EPSTEIN told her he was going through stuff but everything was ok and that he hoped to see her soon. 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Present on the video call was Assistant United States Attorneys and along with Paralegal -• Detective and Special Agent . After being advised of the identities of the above listed individuals and the nature of the interview, MULLEN provided the following information: + +MULLEN had received a type written letter from the media but threw it away. + +MULLEN had worked at a restaurant "DANIEL" right down the street from JEFFREY EPSTEIN's residence. MULLEN had talked with a headhunter and wanted to leave working at the restaurant. This was approximately 14/15 years ago. + +GHISLAINE MAXWELL contacted MULLEN before he met EPSTEIN. MULLEN met MAXWELL at her residence in Manhattan for a tasting. MAXWELL told him something like, "We are looking for a chef...traveling cook...cook breakfast, lunch, dinner". MULLEN then sat down with EPSTEIN and he offered MULLEN the job. MULLEN was given an apartment as part of his salary. MULLEN worked for EPSTEIN for approximately 1.5 years before leaving approximately 15 years ago. + +EPSTEIN's chef before MULLEN had a BBQ joint in Manhattan. MULLEN thought EPSTEIN financed this chef to open the BBQ joint. MULLEN had heard from other members of EPSTEIN's staff and MAXWELL that if MULLEN did well, EPSTEIN would take care of him. + +MULLEN was required to travel anytime he was asked and to be ready at any time. MULLEN did not go to EPSTEIN's Paris residence but flew to France and visited friends while there. MULLEN traveled between EPSTEIN's island, Zorro Ranch, Palm Beach, and the 71st street residence. MULLEN also traveled + +Investigation on 10/29/2020 at New York, New York, United States (, Other (Video)) + +This document contains neither recommendations nor conclusions of the FBI. It is the moµ" ty of the FBI and is loaned to your agency; it and its contents arc not to be distributed outside your agency. + +CominuationafFD-302of (U) Interview of DAVID MULLEN 0, 10/29/2020 " cc 2 of 5 + +with EPSTEIN to Martha's Vineyard. The travel was very sporadic. The island and Zorro Ranch were set up for the holidays. MULLEN thought that they would be there for approximately 3 weeks to a month at a time. + +Working at EPSTEIN's Manhattan residence, MULLEN was there to be on call in the downstairs kitchen where the staff lived. MULLEN would make EPSTEIN peanut butter and jelly sandwiches and take upstairs to him upon his request. MULLEN's work hours were usually 9 to 5. If there were guests, MULLEN was responsible for cooking for the luncheon. + +Working on EPSTEIN's island, MULLEN was on call 24/7. MULLEN was responsible to cook for guests and any requests. MULLEN would go to the main island of St. Thomas via boat for food. + +Working at EPSTEIN's Zorro Ranch in New Mexico, MULLEN stayed at a residence a couple miles from the property. MULLEN was responsible for cooking breakfast, lunch, and dinner. + +Working at EPSTEIN's Palm Beach residence, MULLEN described it was the same routine as working at the other residences. + +When they traveled to Martha's Vineyard they only stayed for a couple of hours. MULLEN had stayed with the pilots. MULLEN thought they may have been there way to somewhere else. + +MULLEN reported to MAXWELL and she would tell MULLEN "the ropes" like where to sit and not sit on the plane and what to do and what not to do. There were different house managers at EPSTEIN's different residences who would tell MULLEN what to do if there were guests around. MULLEN had very little conversations with EPSTEIN. EPSTEIN usually conversed with MULLEN when he did not like the food. EPSTEIN was very short with his answers; EPSTEIN was not rude to MULLEN. MULLEN also received information from and other house staff. + +MAXWELL told MULLEN how to look and how to dress. MAXWELL told MULLEN to be ready at any time. MAXWELL told MULLEN not to be late or he would be fired. MAXWELL told MULLEN to have anything ready at anytime. There was a certain type of bread that MULLEN was responsible for getting while in New York. MULLEN was told not to interact and socialize with the guests. + +CominuationafFD-302of (U) Interview of DAVID MULLEN on 10/29/2020 " cc 3 of 5 + +MAXWELL let MULLEN know when and where he was supposed to be. MAXWELL sometimes traveled with them in the beginning. would also have the information on where and when MULLEN was supposed to be somewhere. MULLEN thought that was the main contact person for about 6 to 8 months. + +There would be a car service to take MULLEN to his apartment from LaGuardia or New Jersey. + +The New York housekeepers and MULLEN were together in Florida when a hurricane happened. They stayed behind then took a commercial airline back. + +When in New York, MULLEN would show up at 9am. MULLEN would check the food in the refrigerator and check in with the house people. MULLEN would go downstairs and wait for a phone call to prepare food. Sometimes he did not get a call. MULLEN would check in at 5pm with the house staff and would cook when they wanted something. and- (known to law enforcement as ) would be around more and MULLEN would cook for them. From what MULLEN understood, was EPSTEIN's girlfriend. + +worked for MAXWELL at MAXWELL's house. was a liaison to EPSTEIN. There was a shift to running the house. This was something MULLEN noticed as MAXWELL was not around as much. During the end of MULLEN working for EPSTEIN, he did not see MAXWELL. + +MULLEN made lunch for AL GORE. MULLEN also cooked for the former prime minister of Israel. MULLEN made lunch for him and flew with him and his wife. + +It was known that EPSTEIN would get massages. MULLEN would see traffic come in and they would go to another room. Usually after a massage, EPSTEIN would want a peanut butter and jelly sandwich or fruit snack. MULLEN was told by likely or house staff that he would have to have food ready at a certain time after a massage. In New York, MULLEN would take the elevator to get to the kitchen. MULLEN knew there were massages in New York because he was told to have snacks ready. The house was secretive. MULLEN would talk to the security guard and he would let MULLEN know if someone was coming to the house for food. MULLEN would be downstairs watching TV waiting until he was needed. MULLEN was not aware who was making the massage appointments. MULLEN saw more people in Florida because they came through the kitchen. + +Comthwdion of FD-302 of (U) Interview of DAVID MULLEN ,o, 10/29/2020 ,Pas, 4 of 5 + +When in Florida, MULLEN spent most of the time in EPSTEIN's house. MULLEN stayed at the house adjacent to EPSTEIN's main house. MULLEN would wake up, make sure there were muffins in the home, and prepare food as needed. MULLEN would have to have lunch ready, along with dinner, and have 10am and/or 3pm snacks ready. was around would go to the movies at night. Anyone else that was around would also go to the movies. MULLEN was done working after he served dinner. A lot of people came in through the door next to the kitchen there were a lot of people who came in for massages. MULLEN was told by either or house staff that the women were there for a massage. Massages were every day in the morning and afternoon. MULLEN stated they looked like 18-22-year-old women. All of them appeared to have been coming to the house prior to MULLEN working for EPSTEIN as they knew their way around the house. MULLEN would make the females something to eat if they wanted. The females would leave with the person that brought them. The younger people/younger women all knew what to do. MULLEN never saw anyone upset and never saw an exchange of cash. MULLEN saw set up rides for them and show them to where they needed to go. MULLEN saw the same people. MULLEN talked with some of them, but his jobs was to be the chef and not their friends from what he had been told. MULLEN assumed those that came to the house were from Florida; sometimes they came via taxi cab. Sometimes there were two ladies at the house, with one upstairs while the other one stayed downstairs waiting for the other one. They appeared carefree and relaxed. MULLEN thought some of them were "working girls" meaning "prostitution". MULLEN based this on their body language and how they spoke. This was just a feeling MULLEN had. MULLEN stated, "I mean who gets that many massages a day". MULLEN did not think they would be under 18 years old because he thought if they were younger they would have been at school. MULLEN felt they looked like they could get in a bar - if MULLEN would have been a bouncer he would have let them into the bar. , and another young woman who + +It would be a simple conversation from another woman, or house member who would tell MULLEN that people would be visiting or coming to give a massage. They would also tell MULLEN when a physical therapist or chiropractor was coming to the house. would greet them. MULLEN would let know via text sometimes and would direct them upstairs. MULLEN would see them for about an hour at the house. and the other woman, who MULLEN described as having a dark complexion and dark + +CominuationafFD-302of (U) Interview of DAVID MULLEN on 10/29/2020 mg, 5 of 5 + +hair, would talk with them in the kitchen and walk them upstairs we well. , and the other woman were always at the house. + +MULLEN's impression was that EPSTEIN was getting a massage. MULLEN felt that a massage every day seemed strange but if a person had that kind of money he could do what he wanted, like having them 2 to 3 times a day. + +MULLEN never asked about it. There was an appointment book that was kept by the phone so MULLEN could see what was going on for the day. The phone in the kitchen was rarely used but that was where the appointment book was kept. MULLEN did not know who scheduled the appointment. + +MULLEN would have certain muffins and fruit that was always around. When a girl came downstairs after a massage, he would make whatever she asked and if he had it in the refrigerator. + +Agent Note: At this point in the interview a break was taken. When everyone reconvened, MULLEN was confronted about the inconsistencies from this interview and his prior interview with the FBI. The interviewing team expressed concern to MULLEN over his lack of truthfulness during this interview and informed him he had the right to have counsel. MULLEN replied that he was trying to be as truthful as possible. MULLEN apologized if his answers were different than they were 15 years ago. MULLEN stated he was trying to be transparent and wished he never worked for EPSTEIN. 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CHILD SEX TRAFFICKING + +## CHILD VICTIM AND CHILD WITNESS IDENTITY INFORMATION + +This document contains information regarding a child victim's or child witness's identity, which may only be disclosed to individuals who have a need-to-know such information by reason of their participation in the associated proceeding, or if disclosure is necessary to protect the welfare and well-being of the child. + +#### Details: + +Ten yearbooks received from FBI West Palm Beach Resident Agency that were collected during the 2006-2008 investigation into Jeffrey Epstein. + +Collected From: (U) FBI West Palm Beach Resident Agency + +Receipt Given?: No + +Holding Office: NY - NEW YORK + +### Item Type Description + +1B General (U) Ten yearbooks collected by FBI West Palm Beach Resident Agency Collected On: 06/06/2019 12:00 PM EDT Seizing Individual: Located By: + +UNCLASSIFIED + +This document contains neither recommendations nor conclusions of the FBI. It is the property of the FBI and is loaned to your agency: it and its contents arc not to be distributed outside your agency. + +Title: (U) Ten yearbooks received from FBI West Palm Beach Resident Agency + +Re: 50D-NY-3027571, 01/13/2021 + +.• + +UNCLASSIFIED \ No newline at end of file diff --git a/marker2/ds9/EFTA00090353/EFTA00090353.metadata.json b/marker2/ds9/EFTA00090353/EFTA00090353.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..22141f6239847b77daa90f15ad913968ad7179ec --- /dev/null +++ b/marker2/ds9/EFTA00090353/EFTA00090353.metadata.json @@ -0,0 +1,218 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090353.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 1444, + "elapsed_seconds": 0.98, + "image_assets": [ + "_page_0_Picture_2.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "FEDERAL BUREAU OF INVESTIGATION", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 129.744, + 59.129999999999995 + ], + [ + 477.0376281738281, + 59.129999999999995 + ], + [ + 477.0376281738281, + 75.032958984375 + ], + [ + 129.744, + 75.032958984375 + ] + ] + }, + { + "title": "CHILD VICTIM AND CHILD WITNESS IDENTITY INFORMATION", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 134.64000000000001, + 271.35 + ], + [ + 480.82440185546875, + 271.35 + ], + [ + 480.82440185546875, + 284.32623291015625 + ], + [ + 134.64000000000001, + 284.32623291015625 + ] + ] + }, + { + "title": "Details:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 59.976, + 384.75 + ], + [ + 122.48794555664062, + 384.75 + ], + [ + 122.48794555664062, + 396.82623291015625 + ], + [ + 59.976, + 396.82623291015625 + ] + ] + }, + { + "title": "Item Type Description", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 61.2, + 549.1800000000001 + ], + [ + 253.42962646484375, + 549.1800000000001 + ], + [ + 253.42962646484375, + 561.8262329101562 + ], + [ + 61.2, + 561.8262329101562 + ] + ] + }, + { + "title": "UNCLASSIFIED", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 259.488, + 39.69 + ], + [ + 348.633056640625, + 39.69 + ], + [ + 348.633056640625, + 52.7052001953125 + ], + [ + 259.488, + 52.7052001953125 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 67 + ], + [ + "Line", + 34 + ], + [ + "Text", + 14 + ], + [ + "SectionHeader", + 4 + ], + [ + "PageHeader", + 1 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 15 + ], + [ + "Line", + 8 + ], + [ + "Text", + 4 + ], + [ + "PageFooter", + 2 + ], + [ + "SectionHeader", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00090353" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00090353/_page_0_Picture_2.jpeg b/marker2/ds9/EFTA00090353/_page_0_Picture_2.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..099a5b6a11e2a86d09a4fcb1d796da5236aa5957 --- /dev/null +++ b/marker2/ds9/EFTA00090353/_page_0_Picture_2.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:d003b068c39978d6b688d557b6deae519ba738141912639bfd44f927c50ffe29 +size 4888 diff --git a/marker2/ds9/EFTA00090355/EFTA00090355.md b/marker2/ds9/EFTA00090355/EFTA00090355.md new file mode 100644 index 0000000000000000000000000000000000000000..57b75a293d8cd6861ad325fb1eacc2466ae9030a --- /dev/null +++ b/marker2/ds9/EFTA00090355/EFTA00090355.md @@ -0,0 +1,1789 @@ +To: + +![](_page_0_Picture_2.jpeg) + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +Date: Wed, 20 Jan 2021 23:19:11 +0000 + +Attachments: KCG\_Appendix\_3-20\_13\_penultimate.docx; KCG\_TCR\_3-20-13-penultimate\_draft.pdf; KCG\_TCR\_3-20-13-penultimate\_draft.docx; KCG\_Appendix\_3-20\_13\_penultimate.pdf; Cifu.jpg; Blostein.jpg; KCGMarch2017.jpg + +Still going strong here Janey. Massive,ongoing, SEC facilitated fraud + +Farkas is Chairman of an OTCM, Jaclin money laundering shell called Balance Labs + +EDGAR Search Results (sec.gov) + +man, he's GOOD! + +Quite the list of selling shareholders for the SEC approved Balance Labs IPO + +https://www.sec.gov/Archives/edgar/data/1632121/000161577415000554/s100789 sl.htm + +SEC.gov I HOME + +1111 Lincoln Road, 4th Floor. Miami Beach, FL 33139 (305) 907-7600 (Address, including zip code, and telephone number, Including area code, of registrant's principal executive offices) + +viww.secgov + +Farkas knows how to pick em! + +Think the grossly corrupt SEC KNEW this when they brought their Jaclin complaint? + +Anton & Chia LLP et al. (sec.gov) + +UNITED STATES OF AMERICA Before the SECURITIES AND EXCHANGE COMMISSION ACCOUNTING AND AUDITING ENFORCEMENT File No. 3- 18292 SECTIONS 4C AND 21C OF THE SECURITIES EXCHANGE ACT OF 1934 AND RULE 102(e) OF THE COMMISSION'S ("A&C" - SEC.gov + +5 RESPONDENT 9. Anton & Chia, LLP, a PCAOB registered audit firm since 2009, is a California limited liability partnership that was headquartered in Newport Beach, California, with additional offices in San Diego and Westlake Village, California. + +www.sec.gov + +the last SEC reviewed 10Q for the Sep 30 2020 quarter + +https://vvvvvv.sec.gov/Archives/edgar/data/1632121/000149315220021288/form10-q,htm + +www.sec.gov + +united states. securities and exchange commission. washington, d.c. 20549 . form 10-q [x] quarterly report pursuant to section 13 or 15(d) of the securities exchange act of 1934 for the quarterly period ended: september 30, 2020 or [ transition report pursuant to section 13 or 15(d) of the securities exchange act of 1934 + +"penny stock trading fairies" no doubt + +Likel said: I stopped saying "unbelievable" in response to SEC criminal obstruction/corruption a LONG time ago. + +Cheers! + +Christopher J Dilorio + +Whistleblower Extraordinaire + +From: Chris Dilorio + +Sent: Monday, January 18, 2021 12:03 PM + +![](_page_2_Picture_8.jpeg) + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +OK, + +Let's wrap this up once and for all: + +The SEC is a grossly corrupt criminal organization ACTIVELY facilitating MULTIPLE criminal frauds on the public while screwing the whistleblower who caught them: ME + +Farkas is a prolific Bag Man as I have said repeatedly and most DEFINITELY on the SEC/Dal "Do not investigate list" + +EVERYTHING and I do Mean EVERYTHING I have been telling the SEC/DoJ/FBI/GAO/Congress, State Regulators,Press, Courts, etc etc etc is irrefutably and overwhelmingly accurate. + +Bush Fundraiser Linked to CIA Drug Plane — MadCow (madcowprod.com) + +![](_page_3_Picture_2.jpeg) + +### Bush Fundraiser Linked to CIA Drug Plane - MadCow + +A MadCowMorningNews investigation has uncovered links between the ownership of the drug-running Gulfstream (Cocaine Two) and the other American-registered plane busted carrying a multi-ton load of cocaine in Mexico recently, the DC9 (Cocaine One) airliner caught with 5.5 tons of cocaine in Mexico 18 months + +www.madcowprod.com + +Stephen Adams/Farkas SkyWay,ilncubator AND Holiday RV Superstore EDGAR Search Results (sec.gov) + +Adams EDGAR Filing Documents for 0001104659-02-000087 (sec.gov) + +Farkas EDGAR Filing Documents for 0000950170-99-001113 (sec.gov) + +"Single Handed"?? Not exactly Billboard magnate pours fortune into unusual Trump effort -- using his signs to push Trump (cnn.com) + +![](_page_3_Picture_10.jpeg) + +## Billboard magnate pours fortune into unusual Trump effort -- using his signs to push Trump -CNN + +Stephen Adams, a billboard magnate who made his fortune in a half-dozen different business ventures over the last five decades, is pouring hundreds of thousands of dollars into a pro-Trump campaign. + +www.cnn.com + +Adams/Bush 04 too 00004685.pdf (fec.gov) So, let's put the charges against Mr Kamansky and the fraud being perpetrated against me by the grossly corrupt SEC/Dal in some context. Honorable SDNY judges: the SEC is once AGAIN playing you for fools. No more continuances Mr Cooper. That really would be a miscarriage of justice. a Criminal and national security investigation into The Grossly corrupt,criminal SEC must commence immediately. ALL SEC actions must cease immediately pending the outcome of a thorough investigation. There is no alternative. EVERY single action brought by the SEC/Dal must be called into question. I demand Norberg and Hoecker be put on leave IMMEDIATELY pending the outcome of this investigation along with EVERYONE at the SEC/DoJ who has been in possession of my information and part of these massive conspiracies while fraudulently denying me what is rightfully due. The SEC needs to write me a check with lots of zeroes. Mr Kamensky should not only have ALL charges against him dropped, he TOO is owed a very big check. + +This would be a nice place to rest my case. But, alas I KNOW there is MUCH more SEC/DoJ fraud to be exposed. + +Cheers! + +Christopher J Dilorio + +Whistleblower Extraordinaire + +From: Chris Dilorio e > + +Sent: Monday, January 18, 2021 8:08 AM + +![](_page_4_Picture_8.jpeg) + +![](_page_5_Picture_157.jpeg) + +**Subject:** Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +Honorable SDNY Judges: did you actually think the SEC would do anything BUT continue its well documented, irrefutable, corrupt, criminal obstruction? The SDNY Court has granted 4 (FOUR) continuances to the DoJ/Strauss/Cooper in Kamensky. Are you waiting for the SEC to produce its defense Mr Cooper? 4 continuances in Kamensky WHILE the SEC facilitates several massive frauds I have detailed. SDNY Judges: once again your courts have been used by the grossly corrupt SEC/DoJ to commit multiple, massive frauds. yet ANOTHER SEC "thorough" investigation WHILE the DoJ appeals to SDNY Courts for "continuances in the interest of justice" in Kamensky. + +Congratulations Mr Cooper, you are an accessory to FRAUD. + +[Blink Charging Announces Closing of Public Offering of Common Stock for Total Gross Proceeds of \\$232.1 Million Nasdaq:BLNK](#) ([globenewswire.com](http://globenewswire.com)) + +![](_page_5_Picture_162.jpeg) + +## Blink Charging Announces Closing of Public Offering of Common Stock for Total Gross Proceeds of \$232.1 Million Nasdaq:BLNK + +MIAMI BEACH, FL, Jan. 12, 2021 (GLOBE NEWSWIRE) -- Blink Charging Co. (the "Company" or "Blink") (Nasdaq: BLNK, BLNKW), a leading owner, operator and provider of electric vehicle (EV ... + +[www.globenewswire.com](http://www.globenewswire.com) + +Yes indeed: Farkas/Jaclin/New et al are CERTAINLY "seasoned". + +Recall, + +Jaclin:Honig + +Honig: Colleran: Trump + +Honig: Alpha Capital Liechtenstein + +Honig: Frost: Ladenburg:Gruntal + +Gruntal:Icahn/Lebow/Lorber: New Valley/Vector:Trump Russia + +Gruntal:Sater/SAC: Milken + +Alpha Cap: IMDS/Sulphco: MY TCR + +Blink: JMJ: MY TCR + +Blink:New: NETE: My TCR + +Grossly corrupt SEC kept Blink/New Image Concepts up and running for exactly this reason. + +Farkas is a KNOWN prolific Bag Man as is Alpha Cap + +Alpha Cap: Martin Schlaff + +Schlaff: Cherney:Russia:Firtash:Mogilevitch + +Schlaff:Bawag:Refco + +Sedona/Scan Graphics: Rhino: Kushners et al + +FBI DC agents, I see where Mr Rosen paid you a visit on 1/15 + +anything else come up in your meeting? + +Give me a call Mr Rosen. I'll get you up to speed + +Cheers! + +Christopher J Dilorio + +Whistleblower Extraordinaire + +From: Chris Dilorio < + +Sent: Thursday, December 3, 2020 12:43 PM + +![](_page_6_Picture_10.jpeg) + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +Grossly corrupt SEC et al, + +I'm not engaging in hyperbole when I REITERATE: The Criminal, corrupt SEC is actively facilitating MULTIPLE frauds on the public. But, it certainly doesn't end there. The criminal obstruction I have detailed with overwhelming and irrefutable supporting evidence rises to the level of treasonous activity. + +Anyone remember once upon a time Treasury Under Secretary for Terrorism and Financial Intelligence Sigal Mandelker? She left Treasury in 2019. + +I believe this is 1 of her last audited reports + +[Audit of the Office of Terrorism and Financial Intelligence's Report on Section 241 of the Countering America's Adversaries Through Sanctions Act \(treasury.gov\)](#) + +## Audit of the Office of Terrorism and Financial Intelligence's Report on Section 241 of the Countering America's Adversaries Through Sanctions Act + +Audit Report OIG-19-033 . ANTI-MONEY LAUNDERING/TER RORIST FINANCING . Audit of the Office of Terrorism and Financial Intelligence's Report on Section 241 of the + +[www.treasury.gov](http://www.treasury.gov) + +Her report was a scathing condemnation of Russian money laundering and other illegal activity + +I point you to pg 4 + +I especially like #3 + +"The exposure of KEY economic sectors of the United States to Russian politically exposed persons and parastatals, including AT LEAST the banking SECURITIES, insurance, and real estate sectors (section 241 (a)(3)) Ms Mandelker has not been replaced by Trump/Mnuchin. In doing so, they have re written the Treasury Org structure. Someone didn't like this audited report. I would note that the Treasury IG actually did what Congress authorized him to do. + +So, while Trump/Mnuchin corruptly have not replaced Ms Mandelker, the public can rest easy knowing the SEC and FBI are on the case. + +Cheers! + +Christopher J Dilorio + +Whistleblower Extraordinaire + +[REDACTED] + +[REDACTED] + +--- + +**From:** Chris Dilorio <[REDACTED]> + +**Sent:** Tuesday, December 1, 2020 7:10 AM + +[REDACTED] + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +FBI Agents, SDNY Judges: + +Unfortunately, the SEC has absolutely no interest in a REAL, THOROUGH investigation of my irrefutably, overwhelmingly accurate allegations of SEC corruption and criminal activity. + +Let's get FBI Agents up to speed: + +Richard Best named Director of SEC NY, Mr Berger moves to Enforcement with Avakian: August 2020. Best is Mr FINRA "BBH AML ALL entities un named/penny stock trading fairies" + +aka: MY INFORMATION + +FINRA Fines Brown Brothers Harriman A Record \$8 Million for Substantial Anti-Money Laundering Compliance Failures I FINRA.org + +## FINRA Fines Brown Brothers Harriman A Record \$8 Million for Substantial Anti-Money Laundering Compliance Failures I FINRA.org + +WASHINGTON — The Financial Industry Regulatory Authority (FINRA) announced today that it has fined New York-based Brown Brothers Harriman & Co. (BBH) \$8 million for substantial anti-money laundering compliance failures including, among other related violations, its failure to have an adequate anti-money laundering program in place to monitor and detect suspicious penny stock transactions. + +www.finra.org + +In July 2020, Bobby Sollazzo: SEC NY BD OCIE retires after 38 years of obstructing criminal activity of criminal BD's like NITE. + +SEC.gov i Broker-Dealer Exam Program Leader Robert Sollazzo RetiringFrom SEC After 38 Years + +## SEC.gov I Broker-Dealer Exam Program Leader Robert Sollazzo Retiring From SEC After 38 Years + +The Securities and Exchange Commission today announced that Robert A. Sollazzo, the longtime leader of the New York Regional Office's Broker-Dealer Examination Program, is planning to retire from the agency in + +On November 19,2020 with ALL of the information I have provided to Norberg et al, the SDNY and others the SEC/Clayton announce the sudden replacements for Sollazzo who "retired" in July: + +SEC.gov i Lourdes Caballes and Michael Rufino Named Associate Directors of OCIE's Broker-Dealer Examination Program in the SEC's New York Regional Office + +## SEC.gov I Lourdes Caballes and Michael Rufino Named Associate Directors of OCIE's Broker-Dealer Examination Program in the SEC's New York Regional Office + +Lourdes Caballes and Michael Rufino Named Associate Directors of OCIE's Broker-Dealer Examination Program in the SEC's New York Regional Office + +www.sec.gov + +Not sure who Ms Caballes is. But Mikey Rufino I know. + +If you read the Clayton/Dick "BBH" Best pr you'd say Mikey Rufino was at the BD SRO FINRA FROM 2013 until joining his former FINRA colleague Dick "BBH" Best at SEC NY. + +Not the Case. + +See, Mikey Rufino was at the BD SRO FINRA for 32 f'n years prior to "retiring" in Sep 2020 + +FINRA Executive Vice President Michael Rufino Announces Departure i FINRA.org + +## FINRA Executive Vice President Michael Rufino Announces Departure FINRA.org + +WASHINGTON - FINRA announced today that Michael Rufino will leave the organization at the end of this year after more than 32 years of dedicated service protecting investors and ensuring market integrity. Rufino most recently served as Head of Member Regulation (Sales Practice), where he guided and oversaw FINRA's Sales Practice Examination, Risk Monitoring and Membership Application ... + +www.finra.org + +Like Bobby Sollazzo, WHAT did Mikey Rufino do in his 32 years at the BD SRO FINRA to stop the massive, ongoing fraud perpetrated on the investing public by the criminal enterprise NITE? Absolutely NOTHING. Meet the new boss/ same as the old boss. OR if you prefer: continuity. + +No doubt like his former colleague Dick Best, Mikey Rufino knows EXACTLY who were the executing BD's/MM's BBH delivered 80%+ of those OTCM money laundering shell trades to. And, it wasm't those damn "penny stock trading fairies". Which is EXACTLY why Dickie Best left ALL of the entities un named in his/Rufino BBH AML complaint. + +If you want to know just some of the entities un named in the BBH complaint just read my TCR(s) + +See Janey, the Dickie Best/BBH/Rufino BBH complaint was filed in Feb 2014. Almost 1 year AFTER I filed my NITE TCR with Berger in March 2013 with you and Seanny Boy. FINRA/the SEC know the un named entities in the BBH complaint implicate several entities in my TCR(s). + +"investigators never saw Mr Dilorio's information" is a BLATANT and egregious lie. Just 1 of the many lies to come out of Norberg/Mckessy: the OWB: related to my information. + +Now SEC cover up continues so that the massive frauds on the public can continue: 38 year Do nothing Sollazzo side kick and 32 year do nothing FINRA/Dick Best side kick are "investigating" my extremely serious allegations. This is yet ANOTHER SEC "thorough" investigation. Nothing has changed. + +Christopher J Dilorio + +Whistleblower Extraordinaire + +From: Chris Dilorio c > + +Sent: Monday, November 30, 2020 7:13 AM + +![](_page_10_Picture_7.jpeg) + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +FBI DC agents, + +Please let me know if I'm going to fast for you. Full Disclosure: FBI agents recently searched me up on Linked In. Do phones at the FBI dial out? Pick 1 up and call me. I'll talk slowly. + +More derivatives 1.0 for these FBI agents: + +FCC???? IT'S MONEY LAUNDERING STUPID!! + +Still MORE record Janey: + +Bravatek: also Fife and NITE trading billions of shares: MY FIN INFORMATION!!!! + +LG Capital Funding:prolific Bag Men + +EDGAR Search Results (sec.gov) + +EDGAR Filing Documents for 0001078782-16-003519 (sec.gov) + +## EDGAR Filing Documents for 0001078782-16-003519 + +Bravatek Solutions, Inc. (Subject) CIK: 0001449574 (see all company filings) IRS No.: 320201472 I State of Incorp.:CO I Fiscal Year End: 0331 Type: SC 13G I Act: 34 ... + +www.sec.gov + +LG: Boruch Greenberg, Joe Lerman, Dan Gellman + +same guys. Same f'n address: + +1218 Union St Brooklyn + +as 2 "payment processors": + +Benchmark Merchant + +Benchmark Merchant Solutions — Beyond the Point of Sale + +## Benchmark Merchant Solutions — Beyond the Point of Sale + +Experts predict that we will soon be a completely cashless society. In fact, a recent Reuters survey showed that 20% of customers already rely solely on credit cards and other forms of online payment for their purchases. + +benchmarkmerchantsolutions.com + +and + +Payrix + +Payrix Holdings, LLC - Who is raising money? I SEC filings of fundraisings and investments in hedge funds, startups and private equity companies + +## Payrix Holdings, LLC - Who is raising money? I SEC filings of fundraisings and investments in hedge funds, startups and private equity companies + +Payrix Holdings, LLC Funding details. Payrix Holdings, LLC raised \$19,250,000 from 8 investors on 2018-12- 18. + +#### Payments Infrastructure I Payrix Payments Technology I United States + +Payrix Payments Technology works with SaaS companies and marketplaces to provide complete payment servicing management and monetization, allowing your platform to generate revenue quickly and create a seamlessly embedded user experience. + +www.payrix.com + +BOTH Benchmark and Payrix are Deutsche Bank ISO partners. + +Remember Deutsche Bank? WireCard? Ring any bells? + +Same DB that passed on buying the fraud WireCard but had no problem hiring their CTO + +Deutsche Bank snags Wirecard exec Kilian Thalhammer - FinTech Futures + +![](_page_12_Picture_8.jpeg) + +### Deutsche Bank snags Wirecard exec Kilian Thalhammer - FinTech Futures + +Deutsche Bank has appointed Kilian Thalhammer, a former Wirecard exec, to oversee its Merchant Solutions pillar. He will be joining the bank in October. + +www.fintechfutures.com + +In November 2020, the criminal bank DB is EXPANDING into Russia. Yes, I said that correctly: Deutsche Bank: mirror trader serial money launderer is EXPANDING in Russia. + +Outside Monitors Urge Deutsche Bank to Quit Russia - WSJ + +![](_page_12_Picture_14.jpeg) + +## Outside Monitors Urge Deutsche Bank to Quit Russia - WSJ + +Deutsche Bank AG executives want to expand in Russia despite a legacy of missteps and massive fines. Outside monitors who watch over the bank's money-laundering controls said it should shut the ... + +wwwwsj.c o + +Why would DB Buy Net Element as part of its expansion into Russia and the EU WHEN according to SEC filings 90%+ of NETE BILLIONS in transactions processed are in the United States???? + +Again: sorry if I typed too fast for the FBI DC agents. Pick up a phone that dials out and give me a call instead of searching for me on Linked In. Happy to walk you through it. + +BTW grossly corrupt SEC/SDNY: How's that WireCard investigation coming along? WireCard trades OTCM Pinks. That's New York isn't it? + +Finally: the grossly corrupt SEC wants to exempt 90% of the 13F filers today. HOW does that benefit the investing public the SEC is mandated to protect? + +SEC.gov i SEC Proposes Amendments to Update Form 13F for Institutional Investment Managers: Amend Reporting Threshold to Reflect Today's Equities Markets + +SEC.gov I SEC Proposes Amendments to Update Form 13F for Institutional Investment Managers; Amend Reporting Threshold to Reflect Today's Equities Markets + +The Securities and Exchange Commission today announced that it has proposed to amend Form 13F to update the reporting threshold for institutional investment managers and make other targeted changes. + +'An:AV.sec g ov + +The SEC is a grossly corrupt, criminal enterprise ACTIVELY facilitating criminal activity while screwing whistleblowers like me and people like Dan Kamensky and Neil Cole and countless others not on the SEC/SDNY "Do not investigate list" + +Cheers! + +Christopher.' Dilorio + +Whistleblower Extraordinaire + +From: Chris Dilorio + +Sent: Wednesday, November 25, 2020 6:29 AM + +![](_page_13_Picture_13.jpeg) + +![](_page_14_Picture_0.jpeg) + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +FBI DC agents: do they teach derivatives at the FBI? + +Otkritie majority holder of SEC fully reporting/NASDAQ traded QIWI + +20-F (sec.gov) + +HOW QIWI ever went public in the US is a story unto itself. "HQ" in Cyprus with ZERO US presence. + +Otkritie: largest QIWI holder + +Report: Otkritie ups stake in payment services provider QIWI i S&P Global Market Intelligence + +![](_page_14_Picture_8.jpeg) + +### Report: Otkritie ups stake in payment services provider QIWI + +Otkritie Holding increased its stake in the capital of Cyprus-based QIWI to 15.66% after its unit Otkritie Financial Corp. Bank acquired 12.2% of the company in three private transactions, Kommersant reported. + +www.spglobal.com + +Net Element: QIWI/Pay Online + +PayOnline Introduces a New Payment Interface (netelement com) + +![](_page_14_Picture_14.jpeg) + +# go, PayOnline Introduces a New Payment Interface + +www.netelement.com + +As I have repeatedly asked the grossly corrupt SEC: NETE has "IT" in both Miami and Moscow. Miami address(es) are office buildings. WHERE are NETE US servers hosted???? + +In SEC reviewed filings: North American "payment processing" accounts for 90% of NETE transactions processed. Yet, no disclosures as to WHERE these servers are hosted. + +Are NETE servers hosted/located in Russia? Seems like a material disclosure. IF of course the SEC was actually interested in that shit. + +Happy Thanksgiving! + +Christopher Dilorio + +Whistleblower Extraordinaire + +From: Chris Dilorio + +Sent: Tuesday, November 24, 2020 6:47 AM + +Subject. Fw. Formal appeal tor preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +Janey, + +EVERY day the RECORD becomes clearer and clearer: My information is overwhelmingly and irrefutably ACCURATE. The GROSSLY corrupt SEC has been protecting the criminal enterprise Knight/KCG/VIRT: NITE for quite some time. A longstanding and corrupt relationship. + +Greifeld: NASDAQ: Friedman: Sungard: Brut:Otkritie:Knight real time rubles to dollars + +No sh!t, really? + +11/2 years prior to the SEC/BX/JEF/Handler/Stifel/JPM/GS/Sandler et al "glitch" + +![](_page_16_Picture_1.jpeg) + +# ,1] Otkritie wins \$150m fraud judgment I Financial Times + +One of Russia's largest independent financial groups has won \$150m in damages after a UK High Court judge found it was the victim of a "cunning and well-orchestrated fraud" committed by ... + +www.ft.com + +My TCR: March 2013: 4 months prior to the post "glitch" Knight/Getco:KCG. July 2017: VIRT/KCG + +ONLY explanation: a GROSSLY corrupt SEC facilitating a massive, ongoing fraud on the public while screwing whistleblowers like me. + +But it gets better. More "RECORD" Janey: + +Blink Charging: BLNK + +The Jaclin \$\$ laundering shell kept up and running by the GROSSLY corrupt SEC: Michael Farkas: ilncubator and Skyway: money laundering shells. Farkas conspicuously absent from SEC complaints. Controlled both. + +Governor Richardson. Drexel Alum. Jonathan New: NETE CFO also BLNK. Prolific Bag Man JMJ/Keener: my TCR. In 2017, BLNK claimed to have 23,000 charging stations installed + +IKEA to Install 3 Electric Vehicle Charging Stations at Future Columbus Store Opening Summer 2017 : Blink Charging + +![](_page_16_Picture_12.jpeg) + +## IKEA to Install 3 Electric Vehicle Charging Stations at Future Columbus Store Opening Summer 2017 : Blink Charging + +Click here to read our must recent news, IKEA to Install 3 Electric Vehicle Charging Stations at Future Columbus Store Opening Summer 2017. Blink Charging provides high-quality and easy to use EV Charging Stations and Networks for homes and businesses. + +www.blinkcharging.com + +In several SEC reviewed filings as of today: 15.7 million installed charging stations. The case of the missing EV charging stations. + +Gets better: + +"Investing" in BLNK along side Keener: Horton Capital Partners: Philly. + +#### EDGAR Filing Documents for 0001193125-18-050585 + +Horton Capital Partners, LLC (Filed by) CIK: 0001575443 (see all company filings) IRS No.: 461613207 I State of Incorp.:DE I Fiscal Year End: 1231 Type: SC 13G/ASC 13G/A + +www.sec.gov + +Joey Manko Jr Swiss Private Bank. Deutsche Bank. Horton. Blink Team I The Horton Fund + +![](_page_17_Picture_5.jpeg) + +## Team I The Horton Fund + +Joe Manko, Jr. has over 20 years of investment experience, predominately in the asset management, investment banking, private equity and corporate securities markets.From 2005-2010 Mr. Manko was a Partner and Chief Executive Officer of Switzerland-based BZ Fund Management Limited, where he was + +thehortonfund.com + +Joey Manko is BUISSSSYYYYY + +Joseph M. Manko - Mufson Howe Hunter (mhhco.com) + +### Joseph M. Manko - Mufson Howe Hunter + +Joe Manko is a Managing Director at Mufson Howe Hunter and has over 20 years of transaction experience as an investment banker, principal investor and corporate finance lawyer + +mhhco.com + +Thanks to the grossly corrupt SEC, a MASSIVE pump and dump in BLNK the last 2 weeks as the money laundering shell is up 200% on massive volume. The SEC CONTINUALLY places the investing public it is MANDATED to protect at risk while facilitating criminal activity. The record is clear Janey: NITE: Russian/Swiss Banks: money laundering/tax evasion. Keener: Bag Man. BLNK: money laundering shell. ALL in my TCR. ALL kept up and running by the GROSSLY CORRUPT SEC et al. + +Cheers! Christopher J Dilorio Whistleblower Extraordinaire From: Chris Dilorio < + +Sent: Thursday, November 19, 2020 7:29 AM + +![](_page_18_Picture_2.jpeg) + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +Janey, + +You are a pathological and very bad liar. + +More "record": + +Stephen Guyer's other money laundering shell: + +Telecom Wireless/TComm + +https://www.sec.gov/cgi-bin/browse-edgar? + +action=getcompany&CIK=0001098923&owner=exclude&count=40&hidefilings=0 + +Revoked by the grossly corrupt SEC 10 years after its last financial disclosure filing. + +Dozens of fraud transactions. MILLIONS of worthless certs dumped on the public and facilitated by those damn "penny stock trading fairies". + +Guyer moved seamlessly onto his next massive fraud: Colorado Goldfields thanks to the SEC. + +Colorado Goldfields: massive NITE/UBSS/Sason et al money laundering fraud thanks to MORE SEC facilitation. + +My claims: OpCo: Norberg/SEC admits to Congress that the OWB is the primary contact between whistleblowers and the Commission. Then Norberg invokes yet to be enacted summary disposition language in her fraud Denial of my Award application: "SEC investigators never saw my information": after FIVE years. Gross negligence? NOPE: Blatant LIES. + +I suspect my information is some of the most widely disseminated within the SEC leading to dozens of actions. Call me Janey. I'll walk you through it. + +Then today: November 19, 2020 NASDAQ/Friedman announce the \$2.8 BILLION acquisition of Verafin. A financial crimes/money laundering detection/prevention firm. Wait, I didn't think NASDAQ had a money laundering problem?!?! That's \$2.8 BILLION. Must be a MASSIVE problem in fact. I've read that somewhere before: see the record including below Janey. NETE and other AQR blank check shells: NASDAQ. Sungard DMA: real time rubles to dollars: NASDAQ:. BRUT: NASDAQ. The record clearly shows my extensive correspondence to NASDAQ as well. + +https://verafin.com/verafin-story] + +Crickets out of OTCM and #1 OTCM money laundering shell trader: Greifeld Chairman: N Island top shareholder: Hutchins: David Urban: created by the mob:Sull Crom client: NITE/VIRT. + +Cheers! + +Christopher J Dilorio + +Whistleblower Extraordinaire + +From: Chris Dilorio < > + +Sent: Friday, November 13, 2020 9:10 AM + +![](_page_19_Picture_9.jpeg) + +![](_page_20_Picture_54.jpeg) + +**Subject:** Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +Janey, + +Because I take great pride in my overwhelmingly and irrefutably accurate information exposing the grossly corrupt, criminal SEC et al: please see the below typo correction: + +"when creditors can/do negotiate with creditors" + +changed to + +"when creditors can/do negotiate with ISSUERS" + +Cheers! + +Christopher J Dilorio + +Whistleblower Extraordinaire + +![](_page_20_Picture_64.jpeg) + +--- + +**From:** Chris Dilorio <[REDACTED]> + +**Sent:** Friday, November 13, 2020 8:13 AM + +![](_page_20_Picture_67.jpeg) + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +Greetings grossly corrupt SEC et al. Time for the "SEC criminal Obstruction/corruption" Friday edition. + +The record Janey. Well, the SEC hasn't limited its massive fraud on JUST the SONY courts. Good to know. The DC Courts are also victim of this massive fraud as well. + +The OpCo Complaint/Denial: My claims. Here AGAIN the SEC has done nothing to shut down a massive fraud on the public. Per my TCR: NITE/UBSS (aka "penny stock trading fairies) traded billions of shares and were also cited by me in extensive correspondence with FINRA and the OWB PRIOR to my March 2013 Berger TCR submission. + +AppTech is very much up and running in November 2020 thanks to the grossly corrupt SEC and is again/still being used as a money laundering vehicle. + +https://www.sec.gov/cgi-bin/browse-edgar? + +company=Apptech&match=&CIK=&filenum=&State=&Country=&SIC=&owner=exclude&Find=Find+Companies &action=getcompany + +In October 2020, AppTech announced this YUGE deal with NEC Payments. WOW NEC and AppTech!?!? + +https://www.globenewswire.com/news-release/2020/10/05/2103341/0/en/AppTech-Announces-Digital-Banking-and-Payment-Technology-Partnership-with-NEC-Payments.html + +![](_page_21_Picture_9.jpeg) + +### ;-) AppTech Announces Digital Banking and Payment Technology Partnership with NEC Payments OTC Markets:APCX + +GlobeNewswire is one of the world's largest newswire distribution networks, specializing in the delivery of corporate press releases financial disclosures and multimedia content to the media ... + +www.globenewswire.com + +Wrong NEC Payments bruh. + +This NEC Payments (NECP) is an entity domiciled in the Kingdom of Bahrain HUH? + +ALL in SEC reviewed filings of course + +https://www.sec.gov/Archives/edgaddata/1070050/0001575705200002 I 4/apcx 8k.htm + +https://www.sec.gov/Archives/edgmidata/1070050/000157570520000214/ex10 2.htm + +And, HOW do you suppose a Bahraini entity searched out and found little of Wyoming money laundering shell AppTech? + +The New Bag man involved is Bahraini business man Ebrahim Daoud Nonoo + +https://en.wikipedia.org/wiki/Ebrahim Daoud Nonoo + +![](_page_22_Picture_3.jpeg) + +![](_page_22_Picture_4.jpeg) + +#### Ebrahim Daoud Nonoo - Wikipedia + +Ebrahim Daoud Nonoo (Arabic "is.; ).9.9 6 4 ) 4 , Hebrew: ornax 1313 'Tr , also known as Abraham David Nonoo) is a Bahraini businessman. He sat in the appointed upper house of the Bahraini Parliaments Shura Council, the only Jewish member of the Council. He is the current CEO of the Basma Company.. The + +en.wikipedia.org + +But alas, none of this illegal activity should have happened. See, the SEC OWB: McKessy/Norberg were in possession of my information when a fraud on the courts was being perpetrated by AppTech/Ottens (see my TCR) + +https://www.leagle.com/decision/infdco20141103a26 + +![](_page_22_Picture_10.jpeg) + +![](_page_22_Picture_11.jpeg) + +### FARRIS v. D'ANGELO I Case No. C14-560 MJP. I 20141103a26 I Leagle.com + +ORDER GRANTING DEFENDANTS MOTION TO DISMISS MARSHA J. PECHMAN District Judge. THIS MATTER comes before the Court on Defendant...20141103a26 + +www.leagle.com + +In fact, AppTech should have been shut down immediately based on my information. However: NITE/UBSS (penny stock trading fairies) were in the process of trading their billions of worthless certs WHILE this case was pending. Questions for Judge Pechman: Did the SEC ever intervene in this case? per my extensive 2013 TCR: Assignments: No legitimate economic rationale for a creditor to assign a note/obligation to a third party when creditors can/do negotiate directly with ISSUERS. Derivatives: further assignments to other third parties are simply a distribution mechanism. As the SEC has discovered using my information (Sason,JMJ, Crede, etc etc): not a legitimate note/obligation to begin with. FREE MONEY. Converted into worthless certs. Converted into real money by criminal Broker Dealers/MM's like NITE,UBSS etc. Who is Ms Farris anyway? Ottens girlfriend? Because assigning \$25,000 worth of fraud notes for \$10,000 happens all the time in the real world of legitimate financial transactions. Yes, as with ALL of my information: OVERWHELMINGLY and IRREFUTABLY accurate. AppTech is a money laundering shell. ACTIVELY facilitated and + +never shut down by a grossly corrupt and criminal SEC while screwing whistleblowers like me. This massive, SEC et al facilitated fraud is very much ONGOING. + +Cheers! + +Christopher.' Dilorio + +Whistleblower Extraordinaire + +PS: I'm sure everyone on this email is acutely aware of the BLATANT and EGREGIOUS SEC facilitated trading activity in ANOTHER "payment processor": AQR/Oleg Firer WireCard etc now Bankrupt Coda/China Qiantu EV massive SEC/Clayton/Sull Crom fraud known as Net Element :NETE + +Massive volume. No PUBLISHED PR's. No SEC filings. Just up 20% in 2 days. + +What do you expect from an SEC Chair who compares compliance with US Securities Laws as "good hygiene"? + +From: Chris Dilorio + +Sent: Tuesday, November 3, 2020 9:01 PM + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +Mr Kim, + +Any representation that doesn't require the SEC to produce exculpatory evidence related to my allegations is malpractice. + +https://casetext.com/case/united-states-v-martoma-3 + +https://casetext.com/case/united-states-v-gupta + +United States v. Gupta, 848 F Supp. 2d 491 I Casetext Search + Citator + +Read United States v. Gupta, 848 E Supp. 2d 491, see flags on bad law, and search Casetext's comprehensive legal database + +casetext.com + +Cheers! + +Christopher.' Dilorio + +Whistleblower + +From: Chris Dilorio + +Sent: Tuesday, November 3, 2020 3:34 PM + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +Greetings Judge Caproni, + +I hope your colleagues as well as Mr Kim's colleagues have forwarded my information to you. The criminal case against Mr Kamensky brought by Ms Strauss, Mr Tracer and Mr Cooper is a fraud on your courts. I have established beyond any shadow of a doubt that the Kamensky/SEC/SDNY actions are a complete fraud and well orchestrated set up by protected and known criminals including but not limited to Richard Handler/Jefferies. This corrupt, criminal relationship between the SEC and Handler/Jefferies goes WAY back and at the heart of my claims: a MASSIVE and ongoing fraud on the public actively facilitated by the SEC/Handler/Jefferies et al (see attached TCR). Unfortunately, Ms Strauss as well as Mr Kim's former boss at the SDNY Preet Bharara have also been in possession of my information for quite some time. Mr Kamensky must re assess his representation.. I am always available to discuss my information. Under oath preferably. This massive, ongoing, SEC/Handler et al fraud on the public must end. It has been my personal mission to see exactly that. This massive fraud also affects other cases currently before the SDNY Courts and ALSO well known to Ms Strauss/the SDNY + +Regards, + +Christopher J Dilorio + +Whistleblower + +From: Chris Dilorio + +Sent: Wednesday, October 14, 2020 9:32 AM + +Su•lect: Fw: Forma appea or pre iminary • enia covere• action 2015-016 Knig t Capita TCR : Appen• ix + +From: Chris Dilorio < + +Sent: Wednesday, October 14, 2020 9:00 AM + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +The corrupt, criminal relationship with Handler/Jefferies as I have stated is NOT the only corrupt,criminal relationship the SEC/SDNY have with members of their respective "do not investigate lists". AQR, Blackstone as well as Jay Clayton good fried Glenn Hutchins. Hutchins also worked at Blackstone with Schwarzman prior to founding Silver Lake. Hutchins bought SunGard. Then sold it to FIS. This transaction was the basis of the formation of North Island with former NASDAQ CEO Greifeld. North Island is a top shareholder of the criminal enterprise NITE/VIRT. More context: Greifeld was a Director UK/NJ company called Automated Securities Clearance Ltd + +hups://find-and-update.company-information.service.gov.uk/company/03385409/officers + +## AUTOMATED SECURITIES CLEARANCE (EUROPE) LIMITED - Officers (free information from Companies House) + +AUTOMATED SECURITIES CLEARANCE (EUROPE) LIMITED - Free company information from Companies House including registered office address, filing history, accounts, annual return, officers, charges, business activity + +find-and-update.company-information.service.gov.uk + +Sold to SunGard. Greifeld then became CEO at SunGard. He wasn't at SunGard very long. Then made the jump to CEO of NASDAQ. Curious to say the least. Shortly after becoming NASDAQ CEO, NASDAQ bought the BRUT ECN from SunGard. Self dealing? MUCH WORSE + +http://irnasdaq.comIstatic-files/6b1ca278-75f0-4259-9372-5b3351126a8b + +ir.nasdaq.com + +121 e< 2 h"' 21 e< 16 \$ 8; l< 76 =23 \$ 54 -:; 2 ((1 -&22 + +irnasciaq.com + +dollars in real time. + +https://www.finextra.com/pressarticle/49357/otkritie-capital-taps-sungard-for-automated-ruble-conversion + +Otkritie Capital taps SunGard for automated + +Ruble conversion + +Otkritie Capital (Otkritie), one of the leading financial services providers in Russia, has selected SunGard to help launch a new direct market access (DMA) service allowing for automatic real ... + +www.finextra.com + +I'll say that again: FROM Russian rubles TO dollars in real time. Providing DMA to WHICH markets???? + +So, the marriage of Blackstone Alum Hutchins and Greifeld to form N Island and become a top investor in the criminal enterprise NITE was a natural fit. Money laundering on a MASSIVE scale. Algos and OTCM shells are very complimentary money laundering vehicles. Not to mention: Russian Mirror trades: RU ADR's trade OTCM Pinks as well. The KCG 1Q2014 astronomical increase in OTCM volumes. Expunged from SEC reviewed + +filings. Attached on previous emails as part of the OWB record. NASDAQ is also the repository of the vast AQR blank check money laundering shells. FULLY SEC reporting for credibility. As with many OTCM shells. The only real difference between a NASDAQ/AQR blank check shell and an OTCM shell is the amount of money being laundered. Clayton should have been investigated and barred from SEC business pending a full and + +thorough investigation. So, that precludes the corrupt SEC IG Hoecker from any involvement. + +Cheers! + +Christopher J Dilorio + +Whistleblower + +From: Chris Dilorio + +Sent: Thursday, September 17, 2020 5:56 PM + +To: + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +Judge Nathan, I applaud your reproof of the SONY. Now, I urge you to look at the Dan Kamensky case. I have never met Kamensky. When I saw the joint SEC/SDNY complaint I became physically ill. I am an SEC whistleblower. The SEC/SDNY have actively and continuously obstructed a thorough investigation of my extremely serious allegations. In favor of Rich Handler/Jefferies. The IB in the Kamensky case. Based on my experience with the SEC/SDNY I believe they both are withholding exculpatory evidence which impeaches the credibility of the SEC/SDNY/Handler/Jefferies. A corrupt relationship + +exists between the SEC/SDNY and Handler/Jefferies. In addition to others in my claims. I have contacted Judge Cave as well as Kamensky counsel. Disclosure of this corrupt relationship puts the Neiman Marcus "sting" in a whole different context. The motives of which should be investigated. + +Respectfully, +Christopher J Dilorio +Whistleblower + +--- + +**From:** Chris Dilorio <[REDACTED]> +**Sent:** Thursday, September 17, 2020 9:17 AM + +[REDACTED] + +**Subject:** Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +Please see the new photos attached: + +Mr Blostein's Eureka moment and Cifu admission that the NITE/VIRT revenue model is driven by the "retail participation" rate: + +Cifu: "The retail segment of what we do is a SIGNIFICANT portion of our overall American equity segment..." + +So, are institutions trading .0001 OTCM money laundering shells? Mr Blostein: what are you modeling for NITE/VIRT OTCM share volumes when you KNOW and Cifu admits the importance of these share volumes on the NITE/VIRT revenue model? Does ANY Sell side analyst model this NITE/VIRT revenue driver? WHY doesn't Cifu disclose these share volumes in SEC filings? He used to. Knight/KCG used to as well. See photo. So why did he stop? Did NITE exit OTCM trading? ABSOLUTELY NOT. So the Goldman Analist Blostein KNOWS these share volumes drive revenue at NITE. Blostein doesn't disclose these volumes in his model. Fraud is also an OMISSION of material fact. Time to ask Cifu WHY he doesn't tell you to model OTCM share volumes fellas. This is WHY the SEC/Handler/Jefferies/VIRT/KCG acquisition took place. As Cifu admits: Retail:OTCM drives NITE/VIRT earnings. + +Cheers! +Christopher J Dilorio +Whistleblower + +--- + +**From:** Chris Dilorio <[REDACTED]> +**Sent:** Wednesday, September 16, 2020 3:01 PM + +[REDACTED] + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +First Sell Sider, SEC,DoJ who can get me a current NITE/VIRT tangible book value calculation wins a prize: Mr Kamensky's freedom. That's BEFORE properly classification of Naked short fails NITE/VIRT KNOWINGLY books as fraud assets: receivable. + +Mr Blostein, I remember a NITE/VIRT earnings call not to long ago where you made a direct correlation between NITE OTCM share volumes and NITE trading profits. Remember the 1? I have hard copies of that too. Did Cifu threaten you if you bring it up again? Please forward your model including these share volumes so we can compare notes. Who else has been threatened with retaliation by Cifu/Handler? Who has been promised business? Mr Repetto/Fannon? Who has BUY ratings on NITE/VIRT currently? + +Cheers! + +Christopher J Dilorio + +Whistleblower + +From: Chris Dilorio ‹ > Sent: Wednesday, September 16, 2020 9:20 AM + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +Judge Cave, + +The criminal, corrupt relationship between the SEC/Handler/NITE goes further. + +Doesn't it Mr Repetto? + +For the Sell Siders on this e mail: + +Please tell Judge Cave, The SEC/Dol, Mr Kamensky's counsel the following: + +- 1) how many red flags in NITE 3 CFO's in a year? +- 2) What you're modeling for NITE OTCM share volumes +- 3) WHY none of you question the once again ballooning balance sheet on earnings calls + +The other questions below can be answered by Mr Repetto and Jefferies Mr Fannon + +Cheers! + +From: Chris Dilorio < + +Sent: Monday, September 14, 2020 9:22 AM + +To: > + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +I look forward to speaking with you + +Regards, + +Chris + +From: Chris Dilorio + +Sent: Monday, September 14, 2020 6:02 AM + +![](_page_29_Picture_9.jpeg) + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +Judge Jones, Judge Cave + +Straight forward, irrefutable proof of SEC corrupt relationship with Handler Jefferies: + +KCG was engaged in abusive naked shorting in months leading up to the SEC/Handler/Jefferies VIRT acquisition closing 7/31/2017 + +SEC/Handler/Jefferies KNEW the core business at KCG is and always has been abusive naked shorting OTCM and other shells to facilitate money laundering. + +SEC/Handler/Jefferies knew KCG was insolvent in 2012 as well as 2017 as a direct result of this illegal activity + +Handler/Jefferies were the largest shareholder of KCG in 2017 when the SEC/Handler/Jefferies/Cifu orchestrated VIRT/KCG merger was consumated + +https://www.clearygottlieb.com/news-and-insights/news-listing/14-billion-merger-of-kcg-holdings-and-virtufinancial + +### \$1.4 Billion Merger of KCG Holdings and Virtu Financial I Cleary Gottlieb + +Cleary Gottlieb is representing Goldman, Sachs & Co., as financial advisor to KCG Holdings in its sale to Virtu Financial in an all-cash transaction valued at \$1.4 billion. + +www.clearygottlieb.com + +SEC/Handler/Jefferies/Cifu used known fraud "assets" on the KCG balance sheet to determine the grossly inflated tangible book value calculation used to value the KCG acquisition price. + +Immediately prior to the transaction closing on 7/31/2017 the SEC/Cifu wrote down more than \$4 billion in leverage from the KCG balance sheet. INCLUDING fraud assets used to calculate the grossly inflated acquisition price of KCG. + +SEC/Handler/Jefferies KNEW KCG was insolvent in 2012 AND July 2017 + +As a direct result of this corrupt, criminal scheme the investing public is put at risk, NITE/VIRT is insolvent again/always, Handler/Jefferies benefit, my rights as a whistleblower have been egregiously abused, Kamensky's life is ruined. + +The SEC/SDNY is making a mockery of your respective courts. Worse: the SEC and SDNY are committing a massive and well known FRAUD on your respective courts. + +The true character of Handler/ Jefferies as well as the corrupt relationship the SEC has with Handler/Jefferies must be disclosed to Mr Kamensky. Any verdict without these disclosures is a known miscarriage of justice. https://www.lexology.com/library/detailaspx?g=9e2b4e49-See2-48f6-b8c7-03d39d02b5ca + +![](_page_30_Picture_5.jpeg) + +### SEC ordered to produce Brady and Giglio materials due to joint investigation with U.S. Attorney's office - Lexology + +A district court ordered the SEC to produce material solely in its possession to a defendant in a parallel criminal prosecution by the U.S. Attorney... + +www.lexology.com + +Mr Kamensky WILL have my information. Mr Kamensky WILL have justice. The SEC/Handler/Jefferies/Cifu corrupt criminal relationship and ongoing frauds on the public will be exposed and ENDED. + +Regards, + +Christopher J Dilorio + +Whistleblower + +From: Chris Dilorio < + +Sent: Saturday, September 12, 2020 8:23 AM + +![](_page_30_Picture_15.jpeg) + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +Judges Cave and Jones, + +The SEC corruption goes well beyond just Handler/Jefferies/NITE. + +My research: I developed a template. I would search NITE top traded OTCM shells. From there: Derivatives. I have filed several separate but related TCR's based on that information. + +The SEC has brought several actions related to my 2013 Knight TCR with Berger: Hanover/Magna, JMJ,Keener, Hicks, Fife,UBSS, and FINRA's NITE Nov 2016 Rule 204 complaint. ALL my information. In addition: FINRA + +brought a complaint against Brown Brothers Harriman AFTER the SEC was in possession of my information for almost a year. That complaint IS also my information. New SEC NY Richard Best brought that FINRA complaint. ALL of the entities are un named. WHY? Per the complaint: BBH delivered 80%+ of the trades to executing BD's/MM's. NITE as the #1 trader in the space would most certainly have executed BBH trades converting worthless certs to real money. The BBH complaint also cites un named Swiss Banks and FFI's. As a result of exposing these frauds the SEC/FINRA no longer allow searches of OTCM share volume by Market Maker. Further, Cifu,Handler,the SEC have allowed the post VIRT/KCG: NITE to no longer disclose these share volumes in any SEC filings NOR SEC reviewed investor presentations. Has NITE exited this business? ABSOLUTELY not. It is and always has been the DRIVER of NITE trading profits. Virtually riskless albeit illegal. The investing public is intentionally misled as to the true, core business of NITE. + +The August 1 2012 "glitch" proved my allegations that Knight was insolvent. Knight had to raise virtually the entire "glitch" loss despite claiming to have a "highly liquid balance sheet". The accounting fraud is a result of the illegal naked shorting. The SEC,Handler,Jefferies et al "glitch" and bailout wasn't JUST a cover up of a massive SEC failure to protect the investing public however. The 2012 "glitch" was the first of many cover ups so that this massive fraud on the public can continue. Per previous correspondence and the extensive record with the SEC: As with the "glitch" ALL participants KNEW exactly the NITE core business and accounting fraud at NITE in 2017 had not changed. As the record clearly shows: NITE was engaged in abusive naked shorting OTCM (and other) money laundering shells immediately prior to the VIRT/KCG merger closing. Many of the same players in the 2017 "glitch" as the 2012 "glitch". JPM,GS,JEF/Handler, and Jay Clayton Sull Crom colleague Jared Fishman. How did the VIRT/KCG merger get approved in the face of the overwhelming evidence I provided? The same way the 2013 Knight/Getco reverse merger got approved: SEC criminal obstruction. + +In 2017 the SEC,Cifu,Handler wrote down 4 billion+ Naked short fails immediately prior to the VIRT/KCG deal closing. These fraud "assets" were sitting on the KCG balance sheet and used to calculate the grossly inflated tangible book value used in the KCG acquisition price. KCG was grossly insolvent. ALL participants and the SEC knew this. The primary beneficiary of this fraud: Handler/Jefferies. + +In 1Q2020 I alerted the SEC that absolutely nothing had changed. NITE reported a receivable of 2.5 BILLION+. This was up 90% sequentially. HUGE red flags. No investigation. In 2Q2020 the receivable had fallen by just \$100 mil from 1Q. Meaning: The 1Q receivable would have zeroed out within days of March 31 2020 as is required: settlement Then, the receivable at June 30 was within 100 mil of the March 31 balance. Inconceivable. The March 31 receivable was NEVER zeroed out as is required by law. Further, the fails listed as "assets" are a fraud. More accurately: liability. AND there is nothing in the receivable that can be converted into cash for company use. There are prior commitments: settlement. Combine this with the THIRD CFO in a year and you have the makings of ANOTHER "glitch" + +As I've told the SEC: HFT holdings:seconds. No receivable there. DMM? KCG sold theirs in 2016. So that leaves the VIRT DMM. Even AFTER the massive 2Q2017 Cifu/Handler/SEC write down, the receivable is up more than 6X from the last VIRT stand alone 2Q2017. AGAIN the effects of the core NITE illegal activity. + +So, what has changed since August 1 2012? Absolutely nothing. This is an ongoing, massive fraud perpetrated on the American people. Well orchestrated by the SEC,Handler/Jefferies,Sull Crom et al. + +Did Clayton recuse himself from my Award denial? Did Clayton recuse himself from the VIRT/KCG approval? Did Clayton EVER disclose his Sull Crom NITE conflicts? + +The answer can be found in the very carefully structured complaints against several entities in my 2013 and derivative TCR's: NONE of the activity in these SEC/FINRA complaints takes place without a willing, executing BD/MM converting worthless certs into real money. Then trader in the space: NITE. Yet, you won't find NITE in ANY of these complaints. As far as the SEC is concerned: :"penny stock trading fairies". The corrupt, criminal SEC/Handler/Jefferies relationship explained. + +I offer AGAIN to fly to SEC DC HQ or NY Office on my own dime to have the best and brightest at the SEC rip me apart and refute my extremely serious allegations 1 by 1. Bring the SDNY too. Better yet: RE forward my information to Handler,Cifu et al. I know they have already seen it from the SEC. I still have yet to be sued by ANYONE related to my information. The Opco Denial Award is also further evidence of SEC criminal obstruction. A gross mishandling of my information to both bring strategic complaints while protecting the criminal entity NITE. Ms Norberg has created some of the most extraordinary reasons for denying my award. The best so far: "SEC investigators never saw my information". An acknowledgement of SEC criminal Obstruction. It is the job of the OWB exclusively and explicitly to distribute whistleblower information within the SEC. A whistleblower has no way of knowing WHO at the SEC is working on a case. Further, despite my request for Norberg to produce the entirety of my extensive record with the SEC, she failed to do so. + +What was the denial in Opco based on? The SEC, Clayton, Handler, Jefferies, NITE et al ongoing massive fraud on the public must continue. So it does. + +Mr Kamensky must have my information. + +This massive fraud on the public MUST end. ALL of it + +Per the extensive record and my derivative TCR's: It isn't just NITE,Cifu,Handler,Jefferies et al the SEC is protecting. Is it Jane? + +Regards, + +Christopher J Dilorio + +Whistleblower + +From: Chris Dilorio + +Sent: Tuesday, July 7, 2020 6:09 AM + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +Janey, + +MORE EXTRAORDINARY SEC corruption and criminal obstruction designed to protect criminals and screw whistleblowers like me. Despite my very generous 4 day offer to produce the entire record which is the basis of my award application/denial/appeal AND REQUIRED by the statute I have referenced: + +240.21F-12 "Materials that may form the basis of an award determination and that may comprise the record on appeal", The several hundred e mails I have sent you, Hoecker et al MUST be part of this record. Janey, you failed to produce this record. As I made clear: my 6/23/2020 emails to you Hoecker, SEC commissioners were merely re re re sent previously sent e mails: the record. Further, my 6/23/2020 e mail: Formal appeal for preliminary denial covered action 2015-016 Knight Capital & Appendix was merely a summary of several hundred e mails sent to you, Hoecker et al. These e mails SHOULD be the record. You failed to produce the + +record. Which begs the question: WHAT "record" was used to determine the SEC preliminary denial exactly IF the SEC can't produce the record? The preliminary denial was completely fabricated and must be reversed. But, it doesn't end there: per my 6/23/2020 summary based on several hundred e mails sent to the SEC, the RECORD of EXTRAORDINARY corrupt obstruction designed to protect criminals and screw whistleblowers is not confined to Opco,NITE,UBSS,Sason,Keener etc etc etc. I have filed 2 TCR's with the OWB related to the money laundering/transaction + +laundering/Putin/Rakishev/Trump/Kushner/Alfa/Crede/Peizer/Milken/Hapoalim/SBNY/CardWorks/ESQ/WireCa rd/AQR etc etc etc fraud known as Net Element. For YEARS the SEC has been in possession of not just my TCR's but HUNDREDS of e mails supporting my TCR's comprising the extensive record. Here again, the SEC is covering up a MASSIVE fraud perpetrated on the public and well within even the grossly corrupt SEC ability to shut down the fraud IF they had used my information to execute its mandate to do so. Instead, the SEC obstructed a thorough investigation. Per my previous e mails: the record: NETE claimed to be a payment processing entity. Claiming further to process BILLIONS of dollars worth of transactions every year. Its subsidiary Pay Online is linked to the massive fraud Wire Card. How's the SEC Wire Card investigation coming along? For years, based on my extensive financials research and other research, I pleaded and pleaded with the SEC to shut down this massive fraud. They did not. email after email. Year after year I wrote the SEC "NETE is a money laundering/transaction laundering fraud". Rather than shut it down, the SEC with the help of NASDAQ allowed fraud public offerings by Crede/Peizer/Milken related entities: Esousa and Cobblestone and a reverse split so NETE could keep its NASDAQ listing. The balance sheet has been grossly insolvent for years: goodwill. + +ALL of my allegations were confirmed when NETE decided to "unlock value in its payment processing" business by doing a reverse merger with a CA EV "manufacturer" started by a musician. This fraud transaction is quite common in money laundering shell land dominated by NITE/VIRT. The SEC cover up of criminal activity while screwing whistleblowers:ME: The "payment processing business" is to be "sold". Related of course was the SEC cover up of criminal activity while screwing whistleblowers: ME: The Goldman/Sull Cromm advised purchase by ALLY of CardWorks: Merrick Bank: NETE and then the recent unwinding of this fraud transaction. No doubt the brain child of Chair Clayton and his Sull Cromm colleague Jared Fishman who has played a key role in keeping the criminal entity NITE/VIRT up and running. + +NETE/Mullen: "here glitchy glitchy" cover up. But, who the hell would EVER touch the massive fraud: NETE? Only another fraud: Mullen. + +Mullen doesn't "manufacture" ANYTHING. Mullen is simply a car dealership. + +The K50 EV is manufactured in China by Cdantu a subsidiary of CH-Auto. Qiantu/CH have a production facility in China. There will be no Mullen "production" of EV vehicles in Washington or anywhere else in the US. + +But, the SEC facilitated fraud doesn't end at protecting criminals and screwing whistleblowers: ME. Per my TCR attached, there is a well orchestrated eco system of fraud. Including "issuer/bag man funded research" that facilitates P&D. In fact, on 11/8/2018 the SEC brought a complaint against an entity I cited in 1 of my emails to the SEC: the record: known as SeeThroughEquity + +https://www.sec.gov/litigation/complaints/2018/comp-pr2018-259.pdf + +#### Seethruequity, LLC, Ajay Tandon, and Amit Tandon + +THE DEFENDANTS 6. SeeThruEquity, LLC is a Delaware limited liability company that was co-founded in 2011 by brothers Ajay Tandon and Amit Tendon. + +www.sec.gov + +![](_page_34_Picture_0.jpeg) + +NEW YORK, NY / ACCESSWIRE / April 10, 2018 / SeeThruEquity, a leading independent equity research and corporate access firm focused on smallcap and microcap public companies, today announced that it has issued an update on Net Element, Inc. 0. The note is available here: NETE April 2018 Update Note. Net Element Inc. (NASDAQ: NETE, "Net Element") is a global financial + +www.netelement.com + +https://www.netelement.com/press-releases/release-content/I 0734671#.XwRXGuWSnIV + +![](_page_34_Picture_5.jpeg) + +#### SeeThruEquity Issues Update on Net Element Inc. + +NEW YORK, NY / ACCESSWIRE / August 6, 2018 / SeeThruEquity, a leading independent equity research and corporate access firm focused on smallcap and microcap public companies, today announced that it has issued an update on Net Element, Inc. 0. The note is available here: NETE August 2018 Update Note. Net Element Inc. (Nasdaq CM: NETE, "Net Element") is a global financial + +www.netelement.com + +So, the SEC SeeThroughEquity complaint acknowledges the fraud associated with NETE. Well orchestrated. This P&D campaign was part of the 2 fraud offerings : Esousa and Cobblestone: I alerted the SEC to. Who PAID for the SeeThrough P&D? Crede/Peizer/Esousa/Cobblestone? + +The cherry on top of the SEC corrupt obstruction: NETE was still in business in 2020 to receive taxpayer Cares Act money. + +A summary of the record. + +Janey, Hoecker et al, + +Please update my Net Element and AQR TCR's + +Cheers! + +Christopher J Dilorio + +Whistleblower + +Not just irony but a massive fraud on the + +From: Chris Dilorio + +Sent: Tuesday, June 30, 2020 1:01 PM + +![](_page_34_Picture_20.jpeg) + +![]()Janey, + +the purpose of your 5 years in the waiting PRELIMINARY denial of my OpCo Award application could not be any more clear: run the clock out and protect NITE,UBSS,Magna et al while denying me rightful compensation. But, As I have repeatedly told you, Hoecker, your colleagues: the last overt act of this vast conspiracy has not yet occurred: + +NITE/VIRT is insolvent today 6/30/2020 as a direct result of the SEC facilitated fraud on the public which is and always has been the core business at NITE/VIRT: Abusive naked shorting publicly traded shells to facilitate money laundering. The public is STILL at risk. The SEC has facilitated NITE intentionally misleading the public as to the true nature of its business. The SEC still facilitates this massive fraud on the public while it intentionally misleads the public there is no naked shorting because the SEC authorized the DTCC to create the illegal, shadow clear mechanism Obligation Warehouse (OW) so NITE's criminal activity can continue and it can circumvent close out REQUIREMENTS of Rule 204 of Reg SHO. ALL very much ongoing in June 2020 as a direct result of the SEC (OWB/Hoecker/Enforcement etc etc) criminal obstruction and ACTIVE facilitation of the criminal enterprise known as Knight/KCG/VIRT: NITE. + +Clayton never disclosed his Sull Crom/Fishman/NITE conflicts. He must step down from the SEC IMMEDIATELY until a criminal investigation can be concluded. NITE must be halted IMMEDIATELY as it still poses a monumental risk to the investing public. FINRA should go back to being a cheerleader as it is just another enabler of this criminal activity. It has NO business enforcing SECURITIES LAWS. It should not be overseeing the OTCM. FINRA fines are a joke and not meant to be a deterrent. INTENTIONALLY siding with criminals over the investing public the SEC is mandated to protect. The cesspool known as the OTCM MUST be shut down. It exists SOLEY for the purpose of facilitating a massive fraud on the public. The OW must be shut down IMMEDIATELY so the public can see just how pervasive naked short selling: MANIPULATION really is. EVERYONE at the SEC who has had contact with my information MUST resign/be terminated IMMEDIATELY. ALL of the AQR blank check shells must be shut down IMMEDIATELY as they pose a serious national security risk. AQR MUST be shut down IMMEDIATELY. + +Certainly not exhaustive BUT a good start + +Cheers! + +Christopher J Dilorio + +Whistleblower + +![]()![]()Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +Janey, please add the following info to my appeal of your preliminary denial of my Opco award. + +More evidence the SEC is using/has used my information to both bring complaints and protect/obstruct complaints. Again, you, McKessy, Hoecker have been in possession of my 2013 TCR filed with Berger for several years. In addition to hundreds of e mails continuing into 2020 showing irrefutable and overwhelming evidence to support my allegations. + +Highlighted in my attached TCR and related to my Opco Award application: Joshie Sason/Hanover/Magna: CGFIA, IMDS,NewLead,FreeSeas, PRTH etc etc etc. The SEC Sason/NewLead complaint is also my information as I filed separate but related NewLead, and FreeSeas TCR's with your office. The SEC complaint: Sason assignments: bogus notes. NO SHIT? Really? detailed by me. In addition to Bag Man Sason/Hanover/Magna, I detailed the illegal activity of Bag Man Justin Keener/JMJ in my 2013 TCR. Keener was the customer in the FINRA World Trade Financial complaint. + +https://www.finra.org/media-center/news-releases/2013/finra-fines-three-firms-900000-inadequate-antimoney-laundering + +### FINRA Fines Three Firms \$900,000 for Inadequate Anti-Money Laundering Programs I FINRA.org + +WASHINGTON - The Financial Industry Regulatory Authority (FINRA) announced today that it has fined three firms a total of \$900,000 for failing to establish and implement adequate anti-money laundering (AML) programs and other supervisory systems to detect suspicious transactions. + +www.finra.org + +Related to the billions of OTCM money laundering shells traded through World Trade, the BD SRO FINRA requested information from Keener related to his assignments and acquisition of bogus convertible notes including bank statements to prove the notes weren't bogus. Keener told FINRA to 'F Off" + +https://www.finra.org/sites/default/files/OHODecision/p182993 0 0.pdf + +## FINANCIAL INDUSTRY REGULATORY AUTHORITY OFFICE OF HEARING OFFICERS + +5 distributions of securities in violation of Section 5 of the Securities Act of 1933. Tr. 158, 179-180.6 On September 22, 2011, FINRA staff served a request on Keener, pursuant to FINRA + +FINRA barred Keener/JMJ in 2013 as a "Bad Actor" + +The SEC was certainly aware of the FINRA action + +https://www.sec.gov/litigation/opinions/2012/34-68014.pdf + +As recently as 2019 Bag Man Keener/JMJ was involved in ANOTHER money laundering shell called Blink Charging fka New Image Concepts + +https://www.sec.gov/cgi-bin/browse-edgar? + +action=getcompany&CIK=0001429764&owner=exclude&count=40&hidefilings=0 + +https://www.sec.gov/Archives/edgar/data/1429764/000114420419004046/0001144204-19-004046-index.htm + +### EDGAR Filing Documents for 0001144204-19-004046 + +Blink Charging Co. (Subject) CIK: 0001429764 (see all company filings) IRS No.: 030608147 I State of Incorp.:NV I Fiscal Year End: 1231 Type: SC 13G/A I Act: 34 ... + +WV:Vi.sec.q ov + +New Image Concepts was detailed by the SEC in their Jaclin et al "Shell factory" complaint in 2016. PRIOR to Keener involvement. + +https://www.sec.gov/litigation/complaints/2016/comp-pr2016-86.pdf + +#### Case No. 2:16-cv-03250 + +1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Case 2:16-cv-03250 Document 1 Filed 05/12/16 Page 1 of 45 Page ID #:1 AMY JANE LONGO, Cal ... + +vo.vvy sec g ov + +But Keener not the only 1 involved who knew New Concept was a money laundering shell. + +CEO of Blink is Michael Farkas. SEC knows him well from his Skyway Communications days. + +The SEC revoked the registration of Farkas/Skyway in 2007 + +https://www.sec.gov/cgi-bin/browse-edgar? + +action=getcompany&CIK=0001128723&owner=exclude&count=40&hidefilings=0 + +The CFO of Blink is Jonathan New. Formerly CFO of the AQR/Crede: Milken money laundering/Transaction laundering blank check shell: Cazador/Arco: Net Element + +A director of Blink is a guy named Donald Engel who worked at Drexel with Milken. + +New Concepts was HQ'd in Santa Monica: Milken + +But it gets better + +![](_page_38_Picture_0.jpeg) + +### Honig's Shell Factory Attorney Gregg Jaclin Barred as SEC lawyer - TERI BUHL + +Your Voice. High Times Admits SEC Filing is Wrong: Stormy Simon off the Board - L.A. Cannabis News on Text messages show Cannabis investors Defrancesco & Serruya allegedly Colluded with Clarus Securities' Christodoulis in Multiple Stocks; High Times Admits SEC Filing is Wrong: Stormy Simon off the Board - + +www.teribuhl.com + +Where the SEC said multi billionaire Frost risked ALL to make a few million. NO, Frost,Alpha (also in my attached TCR), Stetson, Honig were LAUNDERING. Frost bought Ladenburg from Milken flunkie Icahn AFTER Icahn rolled Gruntal int Ladenburg. Gruntal: Icahn,Sater,SAC,Feinberg et al: Milken + +The SEC intentionally omitted a Honig/Stetson shell from this complaint: + +Millenium Bio/lnergetics + +linked to Trump Cleveland fundraiser and healthcare fraud felon: Brian Colleran + +In typical SEC "cover up", revoked the Millenium/Inergetics registration in 2019. + +https://www.sec.gov/cgi-bin/browse-edgar? + +action=getcompany&CIK=0000072170&owner=exclude&count=40&hidefilings=0 + +Finally, + +SEVEN F'n Years AFTER FINRA barred (not exactly) Keener/JMJ and my Berger TCR filed with your office Janey, The SEC is going after Keener/JMJ related to my information AGAIN + +17.5 BILLION shares of money laundering penny stocks. + +https://www.sec.gov/litigation/litreleases/2020/Ir24779.htm + +Justin W. Keener d/b/a JMJ Financial (Release No. LR-24779; Mar. 24, 2020) + +SEC Charges Unregistered Penny Stock Dealer Litigation Release No. 24779 / March 24, 2020 Securities and Exchange Commission v. Justin W. Keener d/b/a JMJ Financial, No. 20-cv-21254 (S.D. Fla. March 24, 2020) + +wwwsecgov + +WHO was/were executing BD's/MM's in these billions of shares of worthless Keener/JMJ money laundering shells???? + +What are odds that bogus note/worthless certs/assignments Sason/Magna would be involved with bogus notes/worthless certs/assignments Keener/JMJ in money laundering shells like IMDS and CGFIA etc) AND CGFIA was detailed by me to the SEC/FINRA AND CGFIA was 1 of the shells in the FINRA Opco AML complaint AND where NITE and UBSS traded billions of shares of CGFIA + +AND where NITE and UBSS traded billions of shares of IMDS also + +Now, what are the odds of all of that? + +Christopher J Dilorio Whistleblower + +From: Chris Dilorio + +Sent: Tuesday, June 23, 2020 4:11 PM + +u•Ject: Fw: Forma appea or pre im na y •enia g t CapitaTCR : Appendix + +small typos/corrections: + +Mirror trade activity peaked in 1H2014 not 2H2014 and this coincides with OTCM astronomical share volume data in 1Q2014 and 2Q2014 that were expunged from KCG 10Q SEC filings. Not 2Q2014 and 3Q2014 SEC reviewed 10Q's as I previously stated + +corrected below + +Chris + +From: Chris Dilorio < + +Sent: Tuesday, June 23, 2020 9:48 AM + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +Ms Norberg, + +I am in receipt of the SEC OWB correspondence allowing me more time to respond to the preliminary denial of my award application for the Oppenheimer 2015 covered action. This e mail was the last 1 I sent to your office related to my appeal. It will serve as the basis of my appeal. Including the attachments of my 2013 TCR submitted with Berger Montague to the SEC. I will also forward correspondence from 2012 and following detailing my extensive correspondence with Robin Traxler at FINRA as well as Sean McKessy in the OWB. Even though, I have previously forwarded your office as well as the SEC IG office the exact same corroborating + +evidence. My response to you will be lengthy and detailed. However, given that it took your office FIVE YEARS to send me a preliminary denial notice, that is understandable and in fact a result of YOUR lengthy delay in notifying me. ALL of my response pertains to the denial appeal at hand. + +In 2011, I filed my first Whistleblower complaint with the SEC. Detailing a massive fraud on the public directly implicating dozens of entities. The center of my claims: Knight/KCG/VIRT: collectively NITE and the Swiss banking giant UBS:UBSS. By far, NITE was and still is today the largest MM/executing BD in the OTCM space. I was shocked to find the Swiss banking Giant UBSS was trading many of the same stocks as NITE and to the extent they were. This came on the heels of the FINRA UBSS Reg SHO complaint where the extent of the UBSS activity "threatened to undermine the integrity of our markets" while the SEC analysis of this activity was simply a case of "sloppy record keeping". My experience as an Institutional Sales trader: executing multi million share equity trades for the largest institutions in the world like Fidelity and Putnam. In addition, as a Research Sales person: analyzing financial statements and making investment recommendations formed the basis of my expertise. In fact, the SEC OWB has paid out awards for information just like mine. In August of 2011, I informed the SEC that NITE was insolvent having reported just \$105 mil in working capital at June 30, 2011. AND, for the resaons cited in my TCR detailing massive accounting fraud as a direct result of illegal naked shorting/self clearing/reverse splits/cusip changes etc. The SEC had a choice: investigate these extremely serious allegations and shut down this massive fraud on the public OR cover up their failure and allow this massive fraud on the public to continue. Unfortunately for the American public the SEC is mandated to protect, the SEC chose the latter. As a direct result, ALL of the activity detailed by me in this TCR and other TCR's filed with the SEC as well as 9 years of additional correspondence with the SEC, this is very much an ongoing, massive scheme. One that the SEC actively facilitates. Countless losses have been incurred as a result. NITE as I detailed is in a constant state of insolvency. The SEC has time and again intentionally misled the investing public that there is no abusive naked shorting. NITE is still in business TODAY. + +The core business at NITE is and always has been: abusive naked shorting OTCM shells to facilitate money laundering. Not DMM, FCM, reverse mortgages, or even HFT. This illegal business is EXTREMELY profitable and virtually riskless. AND, both the SEC and FINRA know this. In 2016, FINRA brought a Rule 204 complaint against NITE. The fine was pathetic and not meant to be a deterrent. This is WHY the OTCM exists. But it's not JUST OTCM as my AQR TCR filed with the SEC clearly proves: NASDAQ Blank check shells as well. I have also filed separate TCR's related to NewLead and FreeSeas: 2 massive money laundering shells which began on NASDAQ,de listed to the OTCM. NONE of the activity detailed in the Opco/Gibraltar complaint takes place without a willing executing BD/MM who ultimately turns worthless certs into real money. That #1 trader is NITE. As you read in my Knight TCR CGFIA is at the heart and, because it was based in Colorado, became a template of sorts for my extensive research. See Ms Norberg, unlike the SEC "investigators" on the Opco/Gibraltar complaint, I've actually seen first hand the CGFIA "world HQ" as well as the rented Littleton home of CGFIA CEO Guyer. I've done extensive research on Properties claimed to be owned and M&A transactions done for the sole purpose of cert printing and distribution (Aurelio AMNP) where the ultimate acquisition amounted to a distributor of Ukrainian folk music. I've also done extensive research on domestic and foreign financial institutions claiming to "invest" in these scam companies like Josh Sason/Hanover/Magna also cited in my 2013 Berger/Knight TCR linked. So, as I detailed to Ms Traxler, I followed Guyer to Neuchatel Switzerland and his previous endeavor: Antelope Technologies also with an office in Highlands Ranch CO. Where I discovered a connection to Swiss/German individuals/entities that were also related to another OTCM shell in the OpCo/Gibraltar complaint as well as my Knight TCR: AppTech. Offices in the Woodlands TX and Boca Raton. AND very much up and running today. SHOCKING. The SEC OpCo/Gibraltar complaint is based on the FINRA complaint. That is absolutely irrefutable. As the Gibraltar complaint alleges just 1 OTCM shell and just a million shares while Commissioners Stein and Aguilar referenced BILLIONS of shares in their OpCo waiver dissent. Who executed those BILLIONS of shares? Was OpCo even a MM? If I ask a question it's typically a rhetorical: I know the answer. The SEC knows the answer also. The SEC OpCo complaint does not mention the executing BD/MM. The SEC complaint doesn't mention Sason/Hanover/Magna either. The SEC complaint makes no mention of illegal naked shorting which is clearly evident in the CGFIA 10Q referenced below. THIS IS MY + +INFORMATION. So, why aren't NITE, Hanover/Magna and UBSS implicated in the SEC OpCo/Gibraltar complaint? What my TCR clearly and irrefutably proves: NITE was engaged in illegal activity both BEFORE and AFTER the SEC et al orchestrated August 1 2012 "trading glitch". So, the SEC bailed out a KNOWN criminal entity. + +Unfortunately for the investing public, the SEC has doubled downed on facilitating this illegal activity into 2020. + +The "glitch". Knight was insolvent in August 2011. 1 told the SEC this. The "glitch" proved my allegations. Key point in my TCR: NITE inadvertently sent 4000 worthless securities to JPM to secure an emergency bridge financing as collateral. These were open, naked short fails that could not be covered/closed due to a cusip change (SEC/FINRA approved rev split) booked as an "asset"(receivable) due to self clearing: MASSIVE accounting fraud. Ironically, the "glitch" proved my allegations: despite claiming to have a "highly liquid balance sheet" NITE had to raise the entire amount of the "glitch". AND the ultimate "financing" was not collateral based. Rather a 50% discounted convert when the stock had already been crushed to \$3 OR \$1.50. ALL of the financing participants knew the NITE balance sheet was complete fraud. NITE also committed securities fraud in pledging those 4000 worthless securities as collateral to JPM: SCOTUS Rubin: pledging collateral to secure financing is an offer to sell. JPM looked the other way. As did the SEC. + +Further, I submitted my amended TCR with Berger in March 2013, In August of 2013, FINRA brought a penny stock AML complaint against OpCo. Sale of unregistered penny stocks. WHO ultimately executed the trades? + +2008-2010. In July 2013, the "glitch" financing Gen Atlantic/Getco reverse merger with Knight to form KCG closed. The new CEO of KCG was Dan Coleman who ran Equities at UBSS during their Reg Sho and cross border activity. For UBSS, the DOJ (Acosta Downing et al) dropped their DPA in 2010. My claims: the FINRA + +OpCo/Gibraltar complaint clearly implicates UBSS criminal activity AFTER the DoJ dropped its UBSS x border DPA. This is what the SEC is protecting in the OpCo/Gibraltar complaint: NITE/UBSS/Hanover/Magna illegal activity. + +Also in my Knight/Berger 2013 TCR: IMDS. A multi year money laundering shell kept up and running by the SEC. + +Also NITE,UBSS, and Hanover Magna. In addition to other entities like JMJ, Southridge, and Alpha Capital Anstalt. Alpha Capital Anstalt is very much in business today as a result of SEC obstruction while the SEC recently brought a complaint against JMJ for activity like that in IMDS even AFTER he was barred by FINRA. In + +IMDS, the SEC allowed 2 barred individuals (CEO/CFO) to do an offering that created 37 BILLION shares of IMDS at .0001 with Chinese Nationals before revoking the IMDS registration. What do you do with 37 billion shares of + +IMDS at .0001 when there are no bids below that? NOTHING. The stock never traded. The SEC orchestrated a NITE/UBSS/Hanover/Magna/JMJ/Alpha etc MASSIVE naked shorting to facilitate money laundering scheme bailout so that the MASSIVE naked short position didn't need to be covered in the open market as is mandated by Rule 204. Thus insuring profits and not MASSIVE losses for NITE and UBSS. + +I also filed separate TCR's for NewLead and FreeSeas. 2 "Greek shipping" money laundering shells started on NASDAQ and delisted to OTCM. NITE top trader in BOTH. Hanover/Magna in both. I contacted the KY Div of + +Mines and notified the SEC that these "transactions" were complete fraud. The SEC Feb 2019 complaint against Hanover/Magna is my information: Bogus obligations, assigned, converted to worthless certs. Then dumped on the public and converted to REAL money by the executing BD/MM:NITE. Who generates illegal trading profits + +by abusive naked shorting. Very symbiotic relationship. 1 of the Hanover/Magna entities was Gibraltar/Hanover. Somehow omitted from the SEC OpCo/Gibraltar complaint. In NewLead, then SEC White and Ceresney firm + +Debevoise did a "fairness opinion" of a Russian Nickel wire transaction where the NewLead CEO had back dated documents. That has been expunged from SEC reviewed filings. FreeSeas: a structured tax evasion/money + +laundering shell. Also involved Credit Suisse and Deutsche Bank. Both Debevoise clients. Both involved in the tens of billions Russian Mirror trade scheme. In addition to Hanover/Magna a Milken related entity Crede: Run by Milken/Drexel/Obstruction of justice/Parking: Terren Peizer and his felon partner Michael Wachs. This led me + +to Net Element NETE. Peizer again. This time with more AML red flags than be counted. Well known to the SEC through TWO of my separate TCR's. CEO is Oleg Firer. Firer former money laundering shell Acies shut down by + +the SEC while NETE was left up and running. Acies very much up and running also in MA. In NETE: NASDAQ. AQR Blank check shell. SEC allowed 2 offerings so that NETE could keep its NASDAQ listing. 1 was with entity + +the offerings. I discovered AQR money laundering blank check shell activity doing research on NITE and Hanover/Magna. A top traded NITE OTCM shell was Cereplast. Another AQR blank check shell. Hanover/Magna/NITE/ and Alpha Capital Anstalt. Alpha is Liechtenstein based and controlled by Martin Schlaff: Austria/Israel. AlsolMDS (w/Schlaff controlled Balmore) and the Frost/Honing/Stetson et al complaint. Schlaff also LH Financial/Wolfson/Sulphco and Bawag: Sedona/Scan Graphics: Refco: Naked shorting. NITE is Refco on steroids. Cereplast ended in bankruptcy. + +NETE claims to be a "payment processor". BILLIONS in transactions processed. Never break even let alone profitable. Balance sheet complete fraud. AML red Flags: Firer is Grenada Amb to Russia living in Miami, Apockinas/Grinshpun/Antonov/RakisheviTrump/Kushner/SBNY/CardWorks/Merrick Bank/ESCt/Cohen etc etc etc money laundering/transaction laundering BILLIONS shell. Kept up and running for years since filing my NETE/AQR SEC TCR's. ALL of my allegations proved accurate in 2020 when NETE received Cares Act taxpayer money then announcing it was "unlocking the value in its misunderstood payment processing business" by doing a reverse merger with a CA electric car company started by a former musician. The payment processing business to be "sold" and the new company (Mullen) will own 80-90%. All made possible by SEC obstruction and ACTIVELY facilitating illegal activity. Another AQR blank check shell is Astra/Phunware. More Greek shippers related to massive swindler Economou originally intended to do an "energy logistics company" acquisition and somehow settled on "mobile app developer" Austin TX: Phunware. PHUN CEO is well known to the SEC with shells going back 15 years. I alerted the DoJ and SEC that PHUN was a money laundering shell. In addition to the "genius quant" AQR, AIPAC: Gerber/Hudson Bay, Nordlicht: Ari Glass/Boothbay, 1MDB: Khazanah Nasional, Global Crown/Rani Jarkas/EFG/BSI/Optima/Max Fang. AG Barr 1MDB waivers: Kirkland also AQR. Broidy: Trump: 1MDB money laundering. PHUN also received Cares Act money. AND PHUN is Trump/Kushner/Parscale campaign mobile App. PHUN should have also been shut down long ago. AQR too. OTHER AQR blank check shells: CIS/Delta/Urban Tea, Ability/Cambridge, Hunter Maritime, and MI Acquisition/Priority Tech Holdings. Ability/Cambridge: Israeli cellular intercept/surveillance. Israel sent employees to jail. In the US it was "securities fraud". The SEC Ability/Cambridge complaint was handled by Ansu Banerjee in the SECLA office. Milken/Mogilevich/BoNY money laundering entity Sinex: Debasish Banerjee. WHY did SECLA have jurisdiction over ABILF/Cambridge? Result: ABILF is very much up and running today. I believe this is the PHUN/Trump/Kushner/Parscale mobile app technology. + +Hunter Maritime:HUNTF: Never consummated an acquisition. Just cert printing/dumping. Also involved: Milken family office: Silver Rock. MI/Priority:PRTH. CEO Tom Priore: well known fraudster to the SEC. Also transaction/money laundering like NETE. Also involved: Hanover/Magna. + +ALL AQR money laundering shells up and running today thanks to the SEC. Only recently did the SEC revoke CGFIA and NewLead. well after going dark and the massive fraud on the public had already been perpetrated. In NewLead, FreeSeas, etc etc etc a common tool used is reverse splits to perpetuate and facilitate illegal activity. SEC/FINRA approved. The result is the massive accounting fraud at NITE. WHEN not IF there is an open naked short fail when a rev split takes place, a new CUSIP/security is issued. Trades in the old cusip/security cease. This creates a structural liability. The fail/short can NOT be closed. Like covering a short in AAPL with MSFT. Because NITE is self clearing it books a prop naked short as a receivable. An asset. But, because NITE won't or CAN'T deliver, massive accounting fraud. Literally a liability booked as an asset. This is how "glitches" are born. But the SEC facilitated fraud doesn't end there. The definition of a failed trade: 1 that hasn't settled. The SEC/DTCC issue new securities where trades in the old haven't settled yet AND not authorized by the issuer. Settlement: buyer brings cash/seller brings securities. The DTCC simply makes journal entries. But there are still "IOU's" in the system. The SEC authorized the DTCC to create a shadow clear,non guaranteed, ILLEGAL (clearly contrary to 34' Act "prompt and accurate settlement) Obligation Warehouse so criminals like NITE et al can circumvent close out REQUIREMENS of Rule 204. The OW is just what it sounds like. Per my Knight TCR, DTCC suspends services (Chill/Lock) and trades are deemed "ex clearing". In a FOIA request made with POGO,Berger and I asked the SEC fails data on dozens of NITE/UBSS top traded stocks like CGFIA,APCX and IM0S. The SEC response: see our website. The SEC fails data is for DTCC cleared trades only. The SEC knows exactly the level of fails sitting in the OW. They don't disclose. Intentionally misleading the public there is no naked shorting. In + +1Q2020, the receivable at NITE/VIRT increased \$1.2 BILLION sequentially. Up almost 90%. AND the tangible book value is grossly insolvent. When it comes down to it, there really isn't ANYTHING in the receivable that NITE can convert into cash for its own use. There are prior commitments on those "assets": SETTLEMENT of transactions. Because the SEC has never shut down this activity, NITE is in a constant state of insolvency. Other examples of SEC attempts to cover up NITE illegal activity so that it can continue include: Cerberus/Feinberg/VIRT bidding on NITE post "glitch". Wasn't their turn. First, Gen Atlantic needed to monetize its GETCO "investment". The HFT business at GETCO was in a death spiral when the rev merger took place. So what was the attraction to NITE? The business that had absolutely ZERO overlap/synergies: OTCM. As low tech as it gets. Literally a trader sitting in a chair. As I have asked the SEC on hundreds of occasions over the years: what would happen to NITE trading profits if their OTCM share volumes went to ZERO? Cerberus is Feinberg: Gruntal/Milken. Also bailed out Bawag:Refco, HSH, and Deutsche Bank (\$50 bil Bad Bank to Goldman). Another Milken/NITE connection is Rich Handler: Jefferies. Also a Milken/Drexel protege. Milken was Gruntal: Feinberg,SAC,Icahn, Sater etc. Gruntal was "sold" to Ladenburg. Controlled by Vector/NewValley:Icahn/Lorber/Elliman etc. And, was sold to multi billionaire Frost. Who, according to the SEC risked it all trying to "make" a few million when he, Honig, Stetson, Alpha et al were really LAUNDERING. Milken also Whiterock ,D H Blair (Morty Davis) and AR Baron (Bressman/D H Blair) which was the precursor to Bear Stearns collapse . So, Milken and his merry crew of flunkies are really at the nexus of JUNK. They own Trump and his White House (Trump casino junk) and they own the SEC. It was Milken, Leon Black, Handler, Moelis, Virtue: Drexel that caused the S&L taxpayer bailout stuffing them with junk like Trump's. It is no coincidence that these same flunkies are also the largest CLO originators/managers. CLO's: Junk on steroids. AGAIN Bailed out by taxpayers in Cares Act HY. There also connections to Epstein. Treasury Sec Mnuchin and Black: HY/Junk/S&L's and Epstein. Black: Money laundering shell ESWW kept up and running by the SEC was/is an Epstein money laundering vehicle: JUNK IS JUNK. + +THIS EXPLAINS the Handler/Jefferies/Milken repeated bailouts of NITE. It also explains the SEC criminal obstruction. + +SEC Chair Clayton is also directly linked to this criminal obstruction. His firm Sullivan Cromwell and Jared Fishman are ACTIVELY facilitating this massive fraud on the public. Clayton did not disclose these conflicts in his disclosures. Sull Crom/Fishman have advised Knight/KCG/VIRT and several transactions designed to facilitate this ongoing and ongoing fraud on the public. Many of the same players involved in the "glitch" were involved in the VIRT acquisition of KCG in July 2017. In addition to Sull Crom/Fishman and Handler/Jefferies: JPM and Goldman. The SEC facilitated fraud in the NITE/VIRT transaction is egregious illegal activity. The transaction NEVER should have happened. KCG was an SEC reporting company until the deal closed on July 31 2017. Despite this FACT, VIRT CEO Cifo refused to "publish" KCG 2Q2017 financials. I estimate Cifu/Coleman/Handler/GS/JPM wrote down more than \$4 billion in open naked short fails: "leverage". The SEC let him. Meaning: "assets" used to determine the take out/ tangible book of KCG was complete fraud. VIRT grossly OVER paid for insolvent KCG. + +Prior to the NITE/VIRT transaction closing in July 2017, NITE would report its trading stats monthly. Including OTCM share volumes. Cifu stopped this post merger. The SEC let him. In fact, you will find NO reference to NITE/VIRT OTCM share volumes in any SEC reviewed filing, sell side research or investor presentation. A well orchestrated fraud on the public. Omissions to Intentionally mislead the public as to the true representation of the NITE/VIRT business model. These share volumes are also at the center of my 2013 Berger TCR. There are no affirmative disclosures in any SEC filings to this day as to the AML risks posed in trading these OTCM and other shells. In a 2014 letter to the SEC, I detailed the first 2 months of NITE OTCM share volumes. When the 1Q2014 10Q was filed, these volumes were confirmed: An ASTRONOMICAL increase sequentially as well as year over year. These share volumes/my letter/TCR SHOULD have triggered an immediate SEC investigation. It did not. This portion of the KCG 1Q2014 10O was expunged as well as 2Q2014 OTCM share volumes. I have detailed this to the SEC/OWB/Enforcement/IG. In the months leading up to the NITE/VIRT closing in July 2017, KCG put out monthly trade stat pr's showing KCG trading more volume than the overall market. Also indicative of naked shorting. Those pr's were also expunged. I also including electronic forms to the SEC OWB/Enforcement/IG. + +The SEC has essentially outsourced the ENTIRE OTCM market to the Broker Dealer SRO FINRA. Including: management of the OTCM share volume website fka OtcBB.com. Today, there is very little transparency into trading activity by MM as a result. Also: ISSUER corporate actions: rev splits, Short interest reporting: an absolute farce given there is still no CAT. AND BD compliance with the BSA. Per my TCR: WHY did NITE and UBSS trade Billions of shares of CGFIA and IMDS AFTER a Chill or Lock was placed (ex clear/OW)? CLEAR AML red flags. Because they had an open naked short position. Why not pull a market? Because they had an open naked short position. SAR's? WHEN? BEFORE OR AFTER THEY TRADED BILLIONS OF SHARES? There were no SAR's either. NITE can not outsource its compliance responsibilities to 3rd parties (like OpCo) when executing trades as MM. In 2015 at a SIFMA conference, Ceresney was "shocked" by the number of BD's under his supervision filing 1 or ZERO SAR's. NITE SHOULD have been investigated for egregious BSA violations long ago based on my TCR. Knight/KCG/VIRT:NITE is and always has been a criminal enterprise. Spitzer Russian/US mob bust: "worthless paper". Ashton Tech became VIE became Optimark became Knight/Trimark NITE literally "made by the mob". The SEC has known this for years. ALL of the "worthless paper" shells were SEC reporting companies. Today, Trump PA Campaign Mgr David Urban sits on the NITE BoD. AND is also on the BoD of his very own money laundering shell: Canadian/Pakastani/pot/COVID: FSD Parma: HUGE. Trump advisers/campaign staff Bannon and Parscale also involved in OTCM money laundering shells.Parscale Cloudcommerce fka Roaming Messenger also receiving taxpayer Cares Act money. Madoff: more money laundering than Ponzi. HOW THE HELL did the SEC let that scam go on for as long as it did? Criminal obstruction. The former SEC IG Kotz actually investigated his "bosses" at the SEC unlike current IG Hoecker. Years of SEC obstruction. Bullshit "investigations" into "running ahead" meant to distract. Similar to the SEC "glitch" "market access complaint" where former SEC "glitch" Enforcement Dir Khuzami/Kirkland(Barr) also rep'd NITE. Can't make this up. The center of IG Kotz scathing failure of the SEC in Madoff: SEC NY and Mr John McCarthy who ended up being Knight/KCG Chief Counsel. As I said: can't make this up. And, as we know Madoff started his career in NASDAQ penny stocks exactly like the l's in the Spitzer/Mob complaint. OTCM: This is WHY the OTCM exists: abusive naked shorting publicly traded shells to facilitate money laundering. CEO Cromwell Coulson CHAIRED the FINRA market Regulation Cmte. Say it with me: Can't make this shit up: CMTSU. A founding OTCM Board member is former NITE trader Andrew Wimpfheimer:CMTSU. This is a very well orchestrated and ongoing fraud on the public. Russian mirror trades: no SEC OR DOJ investigation HOW? According to stories: activity peaked in 1H2014. Coinciding with NITE astronomical OTCM 1Q2014 share volume increase. In additional to money laundering penny stock shells, the OTCM is also home to many ADR's. Including Russian ADR's cited in the NYDFS/DBTCA/mirror trade complaint. Little/no disclosures. Also in my TCR: P&D is just a tool used to facilitate the fraud and NOT a stand alone fraud. The SEC intentionally stops short of thorough investigations into much bigger frauds. The same way it has the public believe the "penny stock trading fairies" convert worthless certs to real money. NO! willing executing BD's and MM's like NITE do that. Less than a year after filing my Knight TCR with Berger, FINRA (not the SEC) brought the BBH AML complaint. This was my information. Swiss banks, foreign/domestic institutions, executing BD's/MM's/ penny stock shells: \$850 mil in proceeds. Did BBH implicate NITE and other entities in my claims? WHY are all of the entities in the complaint UN NAMED? In the interest of transparency for the investing public? In 2019, I also filed an award application for the UBS x border/AML complaint. This is BLATANTLY my information. SEC/FINRA/ AND the SEC. I filed an IRS TCR based on my SEC TCR attached. In April 2016, 2 IRS CI Agents: VIKAS Arora and Nathan Sarnacki flew to Denver from Chicago to meet with me. I believe they were blown away. Then came the UBS complaint. As a follow up to our meeting, they wanted to know WHO at the SEC I shared my information with. I told them. That was the last I heard from them although I continued to send them my information. To the SEC IG Carl Hoecker: In 2015 I parted ways with Berger as I was convinced the SEC was using my information in an unethical/illegal manner to both bring and obstruct complaints. Berger was not willing to file an IG complaint. After parting ways, I almost immediately did just that. Prior to retaining Berger I had filed an award application for the UBS Reg Sho complaint. In my submission and my correspondence with Mckessy/OWB I made the claim based on OWB permissible rules to "open a new line of inquiry". One that would link the trading activity detailed in my ultimate TCR by NITE and UBSS. That link: Abusive naked shorting + +publicly traded shells and money laundering. My application was denied and there was no investigation into this link. The SEC had just bailed out a "known criminal enterprise":NITE "glitch" was not a forthcoming admission. Neither was the blatantly and knowingly false pretext for the DOJ dropping its UBSS x border DPA because "UBSS was in full compliance" in 2010. So, rather than open a new line of inquiry, the SEC chose to obstruct. + +I made clear to Hoecker the egregious conflicts by Khuzami,White and Ceresney with clients UBS,JPM,CS, and DB. Hoecker claims to have conducted a "thorough" investigation of my very serious allegations and found nothing. Despite MJW waivers received to "investigate" her Swiss bank client CS. Then in 2019, Hoecker arrogantly told me I could file a FOIA request on his findings. Then, came 2019 and absolutely nothing had changed. NITE was still trading billions of shares of OTCM shells like ELTZ. There were still no risk disclosures. Cifu refused to publish KCG 2O2017 financials, Hanover/Magna/AQR/Alpha/IMDS etc etc etc were still up and running . I filed ANOTHER complaint with IG Hoecker. Despite the fact that Hoecker himself wroth the IG handbook on "thorough investigations" mandating complainant interviews, I have never been interviewed by Hoecker. In addition, the IG Hoecker is mandated to inform Congress as to serious allegations like mine. He did not. In doing so, obstructed Congress from executing its oversight of the SEC/OWB. And despite hundreds of offers to fly to SEC HQ to have the best and brightest at the SEC rip apart my allegations 1 by 1 I have never been taken up on my offer. Why is that? The SEC OWB has gone to great lengths in other cases to explain the OWB process etc to whistleblowers. I have never been told "no thanks" for my information. In fact, McKessy has solicited MORE information from me after submitting my Berger TCR. In Madoff, an intern could have verified/shut down in weeks NOT years. No contra parties. Only a well orchestrated obstruction by SECNY/McCarthy et al kept it up and running. As I have also repeatedly told the SEC: My claims could be verified in weeks also. NITE has a P&L for every stock they trade. These, aggregated, are basis for quarterly trading profits. These P&L's, combined with OW data, and balance sheet data will validate ALL of my claims. I've offered my service to do exactly that. 2 weeks max. Afterall, proprietary trading strategies are NOT proprietary if they're illegal. For the reasons I have listed in this summary, NITE/VIRT is on the SEC "do not investigate list". And yes, there most definitely is such a thing. Especially when it comes to illegal activity facilitated by the SEC. So, the SEC denial of my OpCo award claim which was 5 years in the making is just another example of my very serious allegations: The SEC solicits and uses whistleblower information like mine to both bring and obstruct complaints. Unethical. Illegal. To deny my award application because the "investigators" didn't see my information is further affirmation of my allegations. They saw it. They used it. They denied my compensation for it. Again Ms Norberg, I will forward my 2012 etc emails with Robin Traxler at FINRA as well as McKessy as further evidence that my Award application denial should be overturned. Further affirmation from 2 dissenting SEC Commissioners and the judge in the Gibraltar case makes this denial both egregious and bizarre. Bizarre ONLY if you believe that there is no SEC obstruction that is. BTW, crazy stuff going on with the firing of Mr Berman/Clayton nomination to take his place/Rabbitt to DoJ/Carpenito replacing Audrey Strauss/Trump/Barr don't you think? The SEC needs some fixers. Wonder why. I'm cc'ing some our mutual friends on this email Jane. The last overt act of this massive ongoing, SEC facilitated conspiracy has not occurred yet. + +Cheers! + +Christopher J Dilorio + +Wistleblower + +![](_page_45_Picture_5.jpeg) + +Sent: Wednesday, June 10, 2020 2:30 PM + +To + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +Mr Roach, + +The SEC is irrefutably using my information in unethical and illegal manner. My information is being used to BOTH Bring complaints AND obstruct/protect investigations into entities detailed in my various TCR's. Denying me rightful compensation. This is the latest example + +Chris + +From: Chris Dilorio ‹ > + +Sent: Monday, May 18, 2020 10:36 AM + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +As straightforward as it gets: + +The SEC OWB dragged its feet for 5 years in issuing its preliminary denial notice. + +The SEC knows this is my information. The SEC committed fraud on the court in Gibraltar. The judge corrected them. The SEC was omitting information that implicated NITE, UBSS and customers like Sason/Hanover/Magna. The SEC was obstructing a thorough investigation of my claims. The naked shorting cited in the CGFIA 10O in 2013 PROVES my allegations. The SEC's "targeted investigation" stops short of a full accounting. The SEC Gibraltar complaint does NOT explain the totality of the Oppenheimer complaint. The SEC Gibralter complaint cites 1 OTCM shell and less than 1 million shares traded by Opco. 2 dissenting Opco waiver SEC Commissioners proved that also citing "BILLIONS" of shares in their dissent. The SEC/Opco AML complaint was based on the FINRA complaint and my information. The SEC OWB concocted a completely fabricated reason for denying my Award: "The SEC investigators involved never saw claimants information". The responsibility to distribute Whistleblower information within the SEC is the exclusive and explicit responsibility of the OWB. As a result, the massive fraud taking place continued well into 2020. The 1Q2020 10O proves this. + +The SEC IG Hoecker is guilty of violating specific IG requirements in keeping Congress informed of serious matters like mine. The SEC IG Hoecker has never interviewed me despite my filing 2 separate complaints with his office. The SEC IG Hoecker is guilty of criminal obstruction. SEC Chair Clayton and Co Enforcement Peikin worked at Sullivan Cromwell with Jared Fishman. Fishman has played a key role in the SEC facilitated criminal obstruction. Peikin and Clayton should have recused themselves from ANY pending NITE/VIRT matter before the SEC: My information. Clayton and Peikin should have recused themselves from the SEC facilitated KCG/VIRT merger. My information, including the Opco AML complaint SHOULD have stopped the merger from ever happening. 2 former SEC Commissioners agree with that analysis. The SEC is actively facilitating a massive ,ongoing fraud on the American people they are mandated to protect. NITE/VIRT is a criminal entity. The SEC MUST invoke emergency powers and halt trading in VIRT IMMEDIATELY. + +In short Mr Arp, the criminal activity actively perpetrated by the SEC OWB/IG must be referred to law enforcement as well as Congress. Separate but related: SEC facilitated criminal activity and my claims. The criminality is a matter for law enforcement. My pending matters with the SEC have no bearing on a criminal investigation OR a GAO investigation. + +You are incorrect in your analysis. + +Christopher J Dilorio + +Whistleblower + +From: Chris Dilorio + +Sent: Tuesday, May 12, 2020 8:54 AM + +To: 1c > + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +Almost immediately I filed a formal appeal to the SEC OWB fabricated denial of my award application. In this appeal I show irrefutable proof of my allegations: The SEC OWB used/ is using my information to both bring complaints AND obstruct complaints while denying me compensation. In short: My information exposes an ongoing, massive in scope, SEC facilitated fraud on the American people. Rather than shut it down, the SEC has chosen to cover up so that the illegal activity can continue. It does in 2020 + +Chris + +From: Chris Dilorio < + +Sent: Monday, May 11, 2020 7:16 PM + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +From: Chris Dilorio + +Sent: Wednesda , April 29, 2020 8:03 AM + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +The SMOKING GUN in my allegations: + +Naked shorting in CGFIA (My TCR/FINRA complaint) by "un named third party BD" in 2013. Well known to the SEC. This is why there was no investigation into the ENTIRETY of the FINRA trading activity. The SEC issued waivers to Opco within days of its AML complaint. WHO was the SEC protecting? WHO were the customers and executing BD's/MM's in the Opco complaint? ALSO well known to the SEC: + +MY INFORMATION. 5 years to get a preliminary denial: statute of limitations. BUT the last overt act of this ongoing conspiracy has not yet occurred. + +Chris + +From: Chris Dilorio c > + +Sent: Wednesday, April 29, 2020 7:56 AM + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +Still more evidence of a well orchestrated scheme to cover up and obstruct a FULL SEC investigation into Opco/Gibraltar/NITE/UBSS trading activity in billions of shares of OTCM money laundering shells. The SEC used my information to bring AND obstruct complaints. + +The 2 SEC Commissioners dissent in granting Oppenheimer waivers after this egregious activity + +https://www.sec.gov/news/statement/dissenting-statement-oppenheimer-inc.html + +## SEC.gov I Dissenting Statement In the Matter of Oppenheimer & Co., Inc. + +Dissenting Statement In the Matter of Oppenheimer & Co., Inc., by Commissioner Luis A. Aguilar and Commissioner Kara M. Stein, February 4, 2015 + +www.sec.gov + +In fact, the SEC waivers came within days of their complaint. Here, these 2 Commissioners cite Oppenheimer trading "BILLIONS of shares of penny stocks". Clearly, they were not JUST referencing the SEC Gibraltar complaint. WHO was the SEC protecting with its complaint then waivers? + +The smoking gun which I have provided to the SEC on several e mails: + +Which came in an SEC reviewed CGFIA 10O + +https://www.sec.gov/Archives/edgar/data/1344394/000135448814000425/cgfi 10q.htm + +## cgfi\_10q.htm - SEC + +Indicate by check mark whether the registrant (1) has filed all reports required to be filed by Section 13 or 15(d) of the Securities Exchange Act of 1934 during the preceding 12 months (or for such shorter period that the registrant was required to file such reports), and (2) has been subject to such filing requirements for the past 90 days. + +www.sec.gov + +pg 27 + +"Our stock is subject to a "Global Lock" imposed by the Depository Trust and Clearing Corporation (DTCC)" "On September 24, 2013, we were notified that the DTCC would be placing a 'Global Lock" on the Company's Class A stock as a result of actions by a third-party broker dealer. On November 11 2013, DTCC imposed the "Global Lock". Since less than 0.02% of the Company's Class A common stock shares were held within DTCC, Management chose to not undertake the expense of challenging the Global Lock. Nevertheless, shares that are held in street name (CEDE & CO), will not be able to be withdrawn from DTCC without further action." + +Of Course, I have hard copies if you prefer. + +This is CLEAR,IREEFUTABLE,INCONTROVETIBLE evidence of naked shorting by executing BD's in CGFIA. This activity took place per my Knight/UBSS TCR submitted to the SEC. So, WHY did the SEC obstruct an investigation into the ENTIRETY of the trading activity in the FINRA (and FINCEN) complaints? WHO were the executing BD's/MM's? WHO were the customers? + +The veracity of my information is also irrefutable and incontrovertible. + +Game. Set. Match. The SEC is a grossly corrupt, criminal enterprise facilitating illegal activity detailed by me so that this activity can continue. It does in 2020. The SEC solicits then uses Whistleblower information (MINE) to bring complaints AND obstruct other illegal activity while denying proper compensation to whistleblowers (ME). The SEC KNEW who the "third party BD" was in the CGFIA filing long before it filed its Opco complaint in 2015. It had my TCR in its possession in March 2013. So why did it take 5 years for the SEC to issue its preliminary denial? I would remind the SEC that this is very much an ONGOING conspiracy on the part of the SEC et al. IN FURTHERANCE OF THE CONSPIRACY + +Cheers! + +Christopher.' Dilorio + +Whistleblower + +From: Chris Dilorio + +Sent: Tuesday, April 28, 2020 7:24 AM + +Subject: Fw: Formai appeal tor preliminary denial covered action tuft-um/ Knignt Capital ILK & Appendix + +Per my extensive SEC TCR's: Josh Sason/Emanuel/Abitebol/Hanover/Magna extensive overlap with NITE/VIRT (and AQR) money laundering shells. + +The SEC Sason/Magna/NewLead Feb 2019 complaint: also my information + +https://www.sec.gov/litigation/complaints/2019/comp24403.pdf + +Marc P Berger SECURITIES AND EXCHANGE COMMISSION Brookfield Place 200 Vesey Street, Suite 400 New York, NY 10281-1022 SOUTHERN DISTRICT OF NEW YORK JOSHUA SASON, MARC MANUEL, + +3 S. In addition, Pallas acted as an underwriter for a primary offering of NewLead stock, which NewLead attempted to disguise as an asset sale transaction. + +AM. sec goy + +(i) Sole power to vote or to direct the vote . The information required by Item 4(c)(i) is set forth in Row 5 of the cover page for each Reporting Person hereto and is incorporated by reference for each such Reporting Person. + +www.sec.gov + +MG Partners Ltd: Abitebol + +But not in the complaint: MAGNA GIBRALTAR INVESTMENTS LLC: also Abitebol + +As with Opco/GIBRALTAR, who is the SEC protecting? + +AND, per my extensive correspondence with the SEC re my TCR's: The SEC is ALSO grossly under estimating the criminal activity in NITE/Magna/NewLead + +SEC: Criminals bailing out/actively facilitating criminals/criminal activity. + +soliciting/using whistleblower information in unethical/illegal manner to bring complaints/obstruct complaints/deny whistleblower rightful compensation. + +Cheers! + +Christopher Dilorio + +Whistleblower + +From: Chris Dilorio + +Sent: Tuesday, April 28, 2020 6:43 AM + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +More evidence of SEC fraud on the court in Gibraltar. + +It is CLEAR that the Opco AML Covered Action 2015-016 was NOT ENTIRELY based on the SEC Gibraltar Action. The SEC Gibraltar action covered trading activity in just 1 OTCM Money laundering shell: Magnum d'Or where Opco traded less than 1 million shares. CLEARLY the SEC Opco complaint was based on the trading activity in the FINRA Opco AML complaint: my information. However, the SEC Opco complaint even stops short of a thorough investigation of the ENTIRETY of the FINRA trading activity. WHY? WHY didn't the SEC Opco/Gibraltar complaint go into trading activity in the FINRA AML OTCM shells through 2014 as FINCEN did? WHY did the SEC omit MATERIAL information to the court in Gibraltar causing a "significant under estimating" of criminal activity? The SEC knows who the accounts were. The SEC knows who the executing BD's/MM's were. The SEC committed a fraud on the court in Gibraltar. + +Gibraltar was ROLLING OUT NEW OTCM services into the end of 2011. + +https://www.prcom/press-release/355246 + +Gibraltar Global Securities Now Offering Offshore Brokerage Accounts - PR.com + +Nassau, Bahamas, The, September 22, 2011 Gibraltar Global Securities is now offering offshore brokerage accounts in addition to their broad array of financial services.Gibraltar Global ... + +www.pr.com + +https://www.pr.com/press-release/355247 + +#### GGSI Bahamas is Now Offering Pink Sheet Clearance + +Offshore Broker Adds to Buying and Selling Services + +www.pr.com + +https://www.pr.com/press-release/369649 + +### GGSI Bahamas Provides State-of-the-Art Security for OTC PINK Transactions and Communication + +GGSI (Gibraltar Global Securities Inc.) has just announced the release of their latest security measures designed to protect their client's personal data, and to secure electronic communication. + +www.pr.com + +The SEC KNEW the Gibraltar/Opco trading activity went well beyond 2011 YET cut off its investigation at "well into 2010". Thus, KNOWINGLY omitting material information in Gibraltar: FRAUD ON THE COURT. Confirming my allegations of SEC criminal activity in handling my information. WHY? to protect NITE and UBSS. 2 criminal entities bailed out by the SEC. + +Now, the SEC is using the completely fabricated reason for denying my award claim for covered action 2015- 016: "The investigators never saw the claimants information". + +WHEN the explicit and exclusive responsibility to distribute whistleblower information within the SEC falls on the OWB itself. + +More criminal activity. + +Criminals bailing out criminals while denying Whistleblowers due process and compensation. + +Cheers! + +Christopher J Dilorio + +Whistleblower + +From: Chris Dilorio < + +Sent: Sunday, April 26, 2020 9:36 AM + +To: + +Subject: Fw: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +Subject: Formal appeal for preliminary denial covered action 2015-016/ Knight Capital TCR & Appendix + +I am in receipt of the SEC preliminary denial of my award claim for the Oppenheimer AML covered action 2015- 016 + +This is my formal appeal of the SEC preliminary determination. + +My award application was based on this very simple FACT: + +The SEC (and FINCEN) Oppenheimer AML actions were based on the FINRA Oppenheimer AML action + +FINRA + +https://www.finra.org/sites/default/files/fda documents/2009018668801 FDA KMX39652.pdf + +#### of - FINRA + +which isFINRA a party, to the entry of findings and violations consistent with the allegations of the (asComplaint sanctions amended andby the Offer of Settlement), to the imposition of the set forth andbelow, understands fully that this Order will become part ofRespondent's permanent disciplinary andrecord may anybe considered in future actions brought by FINRA. BACKGROUND ... + +www.finra.org + +The SEC + +https://www.sec.gov/litigation/admin/2015/33-9711.pdf + +### Before the SECURITIES AND EXCHANGE COMMISSION + +Before the . SECURITIES AND EXCHANGE COMMISSION . SECURITIES ACT OF 1933 . Release No. 9711 / January 27, 2015 . SECURITIES EXCHANGE ACT O F 1934 . Release No. 74141 / January 27, 2015 . ACCOUNTING AND AUDITING ENFORCEMENT . Release No. 3621 / January 27, 2015 . ADMINISTRATIVE PROCEEDING . File No. 3 -16361 . In the Matter of + +www.sec.gov + +FINCEN + +https://www.fincen.gov/news/news-releases/fincen-fines-oppenheimer-co-inc-20-million-continued-antimoney-laundering + +FinCEN Fines Oppenheimer & Co. Inc. \$20 Million for Continued Anti— Money Laundering Shortfalls I FinCEN.gov + +Washington, D.C. — The Financial Crimes Enforcement Network (FinCEN), working closely with the U.S. Securities and Exchange Commission (SEC), assessed a \$20 million civil money penalty today against Oppenheimer & Co., Inc., for willfully violating the Bank Secrecy Act (BSA). Oppenheimer, a securities broker-dealer in New York, admitted that it failed to establish and implement an adequate ... + +www.fincen.gov + +In the summer of 2012, I had extensive correspondence with Robin Traxler at FINRA where I also cc'd Sean McKessy then SEC OWB Chief. The CURRENT OWB Chief and the SEC IG are in possession of this correspondence. My correspondence dealt with 2 penny stock shells cited in my Knight Capital TCR submitted by Berger Montague in March 2013 attached here: Colorado Goldfields and AppTech. Both shells were NITE and UBSS top traded OTCM shells in 2010-2013. These 2 shells were cited by FINRA in their Oppenheimer AML complaint. Again, the SEC and FINCEN Oppenheimer AML complaints were based on this FINRA complaint. In fact, per the FINRA Opco complaint above, customer "TC" was dumping worthless AppTech (APCX) certificates well into mid 2010. DIRECTLY overlapping with the NITE/UBSS APCX trading activity cited in my Berger 2013 TCR attached and discussed by me with Robin Traxler at FINRA. HOW is it possible that the SEC OWB didn't share my information with SEC investigators? Current SEC OWB Chief Norberg was previously an assistant to then OWB Chief McKessy. + +WHO ultimately executed the trades cited in the FINRA Opco complaint? + +Further, the SEC Gibraltar Securities complaint raises more questions than answers as well. + +https://www.sec.gov/litigation/complaints/2013/comp22683.pdf + +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK SECURITIES AND EXCHANGE COMMISSION, 13 Civ. GffiRALTAR GLOBAL SECURITIES, COMPLAINT NATURE OF THE ACTION - SEC.gov + +12. David Della Sciucca, Jr., age 27, is a resident of Fort Lauderdale, Florida. In . the Magnum d'Or complaint, the Commission charged Della Sciucca with acting as a nominee + +www sec g ov + +The SEC Gibraltar Securities complaint references only 1 OTCM money laundering shell: Magnum d'Or. The complaint specifically states that Oppenheimer sold just 969,822 shares. Again, no mention of executing BD/MM. + +The SEC Oppenheimer AML cites Gibraltar trading activity also. + +The share amounts in the SEC complaint grossly under estimate that in the FINRA complaint. WHY? + +The judge in the Gibraltar case said "the SEC's requested amount CLEARLY UNDERESTIMATES the defendants illgotten gains...." + +http://www.tribune242.com/news/2016/jan/13/bahamian-broker-25m-sanction/ + +A former Bahamian broker/dealer and its principal have been hit with a combined \$24.484 million in financial sanctions by a US court, which found that their "ill gotten gains" were likely ... + +www.tribune242.com + +WHY didn't the SEC go after ALL of the sellers in the FINRA Opco AML complaint? WHY did the SEC "strip out" \$46 million from the Gibraltar ill gotten gains claiming the customers were "UNKNOWN"? WHO is the SEC protecting? WHO were the executing BD's/MM's in the FINRA Opco CGFIA and APCX trades? They certainly know who the customers were. Is customer "JK" Justin Keener/JMJ also in my March 2013 TCR attached? While the SEC Opco AML was based on the FINRA Opco AML, it stopped short of a thorough investigation of NITE and UBSS. In fact, the trading activity of NITE/VIRT and UBSS in the FINRA complaint: my information SHOULD have triggered an immediate investigation of NITE and UBSS. It did not. Did the SEC commit fraud on the court in its OMISSION of material information? + +The timing of the SEC's preliminary determination and the reasoning for the denial ALSO raises more questions than answers. + +My Award application for the Oppenheimer AML SEC complaint was 5 years ago. That's FIVE years ago. So, WHY NOW am I so blessed by the SEC with a preliminary judgement? + +The SEC basis for denying my Award claim for covered action 2015-016: + +"Investigative staff responsible for the covered action NEVER RECEIVED ANY INFORMATION FROM THE CLAIMANT OR had any communication with the claimant" + +Let's take this whopper in 2 parts: + +First, the SEC OWB denied my Award application because The investigators in the complaint never received my information. Has the SEC OWB re written the investigative protocol in this denial? How am I or ANY whistleblower supposed to know WHO the investigators are in a particular case WHEN according to the SEC: ALL investigations are done in a confidential manner???? + +WHAT DOES THE SEC DO WITH WHISTLEBLOWER TIPS EXACTLY? Do they share whistleblower information with ENFORCEMENT as is mandated? HOW would ANY whistleblower know WHO to share information with at the SEC? Isn't that the job of the SEC OWB? + +Second, the fact that no one at the SEC contacted me DOES NOT mean the SEC didn't use my information. This is a completely bogus argument. It certainly would NOT be the first time the SEC used my information now would it Jane? + +In fact, it is NOT the responsibility of the whistleblower to get his/her information to the right Enforcement personnel. That responsibility EXPLICITLY falls on the SEC OWB. So, is the SEC OWB admitting gross negligence in handling my information? After the monumental failure in the Madoff Ponzi/ money laundering SEC facilitated scam on the public the then SEC IG made specific recommendations to the SEC with regards to the proper handling/vetting of Tips and Complaints. + +https://www.sec.gov/files/468.pdf + +Review and Analysis of OCIE Examinations of Bernard L. Madoff Investment Securities, LLC + +AGAIN: The responsibility to properly vet Whistleblower information and get the information into the right hands at the SEC falls EXPLICITLY and EXCLUSIVELY with the SEC OWB itself and is NOT the responsibility of the whistleblower. Further, according to the previous SEC IG in the monumental Madoff failure: the responsibility to contact those supplying Tips and Complaints ALSO falls explicitly and exclusively with the SEC OWB and not the whistleblower. Using these excuses as the basis of denial of Award is completely contrary to SEC MANDATED protocols and procedures. + +Is the SEC OWB admitting it doesn't comply with those recommendations? Recall: the monumental SEC Madoff failure was NOT the fault of Whistleblowers either. OR is the SEC OWB scrambling for a 5 years in the waiting preliminary determination? + +So, after 5 years of waiting for a preliminary determination for my award claim, this is what the SEC best and brightest come up with? + +My Denial of Award for covered action 2015-016 was completely made up on the fly. + +The SEC OWB has applied completely fabricated "rules" to issue this denial. Further affirmation of ALL of my allegations. + +Also by SEC admission, the SEC allowed these 2 penny stock shells to remain a clear and present risk to the investing public. Were CGFIA and APCX ONLY money laundering shells for Oppenheimer in 2008-2010 and then suddenly they were no longer money laundering shells when NITE and UBSS traded billions of shares of both shells 2010-2013? + +WHY did it take until September 2018 before the SEC finally revoked the CGFIA registration? + +https://www.sec.gov/cgi-bin/browse-edgar?company=Garpa&owner=exclude&action=getcompany + +So, WHY was there no SEC investigation of NITE and UBSS trading activity in money laundering shells APCX and CGFIA? The SEC et al facilitated NITE "glitch" took place in August 2012. This SEC/Jefferies/JPM/BX/GS/SEC Chair Clayton Sullivan Cromwell colleague Jared Fishman et al bailout coincides directly with NITE trading activity in 2 SEC/FINRA/FINCEN acknowledged money laundering shells. AND the "bailout" penny stock esque reverse merger between Getco and Knight didn't close until July 2013. HOW could the SEC conduct a COMPLETE and thorough investigation into the FINRA Opco AML complaint WITHOUT implicating NITE when NITE was CLEARLY trading billions of shares of OTCM money laundering shells BEFORE and coinciding with the SEC et al facilitated "glitch" bailout? For UBSS, the DOJ dropped its cross border AML DPA complaint in 2010. UBSS was trading money laundering shells well after the Dal claimed UBSS was in compliance with the cross border DPA. To be clear: BOTH NITE and UBSS knew CGFIA and APCX were money laundering shells when they traded billions of shares of each 2010-2013. Is that FACT disputed by the SEC? The SEC OBSTRUCTED a thorough investigation into the ENTIRETY of trading activity of NITE and UBSS in CGFIA and APCX: MY CLAIMS. Josh Sason/Hanover/ Magna knew CGFIA was a money laundering shell also + +https://www.sec.gov/Archives/edgar/data/1344394/000114420413041432/0001144204-13-041432-index.htm ALSO in my claims: Joshua Sason/Hanover Magna. CGFIA. Also my NewLead TCR1426518350699 and FreeSeas TCR1440274395191 separate but related TCR's where NITE was a top trader in both and BOTH TCR's were filed well in advance (years prior) to the Sason/Hanover/Magna February 2019 complaint. Here's one thing the SEC has been consistent about: The SEC ignores the role of executing BD's and MM's in these scams. WHY? Because NITE is the #1 OTCM shell trader. As far as the SEC is concerned Penny stock trading fairies convert worthless certificates into real money. NO! Executing BD's/MM's like NITE do. Did Oppenheimer sell this order flow to NITE? Who ultimately converted these worthless certificates to real money? As the number 1 OTCM money laundering shell trader it is statistically improbable the NITE has never been the focus of an SEC AML complaint. Per my TCR: what does the NITE Compliance Department do exactly? How many SAR's has NITE filed in the last 10 years? In a 2015 SIFMA speech then SEC Enforcement Director Ceresney was "SHOCKED" by the number of BD's filing 1 or ZERO SAR's. That was just 5 years ago. WHEN would NITE file a SAR releted to the billions of shares of OTCM money laundering shells it trades like CGFIA and APCX: BEFORE or AFTER it trades those BILLIONS of shares?Does NITE pull markets and alert regulators OR continue to trade billions of shares of OTCM money laundering shells in the face of GLARING AML red flags? In fact, in December 2019 the top traded NITE/VIRT OTCM money laundering shell was ELTZ + +https://www.sec.gov/cgi-bin/browse-edgar? + +action=getcompany&CIK=0001607281&owner=exclude&count=40&hidefilings=0 + +The SEC knows the people/entities in ELTZ well + +https://www.sec.gov/litigation/admin/34-46993.htm + +### Strata Coal Company and Terrence A. Tecco: Admin. Proc. Rel. No. 34- 46993 / December 13, 2002 + +Strata Coal Company ("Strata" or "the company") is a non-reporting Nevada shell corporation based in Frisco, Texas. Strata's shares are quoted on the Pink Sheets under the symbol SCOC. Until September 2002, the company was known as WesPac Technologies, at which time it changed its name to Strata. 2. Tecco is the sole officer, director, and ... + +www.sec.gov + +https://www.sec.govinews/press-release/2019-16 + +## SEC.gov I SEC Charges Broker-Dealer and Transfer Agent in Microcap Shell Factory Fraud + +The Securities and Exchange Commission today announced charges against a broker-dealer, a transfer agent, and three individuals for their roles in the creation of over a dozen undisclosed "blank check" companies from 2009 to 2014. + +www.sec gov + +Doesn't the NITE/VIRT compliance Department have internet service in Jersey City? As a DIRECT result of the SEC obstructing a complete and thorough investigation into the ENTIRETY of trading activity in APCX and CGFIA, the top NITE/VIRT traded OTCM money laundering shell in December 2019 was AML red flags galore ELTZ. Illegal activity ACTIVELY facilitated by the SEC. The examples cited in this e mail are not exhaustive. + +And, for it's part AppTech is up and running again/still + +https://www.sec.gov/cgi-bin/browse-edgar?company=Apptech&owner=exclude&action=getcompany + +Unfortunately, AppTech is still up and running as a direct result of the aforementioned SEC " CLEARLY under estimating" otherwise known as CLEARLY OBSTRUCTING. + +In conclusion, The SEC solicits information from whistleblowers like me. The SEC uses whistleblower information to bring actions and then doesn't compensate whistleblowers for their information. + +OR + +The SEC uses whistleblower information to protect criminality perpetrated on the investing public so that this criminal activity can continue. BOTH are gross dereliction of the stated and MANDATED SEC Whistleblower statutes. To blame a whistleblower for the SEC's EXPLICIT and EXCLUSIVE responsibility to properly vet and distribute whistleblower information within the SEC as an excuse to deny Awards is also criminal activity. The SEC: criminals using whistleblower information to protect other criminals AND deny whistleblower rightful compensation for their information. + +I appeal the SEC preliminary determination and wish to file ANOTHER complaint with the SEC IG. + +Cheers! + +Christopher J Dilorio + +Janey, + +how long have you been in possession of my Knight Capital TCR? Almost 7 years to the day. How many follow up e mails have I sent the SEC since then? + +For 7 fucking years, the SEC has known about JMJ/Keener. I told them + +https://www.sec.gov/litigation/complaints/2020/comp-pr2020-72.pdf + +## IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORIDA SECURITIES AND EXCHANGE COMMISSION No. COMPLAINT SUMMARY - sec.gov + +5. Justin W. Keener, age 45, resides in San Juan, Puerto Rico.During the Relevant Period, Keener was a resident of Miami Beach, Florida. Keener registered the name "JMJ Financial" as a fictitious name in Florida in 2008 and used it to conduct the business described + +veww sec g ov + +In February 2019, the SEC brought an action against Joshua Sason/NewLead + +I told the SEC about Magna/ Sason ALSO in my 2013 TCR. + +https://www.sec.gov/litigation/litreleases/2019/Ir24403.htm + +Joshua Sason, et al. (Release No. LR-24403; Feb. 15, 2019) + +Washington, D.C., February 15, 2019 - The Securities and Exchange Commission today announced charges against four individuals and related businesses for their roles in two microcap frauds and unlawful securities offerings. + +Then there's the UBS AML complaint. + +ALSO my claims. For which I sent 10 (TEN) separate Award applications from a commercial fax machine in + +April/May 2019. AND I have YET to receive even a preliminary determination from the OWB/Norberg + +IG, I see your "investigation" into my very very serious accusations of Obstruction related to my information was thorough. In short, the SEC has and still is ripping me off. + +Janey, be a hun and update my TCR's/Awards cited in this e mail. + +And Ms Welshhans, a couple of questions for you: + +1) Have you read the FINRA WTFC Keener complaint? Fictitious notes Ring a bell? + +Same MO as Sason/Magna/NewLead/FreeSeas etc etc etc + +2) WHO executed the Keener OTCM trades in your complaint? Penny stock trading fairies? + +YES, NITE was a top trader in BOTH FreeSeas and NewLead + +The core business at NITE/VIRT is and ALWAYS has been: abusive naked shorting OTCM (and other) shells to facilitate money laundering. + +In short Ms Welshhans, NITE/VIRT converts these worthless certs into real money. NONE of + +JMJ/Sason/IBC/Ironridge/Asher etc etc etc activity takes place without a willing,corrupt, criminal, executing BD/MM like NITE/VIRT, CDEL etc + +Finally, The Keener SEC complaint is FURTHER evidence that FINRA has NO business enforcing US securities + +LAWS. When FINRA "invited" Keener to a disciplinary hearing almost 7 years ago, Keener told them to "fuck off". FINRA bar meant nothing the last 7 years. EXCEPT JMJ/Keener/NITE ripping off more investors. + +Obviously the SEC has/is using my information. I expect to be compensated. + +Cheers! + +Christopher Dilorio + +Whistleblower + +Mr Peirce, + +Congratulations on your nomination as SEC Commissioner. I have read your paper on FINRA lack of accountability. I believe the SEC has abdicated its responsibility to enforce Broker Dealer compliance with the BSA to FINRA BECAUSE it is not accountable. The SEC has not initiated a single stand alone AML complaint. The Brown Brothers Harriman AML complaint IS my claim. ALL of the entities in the complaint are un named WHY? My SEC and IRS Whistleblower complaints explain why. + +Hello, My name is Chris Dilorio. I have filed extensive SEC and IRS Whistleblower complaints alleging a direct link between penny stock money laundering, domestic and foreign entities, Swiss Banks, and executing brokers like KCG and UBS. I can provide overwhelming evidence of SEC obstruction. Please read the FINRA Brown Brothers Harriman AML complaint. This is my claim. All of the entities in the complaint are un named. Why? + +The SEC is not only obstructing an investigation, they are aiding and abetting the activity. These are not far flung theories. The UBS Whistleblower Birkenfeld and his attorney sent 52,000 accounts to the SEC and DOJ. The DOJ at the influence of President Obama and Hillary Clinton entered into the UBS DPA based on just 4400. + +What is so egregious is the activity continues un abated today. + +Start with the so calledAugust 2012 Knight/KCG trading "glitch". Initial reports say the NYSE was breaking the trades. WHY did they stop. Former KCG CEO Joyce said he had a very frank discussion with then SEC Chair Schapiro where the SEC wanted to send a very strong message to market participants. Why not just continue to + +break the trades and hit KCG with a hefty fine? That would not create the conditions to grant KCG exception after exception to do their emergency funding which transferred 74% of the company to "glitch" funding participants and ultimate reverse merger partner GETCO. AND, despite claiming to having a "highly liquid balance sheet" KCG had to raise the entire amount of the loss. + +A very significant and public event was cited in a WSJ article where immediately following the "glitch"KCG inadvertently sent 4000 worthless securities to JPM in an attempt to secure a tri party financing where JPM guaranteed the loan. This is discussed in my attached TCR's and also the topic in a March 2014 letter I sent to the SEC. In the end, the emergency funding was NOT collateral based. The participants knew exactly what a fraud the KCG balance sheet was. After the stock was decimated to \$3, the deal was a convertible with a conversion price at a 50% discount or \$1.50/ share. + +There is much more, but this is a good start. + +Recently, KCG did a modified Dutch auction where they "sold" an asset (HotSpot) to an entity both KCG and GETCO were a major shareholder (BATS) KCG CEO Coleman called it a "highly competitive process". + +Virtually all of the proceeds went to buy back stock from "glitch" financing participants. The purchase price was \$14/share. The stock had never traded there and hasn't since. Reports say 82 million shares were tendered at or BELOW \$14. But they chose to repurchase 23 million shares AT \$1499" 9 I have overwhelming evidence that supports my allegations that the SEC is engaging in criminal obstruction to protect KCG. + +I) Current KCG Dan Coleman ran Equities at UBS during the massive REG Sho violations as well as the cross border activity detailed by Whistleblower Birkenfeld. White and Ceresney represented UBS prior to joining the SEC + +2) At June 30 2011 KCG/Knight reported just 105 million in working capital with hundreds of millions in worthless securities sitting on its balance sheet. KCG was insolvent + +3) The SEC orchestrated the emergency funding for KCG following the so called Aug 2012 trading "glitch" + +4) Read FINRA AML complaints against Brown Brothers Harriman. This is my claim. It links penny stock money laundering to executing brokers like KCG, domestic and foreign entities, and Swiss banks. ALL of the entities in the complaint are un named. WHY? + +5) The FINRA World Trade Financial AML complaint discusses several entities cited in my claims. The customer the complaint focuses on is Justin Keener. Still very much in business. The red flags cited by FINRA were cited in my claims as well. Yet still no investigation. + +6) in July 2015 I contacted Kevin Goodman Dir OCIE for Broker Dealrsat the SEC. He had never seen my information. The IG OCIE Madoff report mandated the OCIE to vet information. McKessy and Ceresney never sent my info to him + +7) I'm sure you are familiar with the Manning v Merrill,KCG,UBS et al litigation. The SEC does not want an investigation into my claims while the litigation is pending. + +8) My claims detail ex clearing trading activity by KCG and UBS. despite the glaring red flags in doing so. Ex clearing s the Obligation Warehouse. A NON GUARANTEED SERVICE set up by the SEC and DTCC to allow firms like KCG to circumvent close out requirements of Rule 204. Clearly contrary to the intent of the SEC authorization in Sec I7a of the 1934 Act to create a system of prompt and timely settlement and to remove impediments there of. + +In short, I told the SEC KCG was insolvent in 2011. Rather than investigate and prosecute, they chose to obstruct. The activity in my TCR's pre dates the "glitch". An investigation would show the SEC bailed out a criminal enterprise. Because of the obstruction, the activity continues today unabated in stocks like STBV,VELA,NEWL,FREE, and dozens more. 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b/marker2/ds9/EFTA00090416/EFTA00090416.md @@ -0,0 +1,154 @@ +![](_page_0_Picture_55.jpeg) + +33 + +# Interlochen Arts Camp Application for Admission + +### Instructions + +Please answer all questions below. Refer to the "Admissions" section of the Camp Schedule (page 1) for complete application and financial aid information. The application deadline for first priority review is **February 15**. Applications made after this date are welcome but will be reviewed on a rolling admission basis. **Send all materials to:** Admissions Office, Interlochen Arts Camp, P.O. Box 199, Interlochen, MI 49642-61199. Complete address and phone information are on the back of this form. **Sorry, but we cannot process your application without the following materials:** + +### Application Checklist + +- Completed Application and Class Selection Form +- Application Form Signatures +- Audition materials enclosed if replaced (see audition requirements in the Camp Schedule) +- Tex forms of applying for financial aid + +### Camp Application Fee + +Please enclose the required \$35. with your application. Make check payable to "Interlochen Arts Camp." If you wish, you may charge the application fee to VISA, MasterCard, Discover or American Express. + +Credit Card Name and Number Credition Date Print Card Holder Name Card Holder Signature + +![](_page_0_Picture_66.jpeg) + +![](_page_0_Picture_67.jpeg) + +3-3-98 + +### Signatures + +We cannot process your application without signatures. + +Applicant Signature Date +I have answered the questions on this application to the best of my ability and believe my answers are true and correct. + +### Parent/Guardian Signature + +I have read this application and the responses are true and correct to the best of my knowledge. I support the student's application to the Interlochen Arts Camp. + +### Applicant Information + +What division are you applying for? + +- High School +- Advanced String Quarter Institute (Session A - High School Only) +- Creative, Writing Institute (Session B - High School Only) + + Teacher Session A Intermediate Session A Intermediate Session B If my first session choice is full, I would be interested in an alternative session. + +![](_page_0_Picture_76.jpeg) + +![](_page_0_Picture_77.jpeg) + +International students: When providing telephone number, include the country code before the local telephone number. + +Age Sex of Birth Birth Date (month/day/year) + +Nickname (If any) Applicant Social Security Number + Yes No Have you previously attended Interlochen Arts Camp (excluding All-State)? Write years attended: 1997 + +How did you first learn about Interlochen? from South African Society of Music Teachers + +Optional: Applicant please indicate: Asian American African American Mexican American Pacific Region Asian + Native American Cucusian Other, please specify: + +### Citizenship Information + +If you are not a U.S. Citizen, please complete this section. + +South Africa Country of Birth South Africa + +![](_page_0_Picture_86.jpeg) + +Home Telephone: Area Code + Number + +Fax Number: Area Code + Number + +### Teacher Information + +Name of Brevery Institute in your city area Title/Profition Bornal Address + +City State Zip Home Telephone: Area Code + Number Fax Number: Area Code + Number Office Telephone: Area Code + Number + +Sex/Age Audition Internal Use Cello + +R to R + +Parent or Guardian Information + +![](_page_1_Picture_30.jpeg) + + Does the student have a physical health problem of which the Arts Camp should be award? NO + + Has the student consulted with or been referred to a psychiatrist, psychologist or mental health therapist for predisposing assessment within the past two years? NO + +Financial Aid Information + +Emerson Electric Co. Scholarship + +Note: Applications for the Emerson Electric Co. Scholars program must be postmarked by January 12, 1998. + +The Emerson Electric Co. Scholars program provides full aution grants for one student from each state, the District of Columbia and Puerto Rico. Students currently in grades 9-12 with a high proficiency in any of the following instruments any apply: violin, viela, cello, buss, wint and percussion instruments or harp. Please see page 7 of the Camp Schedule for the suggested repairoire flat for an Emerson Electric Co. Scholars audition. + +SCHOLARSHIP FROM J. EPSTEIN + G. MAXWELL +No you applying for the Emerson Electric Co. Scholars program? Yes No I have enclosed the required audition materials. + +If not an Emerson Electric Co. Scholars winner would you still like to apply to the Arts Camp? Yes No + +If you are not an Emerson Electric Co. Scholars winner and would like to be considered for financial aid for the Arts Camp, please fill out the financial information below and attach a copy of your most recent 1040 Federal Tax Form. + +Are you applying for financial aid? Yes No I have enclosed the required audition materials. Does the student applying expect to be the receipient of any funds (scholarship, grant, award or prize) from any country, state, organization or individual specifically for attendance at the Interstudent Arts Camp? Yes No + +If yes, name the title of award and amount. What is the dollar amount applicant and fill or not frankly out provide award the Camp station. + +Earnings last year + +Value of net status + +Earnings last year + +Value of net status + +Please now universal expenses or circumstances you would like taken into consideration (select additional sheet if necessary). + +Please attach a copy of your most recent Federal Tax Form 1040 to this form + +Choosing Your Classes + +The information below must be completed in order to process your application. + +All Juniors (grades 5-9) are attended based on the date of their completed application and the enrollment needs of the Camp. Juniors do not need to audition enclose applying for financial aid. Intermediate (grades 6-9) and High School (grades 9-12) applicants must apply for audition-based or non-audition-based majors. The remainder of their schedules should be filled with non-audition-based major classes. Students selecting audition-based majors are attended based on their level of ability and the enrollment needs of the camp. Those selecting non-audition-based majors are attended based on the date of their completed application and the enrollment needs of the Camp. The applicant post is competitive and finished space is available therefore your early application is strongly recommended. Please note: very few spaces are available for the non-audition-based general arts major in the Intermediate division. + +Audition-Based and Non-Audition-Based Majors + +Intermediate Please enter the Class Code from the Camp Schedule (i.e. DMODN or CLARB) + +Please refer to the "Intermediate Division" section in the Camp Schedule for a complete discussion of classes, scheduling, prerequisites and audition requirements. Please fulfill audition requirements for each audition-based major entered below. + + If not admitted for the following major classes, please consider my admission for non-audition-based major classes only. + +- 1. Session A: first choice major class code/instrument +- 2. Session B: first choice major class code/instrument +- 3. Session B: first choice major class code/instrument + +High School Please enter the Class Code from the Camp Schedule (ie TMUCI or VIOLO) + +Please refer to the "High School Transient" section in the Camp Schedule for a complete discussion of classes, scheduling, prerequisites and audition requirements. Please fulfill audition requirements for each audition-based major entered below. + + If not admitted for the following major classes, please consider my admission for non-audition-based major classes only. + +- 1. ORCHESTRA (O) First choice major class code +- 2. Alternate choice major class code +- 3. 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+| ELECTRONICALLY FILED | +| DOC #: | +| DATE FILED: 10/22/21 | + +20-CR-330 (AJN) + +ORDER + +ALISON J. NATHAN, District Judge: + +As discussed at yesterday's conference, attached is the Court's draft preliminary remarks to be recorded and played before each questionnaire session. The parties may suggest any proposed edits by letter on or before October 26, 2021, or they shall indicate by that date that they have no objections or suggestions. + +SO ORDERED. + +Dated: October 22, 2021 +New York, New York + +![]()ALISON J. NATHAN +United States District Judge + +United States v. Maxwell, 20cr330 + +Preliminary Remarks Prior to Questionnaire + +To be video recorded and played on 11/4, 11/5, and 11/12 + +Hello everyone. Thank you so much for being here. And welcome to the Southern District of New York. My name is Judge Alison Nathan and I am the judge who will preside over the trial for which you have been summoned. I have recorded this message to you because you are spread out in different rooms and over different times as part of the District's COVID safety protocols. I look forward to seeing you in person as this process moves forward. + +We are about to start the process of selecting a jury to try a criminal case. I'm going to briefly describe the process to you as it may be different than what some of you have previously experienced when summoned for jury duty. + +The first part of the process is going to occur now. In a few minutes, after you've been sworn to tell the truth, you will fill out a questionnaire. The purpose of the questionnaire is for you to provide information to myself, to the prosecutors, to defense counsel, and to the defendant to assist all of us in determining whether you can be a fair and impartial juror in this case. + +When you are done filling out the questionnaire, you will return it to the Jury Department staff and you will be done for the day. Some of you will be asked to return for a phase two, which will involve in-person questioning by me. That is going to start on November 16. So you are free of jury service with respect to this case from whenever you finish the questionnaire until at least November 16. Some of those who are going to return will come in on November 16, some will come on November I7'h, and possibly there will be one or two more days. You will get instructions before you leave here today about how you will find out whether you are going + +to have to come back at all for the in-person questioning in this case and exactly what date and time you would be obliged to be here. + +Once that in-person questioning is completed, some of that group will be asked to return for the last step in the July selection, and some of that last group will be selected to serve on the jury. + +The trial in this case will begin on November 29 and we expect it to last approximately six weeks. We will of course not sit on federal holidays, including Christmas Eve and Christmas and New Year's Eve and New Year's Day. The questionnaire will explain the estimated schedule more fully and you will get to that in a moment. + +But first, I want to tell you a little bit about the case. As I mentioned, this is a criminal case. The charges against the Defendant are set forth in an indictment. An indictment is a formal method of accusing someone of a crime. It is not evidence of any kind. It is the Government's burden at trial to establish a defendant's guilt beyond a reasonable doubt. + +This case is brought by the United States Attorney's Office for the Southern District of New York against Ghislaine Maxwell. The indictment against Ms. Maxwell alleges that she conspired with and aided and abetted Jeffrey Epstein to entice minor females to travel to engage in criminal sexual activity, to transport minors to engage in criminal sexual activity, and to engage in sex trafficking of a minor. Ms. Maxwell has pled not guilty to all charges. Ms. Maxwell is presumed innocent, and before she can be found guilty on any charge, the jury must find that the Government has proven each element of that crime beyond a reasonable doubt. + +Now, as some of you may have already figured out, there is going to be significant press coverage of this trial. Some of you may have already heard about this case in the media, and that is OK. But from this moment on, I instruct you that you are not to read or watch or listen to + +anything that has anything at all to do with this case or anyone involved in the case. You are not to discuss this case among yourselves, you are not to discuss it with anyone, including your family, friends, anyone. You may say that you are part of the jury selection process in a criminal case in federal court, but that is all you may say. Moreover, you are not to do any research through any means about the case or anyone involved in it. That includes the defendant, it includes the judge, it includes the lawyers, and it includes any other names you hear about today. And it means, among other things, that you are not to chatter about it on Facebook, Twitter, Instagram, Tiktok, Snapchat, or any other social media services. You are not to read anything about it online or in the paper. You are not to watch or listen to anything about it on television, the radio, or on podcasts. You are not to do a Google search or any other kind of search. You may not do any of that and that is very important. As I am sure you understand, we must ensure that we have a jury of citizens who will decide the issues in this case based only on the evidence that is presented in court during the trial. + +Because this is a high-profile case AND because we are still in the age of COVID, I want to assure you that the Court will take a number of steps to protect your privacy and safety. First, when you are filling out the questionnaire and as we go through the later stages of the process, I ask that you please not identify yourself by your name or identify anyone you are associated with by name. Throughout the selection process and if you are selected as a juror, although the lawyers and I will know your names, we will only refer to you in Court by your juror number. This will protect your privacy. + +Second, due to COVID and to ensure easy access into and out of the Courthouse, the Court will arrange and provide transportation for selected jurors to and from the Courthouse every day of trial. + +And third, for those of you who are selected, we will provide breakfast, lunch, and snacks as well as places in the Courthouse where you can eat while maintaining adequate distance from each other while doing so. We also have all kinds of measures in place to assure safe distancing and air filtration in the Courtroom. And of course, everyone is required to wear masks. + +Ok, I will end here with a few points about how to fill out the questionnaire and then I will leave you to it. First, read all of the directions in the questionnaire. Second, please enter your juror number on the front page of the questionnaire and at the top of each page. Where indicated, please check the space for yes or no or unsure and, as requested, provide answers, explanations or details on the lines provided. + +Please answer every question. If you don't understand a question, please write, I don't understand. If you don't know the answer to a question, write I don't know. Please do not write on the back of any page. There are pages at the end for extra space if you need it. + +Please don't leave the room while you are completing the questionnaire. If you need to use the restroom, please hand the questionnaire to one of the members of the Jury Department staff, follow their directions, and retrieve it upon your return. + +Please do not discuss the questions or your answers with anyone, including your fellow prospective jurors. + +Ladies and gentlemen, thank you for your service. Jury trials are part of the bedrock of American democracy. Citizen jurors, not judges, decide the outcome of criminal and civil disputes. This right to trial by jury is enshrined in the Sixth and Seventh Amendments to our Constitution. + +Each of you have responded to the call to serve. Doing so will involve some inconvenience and hardship. But by your willingness to serve, by your truthful answers to the questions posed to you, and by your careful following of the rules and instructions I have provided, you are doing your part to support the cherished American institution of trial by jury. + +Thank you. \ No newline at end of file diff --git a/marker2/ds9/EFTA00090418/EFTA00090418.metadata.json b/marker2/ds9/EFTA00090418/EFTA00090418.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..f2c727d90377526f9ec65088df0b3a4a57b48cbd --- /dev/null +++ b/marker2/ds9/EFTA00090418/EFTA00090418.metadata.json @@ -0,0 +1,268 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090418.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 6, + "chars": 8635, + "elapsed_seconds": 4.66, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 71.28 + ], + [ + 280.296, + 71.28 + ], + [ + 280.296, + 98.01 + ], + [ + 68.544, + 98.01 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 51 + ], + [ + "Line", + 26 + ], + [ + "Text", + 22 + ], + [ + "PageFooter", + 4 + ], + [ + "PageHeader", + 2 + ], + [ + "SectionHeader", + 2 + ], + [ + "Caption", + 2 + ], + [ + "Picture", + 1 + ], + [ + "Form", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 49 + ], + [ + "Line", + 25 + ], + [ + "Text", + 7 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 51 + ], + [ + "Line", + 26 + ], + [ + "Text", + 6 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 3, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 51 + ], + [ + "Line", + 26 + ], + [ + "Text", + 3 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 4, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 51 + ], + [ + "Line", + 26 + ], + [ + "Text", + 7 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 5, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 11 + ], + [ + "Line", + 6 + ], + [ + "Text", + 2 + ], + [ + "PageFooter", + 2 + ], + [ + "PageHeader", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00090418" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00090424/EFTA00090424.md b/marker2/ds9/EFTA00090424/EFTA00090424.md new file mode 100644 index 0000000000000000000000000000000000000000..293c87ca7db9724246f07a8586bdf5e7949f4901 --- /dev/null +++ b/marker2/ds9/EFTA00090424/EFTA00090424.md @@ -0,0 +1,39 @@ +![](_page_0_Picture_0.jpeg) + +United States Attorney Southern District of New York + +The Silvio J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 + +October 25, 2021 + +## BY ELECTRONIC MAIL + +Christian Everdell, Esq. Cohen & Gresser LLP 800 Third Avenue New York, NY 10022 + +Laura Menninger, Esq. Jeffrey Pagliuca, Esq. Haddon, Morgan and Foreman, P.C. 150 East Tenth Avenue Denver, CO 80203 + +Bobbi Stemheim, Esq. Law Offices of Bobbi C. Stemheim 33 West 19th Street-4th Fl. New York, NY 10007 + +Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) + +Dear Counsel: + +Today the Government is producing additional materials, including Jencks Act and Giglio material, regarding witnesses who may be called to testify at trial in the above-referenced case. Enclosed please find an index detailing the materials included in today's production. + +The Government is also producing today certain materials relating to individuals the Government does not currently intend to call as witnesses at trial in the above-referenced case. These materials do not contain a comprehensive set of Jencks Act and Giglio materials, as the Government does not expect to call these individuals to testify at trial. Instead, these materials contain, among other things, certain witness statements. Enclosed please find an index detailing these materials. Please note that the records stamped 3501.507 through 3501.516 were previously produced to you on October 11, 2021 with a different stamp (3501.450 through 3501.459), which was inadvertently used for two sets of witnesses. The Government is reproducing the materials to avoid any confusion. This production should not be taken to indicate that the Government believes it has any obligation to provide all of these materials; rather, we make this production as a courtesy. Moreover, although the Government presently does not intend to call the individuals listed in the + +enclosed index, we reserve the right to do so and will notify you should the Government determine that it intends to call any of these individuals at trial. + +Please note that this letter, the enclosed indices, and the enclosed materials are governed by the July 31, 2020 Protective Order in this case. In particular, certain materials are designated as "confidential" under the Protective Order. The index is itself designated as "confidential," because it includes information regarding records designated as "confidential" under the Protective Order. The Department of Justice directed this office to cease the dissemination of materials marked with the word "confidential" in order to avoid potential confusion with markings reserved for classified documents. Accordingly, in order to note the appropriate designation of this production under the operative Protective Order in this case, the materials being produced today are marked with the following label: "SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17." This marking directly refers to the specific paragraphs of the Protective Order that govern today's production. + +Additionally, please note that many of the individuals referenced in this production are represented by counsel, as detailed in the enclosed indices. The Government reserves its right to amend and supplement these disclosures. + +Very truly yours, + +DAMIAN WILLIAMS United States Attorney + +by: s/ + +![](_page_1_Picture_7.jpeg) + +Assistant United States Attorneys \ No newline at end of file diff --git a/marker2/ds9/EFTA00090424/EFTA00090424.metadata.json b/marker2/ds9/EFTA00090424/EFTA00090424.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..c5b7390656adca5539f3e5e693b28112efb2b5bb --- /dev/null +++ b/marker2/ds9/EFTA00090424/EFTA00090424.metadata.json @@ -0,0 +1,158 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090424.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 3410, + "elapsed_seconds": 0.75, + "image_assets": [ + "_page_0_Picture_0.jpeg", + "_page_1_Picture_7.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "U.S. Department of Justice", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 318.24, + 25.92 + ], + [ + 464.0820617675781, + 25.92 + ], + [ + 464.0820617675781, + 40.5 + ], + [ + 318.24, + 40.5 + ] + ] + }, + { + "title": "BY ELECTRONIC MAIL", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 182.9815673828125 + ], + [ + 211.1153564453125, + 182.9815673828125 + ], + [ + 211.1153564453125, + 196.4830322265625 + ], + [ + 68.544, + 196.4830322265625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 75 + ], + [ + "Line", + 38 + ], + [ + "Text", + 10 + ], + [ + "SectionHeader", + 2 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 45 + ], + [ + "Line", + 23 + ], + [ + "Text", + 6 + ], + [ + "PageHeader", + 1 + ], + [ + "Picture", + 1 + ], + [ + "Caption", + 1 + ], + [ + "PageFooter", + 1 + ], + [ + "PictureGroup", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00090424" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00090424/_page_0_Picture_0.jpeg b/marker2/ds9/EFTA00090424/_page_0_Picture_0.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..e1ab81c5ede12985114bf62c106ded0d8907db72 --- /dev/null +++ b/marker2/ds9/EFTA00090424/_page_0_Picture_0.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:e50712d66fc77b4128a27d355bfff492cbd82a6baeae4e02d0455e69331a0b91 +size 3496 diff --git a/marker2/ds9/EFTA00090424/_page_1_Picture_7.jpeg b/marker2/ds9/EFTA00090424/_page_1_Picture_7.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..74f3360cac0631f957dcd325891bcbf9f5224e77 --- /dev/null +++ b/marker2/ds9/EFTA00090424/_page_1_Picture_7.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:64cf68718d38c3dd9374af888f14ae965576250a71494e67597cd3b210f666e0 +size 1963 diff --git a/marker2/ds9/EFTA00090426/EFTA00090426.md b/marker2/ds9/EFTA00090426/EFTA00090426.md new file mode 100644 index 0000000000000000000000000000000000000000..4d3a39c06082cd363d33d7fda0af02124102839c --- /dev/null +++ b/marker2/ds9/EFTA00090426/EFTA00090426.md @@ -0,0 +1,71 @@ +February 11, 2021 Call with + +## Present on Conference Call: + +- AUSAs +- FBI S ecial A ent - +- • +- Covington & Burling LLP General Counsel, Steve Anthony + +## recollections regarding February 29, 2016 Meeting: + +- • confirmed the handwritten notes sent to . by were own notes from the February 29, 2016 meeting. +- In advance of the meeting, . remembers Pete Skinner reaching out to . and asking if he could come in to present on a potential case with some other attorneys. • doesn't recall how Skinner contacted M. Skinner was at Boies Schiller at the time, Skinner and + - are friends and were in the SDNY USA0 together. At this time, . was the land believes she was also the +- Meeting took place in a conference room at 1 St. Andrews Plaza USAO SDNY. Pete Skinner, Brad Edwards, Stan Pottinger, and were at the meeting. o • doesn't recall what each attorney's role was, but her notes say that they represented also understood that Edwards was involved in representing multiple individuals in a civil litigation involving the CVRA, but is not certain of that. o understood that Skinner or his colleagues at Boies were representing . • doesn't know if Skinner was involved in representing o Brad Edwards did most of the talking during the meeting. o • recalls that Pete Skinner spoke a little bit, but doesn't recall what, if anything, he said on substance. • doesn't remember what he said. +- • understood the purpose of the meeting to be the attorneys presenting information that they believed or suggested should be the subject of a criminal investigation into Jeffrey Epstein. o IN understood that the attorneys were advocating that the Jeffrey Epstein case should be investigated by SDNY. +- directed to references to lawsuits on pages 4 and 7 of notes from the meeting, and asked what recalls about what civil lawsuits she learned of during the meeting. o remembers there was a CVRA lawsuit that was mentioned. o remembers that there were other civil lawsuits mentioned. Aside from what is in notes • has no memory of what those lawsuits were about or the nature of those lawsuits. o • does not have an independent memory of the lawsuit being mentioned, and her memory is not refreshed from looking at the notes. + +## EXHIBIT G + +- directed to "they will send me affidavits and depositions" on page 8 of notes and asked if recalls what that line refers to and whether the attorneys sent any such materials. o does not recall what that line refers to. o does not recall if the attorneys sent her any such materials after the meeting. o does not believe the attorneys provided her any materials during the meeting. o has a vague memory that the attorneys sent her something by email, but does not recall what it was. + - One of the emails sent to was an email from Skinner to the evening of February 29, 2016 after the meeting sending documents. does not remember the particular documents she received. • does not recall receiving any additional documents. +- • remembers the mention of several people, including Ghislaine Maxwell as either in the context of who had benefited from the Florida NPA or who the people were that had worked for or helped Epstein. doesn't recall much specifics about Maxwell. Maxwell was not a focus of the meeting. +- does not recall the attorneys saying anything about what charges the office could bring. Related to that, recalls asking questions to understand what kind of charges they were proposing because it was not clear. The attorneys did not present particular statutes that might be pursued. +- • recalls trying to understand what prior statements of existed in the context of assessing how much of a record there already was. • recalls that the information about civil lawsuits came up when asked the attorneys what record there was of statements about Epstein, either in the context of the Florida case or otherwise. notes don't jog memory of what she learned about prior statements. o • does remember that there was some civil litigation, including CVRA litigation and some other civil case, and not just involving but also civil litigation involving other potential witness or witnesses. takeaway was that there was a large and potentially complicated record of civil litigation that would have to be at some point parsed through in assessing what any potential witness had said. It wasn't only that there was civil litigation involving but there was also some person in Europe involved in litigation. • felt this was a situation where there would be a lot of material to gather and read before talking to witnesses. +- doesn't remember being told any specific allegations victims had made against Maxwell. • generally remembers Maxwell being mentioned as someone who had worked for Epstein. o Notes reflect that Maxwell was "head recruiter," butt does not recall that description being attributed to any particular witness + +- recollection is that the attorneys did not make any suggestions regarding what investigative steps SDNY should take. The attorneys did not suggest that SDNY use civil lawsuits as a means to conduct a criminal investigation. +- Discussion of Epstein's conduct expanded beyond . Attorneys described the conduct as involving many or several other girls. There was more detail provided about experience, but there was a broader discussion about Epstein's conduct as a pattern and long-running, if not ongoing, behavior that continued after was no longer involved. +- understanding was not that the attorneys were hoping SDNY would investigate or charge anyone other than Epstein. The meeting was focused on Epstein. There was mention of other people who had helped him over time, including an individual who was in Europe and potentially was a source of evidence against Epstein. The thrust of the discussion was about building a case against Epstein. The other individuals were mentioned or described as part of telling the story, or as potential sources of information. +- I. does not remember exactly what she said at the end of the meeting, but she knows her practice was that in every such meeting she has ever had, she has thanked the people for coming in and been completely non-committal and non-responsive about what the office would do about the information that was provided. o • absolutely did not tell the attorneys that an investigation would be opened. + +Events after February 29, 2016 meeting: + +- After the February 29, 2016 meeting, emailed at the time). Had a meeting in his office. • discussed with what the lawyers had shared, thoughts, and thoughts. Decided on an action plan. o • knew there was the pending CVRA civil case and other civil litigation, which gave some pause because she had other occasions where civil litigants have decided to report something to the USAO because they think it will help them in their civil case. • mentioned that to o Discussed the length of time that had passed; wasn't clear there was any ongoing conduct; USAO SDFL is a reputable USAO with skilled FBI agents, and assumption was that however they concluded their case probably reflected something about the strength of the case or some issue that existed. o One thing that leaned in favor of taking action was that one of the lawyers (Stan or Brad) said that FBI agents in Florida case were not happy with the result and how the case was resolved. That concerned because experienced FBI agents in this area usually, in experience, make collaborative decisions with the USAO. o • & decided (don't recall who came up with idea) that ■ **would reach out to (head of FBI C-20 at the time) and ask him to contact Miami FBI agents to ask if they in fact were unhappy with the outcome and felt like justice had not been served.** +- **After the meeting with M, called and relayed the summary of this and asked him to reach out to the Miami agents who were on the Epstein case. • asked** + +to call back and let her know if the Florida agents had concerns. never called back. doesn't recall ever affirmatively following up with but she took the radio silence to mean that the FBI agents in Florida did not express dissatisfaction. + +- No investigation was opened as a result of the February 29, 2016 meetin . +- No investigation into Epstein was opened while El was the and +- never met with any other Boies Schiller attorneys. does not recall ever speaking with David Boies at any point. +- never met with the attorneys from the February 29, 2016 meeting again. +- When asked what, if any, communications had with the attorneys, noted that she sees an email from May 2016 with Stan Pottenger. believes it's possible Stan called M, but she does not remember that. +- • does not recall any further conversations re Epstein in SDNY until much later when the Miami Herald series was published. + +confirmed she has read the Daily News Article sent + +- • indicated that the article did not accurately describe interactions with attorneys for +- recollection is not that attorneys urged SDNY to open an investigation into "the duo." They were focused on Epstein. Maxwell was mentioned in passing, not as a target. +- • did not participate in a second meeting with anyone. Had there been a meeting on this subject in the summer of 2016 in SDNY, would have known about it in her capacity as o • had been in that role since approximately 2010, and if someone came in to meet with a unit chief about a potential human trafficking matter, El would get contacted about the meeting. • met with chiefs to gather information about any cases they had that touched on human trafficking so that could coordinate. So if a second meeting had taken place with a supervisor in the office, would have known about it. also would have brought in if he learned of a second meeting. o • would have made a record if there had ever been a second meeting. ■ **would remember if there were a second meeting. She has no record and no memory of any second meeting.** +- **El does not recall ever speaking with or meeting David Boies in her life, so to her knowledge, Boies was not making any effort to persuade SDNY to investigate Epstein. noted it is possible Boies could have been on the phone if Stan Pottinger called in or around May of 2016, but has no recollection of such a call.** +- **• does not recall the attorney presentation being framed on highlighting Maxwell's assistance with Epstein's sexual abuse. It was not presented as a "duo." • recalls the mention of a pilot and the mention of someone having an address book, so other people were mentioned as part of telling the story of Epstein.** + +- In did not express any concerns about anything to the attorneys. may have asked something like whether the attorneys are asking SDNY to re-do the Florida investigation because was trying to understand what the attorneys were proposing: was it looking at the same conduct that was investigated in Florida and mishandled, or was it looking at different conduct and possibly ongoing conduct? recalls asking questions to clarify that point. +- U is sure one of the things she asked would have been venue oriented to understand what the attorneys were describing and what the conduct was. would not have responded to a question asking about why wouldn't just open an investigation. Purpose of the meeting was for to understand what the attorneys were trying to convey, not for to make any representation about her thoughts or what she was going to do. +- Brad Edwards's book suggesting that the AUSA seemed "confident that a case would be brought" does not seem accurate to M. did not intend to give such an impression during the meeting. That decision is not one for to make alone, in any event. +- does not recall any mention that the number of victims in NY far exceeded the number in Florida. +- Brad Edwards's description of wanting a case against Epstein is consistent with recollection that the focus was on Epstein. +- If anyone called E, she does not remember that, and she would not have mentioned the comity shown to other USAOs around the country. +- • does not recall anyone ever approaching her to ask if SDNY would consider charging Maxwell with perjury. o • has a vague memory that the attorneys called or emailed at some point and told her that there had been depositions, presumably by contact from one of these lawyers, but cannot recall the specifics. IN does not remember one way or the other if any of the attorneys referenced the possibility of perjury. o recalls thinking that a perjury investigation would have the same challenges. recalls thinking in her mind that if the depositions were about the underlying conduct that had all of the issues that gave pause after the meeting (length of time that had passed, sense there must have been a reason SDFL resolved the case the way they did) were not alleviated by a pequry-based prosecution. o • does not recall ever knowing anything about the substance of the depositions and does not remember anyone sending her a deposition transcript. o • does not remember who had been deposed or who might have been the subject of a possible perjury investigation. o No investigation into perjury was ever opened. +- • took no further action re Epstein after calling o Though there may be emails or calls cannot remember, she knows that she took no action after the call to Part of the reason U felt horrible when reading the Miami Herald article was because took no action after calling + +## When the Topic of Epstein Came Back up with the Miami Herald Article + +- Arose when was in Securities. was no longer the or the +- may have told someone that there had been a presentation for SDNY to prosecute Epstein. • read the article and was very disturbed to read about how the case was resolved in SDFL, which was inconsistent with assumptions when the case was presented by the attorneys in February 2016. +- • remembers speaking with someone in Public Corruption about the February 29, 2016 meeting and shared her notes and emails with Public Corruption. +- • remembers that someone from the original case team (thinks MM.) came by her office and they chatted. • may have also spoken with or but is not sure. o When speaking with members of the Public Corruption team: ■ **remembers telling them that she felt terrible reading the Miami Herald series. • remembers telling them that she had the impression that the lawyers who came in to meet with were disorganized, and impression was that they thought it would help the CVRA case if SDNY opened a criminal case. o • is sure that she gave whatever she had, including the notes that emailed handed to whatever was in folder. o • does not remember having any documents or receiving any documents from the attorneys. o • remembers understanding that Public Corruption had opened an investigation into Epstein.** +- **• did not play any role in opening the SDNY investigation into Epstein.** +- **To knowledge, has not received any discovery materials from any civil case.** \ No newline at end of file diff --git a/marker2/ds9/EFTA00090426/EFTA00090426.metadata.json b/marker2/ds9/EFTA00090426/EFTA00090426.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..b64c527da20e980bae00574239b40f8efd1fd211 --- /dev/null +++ b/marker2/ds9/EFTA00090426/EFTA00090426.metadata.json @@ -0,0 +1,371 @@ +{ + "source_pdf": 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that the City of Palm Beach Police Department and the State Attorney's Office for the 15th Judicial Circuit in and for Palm Beach County (hereinafter, the "State Attorney's Office") have conducted an investigation into the conduct of Jeffrey Epstein (hereinafter "Epstein"); + +IT APPEARING that the State Attorney's Office has charged Epstein by indictment µith solicitation of prostitution, in violation of Florida Statutes Section 796.07; + +IT APPEARING that the United States Attorney's Office and the Federal Bureau of Investigation have conducted their own investigation into Epstein's background and any offenses that may have been committed by Epstein against the United States from in or around 2001 through in or around September 2007, including: + +- (I) knowingly and willfully conspiring with others known and unknown to commit an offense against the United States, that is, to use a facility or mews of interstate or foreign commerce to knowingly persuade, induce, or entice minor females to engage in prostitution, in violation of Title 18, United States Code, Section 2422(b); all in violation ofTitle 18, United States Code, Section 371; +- (2) knowingly and willfully conspiring with others known and unknown to travel in interstate commerce for the purpose of engaging in illicit sexual conduct, as defined in 18 U.S.C. § 2423(1), with minor females, in violation of Title 18, United States Code, Section 2423(b); all in violation of Title 18, United States Code, Section 2423(e); +- (3) using a facility or means of interstate or foreign commerce to knowingly persuade, induce, or entice minor females to engage in prostitution; in violation of Title 18, United States Code, Sections 2422(b) and 2; +- (4) traveling in interstate commerce for the purpose of engaging in illicit sexual conduct, as defined in 18 U.S.C. § 2423(O, with minor females; in violation + +of Title 18, United States Code, Section 2423(b); and + +- (5) knowingly, in and affecting interstate and foreign commerce, recruiting, enticing, and obtaining by any means a person, knowing that the person had not attained the age of 18 years and would be caused to engage in a commercial sex act as defined in 18 U.S.C. § 1591(c)(1); in violation of Title 18, United States Code, Sections 1591(a)(1) and 2; and + +IT APPEARING that Epstein seeks to resolve globally his state and federal criminal liability and Epstein understands and acknowledges that, in exchange for the benefits provided by this agreement, he agrees to comply with its terms, including undertaking certain actions with the State Attorney's Office; + +IT APPEARING, after an investigation of the offenses and Epstein's background by both State and Federal law enforcement agencies, and after due consultation with the State Attorney's Office, that the interests of the United States, the State of Florida, and the Defendant will be served by the following procedure; + +THEREFORE, on the authority of R. Alexander Acosta, United States Attorney for the Southern District of Florida, prosecution in this District for these offenses shall be deferred in favor of prosecution by the State of Florida, provided that Epstein abides by the following conditions and the requirements of this Agreement set forth below. + +If the United States Attorney should determine, based on reliable evidence, that, during the period of the Agreement, Epstein willfully violated any of the conditions of this Agreement, then the United States Attorney may, within ninety (90) days following the expiration of the term of home confinement discussed below, provide Epstein with timely notice specifying the condition(s) of the Agreement that he has violated, and shall initiate its prosecution on any offense within sixty (60) days' of giving notice of the violation. Any notice provided to Epstein pursuant to this paragraph shall be provided within 60 days of the United States learning of facts which may provide a basis for a determination of a breach of the Agreement. + +After timely fulfilling all the terms and conditions of the Agreement, no prosecution for the offenses set out on pages 1 and 2 of this Agreement, nor any other offenses that have been the subject of the joint investigation by the Federal Bureau of Investigation and the United States Attorney's Office, nor any offenses that arose from the Federal Grand Jury investigation will be instituted in this District, and the charges against Epstein if any, will be dismissed. + +#### Terms of the Agreement + +- I. Epstein shall plead guilty (not nolo contendere) to the indictment as currently pending against him in the 15th Judicial Circuit in and for Palm Beach County (Case No. 2006-cf•009495A)OCCMB) charging one (1) count of solicitation of prostitution, in violation of FL Stat § 796.07. In addition, Epstein shall plead guilty to an Information filed by the State Attorney's Office charging Epstein with an offense that requires him to register as a sex offender, that is, the solicitation of minors to engage in prostitution, in violation ofFlorida Statutes Section 796.03; +- 2. Epstein shall make a binding recommendation that the Court impose a thirty (30) month sentence to be divided as follows: + - (a) + - (b) Epstein shall be sentenced to consecutive terms of twelve (12) months and six (6) months in county jail for all charges, without any opportunity for withholding adjudication or sentencing, and without probation or community control in lieu of imprisonment and Epstein shall be sentenced to a term of twelve (12) months of community control consecutive to his two terms in county jail as described in Term 2(a), supra. +- 3. This agreement is contingent upon a Judge of the 15th Judicial Circuit accepting and executing the sentence agreed upon between the State Attorney's Office and Epstein, the details of which are set forth in this agreement +- 4. The terms contained in paragraphs 1 and 2, supra, do not foreclose Epstein and the State Atorneys Office from agreeing to recommend any additional charge(s) or any additional tenn(s) of probation and/or incarceration. +- 5. Epstein shall waive all challenges to the Information filed by the State Attorney's Office and shall waive the right to appeal his conviction and sentence, except a sentence that exceeds what is set forth in paragraph (2), supra. +- 6. Epstein shall provide to the U.S. Attorney's Office copies of all + +proposed agreements with the State Attorney's Office prior to entering into those agreements. + +- 7. The United States shall provide Epstein's attorneys with a list of individuals whom it has identified as victims, as defined in 18 U.S.C. § 2255, after Epstein has signed this agreement and been sentenced. Upon the execution of this agreement, the United States, in consultation with and subject to the good faith approval of Epstein's counsel, shall select an attorney representative for these persons, who shall bepaid for by Epstein. Epstein's counsel may contact the identified individuals through that representative. +- 8. If any of the individuals referred to in paragraph (7), supra, elects to file suit pursuant to 18 U.S.C. § 2255, Epstein will not contest the jurisdiction of the United States District Court for the Southern District of Florida over his person and/or the subject matter, and Epstein waives his right to contest liability and also waives his right to contest damages up to an amount as agreed to between the identified individual and Epstein, so long as the identified individual elects to proceed exclusively under 18 U.S.C. § 2255, and agrees to waive any other claim for damages, whether pursuant to state, federal, or common law. Notwithstanding this waiver, as to those individuals whose names appear on the list provided by the United States, Epstein's signature on this agreement, his waivers and failures to contest liability and such damages in any suit are not to be construed as an admission of any criminal or civil liability. +- 9. Epstein's signature on this agreement also is not to be construed as an admission of civil or criminal liability or a waiver of any jurisdictional or other defense as to any person whose name does not appear on the list provided by the United States. +- 10. Except as to those individuals who elect to proceed exclusively under 18 U.S.C. § 2255, as set forth in paragraph (8), supra, neither Epstein's signature on this agreement, nor its tents, nor any resulting waivers or settlements by Epstein arc to be construed as admissions or evidence of civil or criminal liability or a waiver of any jurisdictional or other defense as to any person, whether or not her name appears on the list provided by the United States. +- 11. Epstein shall use his best efforts to enter his guilty plea and be + +sentenced not later than October 26, 2007. The United States has no objection to Epstein self-reporting to begin serving his sentence not later than January 4, 2008. + +1. 12. Epstein agrees that he will not be afforded any benefits with respect to gain time, other than the rights, opportunities, and benefits as any other immate, including but not limited to, eligibility for gain time credit based on standard rules and regulations that apply in the State of Florida. At the United States' request, Epstein agrees to provide an accounting of the gain time he earned during his period of incarceration. +2. 13. The parties anticipate that this agreement will not be made part of any public record. If the United States receives a Freedom of Information Act request or any compulsory process commanding the disclosure of the agreement, it will provide notice to Epstein before making that disclosure. + +Epstein understands that the United States Attorney has no authority to require the State Attorney's Office to abide by any terms of this agreement. Epstein understands that it is his obligation to undertake discussions with the State Attorney's Office and to use his best efforts to ensure compliance with these procedures, which compliance will be necessary to satisfy the United States' interest. Epstein also understands that it is his obligation to use his best efforts to convince the Judge of the 15th Judicial Circuit to accept Epstein's binding recommendation regarding the sentence to be imposed, and understands that the failure to do so will be a breach of the agreement. + +In consideration of Epstein's agreement to plead guilty and to provide compensation in the manner described above, if Epstein successfully fulfills all of the terms and conditions of this agreement, the United States also agrees that it will not institute any criminal charges against any potential co-conspirators of Epstein, including but not limited to [REDACTED] + +[REDACTED] Further, upon execution of this agreement and a plea agreement with the State Attorney's Office, the federal Grand Jury investigation will be suspended, and all pending federal Grand Jury subpoenas will be held in abeyance unless and until the defendant violates any term of this agreement. The defendant likewise agrees to withdraw his pending motion to intervene and to quash certain grand jury subpoenas. Both parties agree to maintain their evidence, specifically evidence requested by or directly related to the grand jury subpoenas that have been issued, and including certain computer equipment, involate until all of the terms of this agreement have been satisfied. Upon the successful completion of the terms of this agreement, all outstanding grand jury subpoenas shall be deemed withdrawn. + +By signing this agreement, Epstein asserts and certifies that each of these terms is material to this agreement and is supported by independent consideration and that a breach of any one of these conditions allows the United States to elect to terminate the agreement and to investigate and prosecute Epstein and any other individual or entity for any and all federal offenses. + +By signing this agreement, Epstein asserts and certifies that he is aware of the fact that the Sixth Amendment to the Constitution of the United States provides that in all criminal prosecutions the accused shall enjoy the right to a speedy and public trial. Epstein further is aware that Rule 48(b) of the Federal Rules of Criminal Procedure provides that the Court may dismiss an indictment, information, or complaint for unnecessary delay in presenting a charge to the Grand Jury, filing an information, or in bringing a defendant to trial. Epstein hereby requests that the United States Attorney for the Southern District of Florida defer such prosecution. Epstein agrees and consents that any delay from the date of this Agreement to the date of initiation of prosecution, as provided for in the terms expressed herein, shall be deemed to be a necessary delay at his own request, and he hereby waives any defense to such prosecution on the ground that such delay operated to deny him rights under Rule 48(b) of the Federal Rules of Criminal Procedure and the Sixth Amendment to the Constitution of the United States to a speedy trial or to bar the prosecution by reason of the running of the statute of limitations for a period of months equal to the period between the signing of this agreement and the breach of this agreement as to those offenses that were the subject of the grand jury's investigation. Epstein further asserts and certifies that he understands that the Fifth Amendment and Rule 7(a) of the Federal Rules of Criminal Procedure provide that all felonies must be charged in an indictment presented to a grand jury. Epstein hereby agrees and consents that, if a prosecution against him is instituted for any offense that was the subject of the grand jury's investigation, it may be by way of an Information signed and filed by the United States Attorney, and hereby waives his right to be indicted by a grand jury as to any such offense. + +/// + +/// + +/// + +By signing this agreement, Epstein asserts and certifies that the above has been read and explained to him. Epstein hereby states that he understands the conditions of this Non-Prosecution Agreement end agrees to comply with them. + +> R. ALEXANDER ACOSTA UNITED STATES ATTORNEY + +Dated: + +Dated: + +Dated: + +Dated: + +ASSISTANT U.S. ATTORNEY + +GERALD LEFCOURT, ESQ. COUNSEL TO JEFFREY EPSTEIN + +LILLY ANN SANCHEZ, ESQ. ATTORNEY FOR JEFFREY EPSTEIN + +By signing this awecment, Epstein asserts and certifies that the above has been read and explained to him. Epstein hereby states that he undmstands the conditions of this Non-Prosecution Agreement end agrees to comply with them. + +> IL ALEXANDER ACOSTA UNITED STATES ATTORNEY + +Dated: + +Dated; + +Dated: 711.41°7 + +Dated: + +By: + +ASSISTANT U.S. ATTORNEY + +JEFFREY EPSTEIN + +LILLY ANN SANCHE7, ESQ. ATTORNEY FOR JEFFREY EPSTEIN + +ERALD COO t...SQ. OUNSEL TO JEFFREY EPSTEIN + +By signing this agreement, Epstein asserts and certifies that the above has been read and explained to him. Epstein hereby states that he undergoAnds - the conditions of this Non-Prosecutior. Agreement and agrees to comply with than. + +> R ALEXANDER ACOSTA UNITED STATES ATTORNEY + +Dated: BY: + +Dated: + +Dated: + +Dated 9-.01-0?- + +ASSISTANT U.S. ATTORNEY + +JEFFREY EPSTRIN + +GERALD LEFCOURT, ESQ. COUNSEL TO JEFFREY EPSTF.IN + +ESQ. ATTORNEY FOR JEFFREY EPSTEJN EC RE: + +#### INVESTIGATION OF + +JEFFREY EPSTEIN + +#### ADDENDUM TO THE NON-PROSECUTION AGREEMENT + +IT APPEARING that the parties seek to clarify certain provisions of page 4, paragraph 7 of the Non-Prosecution Agreement (hereinafter "paragraph 7"), that agreement is modified as follows: + +7A. The United States has the right to assign to an independent third-party the responsibility for consulting with and, subject to the good faith approval of Epstein's counsel, selecting the attorney representative for the individuals identified under the Agreement. If the United States elects to assign this responsibility to an independent third-party, both the United States and Epstein retain the right to make good faith objections to the attorney representative suggested by the independent third-patty prior to the final designation of the attorney representative. 7B. The panics will jointly prepare a short written submission to the independent third-party regarding the role of the attorney representative and regarding Epstein's Agreement to pay such attorney representative his or her regular customary hourly rate for representing such victims subject to the provisions of paragraph C, infra. 7C. Pursuant to additional paragraph 7A, Epstein has agreed to pay the fees of the attorney representative selected by the independent third party. This provision, however, shall not obligate Epstein to pay the fees and costs of contested litigation filed against him. Thus, If after consideration of potential settlements, an attorney representative elects to file a contested lawsuit pursuant to 18 U.S.C. s 2255 or elects to pursue any other contested remedy, the paragraph 7 obligation of the Agreement to pay the costs of the attorney representative, as opposed to any statutory or other obligations to pay reasonable attorneys fees and costs such as those contained ins 2255 to bear the costs of the attorney representative, shall cease. + +By signing this Addendum, Epstein asserts and certifies that the above has been read and explained to him. Epstein hereby, states that he understands the clarifications to the Non-Prosecution Agreement and agrees to comply with them. + +> R. ALEXANDER ACOSTA UNITED STATES ATTORNEY + +Dated: /DAD 47 + +Dated: / + +Dated: + +Dated: + +By: + +• TA G.S. ATTORNEY + +GERALD LEFCOURT, ESQ. COUNSEL TO JEFFREY EPSTEIN + +LILLY ANN SANCHEZ, ESQ. ATTORNEY FOR JEFFREY EPSTEIN + +By signing this Addendum, Epstein asserts and certifies that the above has been read and explained to him. Epstein hereby states that he understands the clarifications to the Non-Prosecution Agreement and agrees to comply with them. + +R. ALEXANDER ACOSTA +UNITED STATES ATTORNEY + +![]()By: + +ASSISTANT U.S. ATTORNEY + +Dated: 10/30/07 + +Dated: \_\_\_\_\_ + +\_\_\_\_\_ +JEFFREY EPSTEIN + +Dated: 10/29/07 + +![]()GERALD LEFCOURT ESQ. +COUNSEL TO JEFFREY EPSTEIN + +Dated: \_\_\_\_\_ + +\_\_\_\_\_ +LILLY ANN SANCHEZ, ESQ. +ATTORNEY FOR JEFFREY EPSTEIN + +By signing this Addendum, Epstein users\* and certifies that the above ha been read end explained to him. Epstein hereby states that he understands the claire-Zona to the Non-Prosecution Agreement and agrees to comply with than. + +Dated: /D bay 7 + +Dated: + +Dated: + +Dated: ithPaild- + +R. ALEXANDER ACOSTA UNITED STATES ATTORNEY + +By: + +JEFFREY EPSTEIN + +GERALD LEFCOURT, ESQ. COUNSEL TO JEFFREY EPSTEIN + +LILLY CHEZ, ATTORNEY FOR JEFFREY EPSTEIN + +Doc-07-07 04:55pm From-Fowler-White Burnett + +3657820201 + +T-966 P.003/004 F-976 + +**Affirmation** + +I, Jeffrey B. 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letter due today + +Date: Tue, 26 Oct 2021 16:19:35 +0000 + +Attachments: 2021-10-26\_GM Jetter\_re\_preliminary\_remarks\_Final.docx + +Weird. The attached reflects edits to that version. + +From: + +Sent: Tuesday, October 26, 2021 12:08 PM + +To: (USANYS) + +Subject: RE: letter due today + +This document is blank when I open it. Has anything changed since last night, when we drafted this together? Still good with that version. + +From: (USANYS) + +Sent: Tuesday, October 26, 2021 11:51 AM + +To: < > + +Subject: letter due today + +Let me know if you have anything further on this. Planning to send back to chiefs to confirm they have nothing more on this. Thanks. + +Assistant United States Attorney United States Attorney's Office Southern District of New York + +New York, New York 10007 + +Tel: \ No newline at end of file diff --git a/marker2/ds9/EFTA00090449/EFTA00090449.metadata.json b/marker2/ds9/EFTA00090449/EFTA00090449.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..5df49225122fc4383e2194a127bbd5578b550b4c --- /dev/null +++ b/marker2/ds9/EFTA00090449/EFTA00090449.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090449.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 794, + "elapsed_seconds": 0.88, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 49 + ], + [ + "Line", + 24 + ], + [ + "Text", + 19 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00090449" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00090450/EFTA00090450.md b/marker2/ds9/EFTA00090450/EFTA00090450.md new file mode 100644 index 0000000000000000000000000000000000000000..5ec5c0a6a8ce53f195836b6c25cead3217945030 --- /dev/null +++ b/marker2/ds9/EFTA00090450/EFTA00090450.md @@ -0,0 +1,29 @@ +From: " ..> + +To: ' + +Subject: RE: + +Date: Tue, 26 Oct 2021 21:37:20 +0000 + +Thanks, With respect to attending the trial, we're happy to provide you court access information when we learn more, so that you can let people who ask know the details for people who want to attend. Right now, we're scheduled to start trial on 11/29 in courtroom 318 in 40 Foley, but I don't have much information beyond that. But the trial is open to the public. + +From: EMI> + +Sent: Tuesday, October 26, 2021 5:31 PM + +To: + +Subject: + +She called our 800 line. She said that it took her many years and months to get the courage to call. She called the FBI hotline but nobody got back to her and she called She has applied for the Victim Compensation fund. + +She wanted to know if she could come to the trial. I told her that I will do whatever I can within the Judges rules to let her view the trial. + +She met Epstein and Maxwell 25 years ago has had a hard time reliving the events. + +She has the gown that she was wearing and the presents that they gave her. No pictures. + +This might be nothing. She was very nice and asked me for help. She lives in Philadelphia. + +Victim Witness Coordinator United States Attorney's Office Southern District of New York 1 St. Andrews Plaza New York, New York 10007 \ No newline at end of file diff --git a/marker2/ds9/EFTA00090450/EFTA00090450.metadata.json b/marker2/ds9/EFTA00090450/EFTA00090450.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..e69562fb950bf8fddc33c5f611d96306b0b5d7fd --- /dev/null +++ b/marker2/ds9/EFTA00090450/EFTA00090450.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090450.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1269, + "elapsed_seconds": 0.8, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 53 + ], + [ + "Line", + 25 + ], + [ + "Text", + 17 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00090450" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00090451/EFTA00090451.md b/marker2/ds9/EFTA00090451/EFTA00090451.md new file mode 100644 index 0000000000000000000000000000000000000000..13b8b8e1d21455e5e45d49feded5e3fa6d021132 --- /dev/null +++ b/marker2/ds9/EFTA00090451/EFTA00090451.md @@ -0,0 +1,141 @@ +#### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +x + +UNITED STATES OF AMERICA, + +v. + +GHISLAINE MAXWELL, + +Defendant. + +x + +20 Cr. 330 (AJN) + +GHISLAINE MAXWELL'S MOTION TO PRECLUDE THE INTRODUCTION OF ALLEGED CO-CONSPIRATOR STATEMENTS AS A SANCTION FOR FAILING TO COMPLY WITH THIS COURT'S SEPTEMBER 3, 2021, ORDER + +> Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue De Phone:r + +Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: + +Bobbi C. Sternheim Law Offices of Bobbi C. Sternheim 225 Broadway, Suite 715 New York NY 10007 Phone: + +Attorneys for Ghislaine Maxwell + +# TABLE OF CONTENTS + +| Table of Contents | ii | +|----------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------| +| Table of Authorities | iii | +| RELEVANT PROCEDURAL HISTORY | 1 | +| I. The Government has Failed to Identify any Purported Co-Conspirator Statements | 2 | +| H. | Ongoing Document Dumps Containing Thousands of Statements Does Not Satisfy the | +| Court's Order to Disclose | 2 | +| III. | The Failure to Disclose Prevents Defense Cross Examination at Trial and Facilitates the | +| Presentation of False Testimony | 4 | +| IV. Preclusion of the Purported Statements is the only Appropriate Remedy | 5 | + +# TABLE OF AUTHORITIES + +#### Cases + +| Taylor v. Illinois, 484 U.S. 400 (1988) | 5 | +|------------------------------------------------------------|------| +| United States v. Campagnuolo, 592 F.2d 852 (5th Cir. 1979) | 6 | +| United States v. Katz, 178 F.3d 368 (5th Cir. 1999) | 6 | +| United States v. Tellier, 83 F.3d 578 (2d Cir. 1996) | 2 | +| United States v. Tracy, 12 F.3d 1186 (2d Cir.1993) | 2 | +| United States v. Wicker, 848 F.2d 1059 (10th Cir.1988) | 5, 6 | + +### Rules + +| Fed. R. Crim. P. 16 | 4.5 | +|---------------------|---------| +| Fed. R. Evid. 104 | 2 | +| Fed. R. Evid. 801 | 1. 2. 4 | + +Defendant Ghislaine Maxwell, through counsel, requests that the Court enter an order precluding the government from introducing any alleged co-conspirator statements under Federal Rule of Evidence 801(d)(2)(E) because the government failed to comply with the Court's Order of September 3, 2021 (Dkt. 335). In support of this request, Ms. Maxwell states: + +# RELEVANT PROCEDURAL HISTORY + +On multiple occasions Ms. Maxwell requested disclosure of the identity of any alleged co-conspirators in this case along with any statements made by those individuals that the government intends to offer into evidence at trial under Federal Rule of Evidence 801(d)(2)(E). The Court, on September 3, 2021, dismissed the government's arguments against disclosure noting that the concern raised by the government about disclosure "does not outweigh the risk of surprise to the Defendant in this case or the need for the parties to litigate co-conspirator issues in advance of trial to ensure the absence of delay" Dkt. 335 at 3. The Order was explicit regarding what the government was required to do: First, no later than October II, 2021, the government was required to "disclose to the defense the identities of any unnamed coconspirators who allegedly participated in the conspiracies charged in the S2 indictment to whom the government will refer at trial." Id. Second, the Court, unambiguously and emphatically, directed: "The Government is FURTHER ORDERED to disclose all co-conspirator hearsay statements it intends to offer at trial no later than October 11, as consistent with this Court's scheduling order. Dkt. No. 297 at 1." (emphasis in original.) + +On October II, 2021, the government identified three purported co-conspirators for purposes of trial: Jeffrey Epstein, The government, however, failed and refused to disclose "all (or any) co-conspirator statements it intends to introduce at trial...." Instead, the government, circumventing the plain meaning of the Court's Order, offered that "[t]he Government has produced all co-conspirator statements which + +it intends to offer at trial ... in the Government's production today or in its previous productions." And, circumnavigating this Court's Order with Magellan-like skill, promised that, as the government "continues to prepare for trial" it will produce any additional co-conspirator statements "in connection with its ongoing obligation to produce Jencks Act material." See, Ex. + +### I. The Government Failed to Identify Any Purported Co-Conspirator Statements + +For a statement to fall within the definition of Fed.R.Evid. 801(d)(2)(E), "a court must find (1) that there was a conspiracy, (2) that its members included the declarant and the party against whom the statement is offered, and (3) that the statement was made both (a) during the course of and (b) in furtherance of the conspiracy." United States v. Tracy, 12 F.3d 1186, 1196 (2d Cir. 1993). These conditions precedent are "[p]reliminary questions concerning ... the admissibility of evidence" as referenced in Fed. R. Evid. 104(a), and must be proven by a preponderance of the evidence. United States v. Daly, 842 F.2d 1380, 1386 (2d Cir. 1988). + +The Court may consider the coconspirator statements themselves in determining whether the 801(d)(2)(E) prerequisites have been met. However, because "these hearsay statements are presumptively unreliable," United States v. Tether, 83 F.3d 578, 580 (2d Cir. 1996), there must be independent corroborating evidence of the existence of the conspiracy and the participation therein of the declarant and the defendant. Id. + +### II. Ongoing Document Dumps Containing Thousands of Statements Do Not Satisfy the Court's Order to Disclose + +The government neither objected to Ms. Maxwell's request for disclosure nor the Court's Order requiring disclosure at the same time. See Dkt. 317 at 12, n.1 (citing Dkt. 291 and Dkt. 293). The government's reason for not wanting to disclose the statements was considered and + +rejected by the Court which ordered disclosure at the same time as the government's witness list, Rule 404(b) notice, exhibits, and 3500 materials no later than October 11, 2021, so that the Defense would not be surprised at trial and because of "the need for the parties to litigate coconspirator issues in advance of trial...." Dkt. 335 at 3. + +The government seized multiple electronic devices, including computers and servers from alleged co-conspirator Epstein. These devices contain hundreds of thousands of statements spanning decades. The emails on the devices are to and from many other individuals. Many of the emails are cryptic, subject to interpretation, and appear to be outside of the scope of either conspiracy alleged in the S2 Indictment. It is impossible for Ms. Maxwell to identify any statement that she may need to litigate in advance of trial and, even if she wanted to do so, any attempt would be futile because the government could avoid any issue by simply picking some other statement. Absent pre-trial identification of any alleged co-conspirator statement, Ms. Maxwell will be forced to, during trial, object to any proffered statement, request a recess, identify whether the purported statement was actually produced in discovery, and at some point, litigate the admissibility of the statement. Of course, this is precisely what the Court's Order was intended to avoid. + +Given the amount of discourse over this topic, the government must understand what the Court ordered it to disclose. It has chosen, however, to avoid and violate the Court's Order by attempting to overstuff an already full sandbag by ignoring both the plain language and spirit of the Order mandating disclosure. Instead of simply disclosing the purported statements the government has directed Ms. Maxwell back to the hundreds of thousands of "statements" produced or to be produced in the case. + +# III. The Failure to Disclose Prevents Defense Cross Examination at Trial and Facilitates the Presentation of False Testimony + +None of the identified purported coconspirators are available to testify at trial. Jeffrey Epstein is dead, and neither have been granted immunity for their trial testimony. Accordingly, Ms. Maxwell cannot cross-examine any identified coconspirator about whether he or she made any yet-to-be attributed statement. The government's failure to disclose creates a real danger that during trial one or more of the alleged accusers will, for the first time, offer some alleged 801(d)(2)(E) statement attempting to inculpate Ms. Maxwell. Thus, it is entirely possible that any one of the accusers could be asked, for example, + +Government Lawyer: Why did you go to the house? + +Witness/Accuser: Because [insert coconspirator] said that Maxwell said [insert expedient non-disclosed [statement]]. + +This is an invitation to manufacture evidence which Ms. Maxwell cannot cross examine. + +In addition, the failure to disclose implicates many of the issues raised in Ms. Maxwell's previously filed motions. The allegations are decades old, and Ms. Maxwell raised concerns about lack of memory and available witnesses in her Motion to Dismiss for Pre-Indictment Delay, Dkt. 138. It has been difficult to track down and interview relevant percipient witnesses to the alleged events. The failure of disclosure of critical alleged coconspirator statements makes it impossible to prepare a defense. + +# IV. Preclusion of the Purported Statements is the Only Appropriate Remedy + +Fed. R. Crim. P. 16(d)(2)(C) provides that if a party fails to comply with the Court's orders regulating discovery the Court may prohibit that party from introducing the undisclosed evidence as a sanction. + +A district court's decision to impose a Rule 16(d)(2) sanction for the violation of a discovery order, and thus its choice of sanction, is a matter committed to the Court's sound discretion. In exercising its discretion, the district court must weigh several factors, including the reasons for the government's delay in affording the required discovery, the extent of prejudice, if any, the defendant has suffered because of the delay, and the feasibility of curing such prejudice by granting a continuance. United States v. Wicker, 848 F.2d 1059,1060 (10th Cir. 1988). + +The Supreme Court's decision in Taylor v. Illinois, 484 U.S. 400 (1988) is instructive. Taylor involved the exclusion of a witness of whom the defense had known but failed to disclose. The defendant challenged the trial court's exclusion of the witness as a sanction for the discovery violation, alleging that it violated his right to present witnesses under the Sixth Amendment's compulsory process clause. In determining whether a preclusion sanction is appropriate, the Court mandated that a trial court exercise its discretion by balancing a defendant's fundamental right "to offer the testimony of witnesses in his favor" against countervailing public interests. Id. at 414. These interests include "[t]he integrity of the adversary process, which depends both on the presentation of reliable evidence and the rejection of unreliable evidence, the interest in the fair and efficient administration of justice, and the potential prejudice to the truth-determining function of the trial process." Id. at 414-15. The trial court may also consider the willfulness of the violation, the simplicity of compliance with the discovery obligation, and whether some unfair tactical advantage has been sought. See id. at 415-17. Considering these factors, the Court upheld the exclusion of the defendant's witness. + +The Court emphasized that the defendant had acted willfully and in bad faith in not disclosing the witness until the second day of trial after the prosecution's primary witness had testified. See id. at 416-17. Accordingly, "Negardless of whether prejudice to the prosecution could have been avoided [by a less severe sanction] ..., it [was] plain that the case fit[ ] into the category of willful misconduct in which the severest sanction [was] appropriate." Id. at 417; see also United States v. Katz, 178 F.3d 368,371-72 (5th Cir. 1999) (government's failure to disclose the "photographs" to the defendant in the identical form it intended to produce them at trial was either an attempt to "sandbag" the defense or highly unprofessional conduct and therefore limited the government to the use of black and white images); United States v. Campagnuolo, 592 F.2d 852,858 (5th Cir. 1979) (no abuse of discretion where, as here, a district judge for prophylactic purposes suppresses evidence that, under a valid discovery order, the government should have disclosed earlier, even if the nondisclosure did not prejudice the defendants); United States v. Wicker, 848 F.2d 1059,1062 (10th Cir. 1988) (in view of the district court's pressing schedule, the status of the present case, and the failure of a prior continuance and deadlines to ensure timely discovery; a second continuance would not compensate for the prejudice imposed upon the defendant and the district court did not abuse its discretion in suppressing the government's evidence). + +Here, the Court issued its disclosure order months ago. The government did not agree with the Order and sought reconsideration. The Court considered the government's belated request and rejected the government's "concern" that somehow its evidence would be limited at trial. Of course, the government could have made a good faith effort to comply with the Order and, if some other statement came to the government's attention before or during trial it could have, in good faith, requested permission to supplement its proof. Instead, the government has + +willfully violated the Order and has refused to produce statements that it obviously (1) is aware of and (2) could be easily identified by referring to a discovery page number or simply providing the statement. + +Ms. Maxwell had a very narrow window of time to review and consider any alleged coconspirator statements which has expired. Counsel for Ms. Maxwell are concurrently preparing multiple motions in limine, reviewing thousands of pages of newly provided discovery material, addressing other pretrial deadlines, and preparing for trial. At this stage the failure of the government to address a very simple disclosure requirement has prejudiced Ms. Maxwell's ability to prepare for trial and impacts her statutory and constitutional rights to a fair and speedy trial, due process, and effective assistance of counsel. The appropriate remedy is preclusion of the purported statements. + +Dated: October 18, 2021 + +Respectfully submitted, + +s/ Jeffrey S. Pagliuca + +Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver CO 80203 Phone: + +Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York NY 10022 Phone: + +Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim 225 Broadway, Suite 715 New York NY 10007 Phone: + +Attorneys for Chislaine Maxwell + +## **Certificate of Service** + +I hereby certify that on October 18, 2021, I electronically filed the foregoing *Ghislaine Maxwell's Motion to Preclude the Introduction of Alleged Co-Conspirator Statements as a Sanction for Failing to Comply with This Court's September 3, 2021 Order* with the Clerk of Court using the CM/ECF system which will send notification of such filing to the following: + +![](_page_11_Picture_42.jpeg) + +U.S. Attorney's Office, SDNY +One Saint Andrew's Plaza +New York, NY 10007 + +![](_page_11_Picture_44.jpeg) + +*s/* + +![](_page_11_Picture_46.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00090451/EFTA00090451.metadata.json b/marker2/ds9/EFTA00090451/EFTA00090451.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..f7cfe07108ed96bf08ab2f012b3964a4baeb975e --- /dev/null +++ b/marker2/ds9/EFTA00090451/EFTA00090451.metadata.json @@ -0,0 +1,678 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090451.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 12, + "chars": 16608, + "elapsed_seconds": 3.66, + "image_assets": [ + "_page_11_Picture_42.jpeg", + "_page_11_Picture_44.jpeg", + "_page_11_Picture_46.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 71.28 + ], + [ + 299.3348083496094, + 71.28 + ], + [ + 299.3348083496094, + 101.9830322265625 + ], + [ + 68.544, + 101.9830322265625 + ] + ] + }, + { + "title": "TABLE OF CONTENTS", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 233.17200000000003, + 71.28 + ], + [ + 380.10931396484375, + 71.28 + ], + [ + 380.10931396484375, + 87.363037109375 + ], + [ + 233.17200000000003, + 87.363037109375 + ] + ] + }, + { + "title": "TABLE OF AUTHORITIES", + "heading_level": null, + "page_id": 2, + "polygon": [ + [ + 222.768, + 71.28 + ], + [ + 389.91925048828125, + 71.28 + ], + [ + 389.91925048828125, + 86.9830322265625 + ], + [ + 222.768, + 86.9830322265625 + ] + ] + }, + { + "title": "Cases", + "heading_level": null, + "page_id": 2, + "polygon": [ + [ + 69.156, + 98.82 + ], + [ + 104.59761047363281, + 98.82 + ], + [ + 104.59761047363281, + 113.60302734375 + ], + [ + 69.156, + 113.60302734375 + ] + ] + }, + { + "title": "Rules", + "heading_level": null, + "page_id": 2, + "polygon": [ + [ + 69.156, + 296.46 + ], + [ + 104.23119354248047, + 296.46 + ], + [ + 104.23119354248047, + 311.9830627441406 + ], + [ + 69.156, + 311.9830627441406 + ] + ] + }, + { + "title": "RELEVANT PROCEDURAL HISTORY", + "heading_level": null, + "page_id": 3, + "polygon": [ + [ + 187.88400000000001, + 182.25 + ], + [ + 424.0888366699219, + 182.25 + ], + [ + 424.0888366699219, + 197.9830322265625 + ], + [ + 187.88400000000001, + 197.9830322265625 + ] + ] + }, + { + "title": "I. 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Southern District of New York + +The SiMoJ. Mono Building One Saint Andrew's Plana New York, New York 10007 + +October 11. 2021 + +## BY ELECTRONIC MAIL + +Christian Everdell, Esq. Cohen & Gresser LLP 800 Third Avenue New York, NY 10022 + +Laura Menninger, Esq. Jeffrey Pagliuca, Esq. Haddon, Morgan and Foreman, P.C. 150 East Tenth Avenue Denver, CO 80203 + +Bobbi Sternheim, Esq. Law Offices of Bobbi C. Sternheim 33 West 19th Street-4th Fl. New York, NY 10007 + +Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) + +Dear Counsel: + +We write to notify you that the Government may seek to introduce certain evidence at trial. In i articular. the Government ma offer certain exhibits at trial that demonstrate that. + +We are producing t ese propos e i 'its t . y, : GX 401 through 404, GX 409 through 410, and GX 413. wr i tie o owing e it + +In addition, please be advised that the Government may call as a witness at trial. Today, we are producing Jencks Act materialsrelating to , w o was e lo ed by Jeffrey Epstein from The Government anticipates that will testify about, among other things, certain documentary evidence relating to e c g crimes. The Government further anticipates that will testify about her role in scheduling sexualized massages for Jeffrey Epstein with un erage girls. + +This evidence is admissible as direct evidence of the crimes charged and, in the alternative, pursuant to Rule 404(b) as proof of the defendant's intent, preparation, plan, knowledge, identity, and/or absence of mistake of accident with respect to the charges in the above-referenced case. Because this evidence is admissible as direct evidence, the Government is not planning to affirmatively move in limine to seek its admission. + +Please note that this letter and the information contained herein is governed by the July 31, 2020 Protective Order in this case. 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Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver Phone: + +Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: + +Bobbi C. Sternheim Law Offices of Bobbi C. Sternheim 225 Broadway, Suite 715 New York NY 10007 Phone: + +Attorneys for Chislaine Maxwell + +# TABLE OF CONTENTS + +| BACKGROUND | 1 | +|-------------------|---| +| ARGUMENT | 2 | + +# TABLES OF AUTHORITIES + +#### Cases + +![](_page_2_Picture_2.jpeg) + +| Manson v. Brathwaite, 432 U.S. 98 (1977) | 2, 3 | +|------------------------------------------------------------|------| +| Neil v. Biggers, 409 U.S. 188 (1972) | 2, 3 | +| Raheem v. Kelly, 257 F.3d 122 (2d Cir. 2001) | 3 | +| Simmons v. United States, 390 U.S. 377 (1968) | 2, 3 | +| Stovall v. Demo, 388 U.S. 293 (1967) | 2 | +| United States v. Concepcion, 983 F.2d 369 (2d Cir. 1992) | 3 | +| United States v. Hemmings, 482 F. App'x 640 (2d Cir. 2012) | 3 | + +Defendant Ghislaine Maxwell, through counsel, moves to prohibit the Government from offering testimony from Accuser 4 identifying Ms. Maxwell as a perpetrator of any crime. Any in-court identification is tainted by unduly suggestive photo array procedures employed by the Government that violate Ms. Maxwell's right to due process under the United States Constitution for the following reasons: + +### BACKGROUND + +Accuser 4, was first contacted by the FBI in 2007. was interviewed on August 7, 2007 by Agents and asked about any abuse by Jeffrey Epstein. + +did not identify Ms. Maxwell as someone who recruited her, groomed her, or otherwise interacted with her in Palm Beach, Florida, or any other location. She identified as someone she interacted with and who took nude photographs of her at Mr. Epstein's direction. + +After her FBI interview, represented by counsel, filed i.' lawsuits against Jeffrey Epstein . Neither of those lawsuits mentions Ms. Maxwell. MI + +During her deposition in connection with the lawsuit, + +She did not identify Ms. + +Maxwell as having had any role in any alleged sexual abuse or trafficking. + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +On June 23, 2021, almost twenty years after the alleged events, and 14 years after [REDACTED] + +[REDACTED] did not identify Ms. Maxwell as the perpetrator of any crime, the Government presented [REDACTED] with a series of [REDACTED] photographs, attached as Exhibit A. [REDACTED] + +[REDACTED] + +[REDACTED] . [REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] The photographic identification procedure used was the functional equivalent of a one-on-one show-up. Any identification is tainted and should therefore be suppressed by the Court. + +### ARGUMENT + +A defendant's right to due process includes the right not to be the object of suggestive police identification procedures that create "a very substantial likelihood of irreparable misidentification." *Simmons v. United States*, 390 U.S. 377, 384 (1968); *accord Neil v. Biggers*, 409 U.S. 188, 198 (1972); *see also Manson v. Brathwaite*, 432 U.S. 98, 106 n.9, 114 (1977). This principle applies both to show-ups, *see, e.g.*, *Stovall v. Denno*, 388 U.S. 293 (1967), and to photographic identifications. *Simmons v. United States*, 390 U.S. 377, 384 (1968). + +When a defendant challenges the admissibility of identification testimony given by a witness who made a pretrial identification, the Court is required to conduct a two-part inquiry, asking first whether the pretrial identification procedures were unduly suggestive and, if so, whether the identification is nonetheless independently reliable. Raheem v. Kelly, 257 F.3d 122, 133 (2d Cir. 2001). + +A Government arranged photo array is unduly suggestive when a procedure "give[s] rise to a very substantial likelihood of irreparable misidentification." Simmons v. United States at 384 (1968); see also United States v. Hemmings, 482 F. App'x 640, 646 (2d Cir. 2012). In the context of a photo array, familiar examples of a suggestive presentation include the "use of a very small number of photographs," "the use of suggestive comments," or the display of the accused's photograph in a way that "so stood out from all of the other photographs as to suggest to an identifying witness that that person was more likely to be the culprit." United States v. Concepcion, 983 F.2d 369, 377 (2d Cir. 1992). + +The photo looks like a mug shot, is different than the others, and the manner in which it was presented was unduly suggestive. + +Where, as here, pretrial procedures have been unduly suggestive, the court must determine whether an in-court identification will be the product of the suggestive procedures or whether instead it is independently reliable. The factors to be considered include "the opportunity of the witness to view the criminal at the time of the crime, the witness' degree of attention, the accuracy of the witness' prior description of the criminal, the level of certainty demonstrated by the witness at the confrontation, and the length of time between the crime and the confrontation." Neil v. Biggers, 409 U.S. at 199-200; accord Manson v. Brathwaite, 432 U.S. at 114. The factors must be assessed in light of the totality of the circumstances, and the linchpin of admissibility is reliability. + +Here, the factors weigh heavily in favor of suppression. in interviews, court filings, and under oath, never identified Ms. Maxwell as anyone who abused her in any fashion. There was no "opportunity" for to "view the criminal at the time of the crime" because Ms. Maxwell did not participate in any crime. There was no prior description of Ms. Maxwell by and the length of time between the alleged event and the suggestive identification procedure was extraordinarily long. + +Accordingly, any identification, both out of court and in court, should be suppressed. + +Dated: October 18, 2021 + +Respectfully submitted, + +st Jeffrey S. Pagliuca + +Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver CO 80203 Phone: + +Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York NY 10022 Phone: + +Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim 225 Broadway, Suite 715 New York. NY 10007 Phone: + +Attorneys for Ghislaine Maxwell + +## **Certificate of Service** + +I hereby certify that on October 18, 2021, I electronically filed the foregoing *Memorandum of Ghislaine Maxwell's Motion to Suppress Identification* with the Clerk of Court using the CM/ECF system which will send notification of such filing to the following: + +![]()U.S. Attorney's Office, SDNY +One Saint Andrew's Plaza +New York, NY 10007 + +![]()*s/* + +![]() \ No newline at end of file diff --git a/marker2/ds9/EFTA00090466/EFTA00090466.metadata.json b/marker2/ds9/EFTA00090466/EFTA00090466.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..f7a723c59d02d75e1837fca927dfd59daffb927d --- /dev/null +++ b/marker2/ds9/EFTA00090466/EFTA00090466.metadata.json @@ -0,0 +1,479 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090466.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + 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Mollo Building One Saint Andrew's Plaza New York, New York 10007 + +July 23, 2021 + +## BY ELECTRONIC MAIL + +Christian Everdell, Esq. Mark Cohen, Esq. Cohen & Gresser LLP 800 Third Avenue New York, NY 10022 + +Laura Menninger, Esq. Jeffrey Pagliuca, Esq. Haddon, Morgan and Foreman, P.C. 150 East Tenth Avenue Denver, CO 80203 + +Bobbi Stemheim, Esq. Law Offices of Bobbi C. Stemheim 33 West 19th Street-4th Fl. New York, NY 10007 + +Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) + +Dear Counsel: + +Today we are producing certain materials relating to individuals the Government does not currently intend to call as witnesses at trial in the above-referenced case. Attached please find an index detailing the materials included in today's production. + +Please note that both the index and the enclosed materials are governed by the July 31, 2020 Protective Order in this case. In particular, the entire production is designated as "confidential" under the Protective Order. The index is itself designated as "confidential," because it includes information regarding records designated as "confidential" under the Protective Order. Recently, the Department of Justice directed this office to cease the dissemination of materials marked with the word "confidential" in order to avoid potential confusion with markings reserved for classified documents. Accordingly, in order to note the appropriate designation of this production under the operative Protective Order in this case, the materials being produced today are marked with the following label: "SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17." This marking directly refers to the specific paragraphs of the Protective Order that govern today's production. + +Additionally, please note that many of the individuals referenced in this production are represented by counsel, as detailed in the attached index. The Government reserves its right to amend and supplement these disclosures. + +This production should not be taken to indicate that the Government believes it has any obligation to provide all of these materials; rather, we make this production as a courtesy. Moreover, although the Government presently does not intend to call the individuals listed in the enclosed index, we reserve the right to do so and will notify you should the Government determine that it intends to call any of these individuals at trial. Consistent with that representation, the Government hereby provides notice that it now intends to call as a witness at trial. 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Edwards •01 + +Seth M. Lehrman "1- + +Brittany N. Henderson \*0 + +Matthew D. Weissing + +![](_page_0_Picture_0.jpeg) + +EDWARDS POTTINGER LLC + +# VIA E-MAIL AND FEDEX + +The Honorable Audrey Strauss United States Attorney for the Southern District of New York + +do + +425 North Andrews Avenue + +Suite 2 Fort Lauderdale, FL 33301 + +![](_page_0_Picture_9.jpeg) + +July 8, 2021 + +# FOIA PRIVACY EXEMPTION + +New York Office + +J. Stanley Pottinger + +f Admitted in CIWOCIIS + +0 Admitted in Distem of Columba + +• Admitted m ?lin& f Admitted in Nov Yea + +Bond Certified cma Thal lawyer + +Re: Re iiest m for Tangible and Documentary Evidence (Touhy Request) Doc v. Darren K. I ndyke, et at, SDNY Case No. 1:19-cv-07772 + +Dear Mr. + +To follow up to our October 15, 2020 and October 21, 20201 letters, we again request documentary and tangible evidence currently in the in the possession, custody, and control of the Department of Justice by way of the Southern District of New York relating to the sexual abuse of one of Jeffrey Epstein's many victims, Doe? See United States ex rel. Touhy v. Ragen, 340 U.S. 462 (1951). We make this written request pursuant to the Touhy regulations codified as 28 C.F.R. § 16.21 et seq. (a copy of ow October 15 and 21, 2020 letters, FedEx receipt and proof of email service are attached hereto). + +As stated in our prior letters, please contact us should you find any deficiencies in this request, and we will do what is necessary to correct any such shortcomings. + +Doe was repeatedly sexually assaulted and trafficked by prolific pedophile and rapist, Jeffrey Epstein, from 2006 through 2013. Throughout the years of abuse, Epstein purchased a number of commercial flights, provided housing, and purchased a number of items of value for Doe, record of which we believe is currently in the Government's possession as a result + +1 Our October 21, 2020 letter identified our client aS 2 To protect her anonymity, our client has elected to proceed as a to her herein using the pseudonym under which she has filed her lawsuit. Doe. As such, we have referred + +of the investigation that was conducted into Epstein's criminal activity relating to the sexual abuse of minor children. Given the highly relevant nature of this tangible evidence to [REDACTED] Doe's currently pending litigation, we request production of documentary evidence relating to [REDACTED] Doe to enable her to prove her claims from both a liability and damages standpoint. + +28 C.F.R. § 16.24 (c) states that it is the Department of Justice's policy to authorize the production of materials "whenever possible." Pursuant to the *Touhy* regulations set forth by the Department, the Deputy or Associate Attorney General assesses the following considerations in determining whether disclosure is warranted: + +- (a)(1) Whether such disclosure is appropriate under the rules of procedure governing the case or mater in which the demand arose; +- (a)(2) Whether disclosure is appropriate under the relevant substantive law of privilege. + +*See* 28 C.F.R. 16.26 (a) This request satisfies both considerations. The requested materials should be disclosed because disclosure is appropriate under Federal Rule of Civil Procedure 26 and the relevant substantive law of privilege. The requested documentary evidence is not privileged and directly concerns the allegations in Ms. Doe's civil case. + +In addition, the requested documents are not excluded from disclosure by 28 C.F.R § 16.26 (b). Disclosure will not violate any statute, rule of procedure or regulation, will not reveal any classified information, confidential source or informant, and will not interfere with law enforcement proceedings or disclose investigative techniques and procedures. In *In re The City of New York*, 607 F.3d 923, 945 (2nd Cir. 2010), the court recognized that the law enforcement privilege is qualified. *See also Miller v. Mehitretter*, 478 F. Supp. 415, 424 (W.D. N.Y. 2007) ("When the information sought is both relevant and essential to the presentation of the case on the merits and the need for disclosure outweighs need for secrecy, privilege is overcome.") While [REDACTED] Doe can overcome this privilege if asserted, she specifically does not request any investigatory records compiled for law enforcement purposes that would interfere with any ongoing law enforcement proceedings. + +[REDACTED] Doe has recently declined an offer from the Epstein Victims' Compensation Fund and is proceeding to trial in the Southern District of New York. She is simply requesting information in the Government's possession that will assist in the prosecution of her claims and ultimately, aid in her ability to finally obtain the justice that she deserves. Disclosure of the documents she requests is not prohibited by either section 28 C.F.R 16.26 (a) or (b) and is warranted pursuant to 28 C.F.R § 16.26 (c). Subsection 16.26 (c) permits this disclosure, which is necessary for a civil proceeding, because (1) the criminal violations committed against Ms. Doe are serious, (2) Epstein's criminal behavior was outrageous and notorious; he victimized over a hundred young girls and women, inclusive of Ms. Doe, over the course of more than a decade, and (3) the relief sought in federal court is critically important to Ms. Doe and her ability to prove the degree of abuse she suffered at the hands of Jeffrey Epstein and his friends or associates. Ms. Doe strongly believes that pursuing her claims in federal court will give her and other victims a sense that justice was served. While + +the Victims' Compensation Program offered monetary compensation, it did not provide victims, in particular Ms. Doe, the opportunity to expose Epstein in a court of law for the monster he was. Instead of accepting a monetary settlement, Ms. Doe opted for her "day in court." The relief sought by [REDACTED] Doe will ultimately prove that our judicial system works; however, in order to have the opportunity to achieve the justice she deserves, it is essential that she obtain from the Government those documents and information requested herein. + +To that end, we specifically seek copies of the following documents that we believe are currently in the possession of the Government: + +1. 1) Photographs of [REDACTED] Doe; +2. 2) Videos of [REDACTED] Doe; +3. 3) Any and all correspondence between Jeffrey Epstein, his agents, employees, medical providers, or attorneys and [REDACTED] Doe; +4. 4) Any and all correspondence between Jeffrey Epstein, his agents, employees, medical providers, or attorneys about [REDACTED] Doe or which reference [REDACTED] Doe; +5. 5) Any and all records of purchases of gifts or anything of value purchased for or sent to [REDACTED] Doe; +6. 6) Any and all records showing that a letter or package was sent via U.S. Mail, UPS, FedEx, or by any other means of shipping from Jeffrey Epstein, his agents, or his employees to [REDACTED] Doe; +7. 7) Any and all records of payments made to medical providers on behalf of [REDACTED] Doe; +8. 8) Any and all records of payments made to attorneys on behalf of [REDACTED] Doe; +9. 9) Any and all records of payments made to accountants on behalf of [REDACTED] Doe; +10. 10) Any and all records of payments made to [REDACTED] Doe; +11. 11) Any and all documents referencing [REDACTED] Doe residing at 301 East 66th Street, New York; +12. 12) Any and all documents obtained from property belonging to Jeffrey Epstein that contains [REDACTED] Doe's true name; +13. 13) Any and all lists containing or including [REDACTED] Doe's true name or any part thereof; and +14. 14) Any and all other documentary materials relating in any way to [REDACTED] Doe. + +28 C.F.R. 16.24 (d) (1) addresses the resolution of disclosure demands. We are willing to engage in discussions and negotiate a resolution to the request pursuant to section 16.24 (d)(1)(ii). Please contact us at your earliest convenience to discuss [REDACTED] Doe's case in more detail, at which time we are fully prepared to answer any questions that you may have and resolve this matter. + +Very truly yours, +EDWARDS POTTINGER LLC + +![]()Bradley Edwards +Brittany Henderson +BJE:mwk + +![](_page_3_Picture_0.jpeg) + +Florida Office + +Bradley J. Edwards\*\* + +Seth M. Lehman st + +Brittany N. Henderson "0 + +Matthew D. Weissing "I + +### VIA E-MAIL AND FEDEX + +The Honorable Geoffrey S. Berman United States Attorney for the Southern District of New York + +Assistant United States Attorney 86 Chambers Street, Third Floor New York. New York 10007 + +EDWARDS POTTING ER LLC + +425 North Andrews Avenue Suite 2 Fort Lauderdale, FL 33301 + +October 15, 2020 + +New York Office + +J. Stanley Pottinger t + +j Adinetteal Caltfomo o Admitted a, remit of Columba + +• Admitted in Honda + +Admitted in Nev York + +Board Cnctifird Cirl Teal Lawyer + +Re: I, for Tangible and Documentary Evidence (Touhy Request) Doe v. Darren K. I ndyke, et al., SDNY Case No. 1:19-cv-07772 + +Dear Mr. + +In follow up to our previous communications, please accept this as our formal written request for documentary and tangible evidence currently in the in the possession, custody, and control of the Department of Justice by way of the Southern District of New York relating to the sexual abuse of one of Jeffrey Epstein's many victims, Doe.' See United States ex rel. Touhy v. Ragen, 340 U.S. 462 (1951). We make this written request pursuant to the Touhy regulations codified as 28 C.F.R. § 16.21 et seq. Should you find there to be any deficiencies within this request, please notify us and we will do what is necessary to correct any such shortcomings. + +Doe + +Doe was sexually assaulted by prolific pedophile, Jeffrey Epstein, from 2006 through 2013. Frowlhe me they met when she was only twenty years old, Epstein sexually abused and assaulted Doe in the most horrific ways imaginable. Throughout the years of abuse, Epstein purchased a number of commercial flights, provided housing, and purchased a number of + +I To protect her anonymity, our client has elected to proceed as a Doe. As such, we have referred to her herein using the pseudonym under which she has filed her lawsuit. To the extent that her identity is not already known by the prosecutors in the Southern District of New York, please contact us at your earliest convenience to discuss her true identity. + +items of value for Doe, record of which we believe is currently in the Government's possession as a result of the investigation that was conducted into Epstein's criminal activity relating to I abuse of minor children. Given the highly relevant nature of this tangible evidence to 's currently pending litigation, we request production of documentary evidence relating to Doe in order to enable her to prove her claims from both a liability and damages standpoint. + +We specifically seek copies of the following documents that we believe are currently in the possession of the Government: + +- 1) Photograph.. r Doe; +- 2) Videos of Doc; +- 3) Any and all correspondence between Jeffrey Epstein, his agents, employees, medical providers, or attorneys and Doe; +- 4) An and all records of purchases of gifts or anything of value purchased for or sent to Doe; +- 5) Arty and all records showing that a letter or package was sent via U.S. Mail, UPS, FedEx, or by other means of shipping from Jeffrey Epstein, his agents, or his employees to Doe; +- 6) Any and all records of payments made to medical providers on behalf of Doe; +- 7) Any and all records of payments made to attorneys on behalf of Doe; +- 8) Any and all records of payments made to accountants on behalf of Doe; +- 9) Any and all documents referencing Doe residing at 301 East 66th Street, New York; +- 10) Any and all documents includin Doe's true name; +- 11) Any and all lists including Doe's true name; and +- 12) Any and all other documentary materials relating in any way to Doe. + +Pursuant to the Touhy regulations set forth by the Department of Justice, the Deputy or Associate Attorney General assesses the following considerations in determining whether disclosure is warranted: + +(a)(1) Whether such disclosure is appropriate under the rules of procedure governing the case or mater in which the demand arose; (a)(2) Whether disclosure is appropriate under the relevant substantive law of privilege. This request satisfies both of these considerations. As explained previously, the requested non-privileged documentary evidence directly concerns the allegations in Doe's civil case. + +M re establishment of the Epstein Victim Compensation Program that is currently underway, Doe seeks this information on an expedited basis in order to properly and completely present her claim for consideration, and if necessary, to continue to proceed by way of formal litigation. The requested information is within the scope of ordinary practice and does not seek disclosure of information prohibited by statute or regulation. Furthermore, this request does not + +seek info at is classified or that would reveal the source or identity of any informant. To that effect, Doe specifically does not request any investigatory records compiled for law enforcement purposes that would interfere with ongoing law enforcement proceedings. Doe simply requests information in the Government's possession that will assist in the prosecution of her claims and ultimately, aid in her ability to finally obtain Sistice tI that she deserves. To the extent that the requested materials can be made available to Doe on an expedited basis, it would be greatly appreciated. + +Please contact us at your earliest convenience to discuss the identity of Doe in more detail, at which time we are fully prepared to answer any questions that you may have. + +Very truly yours, + +EDWARDS POTTINGER LLC + +Bradley Edwards Brittany Henderson + +From: To: Subject: Date: TraddnollodatooDfodpx Marla Kellktlbn FedEx Shipment 771814211816: Thls shipment is scheduled to be sere Thursday, October 15, 2020 5:52:59 PM + +![](_page_6_Picture_1.jpeg) + +# Hi. This shipment is scheduled to be sent on Thu 10/15/2020. + +![](_page_6_Picture_3.jpeg) + +41 The delivery date may be updated when FedEx receives the package. + +Estimated delivery date + +Fri, 10/16/2020 by 4:30pm + +![](_page_6_Picture_7.jpeg) + +INITIATED + +MANAGE DELIVERY + +TRACKING NUMBER + +![](_page_6_Picture_11.jpeg) + +FROM Edwards Pottinger LLC + +![](_page_7_Picture_1.jpeg) + +TO United StatesStates Attorne + +![](_page_7_Picture_3.jpeg) + +PACKAGING TYPE FedEx Envelope + +ORIGIN + +![](_page_7_Picture_6.jpeg) + +DESTINATION + +STANDARD TRANSIT Fri, 10/16/2020 by 4:30pm + +NUMBER OF PIECES 1 + +TOTAL SHIPMENT WEIGHT 0.50 LB + +SERVICE TYPE FedEx Standard Overnight + +# Download the Fed Ex® Mobile app + +![](_page_7_Picture_12.jpeg) + +Get the flexibility you need to create shipments and request to customize your deliveries through the app. + +( LEARN MORE ) + +![](_page_8_Picture_0.jpeg) + +The following is the proof-ofdeivery for backing number 771814211816 + +#### Delivery Information: + +Status: Delivered + +Signed for by: + +Service type: FedEx Standard Overnight + +Special Handing: Delver Weekday Delivered To: + +Delivery Location: + +Delivery date: + +NEW YORK, NY. + +Oct 16, 2020 10:10 + +### Shipping Information: + +![](_page_8_Picture_16.jpeg) + +Wei" + +Oct15,2020 + +![](_page_8_Picture_22.jpeg) + +Proof-of-delivery details appear below; however, no signature is available for this FedEx Express shipment because a signature was not required. + +**From:** Maria Kelljchian +**To:** [busdoj.gov](mailto:busdoj.gov) +**Cc:** Brad Edwards; Brittany Henderson +**Subject:** Edwards Pottinger Touhy Requests +**Date:** Thursday, October 15, 2020 5:37:00 PM +**Attachments:** [2020-10-15](#) [Doe Touhy Request.pdf](#) +[2020-10-15](#) [Doe Touhy Request.pdf](#) +[image001.pdf](#) +[2020-10-15](#) [Doe Touhy Request.pdf](#) +[2020-10-14](#) VF Touhy Request.pdf +[2020-10-15](#) [Doe Touhy Request.pdf](#) +[2020-10-15](#) [Doe 2 Touhy Request.pdf](#) + +--- + +Good afternoon. Please see attached from Brad Edwards. + +Thank you, +Maria + +![](_page_9_Picture_10.jpeg) + +Maria W. Kelljchian +Florida Registered Paralegal + +![](_page_9_Picture_12.jpeg) + +![](_page_10_Picture_0.jpeg) + +Florida Office + +Bradley J. Edwards \*0f + +Seth M. Lehrman st + +Brittany N. Henderson \*0 + +Matthew D. Weissing + +EDWARDS POTTINGER LLC + +425 North Andrews Avenue Suite 2 Fort Lauderdale, Fl. 33301 + +October 21, 2020 + +# FOIA PRIVACY EXEMPTION + +## VIA E-MAIL AND FEDEX + +The Honorable Geoffrey S. Berman United States Attorney for the Southern District of New York + +Assistant United States Attorney 86 Chambers Street, Third Floor New Yor1 New York 10007 . OV + +New York Office + +J. Stanley Pottinger t + +Adnutud in California 0 Adulated in Ihitriet of Columba + +• Admitted in Honda + +t Admitted in New York I Doan; Cavilled Civil 'Emil lainfer + +Re: abest for Tangible and Documentary Evidence (Touhy Request) Doe v. Darren K. Indyke, et al., SDNY Case No. 1:19-cv-07772 Victim: + +Dear Mr. + +In follow up to our previous communications, please accept this as our formal written request for documentary and tangible evidence currently in the in the possession, custody, and control of the Department of Justice by way of the Southern District of New York relating to the sexual abuse of one of Jeffrey Epstein's many victims, Doe.I See United States ex rel. Touhy v. Raga:, 340 U.S. 462 (1951). We make this written request pursuant to the Touhy regulations codified as 28 C.F.R. § 16.21 et seq. Should you find there to be any deficiencies within this request, please notify us and we will do what is nerncary to correct any such shortcomings. + +Doe + +Doe was sexually assaulted by prolific pedophile, Jeffrey Epstein, from 2006 through 2013. From the time they met when she was only twenty years old, Epstein sexually abused and + +I To protect her anonymity, our client, has elected to proceed as a we have referred to her herein using the pseudonym under which she has filed her lawsuit. Doe. As such, + +assaulted Doe in the most horrific ways imaginable. Throughout the years of abuse, Epstein purchased a number of commercial flights, provided housing, and purchased a number of items of value for Doe, record of which we believe is currently in the Government's possession as a result of the investigation that was conducted into Epstein's criminal activity relating to tl of minor children. Given the highly relevant nature of this tangible evidence to ' currently pending litigation, we request production of documentary evidence relating to Doe in order to enable her to prove her claims from both a liability and damages standpoint. + +We specifically seek copies of the following documents that we believe are currently in the possession of the Government: + +- 1) Photographs of Doe; +- 2) Videos of Doe; +- 3) Any and all correspondence between Jeffrey Epstein, his agents, employees, medical providers, or attorneys and Doe; +- 4) An all records of purchases of gifts or anything of value purchased for or sent to Doe; +- 5) Any and all records showing that a letter or package was sent via U.S. Mail, UPS, FedEx, 1 any other means of shipping from Jeffrey Epstein, his agents, or his employees to Doe; +- 6) Any and all records of payments made to medical providers on behalf of Doe; +- 7) Any and all records of payments made to attorneys on behalf of Doe; +- 8) Any and all records of payments made to accountants on behalf of Doe; +- 9) Any and all documents referencing Doe residing at 301 East 66th Street, New York; +- 10) Any and all documents including Doe's true name; +- 11) Any and all lists including Doe's true name; and +- 12) Any and all other documentary materials relating in any way to Doe. + +Pursuant to the Touhy regulations set forth by the Department of Justice, the Deputy or Associate Attorney General assesses the following considerations in determining whether disclosure is warranted: + +(aX1) Whether such disclosure is appropriate under the rules of procedure governing the case or mater in which the demand arose; (aX2) Whether disclosure is appropriate under the relevant substantive law of privilege. This request satisfies both of these considerations. As explained previously, the requested non-privileged documentary evidence directly concerns the allegations in Doe's civil case. + +S le establishment of the Epstein Victim Compensation Program that is currently underway, Doe seeks this information on an expedited basis in order to properly and completely present her claim for consideration, and if necessary, to continue to proceed by way of formal litigation. The requested information is within the scope of ordinary practice and does not seek disclosure of information prohibited by statute or regulation. Furthermore, this request does not seek inforitint is classified or that would reveal the source or identity of any informant. To that effect, Doe specifically does not request any investigatory records compiled for law enforcement purposes that would interfere with ongoing law enforcement proceedings. Doe simply requests information in the Government's possession that will assist in the prosecution of her claims and ultimately, aid in her ability to finally obtain that she deserves. To the extent that the requested materials can be made available to Doe on an expedited basis, it would be greatly appreciated. + +Please contact us at your earliest convenience to discuss the identity of Doe in more detail, at which time we are fully prepared to answer any questions that you may have. + +Very truly yours, + +EDWARDS POTTINGER LLC + +Bradley Edwards Brittany Henderson + +From: To: Cc: EcC Subject Dab: Attachmentm lirsollatords &lianaleadasga MadaSadecial RE: Edwards Pottinger Touhy Requests Wednesday, 0ctoh& 21, 2020 6:15:00 PM ZQZQ•10.21 VF Taub,/ PeriheliaIf + +Good afternoon. Please see attached from Brad Edwards. + +Thank you, Maria + +![](_page_13_Picture_3.jpeg) + +EDWARDS POTTINGER LLC + +Maria W. 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    , (USANYS)" Cc: ' " SANYS " H + +Subject: Voicemail from Congresswoman Frankel + +Date: The, 27 Jul 2021 23:51:00 +0000 + +Attachments: voicemail-837.m4a + +ancM, + +This afternoon, I received the attached voicemail on my cellphone. Jack Scarola, who represents had told me that someone from Congress had reached out to him about the Epstein case, and Jack said he'd provided them with my cellphone number. + +When would be a good time to discuss? + +Thanks, \ No newline at end of file diff --git a/marker2/ds9/EFTA00090491/EFTA00090491.metadata.json b/marker2/ds9/EFTA00090491/EFTA00090491.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..0c62a9ae5999a60af1d72d7f3ddc9dcc28bea276 --- /dev/null +++ b/marker2/ds9/EFTA00090491/EFTA00090491.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090491.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 469, + "elapsed_seconds": 0.5, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 34 + ], + [ + "Line", + 15 + ], + [ + "Text", + 9 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00090491" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00090493/EFTA00090493.md b/marker2/ds9/EFTA00090493/EFTA00090493.md new file mode 100644 index 0000000000000000000000000000000000000000..d61ac5f176a4878eee3af92ccb2656cbd2df4523 --- /dev/null +++ b/marker2/ds9/EFTA00090493/EFTA00090493.md @@ -0,0 +1,36 @@ +![](_page_0_Picture_81.jpeg) + +*United States Attorney +Southern District of New York* + +*The Silvio J. Mollo Building +One Saint Andrew's Plaza +New York, New York 10007* + +July 28, 2021 + +**VIA FEDERAL EXPRESS** + +MDC—Metropolitan Detention Center +Legal Department +80 29th Street +Brooklyn, NY 11232 + +**Re: *United States v. Ghislaine Maxwell*, 20 Cr. 330 (AJN)** + +Enclosed are witness materials and discovery pertinent to the following inmate: + +- • Ghislaine Maxwell: 02879-509 + +Please allow her access to the materials enclosed. + +Very truly yours, + +AUDREY STRAUSS +United States Attorney + +by: + +[REDACTED] + +*Enclosure* \ No newline at end of file diff --git a/marker2/ds9/EFTA00090493/EFTA00090493.metadata.json b/marker2/ds9/EFTA00090493/EFTA00090493.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..f02ac4894b1f94c9b79bfef60a3ecce31eff99ed --- /dev/null +++ b/marker2/ds9/EFTA00090493/EFTA00090493.metadata.json @@ -0,0 +1,115 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090493.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 636, + "elapsed_seconds": 3.53, + "image_assets": [ + "_page_0_Picture_81.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "U.S. Department of Justice", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 318.24, + 25.11 + ], + [ + 462.67199999999997, + 25.11 + ], + [ + 462.67199999999997, + 40.5 + ], + [ + 318.24, + 40.5 + ] + ] + }, + { + "title": "VIA FEDERAL EXPRESS", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 67.932, + 168.48 + ], + [ + 212.36399999999998, + 168.48 + ], + [ + 212.36399999999998, + 182.25 + ], + [ + 67.932, + 182.25 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 43 + ], + [ + "Text", + 24 + ], + [ + "Line", + 21 + ], + [ + "SectionHeader", + 4 + ], + [ + "Picture", + 2 + ], + [ + "ListGroup", + 2 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00090493" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00090493/_page_0_Picture_81.jpeg b/marker2/ds9/EFTA00090493/_page_0_Picture_81.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..362ae342dd633cc29ee50d8b8c12aa26b47814bd --- /dev/null +++ b/marker2/ds9/EFTA00090493/_page_0_Picture_81.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:cd3054a77d81508b5861dcea097279bcc9e52540f18b3d38da51e343df326546 +size 3473 diff --git a/marker2/ds9/EFTA00090494/EFTA00090494.md b/marker2/ds9/EFTA00090494/EFTA00090494.md new file mode 100644 index 0000000000000000000000000000000000000000..9438594b6139fedc8fcd9582835a91b1d60ddefd --- /dev/null +++ b/marker2/ds9/EFTA00090494/EFTA00090494.md @@ -0,0 +1,303 @@ +UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +United States of America, + +—v— + +Ghislaine Maxwell, + +Defendant. + +| USDC SDNY | | +|----------------------|---------| +| DOCUMENT | | +| ELECTRONICALLY FILED | | +| DOC #: | | +| DATE FILED: | 4/16/21 | + +20-cr-330 (MN) + +OPINION & ORDER + +ALISON J. NATHAN, District Judge: + +In June 2020, a grand jury returned a six-count indictment charging Ghislaine Maxwell with facilitating the late financier Jeffrey Epstein's sexual abuse of minor victims from around 1994 to 1997. The Government filed a first (S1) superseding indictment shortly thereafter, which contained only small, ministerial corrections. The SI superseding indictment included two counts of enticement or transportation of minors to engage in illegal sex acts in violation of the Mann Act and two counts of conspiracy to commit those offenses. It also included two counts of perjury in connection with Maxwell's testimony in a civil deposition. Trial is set to begin on July 12, 2021. + +Maxwell filed twelve pretrial motions seeking to dismiss portions of the Si superseding indictment, suppress evidence, and compel discovery. After the parties fully briefed those motions, a grand jury returned a second (S2) superseding indictment adding a sex trafficking count and another related conspiracy count. + +This Opinion resolves all of Maxwell's currently pending pretrial motions other than those seeking to suppress evidence, which the Court will resolve in due course. The motions, and this Opinion, deal exclusively with the S 1 superseding indictment and do not resolve any issues + +related to the newly added sex trafficking charges. For the reasons that follow, the Court denies Maxwell's motions to dismiss the SI superseding indictment in whole or in part. It grants her motion to sever the perjury charges for a separate trial. It denies her motion to further expedite discovery. + +The Court provides a brief summary of its conclusions here and its reasoning on the pages that follow: + +- Maxwell moves to dismiss all counts based on a non-prosecution agreement between Jeffrey Epstein and the U.S. Attorney for the Southern District of Florida. The Court concludes that the agreement does not apply in this District or to the charged offenses. +- Maxwell moves to dismiss all counts as untimely. The Court concludes that the Government brought the charges within the statute of limitations and did not unfairly delay in bringing them. +- Maxwell moves to dismiss the Mann Act counts because they are too vague, or in the alternative to require the Government to describe the charges in greater detail. The Court concludes that the charges are specific enough. +- Maxwell moves to dismiss the perjury counts because, in her view, her testimony responded to ambiguous questioning and was not material. The Court concludes that these issues are best left for the jury. +- Maxwell moves to sever the perjury counts from the Mann Act counts so that they can proceed in a separate trial. The Court concludes that severance is appropriate and will try the perjury counts separately. +- Maxwell moves to strike language from the indictment that she believes is superfluous and to dismiss conspiracy counts she believes are redundant. The Court concludes that these motions are premature before trial. +- Maxwell moves to compel the Government to immediately disclose certain categories of evidence. The Court concludes that she is not entitled to do so, but the Court will order Maxwell and the Government to confer on a discovery schedule. +- Maxwell moves to dismiss all counts because a grand jury in White Plains, rather than Manhattan, returned the Si superseding indictment. Because a jury in Manhattan returned the S2 superseding indictment, the motion appears moot. + +#### I. Jeffrey Epstein's non-prosecution agreement does not bar this prosecution + +In September 2007, under investigation by both federal and state authorities, Jeffrey Epstein entered into a non-prosecution agreement ("NPA") with the Office of the United States Attorney for the Southern District of Florida. Dkt. No. 142 at 1-2. Epstein agreed in the NPA to plead guilty in Florida state court to soliciting minors for prostitution and to serve eighteen months in a county jail. Id. In exchange, the U.S. Attorney's Office agreed not to charge him with federal crimes in the Southern District of Florida stemming from its investigation of his conduct between 2001 and 2007. Id. It also agreed not to bring criminal charges against any of his "potential co-conspirators." Id. + +As a recent report from the Department of Justice's Office of Professional Responsibility observed, the NPA was unusual in many respects, including its breadth, leniency, and secrecy. OPR Report, Gov. Ex. 3, Dkt. No. 204-3, at x, 80, 175, 179, 260-61. The U.S. Attorney's promise not to prosecute unidentified co-conspirators marks a stark departure from normal practice for federal plea agreements. This provision appears to have been added "with little discussion or consideration by the prosecutors." Id. at 169, 185. The report concluded that the U.S. Attorney's negotiation and approval of the NPA did not amount to professional misconduct, but nonetheless reflected "poor judgment." Id. at 169. + +Only the NPA's effect, and not its wisdom, is presently before the Court. Maxwell contends that the NPA bars this prosecution, because she is charged as a co-conspirator of Jeffrey Epstein and the NPA's co-conspirator provision lacks any geographical or temporal limitations. The Court disagrees for two independent reasons. First, under controlling Second Circuit precedent, the NPA does not bind the U.S. Attorney for the Southern District of New York. Second, it does not cover the offenses charged in the S1 superseding indictment. + +#### A. The non-prosecution agreement does not hind the U.S. Attorney for the Southern District of New York + +United States Attorneys speak for the United States. When a U.S. Attorney makes a promise as part of a plea bargain, both contract principles and due process require the federal government to fulfill it. See Santobello v. New York, 404 U.S. 257, 262 (1971); United States v. Ready, 82 F.3d 551, 558 (2d Cir. 1996). The question here is not whether the U.S. Attorney for the Southern District of Florida had the power to bind the U.S. Attorney for the Southern District of New York. The question is whether the terms of the NPA did so. Applying Second Circuit precedent and principles of contract interpretation, the Court concludes that they did not. + +In United States v. Annabi, the Second Circuit held: "A plea agreement binds only the office of the United States Attorney for the district in which the plea is entered unless it affirmatively appears that the agreement contemplates a broader restriction." 771 F.2d 670, 672 (2d Cir. 1985) (per curiam). This is something akin to a clear statement rule. Single-district plea agreements are the norm. Nationwide, unlimited agreements are the rare exception. Applying Annabi, panels of the Second Circuit have stated that courts cannot infer intent to depart from this ordinary practice from an agreement's use of phrases like "the government" or "the United States." United States v. Salameh, 152 F.3d 88, 120 (2d Cir. 1998) (per curiam); United States v. Gonzalez, 93 F. App'x 268, 270 (2d Cir. 2004). Those are common shorthand. A plea agreement need not painstakingly spell out "the Office of the United States Attorney for Suchand-Such District" in every instance to make clear that it applies only in the district where signed. + +Maxwell asks this Court to draw the opposite conclusion. The provision of the NPA dealing with co-conspirators does not expressly state that it binds U.S. Attorneys in other districts. It does not expressly state that it applies in other districts. The relevant language, in + +its entirety, reads as follows: "the United States also agrees that it will not institute any criminal charges against any potential co-conspirators of Epstein." Dkt. No. 142-1 at 5. Under Annabi, Salatneh, and Gonzalez, a statement that "the United States" agrees not to prosecute implies no restriction on prosecutions in other districts. + +Two provisions of the NPA refer specifically to prosecution in the Southern District of Florida. The first states that the U.S. Attorney for the Southern District of Florida will defer "prosecution in this District" if Epstein complies with the agreement. Dkt. No. 142-1 at 2. The second states that no prosecution "will be instituted in this District, and the charges against Epstein if any, will be dismissed" after he fulfills the agreement's conditions. Maxwell contends that the lack of similar language in the co-conspirator provision must mean that it lacks any geographical limitation. If anything, that language reflects that the NPA's scope was expressly limited to the Southern District of Florida. It is not plausible—let alone "affirmatively apparent", Annabi, 771 F.2d at 672,—that the parties intended to drastically expand the agreement's geographic scope in the single sentence on the prosecution of co-conspirators without clearly so saying. + +Without an affirmative statement in the NPA's text, Maxwell turns to its negotiation history. Under Second Circuit precedent she may offer evidence that negotiations of the NPA between the defendant and the prosecutors included a promise to bind other districts. See United States v. Russo, 801 F.2d 624, 626 (2d Cir. 1986). She alleges that officials in the U.S. Attorney's Office for the Southern District of Florida sought and obtained approval for the NPA from the Office of the Deputy Attorney General and communicated with attorneys in other districts. Any involvement of attorneys outside the Southern District of Florida appears to have been minimal. Maxwell has already received access to an unusually large amount of information about the NPA's negotiation history in the form of the OPR report and yet identifies no evidence that the Department of Justice made any promises not contained in the NPA. The OPR report reflects that the Office of the Deputy Attorney General reviewed the NPA, but only after it was signed when Epstein tried to get out of it. OPR Report at 103. Other documents show that attorneys in the Southern District of Florida reached out to other districts for investigatory assistance but not for help negotiating the NPA. Dkt. No. 204-2. Nor would direct approval of the NPA by the Office of the Deputy Attorney General change the meaning of its terms. No evidence suggests anyone promised Epstein that the NPA would bar the prosecution of his coconspirators in other districts. Absent such a promise, it does not matter who did or did not approve it. + +Second Circuit precedent creates a strong presumption that a plea agreement binds only the U.S. Attorney's office for the district where it was signed. Maxwell identifies nothing in the NPA's text or negotiation history to disturb this presumption. The Court thus concludes that the NPA does not bind the U.S. Attorney for the Southern District of New York. + +# B. The non-prosecution agreement does not cover the charged offenses + +The NPA would provide Maxwell no defense to the charges in the S1 superseding indictment even against an office bound to follow it. The NPA bars prosecution, following Epstein's fulfillment of its conditions, only for three specific categories of offenses: + +- (1) "the offenses set out on pages 1 and 2" of the NPA; namely, "any offenses that may have been committed by Epstein against the United States from in or around 2001 through in or around September 2007" including five enumerated offenses; +- (2) "any other offenses that have been the subject of the joint investigation by the Federal Bureau of Investigation and the United States Attorney's Office"; and +- (3) "any offenses that arose from the Federal Grand Jury investigation." + +Dkt. No. 142-1 at 2. The NPA makes clear that the covered charges are those relating to and deriving from a specific investigation of conduct that occurred between 2001 and 2007. + +Maxwell contends that the NPA's co-conspirator provision lacks any limitation on the offenses covered. The Court disagrees with this improbable interpretation. The phrase "potential co-conspirator" means nothing without answering the question "co-conspirator in what?" The most natural reading of the co-conspirator provision is that it covers those who conspired with Epstein in the offenses covered by the NPA for their involvement in those offenses. Thus, it would cover any involvement of Maxwell in offenses committed by Epstein from 2001 to 2007, other offenses that were the subject of the FBI and U.S. Attorney's Office investigation, and any offenses that arose from the related grand jury investigation. + +The Court has no trouble concluding that the perjury counts are not covered by the NPA. Those charges do not relate to conduct in which Maxwell conspired with Epstein and stem from depositions in 2016, more than eight years after Epstein signed the NPA. Maxwell now concedes as much, though her motion sought to dismiss the Si superseding indictment in its entirety, perjury counts and all. + +The Mann Act counts, too, fall comfortably outside the NPA's scope. The Si superseding indictment charges conduct occurring exclusively between 1994 and 1997, some four years before the period covered by the Southern District of Florida investigation and the NPA. The NPA does not purport to immunize Epstein from liability for crimes committed before the period that was the subject of the FBI and U.S. Attorney's Office investigation. Maxwell's protection is no broader. The Court thus concludes that the NPA does not cover the offenses charged in the SI superseding indictment. + +#### C. Maxwell is not entitled to an evidentiary hearing + +In the alternative to dismissing the indictment, Maxwell requests that the Court conduct an evidentiary hearing as to the parties' intent in the NPA. The Court finds no basis to do so. + +The cases Maxwell cites where courts held hearings on the scope of a plea agreement mostly involved oral agreements where there was no written record of the full set of terms reached by the parties. All of them involved defendants with first-hand knowledge of negotiations who claimed prosecutors breached an oral promise. "An oral agreement greatly increases the potential for disputes such as . .. a failure to agree on the existence, let alone the terms, of the deal." United States v. Aleman, 286 F.3d 86, 90 (2d Cir. 2002). Thus, an evidentiary hearing may be necessary to determine the terms of an agreement never committed to writing. This is no such case. The NPA's terms are clear. Beyond the NPA itself, an extensive OPR report details its negotiation history. No record evidence suggests that prosecutors promised Epstein anything beyond what was spelled out in writing. The Court agrees with the Government that Maxwell's request for a hearing rests on mere conjecture. + +For the same reason, the Court will not order the discovery on the NPA. In any case, it appears that the Government has already produced two of the documents Maxwell seeks in her motion—the OPR report and notes mentioned in a privilege log. Of course, the Government's disclosure obligations would require it to disclose to Maxwell any exculpatory evidence or evidence material to preparing the defense, including any evidence supporting a defense under the NPA. The Government shall confirm in writing within one week whether it views any evidence supporting Maxwell's interpretation of the NPA as material it is required to disclose, and, if so, whether it has disclosed any and all such evidence in its possession. + +#### II. The indictment is timely + +### A. The indictment complies with the statute of limitations + +Federal law imposes a five-year limitations period for most non-capital offenses. 18 U.S.C. § 3282(a). Recognizing the difficulty of promptly prosecuting crimes against children, Congress has provided a longer limitations period for "offense[s] involving the sexual or physical abuse, or kidnaping" of a minor. 18 U.S.C. § 3283. Until 2003, the operative version of § 3283 allowed prosecution of these offenses until the victim reached the age of twenty-five. Congress further extended the limitations period in the PROTECT Act of 2003, Pub. L. No. 108- 21, 117 Stat. 650, to allow prosecution any time during the life of the victim. + +The parties agree that the Mann Act charges are timely if subject to the PROTECT Act, but untimely under the general statute of limitations for non-capital offenses or the pre-2003 version of § 3283. Maxwell contends that the charged offenses do not qualify as offenses involving the sexual or physical abuse or kidnapping of a minor and are thus governed by the general statute of limitations. Alternatively, she contends that the pre-2003 version of § 3283 applies because the charged conduct occurred prior to 2003. The Court concludes that statute of limitations in the PROTECT Act applies and that the charges are timely. + +# 1. The Mann Act charges are offenses involving the sexual abuse of minors + +Maxwell does not dispute that the facts alleged in the SI superseding indictment involve the sexual abuse of minors. The indictment charges that Epstein sexually abused each of the alleged minor victims and that Maxwell allegedly enticed them to travel or transported them for that purpose. Instead, Maxwell contends that charged offenses do not qualify as offenses involving the sexual abuse of minors because sexual abuse is not an essential ingredient of each statutory offense. See Bridges v. United States, 346 U.S. 209, 221 (1953). In Maxwell's view, + +for example, it is possible to transport a minor with intent to engage in criminal sexual activity and not follow through with the planned sexual abuse, and so sexual abuse is not an essential ingredient of the offense. Maxwell makes the same argument for the enticement and related conspiracy charges. + +This approach is analogous to the "categorical approach" employed by courts to evaluate prior convictions for immigration and sentencing purposes. See Taylor v. United States, 495 U.S. 575, 602 (1990). Generally speaking, the "categorical approach" requires that courts "look only to the statutory definitions—i.e., the elements" of the relevant offense to determine if the provision applies "and not to the particular facts underlying those convictions." Descamps v. United States, 570 U.S. 254, 261 (2013) (internal quotation marks omitted). Whether a statute requires a categorical or case-specific approach is a question of statutory interpretation. To determine whether Congress used the word "offense" in a statute to refer to an offense in the abstract or to the facts of each individual case, the Court must examine the statute's "text, context, and history." United States v. Davis, 139 S. Ct. 2319, 2327 (2019). + +Though it has not authoritatively settled the question, the Second Circuit has strongly suggested that Maxwell's approach is the wrong one. In Weingarten v. United States, 865 F.3d 48, 58-60 (2d Cir. 2017), the Second Circuit discussed at length how the text, context, and history of § 3283 show that Congress intended courts to apply the statute using a case-specific approach. The Third Circuit reached the same conclusion in United States v. Schneider, 801 F.3d 186, 196 (3d Cir. 2015). + +The Court sees no reason to depart from the reasoning in Weingarten. First, "[t]he Supreme Court's modem categorical approach jurisprudence is confined to the post-conviction contexts of criminal sentencing and immigration deportation cases." Weingarten, 865 F.3d at 58. To the extent that the categorical approach is ever appropriate in other contexts, it is inappropriate here. + +The Court begins with the statute's text. Statutes that call for application of the categorical approach typically deal with the elements of an offense in a prior criminal conviction. Id. at 59. "The language of § 3283, by contrast, reaches beyond the offense and its legal elements to the conduct involv[ed]' in the offense. That linguistic expansion indicates Congress intended courts to look beyond the bare legal charges in deciding whether § 3283 applied." Id. at 59-60 (alteration in original) (quoting § 3283). Maxwell cites one case holding otherwise, but that case involved a venue statute presenting significantly different concerns. See United States v. Morgan, 393 F.3d 192, 200 (D.C. Cir. 2004). The Supreme Court has likewise held that a statute which uses the language "an offense that . . . involves fraud or deceit in which the loss to the victim or victims exceeds \$10,000" is "consistent with a circumstance-specific approach." Nijhawan v. Holder, 557 U.S. 29, 32, 38 (2009) (emphasis added). Thus, the word "involves" generally means that courts should look to the circumstances of an offense as committed in each case. This reading accords with a robust legislative history indicating that Congress intended to apply § 3283 to a wide range of crimes against children. See Weingarten, 865 F.3d at 60; Schneider, 801 F.3d at 196. + +The purposes underlying the categorical approach do not apply here either. For statutes dealing with prior convictions, "[t]tle categorical approach serves `practical' purposes: It promotes judicial and administrative efficiency by precluding the relitigation of past convictions in minitrials conducted long after the fact." Moncrieffe v. Holder, 569 U.S. 184, 200-01 (2013). In the context of § 3283, there is no prior conviction to assess, and the jury will determine in the first instance whether "the defendant engaged in the applicable abusive conduct." Weingarten, + +865 F.3d at 60. Maxwell nonetheless contends that using a case-specific approach for § 3283 would be impractical because the Government would need to prove conduct beyond the elements of the offense. It may be true that this approach requires the Government to prove some additional facts, but any statute-of-limitations defense presents factual issues (including, at least, when the alleged conduct took place). This is not a serious practical problem and does not justify setting aside the statute's language and apparent purpose. + +Maxwell relies primarily on Bridges v. United States, 346 U.S. 209 (1953), to urge this Court to cast Weingarten aside. The Supreme Court in Bridges addressed a statute that extended the limitations period for defrauding the United States during the Second World War. In that case, the Supreme Court first concluded that making false statements at an immigration hearing was not subject to the extended limitations period because it lacked any pecuniary element as required by the statute. Id. at 221. Then, as an alternative basis for its holding, it explained that the offense did not require fraud as an "essential ingredient." Id. at 222. It reached that conclusion in large part because the statute's legislative history made clear that Congress intended it to apply only to a narrow class of war frauds causing pecuniary loss. Id. at 216. + +As the Second Circuit explained in Weingarten, Congress had the opposite intent in the enacting in the PROTECT Act. Weingarten, 865 F.3d at 59 & n. 10. "In passing recent statutes related to child sex abuse, including extensions of the § 3283 limitations period, Congress `evinced a general intention to "'cast a wide net to ensnare as many offenses against children as possible."' Id. at 60 (quoting Schneider, 801 F.3d at 196 (quoting United States v. Dodge, 597 F.3d 1347, 1355 (I I th Cir. 2010) (en banc))). The primary basis for Bridges' holding legislative history supporting a narrow interpretation—does not exist here. Instead, both the statute's plan meaning and its legislative history suggest it should apply more broadly. + +Based on the statute's text, context, and history, the Court follows Weingarten and concludes that the appropriate inquiry is whether the charged offenses involved the sexual abuse of a minor on the facts alleged in this case. There is no question that they did. The Court thus concludes that § 3283 governs the limitations period for the charges here. + +### 2. The 2003 amendment to the statute of I. lations applies to these offenses + +Maxwell next contends that because the charged conduct took place before the PROTECT Act's enactment, that statute did not lengthen the statute of limitations applicable to her alleged offenses. Here too, the Second Circuit has provided guidance in its decision in Weingarten. Although the court did not provide a definitive answer there, it explained that the view Maxwell now takes conflicts with established principles of retroactivity and the decisions of at least two other circuit courts. Weingarten, 865 F.3d at 58 & n.8; see Cruz v. Maypa, 773 F.3d 138, 145 (4th Cir. 2014); United States v. Leo Sure Chief, 438 F.3d 920, 924 (9th Cir. 2006). + +The Supreme Court has set out a two-step framework to determine whether a federal statute applies to past conduct. See Landgraf v. USI Film Products, 511 U.S. 244, 280 (1994). Courts look first to the language of the statute. If the statute states that it applies to past conduct, courts must so apply it. Weingarten, 865 F.3d at 54. Otherwise, the statute applies to past conduct unless doing so would create impermissible retroactive effects. Id. + +The Court begins with Landgraf s first step. To assess a statute's meaning here, courts must consider the text of the statute along with other indicia of congressional intent, including the statute's history and structure. See Enter. Mortg. Acceptance Co., LLC, Sec. Litig. v. Enter. Mortg. Acceptance Co., 391 F.3d 401, 406 (2d Cir. 2004). + +Section 3283, as amended by the PROTECT Act, broadly states that "[n]o statute of limitations that would otherwise preclude prosecution for an offense involving the sexual or physical abuse, or kidnaping, of a child under the age of 18 years shall preclude such prosecution during the life of the child." The statute lacks an express retroactivity clause, but courts have held that no such clause is necessary, including for this particular statute. See Leo Sure Chief, 438 F.3d at 923. The statute's plain language unambiguously requires that it apply to prosecutions for offenses committed before the date of enactment. Instead of simply providing a new limitations period for future conduct, Congress stated that no statute of limitations that would otherwise preclude prosecution of these offenses will apply. That is, it prevents the application of any statute of limitations that would otherwise apply to past conduct. + +Courts have reached the same conclusion for other statutes employing similar language. The Eighth Circuit has held that the 1994 amendments to § 3283, which allowed prosecution of sex crimes against children until the victim reached age twenty-five, applied to past conduct. See United States v. Jeffries, 405 F.3d 682, 684-85 (8th Cir. 2005). The Second Circuit has observed that the Higher Education Technical Amendments of 1991, Pub. L. No. 102-26, 105 Stat. 123, illustrates language that requires a statute's application to past conduct. See Enter. Mortg. Acceptance Co., LLC, Sec. Litig., 391 F.3d at 407. That statute eliminated the statute of limitations for claims on defaulted student loans by stating that "no limitation shall terminate the period within which suit may be filed." Id. The PROTECT Act's language is quite similar. + +The history of § 3283 confirms Congress's intent to apply the extended limitations period as broadly as the Constitution allows. With each successive amendment to the statute, Congress further extended the limitations period, recognizing that sex crimes against children "may be difficult to detect quickly" because children often delay or decline to report sexual abuse. + +Weingarten, 865 F.3d at 54. Congress enacted the limitations provision of the PROTECT Act because it found the prior statute of limitations was "inadequate in many cases." H.R. Conf. Rep. No. 108-63, at 54 (2003). For example, a person who abducted and raped a child could not be prosecuted beyond this extended limit—even if DNA matching conclusively identified him as the perpetrator one day after the victim turned 25." Id. + +Maxwell makes no argument based on the statute's text. Instead, she contends that because the House version of the bill included an express retroactivity provision absent from its final form, the Court should infer that Congress did not intend the statute to apply to past conduct. However, the legislative history makes clear that Congress abandoned the retroactivity provision in the House bill only because it would have produced unconstitutional results. The Supreme Court has explained that a law that revives a time-barred prosecution violates the Ex Post Facto Clause of the Constitution, but a law that extends an un-expired statute of limitations does not. Stogner v. California, 539 U.S. 607, 632-33 (2003). Senator Leahy, who cosponsored the PROTECT Act, expressed concerns in a committee report that the proposed retroactivity provision was "of doubtful constitutionality" because it "would have revived the government's authority to prosecute crimes that were previously time-barred." 149 Cong. Rec. S5137, S5147 (Apr. 10, 2003) (statement of Sen. Leahy). Congress removed the provision shortly thereafter for this reason. The removal of the express retroactivity provision shows only that Congress intended to limit the PROTECT Act to its constitutional applications, including past conduct—like Maxwell's—on which the statute of limitations had not yet expired. + +Both the text and history of the PROTECT Act's amendment to § 3283 reflect that it applies Maxwell's conduct charged in the SI superseding indictment. The Court could stop here. However, it also concludes that even if the statute were ambiguous, it would properly apply to these charges. + +At Lanfgraf s second step, the Court asks whether application of the statute to past conduct would have impermissible retroactive effects. "[A] statute has presumptively impermissible retroactive effects when it 'takes away or impairs vested rights acquired under existing laws, or creates a new obligation, imposes a new duty, or attaches a new disability, in respect to transactions or considerations already past.' Weingarten, 865 F.3d at 56 (quoting Landgraf, 511 U.S. at 290). Thus, applying a new statute of limitations to previously timebarred claims has an impermissible retroactive effect. Enter. Mortg. Acceptance Co., LLC, Sec. Litig., 391 F.3d at 407. Applying it to conduct for which the statute of limitations has not yet expired does not. Vernon v. Cassadaga Valley Cent. Sch. Dist., 49 F.3d 886, 890 (2d Cir. 1995). + +Maxwell concedes that these offenses were within the statute of limitations when Congress enacted the PROTECT Act. Thus, the Act did not deprive her of any vested rights. Maxwell contends that it is unfair to allow the Government to prosecute her now for conduct that occurred more than twenty years ago, but there is no dispute that Congress has the power to set a lengthy limitations period or no limitations period at all. It has done so here, judging that the difficulty of prosecuting these offenses and the harm they work on children outweighs a defendant's interest in repose. Maxwell's fairness argument is a gripe with Congress's policy judgment, not an impermissibly retroactive application of the statute. The Court concludes that § 3283 allows her prosecution now. + +# B. The Government's delay in bringing charges did not violate due process + +"As the Supreme Court stated in United States v. Marion, the statute of limitations is 'the primary guarantee against bringing overly stale criminal charges.' United States v. Condelle, + +171 F.3d 748, 751 (2d Cir. 1999) (cleaned up) (quoting United States v. Marion, 404 U.S. 307, 322 (1971)). There is a strong presumption that an indictment filed within the statute of limitations is valid. To prevail on a claim that pre-indictment delay violates due process, a defendant must show both that the Government intentionally delayed bringing charges for an improper purpose and that the delay seriously damaged the defendant's ability defend against the charges. See id. This is a stringent standard. "Thus, while the [Supreme] Court may not have shut the door firmly on a contention that at some point the Due Process Clause forecloses prosecution of a claim because it is too old, at most the door is barely ajar." DeMichele v. Greenburgh Cent. Sch. Dist. No. 7, 167 F.3d 784, 790-91 (2d Cir. 1999). + +The Court sees no evidence that the Government's delay in bringing these charges was designed to thwart Maxwell's ability to prepare a defense. However, it is enough to say that Maxwell does not make the strong showing of prejudice required to support this sort of claim. Maxwell contends that the Government's delay in bringing charges has prejudiced her interests because potential witnesses have died, others have forgotten, and records have been lost or destroyed. It is highly speculative that any of these factors would make a substantial difference in her case. + +Maxwell first points to several potential witnesses who have passed away. These include Jeffrey Epstein and his mother, one individual Maxwell believes worked with one of the alleged victims in this case, and a police detective who investigated Epstein in Florida. She contends they all would have provided exculpatory testimony were they alive today. Courts have generally found that vague assertions that a deceased witness might have provided favorable testimony do not justify dismissing an indictment for delay. See, e.g., United States v. Scala, 388 F. Supp. 2d 396, 399-400 (S.D.N.Y. 2005). The Court agrees with this approach. Maxwell + +provides no indication of what many of these potential witnesses might have testified to. The testimony she suggests the detective might have offered—that witnesses in the Palm Beach investigation did not identify Maxwell by name—is propensity evidence that does nothing to establish her innocence of the charged offenses. There are also serious doubts under all of the relevant circumstances that a jury would have found testimony from Epstein credible even if he had waived his right against self-incrimination and testified on her behalf. See United States v. Spears, 159 F.3d 1081, 1085 (7th Cir. 1999). + +Maxwell's arguments that the indictment should be dismissed because of the possibility of missing witnesses, failing memories, or lost records fail for similar reasons. These are difficulties that arise in any case where there is extended delay in bringing a prosecution, and they do not justify dismissing an indictment. United States v. Marion, 404 U.S. 307, 325-26 (1971); see United States v. Elsbery, 602 F.2d 1054, 1059 (2d Cir. 1979). + +Finally, the Court finds no substantial prejudice from the pretrial publicity this case has garnered. Maxwell contends that lengthy public interest in this case has transformed her reputation from that of Epstein's friend to a co-conspirator. And she also alleges—without evidence—that her accusers fabricated their stories based on media allegations. The Court will not dismiss the indictment on Maxwell's bare assertion that numerous witnesses are engaged in a perjurious conspiracy against her. And the Court will take all appropriate steps to ensure that the pretrial publicity in this case does not compromise Maxwell's right to a fair and impartial jury. + +The Court thus concludes that Maxwell has failed to establish actual prejudice from the Government's delay in bringing charges. She may renew her motion if the factual record at trial shows otherwise. On the present record, neither the applicable statute of limitations nor due process bars the charges here. + +#### III. The indictment describes the charged offenses with specificity + +Maxwell seeks to dismiss the Mann Act counts for lack of specificity or in the alternative to compel the Government to submit a bill of particulars providing greater detail of the charges. The Court concludes that the charges in the S1 superseding indictment are clear enough. + +Under Federal Rule of Criminal Procedure 7, an indictment must contain "a plain, concise, and definite written statement of the essential facts constituting the offense charged." The indictment must be specific enough to inform the defendant of the charges and allow the defendant to plead double jeopardy in a later prosecution based on the same events. United States v. Stavrouiakis, 952 F.2d 686, 693 (2d Cir. 1992). "Under this test, an indictment need do little more than to track the language of the statute charged and state the time and place (in approximate terms) of the alleged crime." United States. v. Tramunti, 513 F.2d 1087, 1113 (2d Cir. 1975). In addition to dismissal, "Rule 7(f) of the Federal Rules of Criminal Procedure permits a defendant to seek a bill of particulars in order to identify with sufficient particularity the nature of the charge pending against him, thereby enabling defendant to prepare for trial, to prevent surprise, and to interpose a plea of double jeopardy should he be prosecuted a second time for the same offense." United States v. Bortnovsky, 820 F.2d 572, 574 (2d Cir. 1987). + +The S1 superseding indictment sets out the elements of each charged crime and the facts supporting each element. Nonetheless, Maxwell contends that the indictment is too vague because it refers to open-ended time periods, describes conduct like "grooming" and "befriending" that is not inherently criminal, and does not identify the alleged victims by name. + +Maxwell's first argument fails because the Government need only describe the time and place of charged conduct "in approximate terms." Tramunti, 513 F.2d at 1113. The details are subject to proof at trial. "[T]he Second Circuit routinely upholds the 'on or about' language used to describe the window of when a violation occurred." United States v. Kidd, 386 F. Supp. 3d 364, 369 (S.D.N.Y. 2019) (quoting United States v. Nersesian, 824 F.2d 1294, 1323 (2d Cir. 1987)). "This is especially true in cases of sexual abuse of children: allegations of sexual abuse of underage victims often proceed without specific dates of the offenses." United States v. Young, No. 08-cr-285 (KMK), 2008 WL 4178190, at \*2 (S.D.N.Y. Sept. 4, 2008) (collecting cases). As here, these cases frequently involve alleged abuse spanning a lengthy period of time, and witnesses who were victimized as children may struggle to recall the precise dates when abuse occurred. The indictment adequately describes the time and place of the charged conduct. + +Maxwell next contends that allegations of noncriminal conduct render the charges impermissibly vague. The Court disagrees. Rule 7 requires only that the language of the indictment track the language of the statute and provide a rough account of the time and place of the crime. Tramunti, 513 F.2d at 1113. The language of the Si superseding indictment does so. The Government's decision to provide more details than those strictly required does not hamper Maxwell's ability to prepare a defense. Maxwell's argument that some of the conduct alleged is not inherently criminal goes to the merits of the Government's case, not the specificity of the charges. + +Finally, Maxwell argues that the indictment is vague because the government does not provide the names of the alleged victims. The Court sees no basis to require that the alleged victims' names be included the indictment. The names of victims, even if important, generally need not appear there unless their omission would seriously prejudice the defendant. See United States v. Stringer, 730 F.3d 120, 127 (2d Cir. 2013); United States v. Kidd, 386 F. Supp. 3d 364, 369 (S.D.N.Y. 2019). Maxwell likely knows the identity of the alleged victims described in the indictment at this point because the Government has provided extensive discovery on them. + +Moreover, the Government has agreed to disclose their names in advance of trial. There is thus no unfairness here. See Stringer, 730 F.3d at 126. As discussed below, the Court will require the parties to negotiate and propose a full schedule for all remaining pretrial disclosures. + +### IV. The perjury charges are legally tenable + +The Court turns next to Maxwell's motion to dismiss the perjury counts stemming from her answers to questions in a deposition in a civil case. She contends that these charges are legally deficient because the questions posed were fundamentally ambiguous and the questions were not material to the subject of the deposition. The Court concludes that the charges are legally tenable and Maxwell's defenses are appropriately left to the jury. + +The applicable perjury statute imposes criminal penalties on anyone who "in any proceeding before or ancillary to any court ... knowingly makes any false material declaration." 18 U.S.C. § 1623(a). Testimony is perjurious only if it is knowingly false and is material to the proceeding in which the defendant offered it. + +# A. The questions posed were not too ambiguous to support a perjury charge + +The requirement of knowing falsity requires that a witness believe that their testimony is false. United States v. Lighte, 782 F.2d 367, 372 (2d Cir. 1986). As a general matter, "[a] jury is best equipped to determine the meaning that a defendant assigns to a specific question." Id. Courts have acknowledged a narrow exception for questions that are so fundamentally ambiguous or imprecise that the answer to them cannot legally be false. Id. at 372, 375; see also United States v. Wolfson, 437 F.2d 862, 878 (2d Cir. 1970). A question is fundamentally ambiguous only if reasonable people could not agree on its meaning in context. Lighte, 782 F.2d at 375. The existence of some arguable ambiguity does not foreclose a perjury charge against a witness who understood the question. + +At a minimum, Maxwell's motion is premature. Courts typically evaluate whether a question was fundamentally ambiguous only after the development of a full factual record at trial. See, e.g., United States v. Markiewicz, 978 F.2d 786, 808 (2d Cir. 1992). The evidence at trial may shed further light on whether the questions posed were objectively ambiguous in context or whether Maxwell subjectively understood them. In any event, the Court has closely considered each of the categories of questions that Maxwell argues are ambiguous. None of the alleged ambiguities Maxwell identifies rise to the level supporting dismissal of the charges. The context of the questions and answers, in conjunction with the Government's evidence, could lead a reasonable juror to conclude that the statements were perjurious. Truth and falsity are questions for the jury in all but the most extreme cases. The Court declines to usurp the jury's role on the limited pretrial record. + +### B. A reasonable juror could conclude that Maxwell's statements were material + +Maxwell also argues that the perjury counts should be dismissed because none of the allegedly false statements were material to the defamation action. In a civil deposition, a statement is material if it has a natural tendency to influence the court or if a truthful answer might reasonably lead to the discovery of admissible evidence. United States v. Gaudin, 515 U.S. 506, 509 (1995); United States v. Kross, 14 F.3d 751, 753-54 (2d Cir. 1994). Like knowing falsity, materiality is an element of the offense and thus ordinarily must be "decided by the jury, not the court." Johnson v. United States, 520 U.S. 461, 465 (1997). Only the most extraordinary circumstances justify departure from this general rule. United States v. Forde, 740 F. Supp. 2d 406, 412 (S.D.N.Y. 2010) (citing Gaudin, 515 U.S. at 522-23). + +The charged statements do not fall within this narrow exception. Maxwell contends that the questions did not relate to the sex trafficking and sexual abuse allegations at the center of the + +civil case, but that is not the legal standard. The Government may prevail if it proves that Maxwell's answers could have led to the discovery of other evidence or could influence the factfinder in the civil case. See Gaudin, 515 U.S. at 509; Kross, 14 F.3d at 753-54. At trial, a reasonable juror could conclude that truthful answers to the questions may have permitted the plaintiff to locate other victims or witnesses who could have corroborated the plaintiff's testimony. The factual disputes relating to materiality are at least enough to preclude pretrial resolution. In criminal cases, courts must guard against "invading the 'inviolable function of the jury' in our criminal justice system," and if the "defense raises a factual dispute that is inextricably intertwined with a defendant's potential culpability, a judge cannot resolve that dispute on a Rule 12(b) motion." United States v. Sampson, 898 F.3d 270, 281 (2d Cir. 2018). + +The Court concludes that the perjury charges are legally tenable and appropriately presented to the jury. + +# V. The perjury charges must be severed and tried separately + +Although the perjury charges are legally tenable, the Court concludes that the interests of justice require severing those counts and trying them separately. Trying the perjury counts together with the Mann Act counts would require admitting evidence of other acts likely to be unduly prejudicial. It would also risk disqualifying Maxwell's chosen counsel based on their involvement in the earlier civil case. + +Rule 14(a) of the Federal Rules of Criminal Procedure allows a court to order separate trials if joining all offenses in a single trial would prejudice the defendant. A defendant seeking severance must show significant unfairness to outweigh the burden on the court of conducting multiple trials. United States v. Walker, 142 F.3d 103, 110 (2d Cir. 1998). The harm to the defendant must be more than "solely the adverse effect of being tried for two crimes rather than + +one." United States v. Werner, 620 F.2d 922, 929 (2d Cir. 1980). Though this standard is demanding, the Court concludes that, due to unique features of the perjury counts, Maxwell meets it here. Trying all counts together would compromise Maxwell's right to the counsel of her choice and risk an unfair trial. + +Trying the perjury counts together with the Mann Act counts would risk an unfair trial on each set of counts. First, it would introduce unrelated allegations of sexual abuse, which would potentially expose the jury to evidence that might otherwise not be admissible. In particular, a joint trial would potentially expose the jury to a wider swath of information regarding civil litigation against Epstein that is remote from Maxwell's charged conduct. This presents a significant risk that the jury will cumulate the evidence of the various crimes charged and find guilt when, if considered separately, it would not do so. See United States v. Halper, 590 F.2d 422, 430 (2d Cir. 1978). Second, the evidence presented on the Mann Act counts may prejudice the jury's ability to fairly evaluate Maxwell's truthfulness in her deposition, a critical element of the perjury counts. The Court has concerns that a limiting instruction may be inadequate to mitigate these risks given the nature of the allegations involved. + +Importantly, a joint trial is also likely to require disqualification of at least one of Maxwell's attorneys from participating as an advocate on her behalf. The perjury counts likely implicate the performance and credibility of her lawyers in the civil action—two of whom represent her in this case. The New York Rules of Professional Conduct generally forbid a lawyer from representing a client in a proceeding in which the lawyer is likely also to be a witness. N.Y. R. 114/ 0111 Conduct § 3.7(a). Maxwell's counsel in the civil action and the deposition may be important fact witnesses on the perjury counts. Even if counsel were not required to testify, trying all counts together could force Maxwell to choose between having her counsel testify on her behalf on the perjury charges and having them assist her in defending the Mann Act charges. + +The Second Circuit has recognized that witness testimony offered by a party's attorney presents serious risks to the fairness of a trial. See Murray v. Metro. Life Ins. Co., 583 F.3d 173, 178 (2d Cir. 2009). The lawyer might appear to vouch for their own credibility, jurors might perceive the lawyer as distorting the truth to benefit their client, and blurred lines between argument and evidence might confuse the jury. Id. Disqualification of counsel also implicates Maxwell's Sixth Amendment right to be represented by the counsel of her choice. See, e.g., United States v. Kincade, No. 15-cr-00071 (JAD) (GWF), 2016 WL 6154901, at \*6 (D. Nev. Oct. 21, 2016). The prejudice to Maxwell is especially pronounced because the attorneys who represented her in the civil case have worked with her for years and are particularly familiar with the facts surrounding the criminal prosecution. See United States v. Cunningham, 672 F.2d 1064, 1070-71 (2d Cir. 1982). + +The Court is of course cognizant of the burden separate trials may impose on all trial participants. But much of the proof relevant to the perjury counts and the Mann Act counts does not overlap. In particular, materiality for statements made in a civil deposition is broad, and evidence on that question is unlikely to bear on the other charges here. See Kross, 14 F.3d at 753-54; Gaudin, 515 U.S. at 509. Although some allegations of sexual abuse are relevant to both sets of charges, many are not. At a minimum, this will expand the scope of the trial far beyond the narrower issues presented. And while the Court agrees with the Government that at least some of Maxwell's concerns are overstated, there is little question that the jury's consideration of the nature of the defamation action will require a significant investment of time and resources to provide the requisite context. + +The balance of these considerations favors severance. "Motions to sever are committed to the sound discretion of the trial judge." United States v. Casamento, 887 F.2d 1141, 1149 (2d Cir. 1989). In its discretion, the Court concludes that trying the perjury counts separately will best ensure a fair and expeditious resolution of all charges in this case. + +### VI. Maxwell's motion to strike surplusage is premature + +Maxwell moves to strike allegations related to one of the alleged victims from the S I superseding indictment as surplusage. The Court declines to do so at this juncture. + +Federal Rule of Criminal Procedure 7(d) allows a court to strike surplusage from an indictment on a defendant's motion. "Motions to strike surplusage from an indictment will be granted only where the challenged allegations are not relevant to the crime charged and are inflammatory and prejudicial." United States v. Hernandez, 85 F.3d 1023, 1030 (2d Cir. 1996) (cleaned up). Courts in this District generally delay ruling on any motion to strike until after the presentation of the Government's evidence at trial, because that evidence may affect how specific allegations relate to the overall charges. See, e.g., United States v. Nejad, No. I 8-cr-224 (MN), 2019 WL 6702361, at \*18 (S.D.N.Y. Dec. 6, 2019); United States v. Mostafa, 965 F. Supp. 2d 451, 467 (S.D.N.Y. 2013). + +Maxwell contends that the allegations related to "Minor Victim-3" are surplusage because the indictment does not charge that Minor Victim-3 traveled in interstate commerce or was below the age of consent in England where the alleged activities took place. Thus, she argues, these allegations do not relate to the charged conspiracy and instead reflect an attempt to introduce Minor Victim-3's testimony for impermissible purposes. + +The Court will not strike any language from the S 1 superseding indictment at this juncture. The standard under Rule 7(d) is "exacting" and requires the defendant to demonstrate + +clearly that the allegations are irrelevant to the crimes charged. United States v. Napolitano, 552 F. Supp. 465, 480 (S.D.N.Y. 1982). The indictment does not allege that the alleged victim traveled in interstate commerce or was underage during sexual encounters with Epstein. But the Court cannot rule out that the allegations may reflect conduct undertaken in furtherance of the charged conspiracy or be relevant to prove facts such as Maxwell's state of mind. See United States v. Concepcion, 983 F.2d 369, 392 (2d Cir. 1992). The Court will follow the well-worn path of others in this District and reserve the issue for trial. Maxwell may renew her motion then. + +# VII. Maxwell's motion to dismiss multiplicitous charges is premature + +Maxwell's motion to dismiss either the first or third count of the SI superseding indictment as multiplicitous is also premature. Maxwell contends that the Government has alleged the same conspiracy twice in the indictment. "An indictment is multiplicitous when it charges a single offense as an offense multiple times, in separate counts, when, in law and fact, only one crime has been committed." United States v. Chacko, 169 F.3d 140, 145 (2d Cir. 1999). "The multiplicity doctrine is based upon the double jeopardy clause of the Fifth Amendment, which assures that the court does not exceed its legislative authorization by imposing multiple punishments for the same offense." United States v. Nakashian, 820 F.2d 549, 552 (2d Cir. 1987) (cleaned up). + +"Where there has been no prior conviction or acquittal, the Double Jeopardy Clause does not protect against simultaneous prosecutions for the same offense, so long as no more than one punishment is eventually imposed." United States v. Josephberg, 459 F.3d 350, 355 (2d Cir. 2006). "Since Josephberg, courts in this Circuit have routinely denied pre-trial motions to dismiss potentially multiplicitous counts as premature." United States v. Medina, No. I 3-cr-272 (PGG), 2014 WL 3057917, at \*3 (S.D.N.Y. July 7, 2014) (collecting cases). The Court therefore denies Maxwell's motion to dismiss multiplicitous counts without prejudice. + +# VIII. The parties shall negotiate all remaining disclosures + +Maxwell moves to compel the Government to produce certain documents she believes it has in its possession and has failed to produce. She also seeks accelerated disclosure of the Government's witness list, Jencks Act material, Brady and Giglio material, co-conspirator statements, and Rule 404(b) material. Based on the Government's response in briefing and letters the parties have since submitted to the Court, it appears that most of these requests have been overtaken by events. Accordingly, although the Court concludes that Maxwell is not entitled to expedite this discovery based on the arguments in her motion papers, the Court will require the parties to confer on an overall schedule for all remaining pretrial disclosures. + +### A. The Court accepts the Government's representations that it has disclosed all Brady and Giglio Material + +The Supreme Court's decisions in Brady v. Maryland, 373 U.S. 83 (1963) and Giglio v. United States, 405 U.S. 150 (1972) require the Government to disclose to defendants certain evidence that will aid their defense. Brady requires disclosure of exculpatory evidence. Under Giglio, the Government has a duty to produce "not only exculpatory material, but also information that could be used to impeach a key government witness." United States v. Coppa, 267 F.3d 132, 135 (2d Cir. 2001) (citing Giglio, 405 U.S. at 154). As a general rule, "Brady and its progeny do not require immediate disclosure of all exculpatory and impeachment material upon request by a defendant." Id. at 146. "[A]s long as a defendant possesses Brady evidence in time for its effective use, the government has not deprived the defendant of due process of law simply because it did not produce the evidence sooner." Id. at 144. + +Maxwell requests an order directing immediate disclosure of all Brady and Giglio material and also requests a few specific documents she contends the Government has failed to disclose. The Court begins with the specific requests. The requested materials include (1) records of witness interviews in connection with an ex pane declaration in support of a response to a motion to quash subpoenas; (2) an unredacted copy of two FBI reports; (3) pages from a personal diary that is in the custody of a civilian third party; and (4) copies of all subpoenas the Government has issued for Maxwell's records as part of its investigation in this case. + +The Government represents that it is cognizant of its Brady obligations, that is has reviewed the witness interviews and one of the FBI reports, and that neither set of documents includes exculpatory information not previously disclosed. The Court has no reason to doubt the Government's representation in this case that it is aware of its Brady obligations and that it has complied and will continue to comply with them. And because the witness statements are covered by the Jencks Act, the Court cannot compel production of such statements under the terms of the statute. See 18 U.S.C. § 3500; Coppa, 267 F.3d at 145. Next, the Government represents that it has already produced an unredacted copy of the other requested FBI report, and so that request is moot. The diary pages she requests are within the control of a civilian third party, not the Government, and so the Government need not (and perhaps cannot) produce them. See United States v. Collins, 409 F. Supp. 3d 228, 239 (S.D.N.Y. 2019). Finally, Maxwell's request for copies of all subpoenas the Government has issued is overly broad and lacks a legal basis. Maxwell is not entitled to compel production of these documents. + +The Court also will not issue an order requiring the immediate disclosure of Brady and Giglio material. The Government has represented that it recognizes its obligations under Brady and that it has complied, and will continue to comply, with such obligations. The Court has no + +reason to doubt these representations given its expansive approach to document production thus far in this case. The Government has agreed in its recent letter to produce Giglio material six weeks in advance of trial. The parties shall negotiate the specific timing, but assuming a schedule along those lines is met, the Court concludes that Maxwell will be able to effectively prepare for trial. See Coppa, 267 F.3d at 144. + +### B. Jencks Act material and co-conspirator statements + +Maxwell also seeks to expedite discovery of Jencks Act material and non-exculpatory statements of co-conspirators that the government may offer at trial. The Jencks Act, 18 U.S.C. § 3500, "provides that no prior statement made by a government witness shall be the subject of discovery until that witness has testified on direct examination." Coppa, 267 F.3d at 145. The statute therefore prohibits a district court in most cases from ordering the pretrial disclosure of witness statements unless those statements are exculpatory. "A coconspirator who testifies on behalf of the government is a witness under the Act." In re United States, 834 F.2d 283, 286 (2d Cir. 1987). The Court therefore lacks the inherent power to expedite these disclosures. In any case, the Government has agreed to produce all Jencks Act material at least six weeks in advance of trial. + +The Court also rejects Maxwell's alternative request for a hearing to determine the admissibility of co-conspirator declarations. Co-conspirator statements may often be admitted at trial on a conditional basis. If the Court determines that the Government has not met its burden to show that the conditionally admitted statements were made in furtherance of the charged conspiracy, the Court should provide a limiting instruction or, in extreme cases declare a mistrial. United States v. Tracy, 12 F.3d 1186, 1199 (2d Cir. 1993). Although conditional admissions can pose a problem, a pretrial hearing is unnecessary here because the Government + +has committed to producing co-conspirator statements at least six weeks in advance of trial to allow Maxwell to raise any objections. Maxwell will have adequate time to object to any proffered co-conspirator testimony following the Government's Jencks Act disclosures. + +### C. Witness list + +As a general matter, "district courts have authority to compel pretrial disclosure of the identity of government witnesses." United States v. Cannon, 528 F.2d 296, 300 (2d Cir. 1975). In deciding whether to order accelerated disclosure of a witness list, courts consider whether a defendant has made a specific showing that disclosure is "both material to the preparation of the defense and reasonable in light of the circumstances surrounding the case." United States v. Bejasa, 904 F.2d 137, 139-140 (2d Cir. 1990) (cleaned up). + +Maxwell has made a particularized showing that the Government must produce a witness list reasonably in advance of trial. The nature of the allegations in this case—decades-old allegations spanning multiple locations—present considerable challenges for the preparation of the defense. However, the Government's proposed disclosure schedule—which will afford Maxwell at least six weeks to investigate testifying witness statements—allows Maxwell significantly more time to review disclosures than schedules adopted in most cases in this District. See, e.g., United States v. Rueb, No. 00-CR-91 (RWS), 2001 WL 96177, at \*9 (S.D.N.Y. Feb. 5, 2001) (thirty days before trial); United States v. Nachamie, 91 F. Supp. 2d 565, 580 (S.D.N.Y. 2000) (fourteen days before trial). In addition, on April 13, 2021, the Government produced over 20,000 pages of interview notes, reports and other materials related to non-testifying witnesses. After considering the circumstances, including the complexity of the issues in this case and what the defense has already received and likely learned in the course of discovery, the Court concludes that the Government's proposal is generally reasonable. + +#### D. Rule 404(b) material + +Maxwell's final discovery request is for early disclosure of evidence the Government seeks to offer under Federal Rule of Evidence 404(b). Under Rule 404(b), if the prosecutor in a criminal case intends to use "evidence of a crime, wrong, or other act" against a defendant, the prosecutor must "provide reasonable notice of the general nature of any such evidence that the prosecutor intends to offer at trial" and must "do so in writing before trial—or in any form during trial if the court, for good cause, excuses lack of pretrial notice." The Government represents that it will notify the defense of its intent to use 404(b) evidence at least 45 days in advance of trial to allow Maxwell to file any motions in limine to be considered at the final pretrial conference. The Government's proposal will give Maxwell an opportunity to challenge admission of that evidence and to bring to the Court's attention any issues that require resolution before trial. "This is all that Rule 404(b) requires." United States v. Thompson, No. 13-cr-378 (MN), 2013 WL 6246489, at \*9 (S.D.N.Y. Dec. 3, 2013). The Court concludes this schedule is generally reasonable, although additional time to enable briefing and resolution in advance of trial is strongly encouraged. + +The Court's denial of Maxwell's requests to compel pretrial disclosures does not preclude the parties from negotiating in good faith for an expedited discovery timeline that will account for Maxwell's specific concerns. "[I]n most criminal cases, pretrial disclosure will redound to the benefit of all parties, counsel, and the court." United States v. Percevault, 490 F.2d 126, 132 (2d Cir. 1974). In general, the Court will require the parties to negotiate a final, omnibus schedule to propose to the Court. The Court concludes that the disclosure of all of the above materials approximately six to eight weeks in advance of trial is appropriate and sufficient. + +Given the complexities of the case and the addition of two counts via the S2 indictment, the Court encourages the parties to agree to approximately eight weeks. + +# IX. The S2 superseding indictment moots Maxwell's grand jury challenge + +The Court has not received supplemental briefing on the motions in light of the return of the S2 superseding indictment and so does resolve any such issues here.' However, Maxwell's motion seeking to dismiss the Si superseding indictment because it was returned by a grand jury sitting at the White Plains courthouse appears moot. Maxwell argued that the use of a grand jury drawn from the White Plains Division in this District did not represent a fair cross-section of the community, because her trial would proceed in the Manhattan Division. A grand jury sitting in Manhattan returned the S2 superseding indictment. By April 21, 2021, Maxwell shall show cause why her grand jury motion should not be dismissed on that basis. + +### Conclusion + +The Court DENIES Maxwell's motions to dismiss the indictment as barred by Epstein's non-prosecution agreement (Dkt. No. 141), to dismiss the Mann Act counts as barred by the statute of limitations (Dkt. No. 143), to dismiss the indictment for pre-indictment delay (Dkt. No. 137), to dismiss the Mann Act counts for lack of specificity (Dkt. No. 123), to dismiss the perjury counts as legally untenable (Dkt. No. 135), to strike surplusage (Dkt. No. 145), to dismiss count one or count three as multiplicitous (Dkt. No. 121), and to expedite pretrial disclosures (Dkt. No. 147). The Court GRANTS Maxwell's motion to sever the perjury counts for a separate trial (Dkt. No. 119). + +&#x27; The parties shall negotiate and propose a schedule for any available additional or supplement rulings in light of the filing of the S2 indictment. + +The Court ORDERS the Government to confirm within one week whether it considers any evidence related to negotiation of the non-prosecution agreement to constitute *Brady* or Rule 16 material and, if so, to confirm that it has or will disclose such evidence. + +The Court further ORDERS the parties to negotiate a final schedule for all pretrial disclosures that remain outstanding, including: *Brady*, *Giglio*, and Jenks Act materials, including co-conspirator statements; non-testifying witness statements; testifying witness statements; the identity of victims alleged in the indictment; 404(b) material; and the Government's witness list. The Court also requires the parties to negotiate a schedule for any additional or supplemental motions briefing in light of the S2 indictment. The Court ORDERS a joint proposal to be submitted by April 21, 2021. If agreement is not reached, the parties shall submit their respective proposals. + +The Court further ORDERS Maxwell to show cause by April 21, 2021 why her motion to dismiss the S1 superseding indictment under the Sixth Amendment (Dkt. No. 125) should not be denied as moot. + +SO ORDERED. + +Dated: April 16, 2021 +New York, New York + +![]() + +--- + +ALISON J. NATHAN +United States District Judge \ No newline at end of file diff --git a/marker2/ds9/EFTA00090494/EFTA00090494.metadata.json b/marker2/ds9/EFTA00090494/EFTA00090494.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..b016f329c6597e2cda5d80950aaee6b35f20f8fc --- /dev/null +++ b/marker2/ds9/EFTA00090494/EFTA00090494.metadata.json @@ -0,0 +1,1810 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090494.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 34, + "chars": 67262, + "elapsed_seconds": 13.4, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "I. Jeffrey Epstein's non-prosecution agreement does not bar this prosecution", + "heading_level": null, + "page_id": 2, + "polygon": [ + [ + 68.544, + 72.08999999999999 + ], + [ + 491.98516845703125, + 72.08999999999999 + ], + [ + 491.98516845703125, + 86.103515625 + ], + [ + 68.544, + 86.103515625 + ] + ] + }, + { + "title": "A. The non-prosecution agreement does not hind the U.S. Attorney for the \nSouthern District of New York", + "heading_level": null, + "page_id": 3, + "polygon": [ + [ + 105.26399999999998, + 72.08999999999999 + ], + [ + 494.1296081542969, + 72.08999999999999 + ], + [ + 494.1296081542969, + 99.603515625 + ], + [ + 105.26399999999998, + 99.603515625 + ] + ] + }, + { + "title": "B. 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Epstein & Chislaine Maxwell: +**Date:** Thu, 29 Jul 2021 08:44:07 +0000 + +I would send it to the PC chiefs. [REDACTED] typically refers this type of thing to the relevant chiefs anyway (she may have already done so here, as it appears at least one Civilian Crime Report was already completed), and they'll be the best positioned to assess what (if any) follow up is appropriate. + +On Jul 28, 2021, at 10:30 PM, [REDACTED] > wrote: + +How to handle ? Send to PC Chiefs or civ complaints? + +Sent from my iPhone + +Begin forwarded message: + +**From:** "Randolph T. (The New York Times Customer Care)" <[REDACTED]> + +**Date:** July 28, 2021 at 9:23:15 PM EDT + +**Cc:** [REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] + +**Subject:** Jeffrey Epstein & Chislaine Maxwell: +**Reply-To:** The New York Times Customer Care <[REDACTED]> + +##- Please type your reply above this line -## + +You are registered as a CC on this support request (1640314). Reply to this email to add a comment to the request. + +--- + +**Randolph T. (The New York Times Customer Care)** +Jul 28, 2021, 9:23 PM EDT + +Thank you for contacting Customer Care at The New York Times. We value your readership and loyalty. + +If you need assistance with News please contact our team at delighted to better help you! They will be + +If you have any questions or require any other assistance, please feel free to reply to this email. You can also call us at 800-698-4637 or chat with us. + +We at the New York Times wish you well, + +Randolph T. Customer Care Advocate The New York Times + +## Richard Curtiss + +Dear Mr. Dean: Thomson Reuters News + +I received your emails saying that the Jeffrey Epstein murder inside the Metropolitan Correctional Center in New York City, NY is a local news story and that the corruption going on inside our government and the courts with government employees, court employees and Judges goes on all over the place. + +I contacted all my local news organizations and they told me to contact the larger National News Organizations because you have more money to do National News stories like the murder of Jeffrey Epstein and government employees and court employees writing all of the courts decisions, orders, search warrants, FISA warrants, arrest warrants and other court documents and either typing some Judges name to those court documents or forging the Judges signature to make it look like the Judges signature or just act for Judges. + +Do you know someone I could contact that does news? + +Richard C. Curtiss + +Wayland, New York 14572 + +Phone + +Fax + +To: Subject: Re: Federal Courts: + +"Also I was inside the SHU section of the Metropolitan Correctional Center in New York City, NY where Jeffrey Epstein died. Would that be anything you would want on why the guards turned both the cameras and backup cameras off and why the guards didn't check on Epstein every 30 minutes"? + +Yes, We have followed Epstein extensively, know tons on his background, and sourcing inside a group of contacts was able to stay out of the media, but who were very close to two decades. + +Epstein is a huge blackmail jackpot, and Gislaine Maxwell may be holding the final stash to negotiate a plea. But what she may have is so toxic, the prosecutors' employers would probably say 'we won't touch this with a ten foot pole'. + +As for his jail stay, we had expected he would be bumped off, when he was not kept in a more secure facility. That screamed that he had to be prevented from talking at all costs, even if that entailed great risks. and wondered how 'they' would not be exposed when they did, ie 'how could the guards hold up under the investigation, or really dare to goof off while guarding him. + +From: Richard Curtiss < Sent: Wednesday, July 21, 2021 12:29 PM To: Editor Jim W. Dean < Subject: Federal Courts: + +Dear Mr. Dean: Thomson Reuters News + +I received your July 11, 2021 email. Would you have time to review these attachments for a news story? I received a Civilian Crime Report from the US Attorney for the Southern District of New York to fill out and return to her. + +Also I was inside the SHU section of the Metropolitan Correctional Center in New York City, NY where Jeffrey Epstein died. Would that be anything you would want on why the guards turned both the cameras and backup cameras off and why the guards didn't check on Epstein every 30 minutes? + +Richard C. Curtiss Wayland, New York 14572 Phone Fax + +From: Sent: Sunday, July 11, 2021 7:05 PM To: Subject: Re: Federal Courts: + +Jim + +From: Richard Curtiss < + +Sent: Sunday, July 11, 2021 6:22 PM + +To: Editor Jim W. Dean < + +Subject: Federal Courts: + +Dear Mr. Dean: Thomson Reuters News + +Do you accept stories about court corruption at Thomson Reuters News? + +Richard C. Curtiss + +Wayland, New York 14572 + +Phone + +Fax + +From: + +Sent: Friday, January 15, 2016 8:16 AM + +To: Richard C Curtiss + +Cc: + +Subject: Re: Supreme Court Submission: Judicial Conduct + +Good morning - + +I've been in touch with the marshals this morning and forwarded to the recent emails. She suspects Mr. Curtiss may have switched email addresses because the IT folks previously blocked a number of his addresses. If there are updates, I'll pass them along. + +Have a good day. + +Clerk of the Second Circuit Court of Appeals + +From: + +Sent: Friday, January 15, 2016 7:59 AM + +To: Richard C Curtiss < + +Subject: Re: Electronic Filling, Western District of New York + +On behalf of all the recipients of your recent emails, I am writing to advise you that no responses will be sent to you. + +Email is an inappropriate way to communicate with the Court. The proceedings you commence must be determined in the ordinary course, not by way of improper communications. + +Sincerely, + +Clerk of Court + +U. S. Court of Appeals + +Second Circuit + +Agency Appeals + +Attorney Admissions + +Calendar + +Case Initiation + +Case Closing + +Civil Appeals + +Criminal/Prisoner Appeals + +Records + +Original Message + +From: Chief Judge Robert Katzmann < + +To: RICHARD C. CURTISS < + +Sent: Wednesday, February 03, 2016 4:49 PM + +Subject: AUTO: Robert Katzmann is out of the office + +I am out of the office until 02/07/2016. + +I will be away until February 7, and will be checking email intermittently. I may not respond until my return. Thank you. + +Attorney David Schoen February 2, 2021 + +Schoen reportedly believed that convicted sex offender Jeffrey Epstein didn't commit suicide in 2019, because he met him in jail earlier the same day to discuss Schoen leading his defense team. "The reason I say I don't believe it was suicide is for my interaction with him that day. The purpose of asking me to come there that day and over the past couple of weeks was to ask me to take over his defense," Schoen stated. + +"Richard, these people will kill you, you don't go into the warden's office, these people will kill you." "They will come into your room at night when you're sleeping and beat you over the head with a fire extinguisher and kill you and then they will throw the fire extinguisher into one of our rooms and blame one of us for killing you." "You don't go into the warden's office." + +Goon Squad + +a group of hired thugs used to perform ruthless or violent acts inside prisons. + +Medical examiner rules Epstein death a suicide by hanging + +Chief Medical Examiner Dr. Barbara Sampson said in a statement that she made the suicide determination "after careful review of all investigative information, including complete autopsy findings." + +From: (OCME) > On Behalf Of OCME Website Mail + +To: + +Subject: RE: City of New York - Correspondence #1-1-71 59508 Message to Agency Head, OCME - Other + +Good afternoon Mr. Curtiss, + +Thank you for reaching-out to the NYC Office of the Chief Medical Examiner (OCME). + +I believe you're inquiring about the fatality of Jeffrey Epstein, who died on August 10th of hanging (suicide). + +Please reach out to me directly at responses on media inquiries. for timely + +Thanks, + +Office of the Chief Medical Examiner + +520 1st Avenue + +New York, NY 10016 + +Original Message + +From: Richard Curtiss + +Sent: Wednesday, October 30, 2019 4:33 PM + +To: + +Cc: + +Subject: Response: Office of the Chief Medical Examiner (OCME) + +Dear Chief Medical Examiner Sampson: City of New York + +Would you have the drug test you did on Jeffrey Epstein at his autopsy? + +Richard C. Curtiss + +Wayland, New York 14572 + +Sent: Wednesday, October 30, 2019 4:36 PM + +To: Richard Curtiss < >; + +Subject: RE: Response: + +I'm not aware we ever stated we did a drug test as part of this investigation. We do not outline the tests we perform in medical investigations. + +Executive Director for Public Affairs (OCME) + +From: CN=NYM/Exec Assistant— CN=NYM/Exec Assistant— < + +Sent: Monday, February 2, 201 5 9:05 AM + +To: Richard C Curtiss < + +Subject: Re: FOIA/PA Request: BOP Inmate Number 08448-055 + +The information you request cannot be provided via a written request to the institution. Rather, you must submit a Freedom of Information Act (FOIA) request to: + +Freedom of Information Act/Privacy Act Section + +Office of General Counsel, + +Room 841 Federal Bureau of Prisons + +320 First Street, N.W. + +Washington, D.C. 20534 + +Executive Assistant + +Metropolitan Correctional Center + +New York + +150 Park Row + +"One team...one mission" + +Guards at the Metropolitan Correctional Center, where Jeffrey Epstein was detained and died, pressured his former cellmate not to discuss it, according to his lawyer. + +The photos from inside the cell also showed multiple prescription pill bottles and food on the top bunk (Nurse brings medicine morning and night only) No medicine allowed in cells. + +18 U.S. Code §2385.Advocating overthrow of the United States Government + +Whoever knowingly or willfully advocates, abets, advises, or teaches the duty, necessity, desirability, or propriety of overthrowing or destroying the government of the United States or the government of any State, Territory, District or Possession thereof, or the government of any political subdivision therein, by force or violence, or by the assassination of any officer of any such government; or + +Whoever, with intent to cause the overthrow or destruction of any such government, prints, publishes, edits, issues, circulates, sells, distributes, or publicly displays any written or printed matter advocating, advising, or teaching the duty, necessity, desirability, or propriety of overthrowing or destroying any government in the United States by force or violence, or attempts to do so; or + +Whoever organizes or helps or attempts to organize any society, group, or assembly of persons who teach, advocate, or encourage the overthrow or destruction of any such government by force or violence; or becomes or is a member of, or affiliates with, any such society, group, or assembly of persons, knowing the purposes thereof— + +As used in this section, the terms "organizes" and "organize", with respect to any society, group, or assembly of persons, include the recruiting of new members, the forming of new units, and the regrouping or expansion of existing clubs, classes, and other units of such society, group, or assembly of persons. + +Lt. Col. Vindman was the original source of Ukraine Investigation + +The investigators came to realize that the person driving the events of 'Ukraine Investigation' wasn't the so-called whistleblower, but none other than Lt. Col. Alexander Vindman. + +From: Richard C. Curtiss < + +Sent: Friday, July 31, 2020 9:49 AM + +To: 'Adam Schiff' < >; 'House Speaker Nancy Pelosi' + +>; 'Congressman Jerrold Nadler (Judiciary Committee)' + +Cc: 'Senate Minority Leader Chuck Schumer' < >; + +'General Counsel Keith Castaldo (Senator Gillibrand)' < + +Could you respond today to thousands of letters, emails, faxes, phone calls and documents I sent you about government employees, court employees and Judges organizing all their government employee unions into one new government employee union of all the government employees in the United States? + +Also my 9 false arrests, imprisonments and my attempted murder by government employees, court employees and Judges for reporting these crimes to you. + +Richard C. Curtiss + +Wayland, New York 14572 + +Phone + +Fax + +WASHINGTON (Sinclair Broadcast Group) - Vice President Mike Pence told reporters on Capitol Hill that FBI Director James Comey wasn't fired over the investigation of Russia's influence in the 2016 election. + +From: FBI Buffalo < + +Sent: Saturday, February 8,2020 4:56 AM + +To: Richard C. Curtiss < + +Subject: RE: Response: Investigation + +To whom it may concern, + +We are unable to open attachments or links. Please email us the information in the body of the email, not as an attachment. + +Thank you, + +FBI Buffalo + +Attachment(s) + +Scan.pdf 2-19-20 USDOJ Civilian Crime Report (Courts).pdf + +Scan.pdf 2-3-20 US Attorney Letters.pdf + +Scan.pdf 12-8-19 CARTER PAGE FISA WARRANT.pdf + +This email is a service from The New York Times Customer Care. \ No newline at end of file diff --git a/marker2/ds9/EFTA00090528/EFTA00090528.metadata.json b/marker2/ds9/EFTA00090528/EFTA00090528.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..ec9b78ddcdc248ac09c9c446557d436a52de8d46 --- /dev/null +++ b/marker2/ds9/EFTA00090528/EFTA00090528.metadata.json @@ -0,0 +1,352 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090528.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + 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"previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00090528" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00090538/EFTA00090538.md b/marker2/ds9/EFTA00090538/EFTA00090538.md new file mode 100644 index 0000000000000000000000000000000000000000..005480c3890613428554ec218db190420906f885 --- /dev/null +++ b/marker2/ds9/EFTA00090538/EFTA00090538.md @@ -0,0 +1,81 @@ +To: + +Subject: Fwd: From Andrew's PR team + +Date: Mon, 08 Jun 2020 15:28:33 +0000 + +Inline-Images: image001.jpg + +Sent from my iPhone + +Begin forwarded message: + +From: daniel bates + +Date: June S. 2020 at 10:39:03 AM EDT + +To: ' + +Subject: Front Andrew's PR team + +This has just been released. + +Please note the line about them making three offers to be a witness, which flatly contradicts Mr Berman's public comments. + +Is it right you are treating Prince Andrew with a 'lower standard' than other people? + +And can you clarify if you want to speak to him as a suspect or a witness? + +If you want to call me I'm am happy to chat on background but we will need something on the record for the Daily Mail. + +Regards + +Daniel + +![](_page_0_Picture_18.jpeg) + +## FOR IMMEDIATE RELEASE —JUNE 8TH, 2020 + +## Statement regarding HRH The Duke of York + +In January 2020, Blaekfords LLP and instructed counsel, Clare Montgomery QC and Stephen Ferguson, were commissioned to support HRH The Duke of York in his desire to provide cooperation to the US authorities regarding the victims of the late Jeffrey Epstein, should those authorities request his assistance. The working group is supported by Riverside Advisory on media relations. + +To date, we have chosen not to make any public statement regarding our discussions with the US Department of Justice (DOJ). Our commitment to confidentiality is not only regarded as best practice in the UK but is also intended to respect the DOJ's commitment to confidentiality, as set out in its own rules as they apply to discussions with potential witnesses. + +However, in view of misleading media briefings, we owe it to our client to issue this clarifying statement. + +As the public record indicates the DOJ has been actively investigating Mr Epstein and other targets for more than 16 years, yet the first time they requested the Duke's help was on 2"d January 2020. + +Importantly, the DOJ advised us that the Duke is not and has never been a 'target' of their criminal investigations into Epstein and that they sought his confidential, voluntary co-operation. + +In the course of these discussions, we asked the DOJ to confirm that our co-operation and any interview arrangements would remain confidential, in accordance with the ordinary rules that apply to voluntary co-operation with the DOJ. We were given an unequivocal assurance that our discussions and the interview process would remain confidential. + +The Duke of York has on at least three occasions this year offered his assistance as a witness to the DOJ. Unfortunately, the DOJ has reacted to the first two offers by breaching their own confidentiality rules and claiming that the Duke has offered zero cooperation. In doing so, they are perhaps seeking publicity rather than accepting the assistance proffered. + +On 27t" January 2020, Mr Geoffrey S Berman, the United States Attorney for the Southern District of New York, chose to make a public statement about the Duke. This led to worldwide media reports that there had been "a wall of silence" and that there had been "zero co-operation" by the Duke. These statements were inaccurate, and they should not have been made. + +On 9th March 2020, Mr Berman made further public statements saying that the Duke had "completely shut the door" on cooperating with the US investigation and that they are now "considering" further options. Again, the first statement was inaccurate and should not have been made. + +It is a matter of regret that the DOJ has seen fit to breach its own rules of confidentiality, not least as they are designed to encourage witness cooperation. Far from our client acting above the law, as has been implied by press briefings in the US, he is being treated by a lower standard than might reasonably be expected for any other citizen. Further, those same breaches of confidentiality by the DOJ have given the global media - and, therefore, the worldwide audience - an entirely misleading account of our discussions with them. + +Any pursuit of an application for mutual legal assistance would be disappointing, since the Duke of York is not a target of the DOJ investigation and has recently repeated his willingness to provide a witness statement. It is hoped that this third offer has not been the cause of the most recent leak about the Duke of York. + +We do not intend to make any further public statement at this time as we wish to respect the rules of confidentiality under both English law and the US guidelines. + +ENDS + +## NOTES TO EDITORS + +The case is being handled by Blackfords City office + +FOR MORE INFORMATION PLEASE CONTACT RIVERSIDE ADVISORY + +Mark.gallagherlariversideadvisory.co.uk — tel: +44 7968 939291 + +Lucy.goodwin@riversideadvisory.co.uk — tel: + 44 7961 452558 + +Daniel Bates + +Journalist in New York + +www.danielgbates.com \ No newline at end of file diff --git a/marker2/ds9/EFTA00090538/EFTA00090538.metadata.json b/marker2/ds9/EFTA00090538/EFTA00090538.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..22091b660b4b9983a7af80697826e1af4e257ca7 --- /dev/null +++ b/marker2/ds9/EFTA00090538/EFTA00090538.metadata.json @@ -0,0 +1,198 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090538.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 4780, + "elapsed_seconds": 1.18, + "image_assets": [ + "_page_0_Picture_18.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "FOR IMMEDIATE RELEASE \u2014JUNE 8TH, 2020", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 34.272, + 77.76 + ], + [ + 297.3499450683594, + 77.76 + ], + [ + 297.3499450683594, + 94.8170166015625 + ], + [ + 34.272, + 94.8170166015625 + ] + ] + }, + { + "title": "Statement regarding HRH The Duke of York", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 187.88400000000001, + 130.41 + ], + [ + 424.0908508300781, + 130.41 + ], + [ + 424.0908508300781, + 145.8170166015625 + ], + [ + 187.88400000000001, + 145.8170166015625 + ] + ] + }, + { + "title": "NOTES TO EDITORS", + "heading_level": null, + "page_id": 2, + "polygon": [ + [ + 33.660000000000004, + 288.35999999999996 + ], + [ + 135.6380615234375, + 288.35999999999996 + ], + [ + 135.6380615234375, + 304.0670471191406 + ], + [ + 33.660000000000004, + 304.0670471191406 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 43 + ], + [ + "Line", + 22 + ], + [ + "Text", + 18 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 65 + ], + [ + "Line", + 31 + ], + [ + "Text", + 9 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 45 + ], + [ + "Line", + 20 + ], + [ + "Text", + 12 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00090538" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00090538/_page_0_Picture_18.jpeg b/marker2/ds9/EFTA00090538/_page_0_Picture_18.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..e55541d9df4fccc0c66b7da94a117e97bc8f295c --- /dev/null +++ b/marker2/ds9/EFTA00090538/_page_0_Picture_18.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:e5308fd41a9db4fdaf12e5832b7658583bb9be35e0c97d1685177fe6726fc8ae +size 19898 diff --git a/marker2/ds9/EFTA00090541/EFTA00090541.md b/marker2/ds9/EFTA00090541/EFTA00090541.md new file mode 100644 index 0000000000000000000000000000000000000000..bb310e3a29d219474934a73297ba57ab0fdd0bce --- /dev/null +++ b/marker2/ds9/EFTA00090541/EFTA00090541.md @@ -0,0 +1,95 @@ +To:' + +Subject: RE: From Andrew's PR team + +Date: Mon, 08 Jun 2020 15:24:02 +0000 + +Inline-Images: image001.jpg + +Can you send to =, copying me and only? + +From: + +Sent: Monday, June 8, 202011:22 AM + +To: + +Cc: + +Subject: Fwd: From Andrew's PR team + +FYI. + +Sent from my iPhone + +Begin forwarded message: + +From: daniel bates + +Date: June 8, 2020 at 10:39:03 AM EDT + +To: ' + +Subject: From Andrew's PR team + +This has just been released. + +Please note the line about them making three offers to be a witness, which flatly contradicts Mr Berman's public comments. + +Is it right you are treating Prince Andrew with a 'lower standard' than other people? + +And can you clarify if you want to speak to him as a suspect or a witness? + +If you want to call me I'm on am happy to chat on background but we will need something on the record for the Daily Mail. + +Regards + +Daniel + +![](_page_1_Picture_0.jpeg) + +FOR IMMEDIATE RELEASE —JUNE 8TH, 2020 + +## Statement regarding HRH The Duke of York + +In January 2020, Blackfords LLP and instructed counsel, Clare Montgomery QC and Stephen Ferguson, were commissioned to support HRH The Duke of York in his desire to provide cooperation to the US authorities regarding the victims of the late Jeffrey Epstein, should those authorities request his assistance. The working group is supported by Riverside Advisory on media relations. + +To date, we have chosen not to make any public statement regarding our discussions with the US Department of Justice (DOJ). Our commitment to confidentiality is not only regarded as best practice in the UK but is also intended to respect the DOJ's commitment to confidentiality, as set out in its own rules as they apply to discussions with potential witnesses. + +However, in view of misleading media briefings, we owe it to our client to issue this clarifying statement. + +As the public record indicates the DOJ has been actively investigating Mr Epstein and other targets for more than 16 years, yet the first time they requested the Duke's help was on 2"d January 2020. + +Importantly, the DOJ advised us that the Duke is not and has never been a 'target' of their criminal investigations into Epstein and that they sought his confidential, voluntary co-operation. + +In the course of these discussions, we asked the DOJ to confirm that our co-operation and any interview arrangements would remain confidential, in accordance with the ordinary rules that apply to voluntary co-operation with the DOJ. We were given an unequivocal assurance that our discussions and the interview process would remain confidential. + +The Duke of York has on at least three occasions this year offered his assistance as a witness to the DOJ. Unfortunately, the Dal has reacted to the first two offers by breaching their own confidentiality rules and claiming that the Duke has offered zero cooperation. In doing so, they are perhaps seeking publicity rather than accepting the assistance proffered. + +On 27t" January 2020, Mr Geoffrey S Berman, the United States Attorney for the Southern District of New York, chose to make a public statement about the Duke. This led to worldwide media reports that there had been "a wall of silence" and that there had been "zero co-operation" by the Duke. These statements were inaccurate, and they should not have been made. + +On 9th March 2020, Mr Berman made further public statements saying that the Duke had "completely shut the door" on cooperating with the US investigation and that they are now "considering" further options. Again, the first statement was inaccurate and should not have been made. + +It is a matter of regret that the DOJ has seen fit to breach its own rules of confidentiality, not least as they are designed to encourage witness cooperation. Far from our client acting above the law, as has been implied by press briefings in the US, he is being treated by a lower standard than might reasonably be expected for any other citizen. Further, those same breaches of confidentiality by the DOJ have given the global media - and, therefore, the worldwide audience - an entirely misleading account of our discussions with them. + +Any pursuit of an application for mutual legal assistance would be disappointing, since the Duke of York is not a target of the DOJ investigation and has recently repeated his willingness to provide a witness statement. It is hoped that this third offer has not been the cause of the most recent leak about the Duke of York. + +We do not intend to make any further public statement at this time as we wish to respect the rules of confidentiality under both English law and the US guidelines. + +ENDS + +## NOTES TO EDITORS + +The case is being handled by Blackfords City office + +FOR MORE INFORMATION PLEASE CONTACT RIVERSIDE ADVISORY + +Mark.gallagherlariversideadvisory.co.uk — tel: +44 7968 939291 + +Lucy.goodwin@riversideadvisory.co.uk — tel: + 44 7961 452558 + +Daniel Bates + +Journalist in New York + +www.danielgbates.com \ No newline at end of file diff --git a/marker2/ds9/EFTA00090541/EFTA00090541.metadata.json b/marker2/ds9/EFTA00090541/EFTA00090541.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..1087645c1479e7304cff53c853e7979bbe9a5af9 --- /dev/null +++ b/marker2/ds9/EFTA00090541/EFTA00090541.metadata.json @@ -0,0 +1,175 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090541.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 4915, + "elapsed_seconds": 1.44, + "image_assets": [ + "_page_1_Picture_0.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Statement regarding HRH The Duke of York", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 187.88400000000001, + 162.0 + ], + [ + 424.0908508300781, + 162.0 + ], + [ + 424.0908508300781, + 177.3170166015625 + ], + [ + 187.88400000000001, + 177.3170166015625 + ] + ] + }, + { + "title": "NOTES TO EDITORS", + "heading_level": null, + "page_id": 2, + "polygon": [ + [ + 33.660000000000004, + 241.38 + ], + [ + 135.6380615234375, + 241.38 + ], + [ + 135.6380615234375, + 256.0670166015625 + ], + [ + 33.660000000000004, + 256.0670166015625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 55 + ], + [ + "Line", + 28 + ], + [ + "Text", + 27 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 67 + ], + [ + "Line", + 32 + ], + [ + "Text", + 10 + ], + [ + "Picture", + 1 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 44 + ], + [ + "Line", + 20 + ], + [ + "Text", + 12 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00090541" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00090541/_page_1_Picture_0.jpeg b/marker2/ds9/EFTA00090541/_page_1_Picture_0.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..c9dd9f27e971bcf69dfefb9f960b2583e257f2ae --- /dev/null +++ b/marker2/ds9/EFTA00090541/_page_1_Picture_0.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:73d8b1b773ffdd81e3d3a217b29ebff91e46d47b3c24777ecd260679aefd278b +size 19897 diff --git a/marker2/ds9/EFTA00090544/EFTA00090544.md b/marker2/ds9/EFTA00090544/EFTA00090544.md new file mode 100644 index 0000000000000000000000000000000000000000..cc578c12efec66b9f3d4370ad24f34d7be17b058 --- /dev/null +++ b/marker2/ds9/EFTA00090544/EFTA00090544.md @@ -0,0 +1,13 @@ +From: (USANYS)" To: (USANYS)" alMIE> Cc: (USANYS) [Contractor]" <=1=IMIE> Subject: Re: Andrew Statement Date: Mon, 08 Jun 2020 17:08:17 +0000 + +Thanks. Let's see whatMistributed and then discuss. + +> On Jun 8, 2020, at 12:53 PM, (USANYS) alMIN> wrote: + +> Since time is of the essence and I'm sure will have a lot to add, here is a quick draft. Would you like for me too loop them in as well? + +> Earlier today, a statement was issued by the UK law firm of Blackfords LLP on behalf of their client, Prince Andrew, regarding the communications between this Office and Andrew's counsel to interview their client. Blackfords' statement contains several false assertions regarding those discussions. Firstly, their statement claims that they were "given an unequivocal assurance that the discussions would remain confidential," which is false. The statement also falsely claims that this Office somehow communicated that the Duke is not a `target' of any criminal investigation into the conduct of Jeffrey Epstein. + +> While this statement is not something we routinely issue as a matter of course, we felt it was important to state for the public in clear and unequivocal language: the career prosecutors of the Office have not violated any of the rules of confidentiality or guidelines referenced in this statement. Furthermore, any misunderstandings the Prince or his counsel may have could be resolved if he simply agreed to be interviewed. + +> Sent from my iPati \ No newline at end of file diff --git a/marker2/ds9/EFTA00090544/EFTA00090544.metadata.json b/marker2/ds9/EFTA00090544/EFTA00090544.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..bdef39d464fc4dd7c25c08fddbce9171eac195d1 --- /dev/null +++ b/marker2/ds9/EFTA00090544/EFTA00090544.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090544.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1457, + "elapsed_seconds": 0.73, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 41 + ], + [ + "Line", + 21 + ], + [ + "Text", + 14 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00090544" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00090545/EFTA00090545.md b/marker2/ds9/EFTA00090545/EFTA00090545.md new file mode 100644 index 0000000000000000000000000000000000000000..2d3181a0b01f06dfab2ae209456a6d4920ed5c68 --- /dev/null +++ b/marker2/ds9/EFTA00090545/EFTA00090545.md @@ -0,0 +1,97 @@ +From: ' To: :=iSANYS)" Cc: '1 < (USANYS)" '1 + +Subject: Fwd: Sensitive correspondence. + +Date: Mon, 08 Jun 2020 14:14:53 +0000 + +Begin forwarded message: + +From: Gary Bloxsome Date: June 8, 2020 at 09:55:54 EDT To:" Cc: ' Subject: Re: Sensitk e correspondence. + +DearIM, + +Thank you for your email of 5 June 2020. + +Given the unfortunate history of this matter, already well documented, our view is that we cannot commit to a particular form of cooperation until we are properly informed and assured as to what protections, including as to confidentiality and use, are to pertain. Our ongoing concerns in this regard are only increased as a result of yesterday's leak to the world's media regarding the existence of the MLA request. For that reason I ask you again to address the questions in my previous communication. + +Kind regards + +Gary + +Gary Bloxsome I Partner + +Blackfords LLP London + +Coronavirus — COVID-19 — A message to our clients and fellow professionals + +All of the partners of the firm are still working and their contact details can be found on our website at www.blackfords.com. In addition we have a team of key workers supporting us across all offices. We continue to take instructions from existing and new clients. + +As a consequence of the coronavirus pandemic and the need to ensure the safety of our staff, the firm will be operated by a limited number of key personnel. + +Criminal and Regulatory hearings - most court and tribunal hearings are being adjourned but you must please stay in contact with us to check hearing dates and deadlines until we have confirmation that they have been moved or extended. For individuals held in custody, cases are being dealt with where social distancing measures or electronic hearings can be implemented. + +In the meantime if you need to speak to one of our lawyers, please leave a voicemail by dialling= where we will respond to the messages in the order they are received or by emailing your enquiry to] + +Blackfords LLP is a limited liability partnership registered in England & Wales with registered numbe l Croydon, CRO LEA. A list of members' names is available at this address. + +GDPR: details of how we handle personal data can be found in ourPrivacy Statement + +Authorised and regulated by the Solicitors Regulation Authority under number + +On 5 Jun 2020, at 17:39, > wrote: + +External email: is it safe to open attachments and links? + +Gary, Thank you for your email. We are prepared to respond to your questions in full, but before proceeding further, we want to confirm that by "witness statement" you are referring to a live interview (to be conducted in person or via video conference), at which your client will answer our questions and, in advance of which, will produce any documents, including communications, relevant to the subjects to be covered at the interview. + +Regards, + +Assistant U.S. Attorney Southern District of New York + +From: Gary Bloxsome + +Sent: Wednesday, June 3, 2020 3:17 PM + +To: + +Cc: rallit < + +Subject: Sensitive correspondence. + +Dear Ma The UK Central Authority (UKCA) has informed us that the United States has formally sought assistance in interviewing our client. + +The UKCA told us that we would have the opportunity to contact from the US Embassy to explore whether, notwithstanding our concerns at the unfair treatment of the Duke by the United States Attorney for the Southern District of New York and the failure by the DOJ to abide by its promise to provide an appropriate level of confidentiality to him and us, it would be possible for the Duke to reach an agreement with the DOJ and to provide a voluntary witness statement. + +Unfortunately, it appear as no authority in the matter and has directed us to contact the U.S. case team directly via youren tss. With a view to progressing the request for assistance: + +[1] Please confirm that any communications between us, with a view to providing the DOJ with a voluntary witness statement from the Duke will be treated confidentially and in particular will not be the subject of DOJ press statements or commentary. + +[2] Please provide confirmation (given the reports of connections between the DOJ and US lawyers acting on no win/no fee arrangements) that any voluntary witness statement will not be used for any purpose other than the DOJ's criminal investigations. + +[3] We would be grateful if you would confirm the areas of testimony that you would wish the Duke's witness statement to cover. + +Kind regards + +Gary Bloxsome + +Gary BloxsomelPartner + +Blackfords LLP I London + +Coronavirus — COVID-19 —A message to our clients and fellow professionals + +All of the partners of the firm are still working and their contact details can be found on our website at www.blackfords.com. In addition we have a team of key workers supporting us across all offices. We continue to take instructions from existing and new clients. + +As a consequence of the coronavirus pandemic and the need to ensure the safety of our staff, the firm will be operated by a limited number of key personnel. + +Family Court hearings and proceedings — these are operating through video and telephone hearings. Our family team is operating as normal. + +Criminal and Regulatory hearings - most court and tribunal hearings are being adjourned but you must please stay in contact with us to check hearing dates and deadlines until we have confirmation that they have been moved or extended. For individuals held in custody, cases are being dealt with where social distancing measures or electronic hearings can be implemented. + +In the meantime if you need to speak to one of our lawyers, please leave a voicemail by dialling where we will respond to the messages in the order they are received or by emailing your enquiry to + +Blackfords LLP is a limited liability partnership registered in England & %Vales with registered number MN Croydon, CR0 l EA. A list of members' names is available at this address. + +GDPR: details of how we handle personal data can be found in ourPrivary Statement + +Authorised and regulated by the Solicitors Regulation Authority under number \ No newline at end of file diff --git a/marker2/ds9/EFTA00090545/EFTA00090545.metadata.json b/marker2/ds9/EFTA00090545/EFTA00090545.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..7b0a9711e5d2a767498c09c72524353350d02b2e --- /dev/null +++ b/marker2/ds9/EFTA00090545/EFTA00090545.metadata.json @@ -0,0 +1,114 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090545.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 6062, + "elapsed_seconds": 1.47, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 64 + ], + [ + "Line", + 31 + ], + [ + "Text", + 15 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 97 + ], + [ + "Line", + 44 + ], + [ + "Text", + 21 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 65 + ], + [ + "Line", + 30 + ], + [ + "Text", + 17 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00090545" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00090548/EFTA00090548.md b/marker2/ds9/EFTA00090548/EFTA00090548.md new file mode 100644 index 0000000000000000000000000000000000000000..c3ef299db4932cc95e0a04d98ee91c0279af5f5b --- /dev/null +++ b/marker2/ds9/EFTA00090548/EFTA00090548.md @@ -0,0 +1,63 @@ +From: " Ial" ca' To: ' lYS)" , ' (USANYS)" Cc: M' IMI.' alMIN>, In" + +Subject: FW: DOJ ongoing Investigation. + +Date: Fri, 14 Feb 2020 17:17:23 +0000 + +Inline-Images: image543915.jpg; image517195.jpg + +FYI + +From: Gary Bloxsome + +Sent: Frida , February 14, 2020 12:00 + +To: + +Subject: DOJ ongoing Investigation. + +Dear We and the Duke of York set out to assist your investigation when the DOJ asked for his help in January 2020. However, we regret to say that we have reached the conclusion that the DOJ's dealings with the Duke of York have not been designed to seek his assistance in investigating and prosecuting the targets of the investigation but instead have been used only to gather publicity for Mr Geoffrey S. Berman, the United States Attorney for the Southern District of New York. + +It is essential, if justice is to be done for Epstein's victims, that a proper and thorough criminal investigation is carried out. Although the public record indicates your office (SDNY) has been actively investigating Mr. Epstein and other targets for more than 2 years, the first time you ever attempted to make contact and request The Duke of York's help was on 2 January 2020. + +The Duke instructed my firm to make contact with you pertaining to this request. When we made contact, you confirmed that the Duke of York was not and is not a target of the US criminal investigation. + +Due to the publicity surrounding the investigation, we asked you to confirm that our discussions and any interview arrangements would remain confidential, in accordance with your rules. The Duke did not want to add to the media circus that has now surrounded the investigation. On 10 January 2020 you confirmed that any arrangements would indeed be kept confidential. + +We indicated that we would refer back to you once we had dealt with the various issues and procedures, which would need to be addressed to enable the Duke to cooperate to the fullest extent possible, including the need to obtain all the information that you might need to consider. It was at that time that we informed you, by email dated 20 January, that such preliminary issues would be dealt with within 14 days. It was also in that email that we confirmed that The Duke has a strong desire to cooperate with the ongoing investigation by the DOJ. + +Instead of waiting to hear from us (as you indicated on 22 January 2020), Mr Geoffrey S. Berman, the United States Attorney for the Southern District of New York, chose to make a public statement about the Duke on 27 January 2020. This led to press reports that there had been "a wall of silence" and that there had been "zero cooperation" by the Duke. These statements were not true. They should not have been made. + +Quite apart from your promise of confidentiality, in England it would not be thought to be in the interests of justice for any prosecutor or investigator to make public statements about witnesses who may be willing, in confidence, to assist their investigation. + +In England, prosecutors and investigators try to make sure that the investigation and trial of serious criminal cases take place in court and not in press conferences or publicity battles. + +When we complained about the way the Duke (and we) had been treated by the DOJ, you refused to apologise and you have now also gone back on your promise that any arrangements for the interview will be confidential. We cannot advise the Duke to speak to prosecutors who cannot be trusted to deal with him fairly nor to treat what he says or does confidentially. He has reluctantly accepted our advice that, in those circumstances, there is no purpose to be served in continuing to try to assist further. + +Finally we have no wish to engage in any further publicity battle about the DOJ's conduct and for that reason we ask that you treat this email as private and confidential. + +Regards + +Gary + +**Gary Bloxsome** | Partner + +[REDACTED] +[REDACTED] +[REDACTED] + +**Blackfords** | [REDACTED] | London | +**LLP** | [REDACTED] + +[REDACTED] [www.blackfords.com](http://www.blackfords.com) +[REDACTED] + +![](_page_1_Picture_117.jpeg) + +![](_page_1_Picture_118.jpeg) + +Blackfords LLP is a limited liability partnership registered in England & Wales with registered number [REDACTED] at [REDACTED]. Croydon, CR0 1EA. 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I had some preliminary, high level comments, reflected in the attached. Perhaps we could set up a time next week to talk these through? + +Have a great weekend. + +From: Sent: Thursday, June 11, 2020 6:13 PM To: (USANYS) (USANYS) < (USANYS) < >; USANYS) < >;' (USANYS) Cc: (USANYS) ; (USANYS) >:1 <->; > + +Subject: Draft Maxwell Indictment + +All, + +Attached please find draft of the Maxwell indictment. + +One thing to flag for discussion: The perjury charge in Count Five currently includes Maxwell's testimony about Mt ge. Our understanding is that we need to include the full transcript excerpt in the indictment and that, a t ough we can anonymize name, we need to use the same alias (here, "Minor Victim-1") whenever we refer to her in the entire indictment. lt, anyone who has access to the deposition transcri t will be able to identify a Minor Victim-1. That would significantly undermine the assurances we have made hat we will do everything in our power to protect her identity. Our hope is that either (a) there is a legally permissi le way to further anonymize the reference toliallin that perjury count, or (b) if not, we will be permitted to cut that specification from the indictment to protect identity. + +Thanks, \ No newline at end of file diff --git a/marker2/ds9/EFTA00090550/EFTA00090550.metadata.json b/marker2/ds9/EFTA00090550/EFTA00090550.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..447316f4c1dfbe0407eef34e3612f7ed0fa17713 --- /dev/null +++ b/marker2/ds9/EFTA00090550/EFTA00090550.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090550.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1461, + "elapsed_seconds": 0.66, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 76 + ], + [ + "Line", + 35 + ], + [ + "Text", + 13 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00090550" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00090551/EFTA00090551.md b/marker2/ds9/EFTA00090551/EFTA00090551.md new file mode 100644 index 0000000000000000000000000000000000000000..933756d6cd50d3517e9c347b4637a50641ad4767 --- /dev/null +++ b/marker2/ds9/EFTA00090551/EFTA00090551.md @@ -0,0 +1,39 @@ +To: " + +Cc: ' + +Subject: RE: NB + +Date: Fri, 12 Jun 2020 22:00:13 +0000 + +Thanks, M. That is helpful, and I'll flag for him that some of the allegations that I take it she has not confirmed to us? For example, the frequent flights with Maxwell on a jet is something in the complaint that I'm sure he will take interest in she has told us that is untrue? + +And unfortunately, I don't know much more — he just asked for it. But it would not surprise me if he is looking for additional factual allegations, like the one noted above, that we could add to the Indictment. + +From: + +Sent: Friday, June 12, 2020 5:48 PM + +To: + +Cc: + +Subject: RE: NB + +Attached. Please note to him that the complaint contains some inconsistencies both with incontrovertible facts (for example, her age when she met Epstein) and with her descriptions to us (for example, a vague reference to threats, references to frequent flights that both and Maxwell took on the jet, and certain references to her age at the time of certain events). + +Do you have any sense of what he's looking for (or at) in particular? + +From: + +Sent: Friday, June 12, 2020 16:43 + +To: >; + +=M E> + +Cc: + +Subject: NB + +Do you guys have a copy of her Jane Doe civil complaint? If so, would like a copy, so would you mind sending on? Thanks \ No newline at end of file diff --git a/marker2/ds9/EFTA00090551/EFTA00090551.metadata.json b/marker2/ds9/EFTA00090551/EFTA00090551.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..54d1198b7eeab8af845a39f921dc532e8f4eb905 --- /dev/null +++ b/marker2/ds9/EFTA00090551/EFTA00090551.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090551.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1267, + "elapsed_seconds": 0.99, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 61 + ], + [ + "Line", + 30 + ], + [ + "Text", + 23 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00090551" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00090552/EFTA00090552.md b/marker2/ds9/EFTA00090552/EFTA00090552.md new file mode 100644 index 0000000000000000000000000000000000000000..3d3e49700d90ac6e941859d15fbb3756bd7c0c63 --- /dev/null +++ b/marker2/ds9/EFTA00090552/EFTA00090552.md @@ -0,0 +1,19 @@ +From: (USANYS)" cza " To: MMIEF(NY) (FBI)" , 1 (NYPD)" Cc: r" + +Subject: ADG Follow Up + +Date: Sun, 01 Aug 2021 19:13:53 +0000 + +Attachments: 2019-12-15 \_Interview\_3O2.pdf + +Can you please send the photos referenced in the attached 302? The 302 says they are attached in a 1A. + +Also, can you please let me know of place of birth and citizenship? I think both are the UK, but would appreciate you checking tomorrow. + +Thanks, + +M + +Assistant United States Attorney United States Attorney's Office Southern District of New York One St. Andrew's Plaza New York, New York 10007 + +Tel: \ No newline at end of file diff --git a/marker2/ds9/EFTA00090552/EFTA00090552.metadata.json b/marker2/ds9/EFTA00090552/EFTA00090552.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..20fd3eab2fcc10abc8ae18368e9e37333b682710 --- /dev/null +++ b/marker2/ds9/EFTA00090552/EFTA00090552.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090552.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 581, + "elapsed_seconds": 0.62, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 46 + ], + [ + "Line", + 19 + ], + [ + "Text", + 12 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00090552" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00090553/EFTA00090553.md b/marker2/ds9/EFTA00090553/EFTA00090553.md new file mode 100644 index 0000000000000000000000000000000000000000..63eb73fe4a4197c422000babd73f9e6fe9da0440 --- /dev/null +++ b/marker2/ds9/EFTA00090553/EFTA00090553.md @@ -0,0 +1,61 @@ +To: (NY) (FBI) a.M.; (NYPD) + +Cc: + +SubjectWollow Up + +To: + +Cc: + +Subject: Re: Follow Up + +Date: Mon, 02 Aug 2021 22:03:54 +0000 + +Attachments: 2008-09-O3\_Convo\_with\_Epstein.pdf; 2008-09- + +03 i\_ hear\_youve\_had a\_spot of bother.pdf; 2009-07- + +22— mail\_from\_Jeffre-y\_Epst .leffre E stein.pdf; 2010-06- + +29\_where\_are\_u.pdf; 2010-9 ; 2010-10- + +23 Email from\_Jeffrey\_Epstei nail immW ili ' on2012-10- + +3\_ 11\_Jelfrey\_Epstein.pdf; + +Attached are all the attachments from that 302. + +From: + +Sent: Monday, August 2, 2021 9:32 AM + +To: (USANYS)< >; (NYPD) (NY) (FBI) < >; + +Cc: + +Subject: [EXTERNAL EMAIL] - RE: follow Up + +I think these are the photos, right? + +From: (USANYS) + +Sent: Sunday, August 1, 20213:14 PM + +Can you please send the photos referenced in the attached 302? The 302 says they are attached in a 1A. + +Also, can you please let me know of place of birth and citizenship? I think both are the UK, but would appreciate you checking tomorrow. + +Thanks, + +Assistant United States Attorney + +United States Attorney's Office + +Southern District of New York + +One St. Andrew's Plaza + +New York, New York 10007 + +Tel: \ No newline at end of file diff --git a/marker2/ds9/EFTA00090553/EFTA00090553.metadata.json b/marker2/ds9/EFTA00090553/EFTA00090553.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..910553e51b3cfd9e1779c8baa5cd763c785775e1 --- /dev/null +++ b/marker2/ds9/EFTA00090553/EFTA00090553.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090553.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1114, + "elapsed_seconds": 1.48, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 99 + ], + [ + "Line", + 41 + ], + [ + "Text", + 35 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00090553" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00090554/EFTA00090554.md b/marker2/ds9/EFTA00090554/EFTA00090554.md new file mode 100644 index 0000000000000000000000000000000000000000..9eb76038b3967b7de9b8fe50af42dee3c26015b5 --- /dev/null +++ b/marker2/ds9/EFTA00090554/EFTA00090554.md @@ -0,0 +1,21 @@ +Forwarded message ------- + +From: Lesley Groff •< > + +Date: Tue, Jun 29, 2010 at 8:33 AM + +Subject: Jeffrey Epstein + +To: + +Hello Jeffrey looks forward to seeing you on Wed. July 8th at 5:00 at his home. He lives at: + +9 East 71st Street between 5th and Madison. + +I will re-confirm with you on the 8th . + +Take care and safe trip here! + +Lesley + +Tel: \ No newline at end of file diff --git a/marker2/ds9/EFTA00090554/EFTA00090554.metadata.json b/marker2/ds9/EFTA00090554/EFTA00090554.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..92b10ea2ba10de6b1632435d4c24d1dc6b7fbef3 --- /dev/null +++ b/marker2/ds9/EFTA00090554/EFTA00090554.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090554.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 342, + "elapsed_seconds": 0.54, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 35 + ], + [ + "Line", + 12 + ], + [ + "Text", + 10 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Text", + 3 + ], + [ + "Span", + 3 + ], + [ + "Line", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00090554" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00090558/EFTA00090558.md b/marker2/ds9/EFTA00090558/EFTA00090558.md new file mode 100644 index 0000000000000000000000000000000000000000..caf3866046ea08de1e97889fcdec761c7e693b5f --- /dev/null +++ b/marker2/ds9/EFTA00090558/EFTA00090558.md @@ -0,0 +1,23 @@ +From: Bruce Barket < + +To: + +Cc: Aida Leisenring < + +Subject: Statements by Mr. Tartaglione + +Date: Sun, 17 Nov 2019 22:03:09 +0000 + +It is my understanding that Mr. Tartaglione was interviewed by members of Bureau of Prisons in the late hours of July 22nd or the early hours of July 23, 2019 concerning Jeffrey Epstein's reported attempted suicide attempt. Pease provide the record of any statements made by Mr. Tartaglione, any written statements made by Mr. Tartaglione and any recording of any such statements. + +Bruce A. Barket, Esq. + +Barket Epstein Kearon Aldea & LoTurco, LLP + +666 Old Country Road , Ste. 700 + +Garden City, NY 11530 + +www.barketepstein.com + +This transmittal may be a confidential attorney client communication or may otherwise be privileged or confidential. If it is not clear that you are the intended recipient, you are hereby notified that you have received this transmittal in error; any review, dissemination, distribution or copying of this transmittal is strictly prohibited. If you suspect that you have received this communication in error, please notify us immediately by telephone or email and immediately delete this message and all its attachments \ No newline at end of file diff --git a/marker2/ds9/EFTA00090558/EFTA00090558.metadata.json b/marker2/ds9/EFTA00090558/EFTA00090558.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..625a04cda70ec6683710287192b75125610d4ba1 --- /dev/null +++ b/marker2/ds9/EFTA00090558/EFTA00090558.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090558.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1176, + "elapsed_seconds": 0.61, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 40 + ], + [ + "Line", + 19 + ], + [ + "Text", + 12 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00090558" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00090559/EFTA00090559.md b/marker2/ds9/EFTA00090559/EFTA00090559.md new file mode 100644 index 0000000000000000000000000000000000000000..1ccd223fff3b09e3529461a4d80309f9fb0b9e8b --- /dev/null +++ b/marker2/ds9/EFTA00090559/EFTA00090559.md @@ -0,0 +1,781 @@ +From: Robert Glassman To: " Cc: , Nathan Werksman , Kevin Boyle + +Subject: RE: SDNY investigation + +Date: Wed, 12 Feb 2020 16:55:29 +0000 + +Thanks for letting us know. Can you send me a list of the schools you've subpoenaed and reached out to? Just want to make sure if she gets a call from someone, it is actually from someone who you've contacted and is legit. As you can imagine, there are lots of calls and emails to her and her manager saying all kinds of stuff. + +Robert Glassman, Esq. Panish Shea & Boyle LLP + +![](_page_0_Picture_5.jpeg) + +Web: www.psblaw.com + +## CONFIDENTIALITY NOTICE: + +This e-mail may contain confidential and privileged material for the sole use of the intended recipient(s). Any review, use, distribution or disclosure by others is strictly prohibited. If you are not the intended recipient (or authorized to receive for the recipient), please contact the sender by reply e-mail or telephone, and delete all copies of this message. + +If you are a potential client, the information you disclose to us by email will be kept in strict confidence and will be protected to the full extent of the law. Please be advised, however, that Panish Shea & Boyle LLP and its lawyers do not represent you until you have signed a retainer agreement with the firm. Until that time, you are responsible for any statutes of limitations or other deadlines for your case or potential case. + +## Ori inal Messa e + +From: [mailto: Sent: Wednesday, February 12, 2020 8:51 AM To: Robert Glassman < Cc: ; Nathan Werksman < ; Kevin Boyle + +Subject: RE: SDNY investigation + +Robert, + +Just as a brief heads up, we're in the process of requesting certain student records from schools previously attended, to corroborate aspects of the relevant timeline, and some of those entities position that they need to notify her of our requests. Rather than have her hear that in the first instance from them, we wanted to let you know. As you would expect, we have not referenced the Epstein investigation in our communications with any of those entities, or in the subpoenas, but again in an abundance of caution we wanted to reach out so you knew. + +Ori inal Messa e + +From: + +Sent: Monday, February 10, 2020 17:09 + +To: Robert Glassman < + +Cc: + +Nathan Werksman Kevin Boyle + +Subject: RE: SDNY investigation + +Confirmed, thanks -- see you at 11:00 on the 27th. + +Original Message + +From: Robert Glassman + +Sent: Monda Febru• 10 2020 17:08 + +To: + +Cc: + +Nathan Werksman < Kevin Boyle + +Subject: RE: SDNY investigation + +Yes. See you then. + +Robert Glassman, Esq. + +Panish Shea & Boyle LLP + +Los Angeles, CA 90025 + +Web: www.psblaw.com + +## CONFIDENTIALITY NOTICE: + +This e-mail may contain confidential and privileged material for the sole use of the intended recipient(s). Any review, use, distribution or disclosure by others is strictly prohibited. If you are not the intended recipient (or authorized to receive for the recipient), please contact the sender by reply e-mail or telephone, and delete all copies of this message. + +If you are a potential client, the information you disclose to us by email will be kept in strict confidence and will be protected to the full extent of the law. Please be advised, however, that Panish Shea & Boyle LLP and its lawyers do not represent you until you have signed a retainer agreement with the firm. Until that time, you are responsible for any statutes of limitations or other deadlines for your case or potential case. + +Ori inal Messa e + +From: [mailto: + +Sent: Saturday, Februa 08 2020 11:59 AM + +To: Robert Glassman < + +Cc: + +; Nathan Werksman Kevin Boyle + +Subject: RE: SDNY investigation + +Great, thanks. Should we plan for 11:00 again? Or let us know if you prefer a different time, we should be flexible. + +Original Message + +From: Robert Glassman < + +Sent: Frida Febru. + +To: + +Cc: + +Nathan Werksman < Kevin Boyle < + +Subject: RE: SDNY investigation + +2/27 works. Thanks, and see you then. + +Robert Glassman, Esq. + +Panish Shea & Boyle LLP + +Web: www.psblaw.com + +Los Angeles, CA 90025 + +## CONFIDENTIALITY NOTICE: + +This e-mail may contain confidential and privileged material for the sole use of the intended recipient(s). Any review, use, distribution or disclosure by others is strictly prohibited. If you are not the intended recipient (or authorized to receive for the recipient), please contact the sender by reply e-mail or telephone, and delete all copies of this message. + +If you are a potential client, the information you disclose to us by email will be kept in strict confidence and will be protected to the full extent of the law. Please be advised, however, that Panish Shea & Boyle LLP and its lawyers do not represent you until you have signed a retainer agreement with the firm. Until that time, you are responsible for any statutes of limitations or other deadlines for your case or potential case. + +From: [mailto: + +Ori inal Messa e + +Sent: Friday, February 07, 2020 3:08 PM + +To: Robert Glassman + +Cc: + +; Nathan Werksman < ; Kevin Boyle + +Subject: RE: SDNY investigation + +Robert, + +We should be able to do any time Wednesday through Friday (26th-28th) of that week, with a preference for Thursday the 27th if that would be convenient for you and What's good on your end? + +thanks, + +Original Messa e + +From: + +Nathan Werksman ; Kevin Boyle + +Subject: RE: SDNY investigation + +Robert, + +Thanks very much for getting back to us -- I left a voicemail just a few minutes ago, hadn't yet seen your email, but we'll figure out the team's schedule and get back to you very shortly. That should work, but let us confirm. + +thanks, + +Original Message + +From: Robert Glassman + +Sent: Frida Febru. 07 2020 15:43 + +To: + +Cc: + +Nathan Werksman ; Kevin Bogie + +Subject: Re: SDNY roves iga ion + +how's the week of 2/24 instead? That's better for her. + +Robert S. Glassman + +Panish Shea & Boyle + +psblaw.com + +> On Feb 6, 2020, at 11:08 AM, < 1=1.> wrote: + +> Robert, + +> We're still hoping to try to schedule an interview with on February 19 (or the following couple days), per the below -- would that be a possibility? I'll give you a call tomorrow if we haven't connected by then but wanted to bump this from last week. Thank you! + +> ----Ori inal Messa e + +> From: + +> Sent: Friday, January 31 2020 14:01 + +> To: 'Robert Glassman' < + +> Cc: + +• Nathan Werksman' • ; 'Kevin + +> Boyle' + +> Subject: RE: SDNY investigation + +> Robert, + +> Wanted to follow up on the below in case it was still useful to chat -- some combination of the team will be around next week if you want to have a call. + +members, and we wanted to see if we might be able to put something on the calendar to come talk with again once we've completed those steps. Would it work for you and her to meet anytime noon or later on February 19? Or if not the 19th, any availability on the 20th or 21st? + +> thanks very much, + +> Ori inal Messa e + +> From: + +> Sent: Friday, January 24, 2020 03:45 + +> To: Robert Glassman + +> Cc: + +; Nathan Werksman ; Kevin + +> Boyle < + +> Subject: RE: SDNY investigation + +> Robert, + +> Apologies for the belated reply, it's been a crazy week for us, but we'd be happy to talk. We should be generally available tomorrow (Friday) until about 2 p.m. our time, or also early next week if that's easier. + +> thanks, + +> Original Message + +> From: Robert Glassman + +> Sent: Wednesda Janua 22 2020 15:39 + +> To: + +> Cc: + +; Nathan Werksman < ; Kevin + +> Boyle < + +> Subject: Re: SDNY investigation + +> Thanks MI ended up seeing these too. + +> Our judge is John Koeltl and the magistrate is Barbara Moses. + +> Moskowitz already reached out to us. + +> Is there a good time to chat? + +> Robert S. Glassman + +> Panish Shea & Boyle + +> psblaw.com + +>> On Jan 20, 2020, at 1:11 PM, < 1=1.> wrote: + +you wouldn't mind letting us know when a judge is assigned, that would also be helpful. In terms of media, it was covered in the Daily News on Friday, here: + +>> https://www.nydailynews.com/new-yorlc/ny-epstein-trump-victim-suit-202 + +>> 00118-m6sqsa2h7venpf5 uewjrkvigo4-story.html + +>> + +>> And then picked up by the Post and other outlets on Saturday: + +>> https://nypost.corn/2020/01/18/new-jeffrey-epstein-accuser-says-he-mol + +>> ested-her-at-13-told-her-to-wear-childrens-underwear/ + +>> https://www.the-sun.corn/news/274369/jeffrey-epstein-first-victim-kids + +>> -underwear/ + +>> https://www.dailymail.co.ukJnews/article-7901651/Woman-claiming-Jeffr + +>> ey-Epsteins-victim-says-introduced-Trump-age-14.html + +» thanks, + +>> + +>> Original Message + +>> From: Robert Glassman C + +>> Sent: Friday, January 17, 2020 22:18 + +» To: + +» Cc: + +>> ; Nathan Werksman + +>> Subject: RE: SDNY investigation + +>>.sorry for not giving you a heads up on this. That was not my intent. Just been really busy with a couple of of er ig matters going on now. Please see attached. What media is picking it up? I don't see anything. + +» Robert Glassman, Esq. + +» Panish Shea & Boyle LLP + +» Web: www.psblaw.com + +>> + +>> CONFIDENTIALITY NOTICE: + +>> This e-mail may contain confidential and privileged material for the sole use of the intended recipient(s). Any review, use, distribution or disclosure by others is strictly prohibited. If you are not the intended recipient (or authorized to receive for the recipient), please contact the sender by reply e-mail or telephone, and delete all copies of this message. + +>> + +>> If you are a potential client, the information you disclose to us by email will be kept in strict confidence and will be protected to the full extent of the law. Please be advised, however, that Panish Shea & Boyle LLP and its lawyers do not represent you until you have signed a retainer agreement with the firm. Until that time, you are responsible for any statutes of limitations or other deadlines for your case or potential case. + +>> Original Message + +» From: + +» [mailto: + +Los Angeles, CA 90025 + +; Nathan Werksman + +>> Subject: RE: SDNY investigation + +» Robert, + +>> Based on media reports today it looks like you filed the civil lawsuit? I don't think we realized that was imminent -- could we ask you to please send us a copy of the filing? I don't yet see it on PACER. + +» thanks, + +>> Ori inal Messa e + +» From: + +>> Sent: Monday, December 30.2019 22:28 + +» To: Robert Glassman < + +» Cc: + +; Nathan Werksman < + +>> Subject: RE: SDNY investigation + +» Great, thanks very much. We'll likely start with siblings and mother and then go from there. As soon as we have a sense of when it would be productive for us to return for a follow-up meeting with =IM we'll reach out -- as I mentioned, we're hoping that will be sometime in January, but just depending on how quickly we're able to schedule these discussions. And as always, please don't hesitate to let us know if anything comes up in the meantime. + +>>. + +>> Original Message---- + +>> From: Robert Glassman + +>> Sent: Monday. December 30.2019 22:20 + +» To: + +» Cc: + +; Nathan Werksman + +>> Subject: Re: SDNY investigation + +>>. - yes, all good to contact those folks. Thanks for checking in. + +>> Robert S. Glassman + +» Panish Shea & Boyle + +>> psblaw.com + +»>> On Dec 30, 2019, at 1:10 pm, wrote: + +>» + +>» Robert, + +>» + +>>> Following up on our most recent meeting with you and MIMI we wanted to confirm that it's alright for us to begin re • ' wee ntacts she ident ified for us-- in particular, we would initiall expect to contact andibiliand then + +We also wanted to see if it we are able at this stage to contact her mother, who is potentially a key witness -- I know had wanted to speak with her mother in advance of us doing that. Please let us know if it's alright to make those calls? And se arately, if you could please let us know if her brother has happened to have any contact with since we last spoke -- no problem at all if not, but I think she mentioned that was a possibility so wante to c eck. + +>>> Thanks very much, and hope you're having a good holiday season. + +>» thanks again, + +»>- + +»> + +>» + +>» ----Ori inal Messa e + +>» From: + +>>> Sent: Friday, December 13, 2019 17:06 + +>» To: Robert Glassman + +>» Cc: + +>>> ; Nathan Werksman + +>>> Subject: RE: SDNY investigation + +>» + +>>> Totally understand, just wanted to ask. We'll see you Monday at 11:00. And thanks for that additional info as well. + +>» + +>». + +>» + +>» ----Original Message----- + +Glassman >»From: Robert + +>>> Sent: Frida , December IS M + +>» To: + +>» Cc: + +>>> ; Nathan Werksman + +>>> Subject: Re: SDNY investigation + +unfortunately, we can't do earlier than 11. She just needs time to get to my office after taking care of kid stuff etc. + +>>> Re the mom, my understanding is that she is overseas somewhere. Pretty sure she's not in the US. I will find out and we can chat about it on Monday. + +>» + +>» + +>» Robert S. Glassman + +• Panish Shea & Boyle + +• psblaw.com + +>» + +>» + +>>>>> On Dec 12, 2019, at 1:30 pm, O wrote: + +>>» + +»» Robert, + +>>» + +>>>> We wanted to ask if it might be possible to start at 10:00 on Monday rather than 11:00? If not, we totally understand (I think you may have wanted time to meet with her before starting with us) but wanted to check. + +>>» + +>>>> Separately, I know III left you a message earlier ' ' emailing about this we can just ask - we were wondering if it mig . t e possible to tell us where re mother currently lives? Not her literal + +address, but just city and/or state — we don't have any intention of contacting her before we speak to you and your client in person, but just for our longer-term logistical planning, we're wondering where we would be headed if and when an interview of her were to be appropriate. + +>>» + +>>» thanks, + +>>» + +>>» + +»» ----Ori inal Messa e + +»» From: + +>>>> Sent: Wednesday, December 11, 2019 13:15 + +»» To: Robert Glassman + +>>>> Cc: + +; Nathan Werksman + +>>>> + +>>» u jec roves igation + +>>» + +>>>> Confirmed, thanks -- we'll see you then. And just on substance, I think we mentioned these topics when we spoke on the phone earlier, but just to refresh, I expect we'll want to talk through some additional specifics on travel, we'll talk more about other steps we'll be looking to take in our investigation for corroboration and what the appropriate timing and f Maxwell to whatever extent would be, and to start to talk about specific conduct by Epstein and/or is comfortable with that at this stage. And we'll also likely refresh on some other topics as well, but just to ag some of the more immediate areas we'll expect to cover. Let us know if it's useful to chat again before Monday, otherwise we'll see you then. + +>>» + +>>» thanks again, + +>>>>111M + +>>>> + +>>» + +>>>> -----Original Message-- + +»» From: Robert Glassman < + +>>>> Sent: Wednesda December 11 2019 12:38 + +»» To: + +>>» Cc: + +; Nathan Werksman + +>>» + +>>>> Su ject: investigation + +>>» + +>>>> Let's do ll a.m. on Monday. + +>>» + +>>» Robert Glassman, Esq. + +>>>> Panish Shea & Boyle LLP + +>>» Los Angeles, CA 90025 + +>>» + +>>» + +>>» >>>> e : www.ps aw.com + +>>» + +>>» CONFIDENTIALITY NOTICE: + +>>>> This e-mail may contain confidential and privileged material for the sole use of the intended recipient(s). + +Any review, use, distribution or disclosure by others is strictly prohibited. If you are not the intended recipient (or authorized to receive for the recipient), please contact the sender by reply e-mail or telephone, and delete all copies of this message. + +>>» + +and will be protected to the full extent of the law. Please be advised, however, that Panish Shea & Boyle LLP and its lawyers do not represent you until you have signed a retainer agreement with the firm. Until that time, you are responsible for any statutes of limitations or other deadlines for your case or potential case. + +>>» + +>>» + +>>>> ----Original Message + +»» From: + +»» [mailto: + +>>>> Sent: Wednesday, llcc,Inber l 1.2019 8:26 AM + +»» To: Robert Glassman • + +»» Cc: ; Nathan Werksman + +>7'7> + +>>>> Su )3Lcl. investigation + +>7'7> + +>>» Robert, + +>>» + +>>>> That's great, thanks very much. Do you have a preference on timing? Anytime that morning starting at 10:00 a.m. or later would be fine for us, or we could also start early afternoon if that's easier--whatever you and prefer. And our hope is that we'd be able to cover everything on Monday, but we'll also be available on Tuesday if that ends up being useful as well. + +>>» + +>>» thanks, + +>>» + +>>» + +>>» + +>>>> -----Original Message + +»» From: Robert Glassman < + +>>>> Sent: Tuesda December 10 2019 20:59 + +»» To: + +>>» Cc: ; Nathan Werksman + +>>>> + +>>>> Subject: Re: SDNY investigation + +>>» + +>>>> Monday morning works at my office. Tuesday may also work too if you need more time. But confirm for Monday. + +>>» + +>>» + +>>>> Robert S. Glassman + +»» Panish Shea & Boyle + +>>>> psblaw.com + +>>» + +>>» + +>>>>>> On Dec 10, 2019, at 9:35 AM, wrote: + +>>>» + +>»» Robert, + +>>>» + +>>>>> Following up on our call, in terms of logistics, we can come to California to meet with anytime this coming Sunday, Monday, or Tuesday, if any of those work? Also, if it's at all possible to either set aside a significant amount of time on one day or--possibly preferably--a few hours on two consecutive days (and if so, we could do the second meeting on Wednesday if that's helpful), that will allow us to review relevant case notes, do quick research, or anything else that would provide for helpful follow-up where we'd just need a little + +>>>» + +>»» thanks, + +>>>» + +»»> + +>>>>> Ori inal Messa e + +>>>» From: + +>>>>> Sent: Monday, December 09 2019 17:46 + +>»» To: Robert Glassman < + +>>>>> Cc: ; Nathan Werksman + +>>>» >>>» + +>>>>> Subject: RE: SDNY investigation + +>>>» + +>>>>> Thanks Robert -- we'll call you in 5-10 minutes, just gathering everybody up in the same place. Thanks very much. + +>>>» + +>>>>> Original Message + +>>>» From: Robert Glassman + +>>>>> Sent: Monday,December 09, 2019 17:34 + +>>>» To: + +>>>» Cc: ; Nathan Werksman + +>>>» • >>>» + +>>>>> Subject: Re: SDNY investigation + +>>>» + +>»» Yes. Call me on my cell today. + +>>>» + +>>>» + +>»» Robert S. Glassman + +>»» Panish Shea & Boyle + +>>>>> psblaw.com + +>>>» + +>>>» + +>>>>>» On Dec 9, 2019, at 9:21 AM, wrote: + +>>>>» + +>>»» Robert, + +>>>>» + +>>>>>> Checking in on the below -- is there a good time to chat this week? + +>>>>» + +>>»» thanks, + +»»»- + +»»» + +>>>>>> -----Ori inal Messa e + +>>>>» From: + +>>>>>> Sent: Wednesday, December 04, 2019 13:06 + +>>>>» To: Robert Glassman + +>>>>» Cc: 1 • Nathan Werksman + +>>>>» >>>>» + +>>>>>> Subject: RE: SDNY investigation + +>>>>>> Following up on our discussion a couple weeks ago, would it make sense to have a quick call later this week or early next to check in on current status? We also have one additional data point we'd like to convey as well, at your convenience. + +>>>>» + +>>>>» thanks, + +>>>>» + +>>>>» + +>>>>» + +>>»» -----Original Message----- + +>>»» From: Robert Glassman C + +>>>>>> Sent: Friday. November 22.2019 13:31 + +>>».» To: + +>>>>» Cc: ; Nathan Werksman + +>>>>» + +>>>>» + +>>>>» Subject: Re: SDNY investigation + +>>>>» + +>>»» Thanks. Cell is best + +>>>>» + +>>>>» + +>>»» Robert S. Glassman + +>>»» Panish Shea & Boyle + +>>»» psblaw.com + +>>>>» + +>>>>» + +>>>>>>>> On Nov 22 2019 at 10:14 AM, + +wrote: + +>>>>>>> + +>>>>>> \ No newline at end of file diff --git a/marker2/ds9/EFTA00090559/EFTA00090559.metadata.json b/marker2/ds9/EFTA00090559/EFTA00090559.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..b3818d8b0e8965104449ec4ae1513ec9105daf55 --- /dev/null +++ b/marker2/ds9/EFTA00090559/EFTA00090559.metadata.json @@ -0,0 +1,495 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090559.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 12, + "chars": 18790, + "elapsed_seconds": 3.52, + "image_assets": [ + "_page_0_Picture_5.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + 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Messages sent through dictation. + +![](_page_0_Picture_125.jpeg) + + + +**NOTICE:** The information contained in this communication is legally privileged and/or confidential information, which is intended only for use of recipient. If the reader of this communication is not the intended recipient (or the agent or employee responsible to deliver it to the intended (recipient), you are hereby notified that any dissemination, distribution, or reproduction of this communication is strictly prohibited. If you have received this communication by error, please immediately notify the sender by e-mail and delete this email from your system. Nothing in this email should be construed as a legal opinion or tax advice. + +On Feb 15, 2020, at 3:44 PM, [REDACTED] <[REDACTED]> wrote: + +Got it -- I had that down as London, rather than Paris, so that's helpful. And I should say, these questions aren't immediately time-sensitive, I just didn't want to forget to ask, since I'm reviewing the notes now. + +thanks, +[REDACTED] + +--- + +**From:** Michael Bachner [REDACTED] +**Sent:** Saturday, February 15, 2020 15:41 +**To:** [REDACTED] <[REDACTED]> +**Cc:** [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> +**Subject:** Re: [REDACTED] Attorney Proffer + +Hi [REDACTED] is away for the weekend. In our meeting I indicated that she stayed in the Paris apartment with her husband on one occasion. I will get back to you on Monday or Tuesday regarding the other questions you've asked today as well as at the meeting. Have a nice weekend + +Michael Bachner Bachner & Weiner, PC + +![](_page_1_Picture_1.jpeg) + +Please excuse typographical errors. Messages sent through dictation. + +c-WRD000.jpg> + +https://www.actl.cotn/ + +NOTICE: The information contained in this communication is legally privileged and/or confidential information, which is intended only for use of recipient. If the reader of this communication is not the intended recipient (or the agent or employee responsible to deliver it to the intended (recipient), you are hereby notified that any dissemination, distribution, or reproduction of this communication is strictly prohibited. If you have received this communication by error, please immediately notify the sender by e-mail and delete this email from your system. Nothing in this email should be construed as a legal opinion or tax advice. + +On Feb 15, 2020, at 3:05 PM, > wrote: + +Michael, + +Following up on our meeting, one additional question / clarification we have from reviewing our notes is about whether ever visited certain Epstein properties other than his New York mansion and the brief visit to the Palm Beach residence. I apologize if you addressed that and I missed it, but we wanted to add it to the list of additional questions — in particular, whether she ever visited the New Mexico ranch, the Little St. James Island, the Great St. James island, and/or the Paris residence. Also, is it correct that she just visited the Palm Beach residence the one time you referenced? It's not a problem or issue if she visited any of those other locations, we just wanted to clarify one way or the other. And happy to discuss via phone if that's useful. + +![](_page_1_Picture_10.jpeg) + +From: + +Sent: Thursday, Fe + +To: Michael Bachn + +Cc: '4 >; + +Subject: RE: ttorney Proffer + +Michael, + +We do understand that your attorney proffer today will be preliminary, and to the best of your client's current recollection and to the best of your current understanding, and without, e.g., having been provided documents or other materials by the Government. + +We also confirm that your statements will be considered to be made pursuant to Fed. R. Evid. 410 and Fed. R. Crim. P. 11(f), and therefore under those protections. Regarding Rule 408, we'll just note what we have for other counsel in this case and others who have made similar statements or submissions, which is that we don't take any position on the effect or application of Rule 408 in a prospective or hypothetical dispute in civil litigation, because it doesn't implicate any rights the Government would or would not have, but you can consider us advised that your position is that your statements are also covered under 408. (While our Office itself can't guarantee the protections of Rule 408 because any dispute on that issue would be beyond our purview, we are also not taking the position that we believe it does not apply.) + +u, + +From: Michael Bachner Sent: Thursday, February 13, 2020 10:08 To: Subject: Mttorney Proffer + +Hi + +Prior to our meeting today, I am writing to confirm that s ments I make to you today are preliminary and subject to further refinement once M nd I have the benefit of additional document review and refreshed recollection if necessary b e upon input we may receive from your office. My statements to you are intended in hypothetical form only and in any event, we understand that the provisions of FRE 408 and 410 apply. + +Please advise if my understanding is correct. + +Thanks. + +Michael Bachner Bachner & Associates, PC + + + +https://www.actl.com/ \ No newline at end of file diff --git a/marker2/ds9/EFTA00090571/EFTA00090571.metadata.json b/marker2/ds9/EFTA00090571/EFTA00090571.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..401a252e7eb46e4ba3b35684765534b95da78004 --- /dev/null +++ b/marker2/ds9/EFTA00090571/EFTA00090571.metadata.json @@ -0,0 +1,126 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090571.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 5482, + 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b/marker2/ds9/EFTA00090574/EFTA00090574.md @@ -0,0 +1,17 @@ +From: To Cc: " aMIMIE> (NY) (FBI)" (NY) (FBI)" rout tact + +Subject: RE: Epstein search warrant documents + +Date: Sat, 15 Feb 2020 21:30:19 +0000 + +I'm not sure who's the exact right person to ask this, so wanted to get everybody on one email chain about it — I have the hard drive than dropped off that has new Epstein search warrant materials, but it looks like there are also old materials (that I think we had previously received and uploaded??) on the hard drive, and so I'm not sure what's new. + +Just generally, an' I talked about this last week too, but it's basically impossible for us to keep track of what we're getting, and what has been completed, without some kind of identification or labeling system, along with a list of which devices have been extracted and downloaded. + +So for example on the hard drive currently, there are 38 folders labeled "loadFiles" through "37loadFiles" with a modified date of 11/14/19, which I think we may have already previously received — but I'm not sure, because we haven't gotten any info on which folders match up to which devices, etc. And then there's another folder titled "NYC024362" that has a modified date of 1/27/20, so I think that may be the materials we hadn't previously received? That folder by itself has more than 600,000 items. + +I don't want to giveaanything that we've already previously received and uploaded, and I can't tell from the folder or file names whether everything on the drive is new, or whether just additional materials were saved onto it in addition to what we already have-re you able to give us some guidance on this? Ultimately what we really need is a spreadsheet of every device, whether it's been dumped (or partially dumped), and then identifying that same info which device, and what materials from it— are being given to us with each data transfer. Otherwise I think organizationally and for review purposes it will be a total disaster for us. + +We're happy to have a meeting on this if that's helpful — and thanks everybody for the assistance. + +Assistant U.S. Attorney Southern District of New York \ No newline at end of file diff --git a/marker2/ds9/EFTA00090574/EFTA00090574.metadata.json b/marker2/ds9/EFTA00090574/EFTA00090574.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..74d9ce6b58f98d696a52ac3834c1630272701452 --- /dev/null +++ b/marker2/ds9/EFTA00090574/EFTA00090574.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090574.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 2086, + "elapsed_seconds": 0.52, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 61 + ], + [ + "Line", + 29 + ], + [ + "Text", + 9 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00090574" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00090575/EFTA00090575.md b/marker2/ds9/EFTA00090575/EFTA00090575.md new file mode 100644 index 0000000000000000000000000000000000000000..739bb51b283cd8e8a5124f03c1958076c9d55c86 --- /dev/null +++ b/marker2/ds9/EFTA00090575/EFTA00090575.md @@ -0,0 +1,689 @@ +From: '1 ~ 1. ~la To: Robert Glassman Cc: , Nathan Werksman Kevin Boyle + +Subject: RE: SDNY investigation + +Date: Wed, 12 Feb 2020 17:30:59 +0000 + +Of course, and I should say, if it's alright, we can give the schools our information in the first instance in the hopes that they're willing to go through you rather than bothering irectly (or if that adds complications, rather than reducing them, let us know). The schools / entities are + +n 'ew 'or .In p u , mu r m•yr n n pr r- .r ac, T. y connect with you separately on a , and we can continue to keep you posted. As to Kevin's note, ordinarily there's no notice requirement, but there are some unusual rules that apply to educational institutions, which we think is driving some of the back-and-forth we're having. + +Thanks for your help with this, as always, and we'll keep in touch on this. + +Original Message + +From: Robert Glassman ‹ > + +Sent: Wednesda Febru• 12, 2020 11:55 + +To: + +Cc: + +Nathan Werksman '-; Kevin Boyle + +Subject: RE: SDNY investigation + +Thanks for letting us know. Can you send me a list of the schools you've subpoenaed and reached out to? Just want to make sure if she gets a call from someone, it is actually from someone who you've contacted and is legit. As you can imagine, there are lots of calls and emails to her and her manager saying all kinds of stuff. + +Robert Glassman, Esq. + +Panish Shea & Boyle LLP + +11111 Santa Monica Boulevard, Suite 700 Los Angeles, CA 90025 + +Tel: + +Fax + +Email: + +Web: www.psblaw.com + +## CONFIDENTIALITY NOTICE: + +This e-mail may contain confidential and privileged material for the sole use of the intended recipient(s). Any review, use, distribution or disclosure by others is strictly prohibited. If you are not the intended recipient (or authorized to receive for the recipient), please contact the sender by reply e-mail or telephone, and delete all copies of this message. + +If you are a potential client, the information you disclose to us by email will be kept in strict confidence and will be protected to the full extent of the law. Please be advised, however, that Panish Shea & Boyle LLP and its lawyers do not represent you until you have signed a retainer agreement with the firm. Until that time, you are + +Ori inal Messa e + +From: [mailto: Sent: Wednesday, February 12, 2020 8:51 AM To: Robert Glassman Cc: ; Nathan Werksman u jest: : investigation Kevin Boyle + +Robert, + +Just as a brief heads up, were in the process of requesting certain student records from schoolspreviously attended, to corroborate aspects of the relevant timeline, and some of those entities may take the position that they need to notify her of our requests. Rather than have her hear that in the first instance from them, we wanted to let you know. As you would expect, we have not referenced the Epstein investigation in our communications with any of those entities, or in the subpoenas, but again in an abundance of caution we wanted to reach out so you knew. + +thanks, + +Ori inal Messa e + +From: Sent: Monday, Februa 10 2020 17:09 To: Robert Glassman Cc: ;I~~~) ana; Nathan Werksman ; Kevin Boyle Subject: RE: SDNY investigation + +Confirmed, thanks -- see you at 11:00 on the 27th. + +Original Message + +From: Robert Glassman Sent: Monda Febru To: Cc: Nathan Werksman Subject: RE: SDNY investigation ; Kevin Boyle + +Yes. See you then. + +Robert Glassman, Esq. Panish Shea & Boyle LLP 111 11 Sant oulevard, Suite 700 Los Angeles, CA 90025 Tel: Fax Email: Web: www.psblaw.com + +review, use, distribution or disclosure by others is strictly prohibited. If you are not the intended recipient (or authorized to receive for the recipient), please contact the sender by reply e-mail or telephone, and delete all copies of this message. + +If you are a potential client, the information you disclose to us by email will be kept in strict confidence and will be protected to the full extent of the law. Please be advised, however, that Panish Shea & Boyle LLP and its lawyers do not represent you until you have signed a retainer agreement with the firm. Until that time, you are responsible for any statutes of limitations or other deadlines for your case or potential case. + +Ori inal Messa e + +From: [mailco: Sent: Saturday, Februa 08 2020 11:59 AM To: Robert Glassman C Cc: ; Nathan Werksman Subject: RE: SDNY investigation ; Kevin Boyle + +Great, thanks. Should we plan for 11:00 again? Or let us know if you prefer a different time, we should be flexible. + +Original Message + +Frida Febru On From: Robert Glassman Sent: To: Cc: Nathan Werksman ‹ ; Kevin Boyle Subject: RE: SDNY investigation + +2/27 works. Thanks, and see you then. + +Robert Glassman, Esq. Panish Shea & Boyle LLP 11111 Santa Monica Boulevard, Suite 700 Los Angeles, CA 90025 Tel: Fax: Email: Web: www.psblaw.com + +## CONFIDENTIALITY NOTICE: + +This e-mail may contain confidential and privileged material for the sole use of the intended recipient(s). Any review, use, distribution or disclosure by others is strictly prohibited. If you are not the intended recipient (or authorized to receive for the recipient), please contact the sender by reply e-mail or telephone, and delete all copies of this message. + +If you are a potential client, the information you disclose to us by email will be kept in strict confidence and will be protected to the full extent of the law. Please be advised, however, that Panish Shea & Boyle LLP and its lawyers do not represent you until you have signed a retainer agreement with the firm. Until that time, you are responsible for any statutes of limitations or other deadlines for your case or potential case. + +From: Sent: Friday, February 07, 2020 3:08 PM To: Robert Glassman Cc: [mailto: ; Nathan Werksman < ; Kevin Boyle Subject: RE: SDNY investigation + +Robert, + +We should be able to do any time Wednesday through Frida.h-28th) of that week, with a preference for Thursday the 27th if that would be convenient for you and What's good on your end? + +thanks, + +Original Messa e + +From: Sent: Friday, February To: Robert Glassman Cc: Nathan Werksman Subject: RE: SDNY investigation aNIMIE>, ; Kevin Boyle <11.1e> + +Robert, + +Thanks very much for getting back to us -- I left a voicemail just a few minutes ago, hadn't yet seen your email, but we'll figure out the team's schedule and get back to you very shortly. That should work, but let us confirm. + +thanks, + +Original Message + +From: Robert Glassman -c i> Sent: Frida , Februa 07 2020 15:43 To: Cc: Nathan Werksman Kevin Boyle Subject: Re: SDNY investigation + +how's the week of 2/24 instead? That's better for her. + +Robert S. Glassman Panish Shea & Boyle psblaw.com + +> On Feb 6, 2020, at 11:08 AM, a a wrote: > Robert, > We're still hoping to try to schedule an interview with on February 19 (or the following couple days), + +per the below -- would that be a possibility? I'll give you a call tomorrow if we haven't connected by then but wanted to bump this from last week. Thank you! + +> +> [REDACTED] +> +> +> -----Original Message----- +> From: [REDACTED] +> Sent: Friday, January 31, 2020 14:01 +> To: 'Robert Glassman' < [REDACTED] >; [REDACTED] +> Cc: [REDACTED] < [REDACTED] >; [REDACTED] +> < [REDACTED] >; 'Nathan Werksman' < [REDACTED] >; 'Kevin +> [REDACTED] +> +> Subject: RE: SDNY investigation +> +> Robert, +> +> + +> Wanted to follow up on the below in case it was still useful to chat -- some combination of the team will be around next week if you want to have a call. + +> +> Separately, we're continuing to move forward with the investigation, including interviews with [REDACTED] family members, and we wanted to see if we might be able to put something on the calendar to come talk with [REDACTED] again once we've completed those steps. Would it work for you and her to meet anytime noon or later on February 19? Or if not the 19th, any availability on the 20th or 21st? + +> +> thanks very much, +> [REDACTED] +> +> +> + +> -----Original Message----- +> From: [REDACTED] +> Sent: Friday, January 24, 2020 03:45 +> To: Robert Glassman < [REDACTED] > +> Cc: [REDACTED] < [REDACTED] > +> < [REDACTED] >; Nathan Werksman < [REDACTED] >; Kevin +> [REDACTED] +> +> Subject: RE: SDNY investigation +> +> Robert, +> +> + +> Apologies for the belated reply, it's been a crazy week for us, but we'd be happy to talk. We should be generally available tomorrow (Friday) until about 2 p.m. our time, or also early next week if that's easier. + +> +> thanks, +> [REDACTED] +> +> +> + +> -----Original Message----- +> From: Robert Glassman < [REDACTED] > +> Sent: Wednesday, January 22, 2020 15:39 +> To: [REDACTED] < [REDACTED] > +> Cc: [REDACTED] < [REDACTED] >; [REDACTED] +> < [REDACTED] >; Nathan Werksman < [REDACTED] >; Kevin +> [REDACTED] +> + +> Subject: Re: SDNY investigation + +> Thanks MI ended up seeing these too. + +> Our judge is John Koeltl and the magistrate is Barbara Moses. + +> Moskowitz already reached out to us. + +> Is there a good time to chat? + +> Robert S. Glassman + +> Panish Shea & Boyle + +> psblaw.com + +>> On Jan 20, 2020, at 1:11 PM, C wrote: + +» Robert, + +» Thanks very much for sending the complaint, we appreciate it. We'll try to keep an eye on the docket, but if you wouldn't mind letting us know when a judge is assigned, that would also be helpful. In terms of media, it was covered in the Daily News on Friday, here: + +>> https://vvww.nydailynews.com/new-yorlc/ny-epstein-trump-victim-suit-202 + +>> 00118-m6sqsa2h7venpf3uewjrkvigo4-story.html + +>> And then picked up by the Post and other outlets on Saturday: + +>> https://nypost.corn/2020/01/18/new-jeffrey-epstein-accuser-says-he-mol + +>> ested-her-at-13-told-her-to-wear-childrens-underwear/ + +>> https://www.the-sun.corn/news/274369/jeffrey-epstein-first-victim-kids + +>> -underwear/ + +>> https://www.dailymail.co.ukJnews/article-7901651/Woman-claiming-Jeffr + +>> ey-Epsteins-victim-says-introduced-Trump-age-14.html + +» thanks, + +>> Original Message + +>> From: Robert Glassman + +>> Sent: Friday, January 17. 2020 22:18 + +» To: + +» Cc: + +; Nathan Werksman + +>> Subject: RE: SDNY investigation + +sorry for not giving you a heads up on this. That was not my intent. Just been really busy with a couple ofilMig matters going on now. Please see attached. What media is picking it up? I don't see anything. + +>> + +» Fax + +» Email + +>> Web: www.ps aw.com + +>> + +## >> CONFIDENTIALITY NOTICE: + +>> This e-mail may contain confidential and privileged material for the sole use of the intended recipient(s). Any review, use, distribution or disclosure by others is strictly prohibited. If you are not the intended recipient (or authorized to receive for the recipient), please contact the sender by reply e-mail or telephone, and delete all copies of this message. + +>> If you are a potential client, the information you disclose to us by email will be kept in strict confidence and will be protected to the full extent of the law. Please be advised, however, that Panish Shea & Boyle LLP and its lawyers do not represent you until you have signed a retainer agreement with the firm. Until that time, you are responsible for any statutes of limitations or other deadlines for your case or potential case. + +>> + +#### » Ori inal Messa e + +» From: + +» [mailto: + +>> Sent: Friday, January 17 2020 4:52 PM + +>> To: Robert Glassman + +» Cc: + +>> + +Nathan Werksman + +>> Subject: RE: SDNY investigation + +» Robert, + +>> Based on media reports today it looks like you filed the civil lawsuit? I don't think we realized that was imminent -- could we ask you to please send us a copy of the filing? I don't yet see it on PACER. + +### >> Original Messa e + +» From: + +>> Sent: Monday, December 30, 2019 22:28 + +>> To: Robert Glassman + +» Cc: + +; Nathan Werksman < + +>> Subject: RE: SDNY investigation + +>> Great, thanks very much. We'll likely start with siblings and mother and then go from there. As soon as we have a sense of when it would be productive for us to return for a follow-up meeting with we'll reach out -- as I mentioned, we're hoping that will be sometime in January, but just depending on how quickly we're able to schedule these discussions. And as always, please don't hesitate to let us know if anything comes up in the meantime. + +» To: » Cc: + +; Nathan Werksman + +>> Subject: Re: SDNY investigation + +>> yes, all good to contact those folks. Thanks for checking in. + +» Robert S. Glassman » Panish Shea & Boyle + +» psblaw.com + +»>> On Dec 30, 2019, at 1:10 pm, wrote: + +>» + +>» Robert, >» + +for us to begin reachin out this week to the contacts she idellMs -- in articular, w w Id in:. >>> Following up on our most recent meeting with you and we wanted to confirm that it's alright isto contact and and then an We also wanted to see if it we are able at this stage to contact her mot er, w o is po en is y a key witness -- I know had wanted to speak with her mother in advance of us doing that. Please let us know if it's alright to m e t ose calls? And separately, if you could please let us know if her brother has happened to have any contact with since we last spoke -- no problem at all if not, but I think she mentioned that was a possibility so wanted to check. + +>» + +>>> Thanks very much, and hope you're having a good holiday season. + +>» + +>» thanks again, + +» a >» + +>» + +>>> -----Ori inal Messa e + +>» From: + +>>> Sent: Friday, December 13, 2019 17:06 >» To: Robert Glassman < + +>» Cc: + +>>> ; Nathan Werksman + +>>> Subject: RE: SDNY investigation + +>» + +>>> Totally understand, just wanted to ask. We'll see you Monday at 11:00. And thanks for that additional info as well. + +>» + +»>- + +»> >>> Original Message + +Glassman >» From: Robert + +>>> Sent: Frida December 11.1. Mi + +>» To: + +>» Cc: + +>>> ; Nathan Werksman < >>> Subject: Re: SDNY investigation + +>» unfortunately, we can't do earlier than 11. She just needs time to get to my office after taking care of kid stu etc. + +>>> Re the mom, my understanding is that she is overseas somewhere. Pretty sure she's not in the US. I will find out and we can chat about it on Monday. + +>» + +>» + +>» Robert S. Glassman + +>» Panish Shea & Boyle + +>>> psblaw.com + +>» + +>» + +>>>>> On Dec 12, 2019, at 1:3o pm, wrote: + +>>» + +>>» Robert, + +>>» + +>>>> We wanted to ask if it might be possible to start at 10:00 on Monday rather than 11:00? If not, we totally understand (I think you may have wanted time to meet with her before starting with us) but wanted to check. + +>>>> + +>>>> Separately, I know left you a message earlier, but since we're emailing about this we can just ask - we were wondering if it might be possible to tell us where mother currently lives? Not her literal address, but just city and/or state -- we don't have any intention of contacting her before we speak to you and your client in person, but just for our longer-term logistical planning, we're wondering where we would be headed if and when an interview of her were to be appropriate. + +>>» + +>>» + +>>» + +>>>> Ori inal Messa e----- + +»» From: + +>>>> Sent: Wednesday, December 11, 2019 13:15 + +»» To: Robert Glassman C + +>>» Cc: ; Nathan Werksman + +>>» + +>>>> u ject: inves igation + +>>» + +>>>> Confirmed, thanks -- we'll see you then. And just on substance, I think we mentioned these topics when we spoke on the phone earlier, but just to refresh, I expect we'll want to talk through some additional specifics on travel, we'll talk more about other steps we'll be looking to take in our investigation for corroboration and what the appropriate timing and format f that would be, and to start to talk about specific conduct by Epstein and/or Maxwell to whatever extent s comfortable with that at this stage. And we'll also likely refresh on some other topics as well, bu jus o ag some of the more immediate areas we'll expect to cover. Let us know if it's useful to chat again before Monday, otherwise we'll see you then. + +>>» + +>>» thanks again, + +>>» + +>>» + +>>» + +»» -----Original Message---- + +»» From: Robert Glassman + +>>>> Sent: Wednesda Decem er , : + +>>>> >>>> u jec : : wives igation + +>>» >>>> Let's do 11 a.m. on Monday. + +>>» >>» Robert Glassman, Esq. >>>> Panish Shea & Boyle LLP >>>> 11111 Santa Monica Boulevard, Suite 700 Los Angeles, CA 90025 + +»» Tel: + +»» Fax + +»» Email: »» Web: www.psblaw.com + +>>» + +#### >>» CONFIDENTIALITY NOTICE: + +>>>> This e-mail may contain confidential and privileged material for the sole use of the intended recipient(s). Any review, use, distribution or disclosure by others is strictly prohibited. If you are not the intended recipient (or authorized to receive for the recipient), please contact the sender by reply e-mail or telephone, and delete all copies of this message. + +>>» + +>>>> If you are a potential client, the information you disclose to us by email will be kept in strict confidence and will be protected to the full extent of the law. Please be advised, however, that Panish Shea & Boyle LLP and its lawyers do not represent you until you have signed a retainer agreement with the firm. Until that time, you are responsible for any statutes of limitations or other deadlines for your case or potential case. + +>>» + +>>» + +#### >>>> ----Original Messa + +»» From: + +»» [mailto: + +>>>> Sent: Wednesday, December 11 2019 8:26 AM + +»» To: Robert Glassman + +>>» Cc: + +; Nathan Werksman + +>>» + +#### >>>> Subject: RE: SDNY investigation + +>>» + +»» Robert, + +>>» + +>>>> That's great, thanks very much. Do you have a preference on timing? Anytime that morning starting at p uesi • a.m. or later would be fine for us, or we could also start early afternoon if that's easier--whatever you and prefer. And our hope is that we'd be able to cover everything on Monday, but we'll also be available on ay if that ends up being useful as well. + +>>» + +>>» thanks, + +>>» + +>>» + +# >>>> -----Original Message----- + +»» From: Robert Glassman + +>>>> Sent: Tuesday. December + +»» To: + +»» Cc: + +>>» + +>>>> Monday morning works at my office. Tuesday may also work too if you need more time. But confirm for Monday. + +>>» + +>>» + +»» Robert S. Glassman + +»» Panish Shea & Boyle + +>>>> psblaw.com + +>>» + +>>» + +>>>>>> On Dec 10, 2019, at 9:35 AM, wrote: + +>>>» + +>»» Robert, + +>>>» + +>»» Following up on our call, in terms of logistics, we can come to California to meet wi anytime this coming Sunday, Monday, or Tuesday, if any of those work? Also, if it's at all posse e o ef erset aside a significant amount of time on one day or--possibly preferably--a few hours on two consecutive days (and if so, we could do the second meeting on Wednesday if that's helpful), that will allow us to review relevant case notes, do quick research, or anything else that would provide for helpful follow-up where we'd just need a little time between discussion sessions. And as always, happy to discuss via phone if that's helpful. + +>>>» + +>»» thanks, + +>>>»= + +>>>» + +>»» Ori inal Messa e + +>»» From: + +>>>>> Sent: Monday, Decemb + +>»» To: Robert Glassman < + +>>>» ; Nathan Werksman + +>>>» + +>>>» + +>>>>> Subject: RE: SDNY investigation + +>>>» + +>>>>> Thanks Robert -- we'll call you in 5-10 minutes, just gathering everybody up in the same place. Thanks very much. + +>>>» + +>>>>> Original Message---- + +>>>» From: Robert Glassman + +>>>>> Sent: Monday. Decembe + +>»» To: + +>>>» Cc: ; Nathan Werksman + +>>>» + +>>>» + +>>>>> Subject: Re: SDNY investigation + +>>>» + +>»» Yes. Call me on my cell today. + +>>>» + +>>>» + +>»» Robert S. Glassman + +>»» Panish Shea & Boyle + +>>>>>>> On Dec 9, 2019, at 9:21 AM, + +wrote: + +>>>>» + +>>»» Robert, + +>>>>» + +>>>>>> Checking in on the below -- is there a good time to chat this week? + +>>>>» + +>>»» thanks, + +>>>>» + +>>>>» + +>>>>>> -----Ori inal Messa e + +>>>>». From: + +>>>>>> Sent: Wednesday, December 04.2019 13:06 + +>>>>» To: Robert Glassman + +>>>>» Cc: ; Nathan Werksman + +>>>>» + +>>>>» + +>>>>» Subject: RE: SDNY investigation + +>>>>» + +>>»» Hi Robert, + +>>>>» + +>>>>>> Following up on our discussion a couple weeks ago, would it make sense to have a quick call later this week or early next to check in on current status? We also have one additional data point we'd like to convey as well, at your convenience. + +>>>>» + +>>»» thanks, + +>>»».= + +>>>>» + +>>>>» + +>>»» Original Message + +>>»» From: Robert Glassman + +>>>>>> Sent: Friday. November 2 : + +>>>>>>. To: + +>>>>» Cc: ; Nathan Werksman + +>>>>» + +>>>>» + +>>>>» Subject: Re: SDNY investigation + +>>>>» + +>>»» Thanks. Cell is best + +>>>>» + +>>>>» + +>>»» Robert S. 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Cc: > " + +Subject: RE: attorney Proffer + +Date: Sun, 23 Feb 2020 02:59:24 +0000 + +Inline-Images: image001.jpg + +Michael, + +Received, thank you. This information is helpful, and as with the prior attorney proffer, does not cause us to change our view of status. + +We will be traveling most of this upcoming week, but I hope that we will be able to follow up with you the following week to discuss possible next steps. + +thank you, + +From: Michael Bachner + +Sent: Friday, February 21, 2020 10:45 + +To: + +Subject: RE:Mttorney Proffer + +Is see attached replies to your questions. + +From: Michael Bachner + +Sent: Tuesday, February 18, 2020 12:01 + +To: + +Cc: + +Subject: RE: Attorney Proffer + +Good morning. was away over the weekend. I expect to have a reply to your questions by tomorrow. + +From: •fl + +Sent: Saturday, Febr • + +To: Michael Bachner + +Cc: + +Subject: RE: Attorney Proffer + +Got it -- I had that down as London, rather than Paris, so that's helpful. And I should say, these questions aren't immediately time-sensitive, I just didn't want to forget to ask, since I'm reviewing the notes now. + +thanks, + +Hi is away for the weekend. In our meeting I indicated that she stayed in the Paris apartment with her husband on one occasion. I will get back to you on Monday or Tuesday regarding the other questions you've asked today as well as at the meeting. Have a nice weekend + +Michael Bachner Bachner & Weiner, PC + +Please excuse typographical errors. Messages sent through dictation. + +https://www.actl.com/ + +NOTICE: The information contained in this communication is legally privileged and/or confidential information, which is intended only for use of recipient. If the reader of this communication is not the intended recipient (or the agent or employee responsible to deliver it to the intended (recipient), you are hereby notified that any dissemination, distribution, or reproduction of this communication is strictly prohibited. If you have received this communication by error, please immediately notify the sender by e-mail and delete this email from your system. Nothing in this email should be construed as a legal opinion or tax advice. + +On Feb 15, 2020, at 3:05 PM, > wrote: + +Michael, + +Following up on our meeting, one additional question / clarification we have from reviewing our notes is about whether Ms.= ever visited certain Epstein properties other than his New York mansion and the brief visit to the Palm Beach residence. I apologize if you addressed that and I missed it, but we wanted to add it to the list of additional questions in particular, whether she ever visited the New Mexico ranch, the Little St. James Island, the Great St. James island, and/or the Paris residence. Also, is it correct that she just visited the Palm Beach residence the one time you referenced? It's not a problem or issue if she visited any of those other locations, we just wanted to clarify one way or the other. And happy to discuss via phone if that's useful. + +thank you, + +From: Sent: Thursday, Febr To: Michael Bachner + +Michael, + +We do understand that your attorney proffer today will be preliminary, and to the best of your client's current recollection and to the best of your current understanding, and without, e.g., having been provided documents or other materials by the Government. + +We also confirm that your statements will be considered to be made pursuant to Fed. R. Evid. 410 and Fed. R. Crim. P. 11(f), and therefore under those protections. Regarding Rule 408, we'll just note what we have for other counsel in this case and others who have made similar statements or submissions, which is that we don't take any position on the effect or application of Rule 408 in a prospective or hypothetical dispute in civil litigation, because it doesn't implicate any rights the Government would or would not have, but you can consider us advised that your position is that your statements are also covered under 408. (While our Office itself can't guarantee the protections of Rule 408 because any dispute on that issue would be beyond our purview, we are also not taking the position that we believe it does not apply.) + +thank you, + +[REDACTED] + +--- + +**From:** Michael Bachner [REDACTED] +**Sent:** Thursday, February 13, 2020 10:08 +**To:** [REDACTED] <[REDACTED]> +**Subject:** [REDACTED] Attorney Proffer + +Hi [REDACTED] + +Prior to our meeting today, I am writing to confirm that statements I make to you today are preliminary and subject to further refinement once Ms. [REDACTED] and I have the benefit of additional document review and refreshed recollection if necessary based upon input we may receive from your office. My statements to you are intended in hypothetical form only and in any event, we understand that the provisions of FRE 408 and 410 apply. + +Please advise if my understanding is correct. + +Thanks. + +Michael Bachner +Bachner & Associates, PC + +[REDACTED] + + + + \ No newline at end of file diff --git a/marker2/ds9/EFTA00090587/EFTA00090587.metadata.json b/marker2/ds9/EFTA00090587/EFTA00090587.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..a0de51bf00a8c24c318702890fbf092468aeb85a --- /dev/null +++ b/marker2/ds9/EFTA00090587/EFTA00090587.metadata.json @@ -0,0 +1,114 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090587.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 4933, + 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Just a couple of names that were different that I want to point out. + +- 1. In the new 302s, our files) is listed a +- 2. In the new 302s, our files) is listed a + +Everything else is all good and updated on the tracker. + +From + +Sent: Thursday, April 23, 2020 1:30 PM + +To: Cc: + +Subject: FW: 302s (3 of 3) + +Following up on my email from a minute ago, this is email 3 of 3 + +From• + +Sent: ennesuay, Apra 11, ZULU 11:41 + +To: + +Cc: + +Subj : s o + +nterview is in this batch. It ends in 377. \ No newline at end of file diff --git a/marker2/ds9/EFTA00090593/EFTA00090593.metadata.json b/marker2/ds9/EFTA00090593/EFTA00090593.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..2928765d1d5f6752e03a0e48ca82cd26b0b70a0b --- /dev/null +++ b/marker2/ds9/EFTA00090593/EFTA00090593.metadata.json @@ -0,0 +1,62 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090593.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 589, + "elapsed_seconds": 0.83, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 42 + ], + [ + "Line", + 21 + ], + [ + "Text", + 17 + ], + [ + "ListItem", + 2 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00090593" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00090594/EFTA00090594.md b/marker2/ds9/EFTA00090594/EFTA00090594.md new file mode 100644 index 0000000000000000000000000000000000000000..47dab00c1f0e364dc05f83f10bc72c1f10c74b6d --- /dev/null +++ b/marker2/ds9/EFTA00090594/EFTA00090594.md @@ -0,0 +1,53 @@ +![](_page_0_Picture_3.jpeg) + +Date of entry 0 1 / 1 4 /2020 + +-• date of birth -• was interviewed at Present for the interview was AUSA AUSA Detective , Special Agent and attorney Gloria Allred. After being advised of the identities of the above listed individuals and the nature of the interview, provided the following information: + +was born in Los Angeles but moved around the mid-west for much of her childhood. Between the ages of 14-18 (approximately 2002-2006) lived in Michigan. She has an older sister ( ) who moved out when she was 16 years old. She attended College which JEFFREY EPSTEIN helped to pay for. She then traveled as a model and eventually came back to Los Angeles. + +met EPSTEIN through her sister. was a freshman in high school and 15 years old when she was on a drama field trip to New York City. During this trip, was granted special permission from her school to visit with her sister. Her sister was staying at EPSTEIN's house at this time and went there to meet her. met his secretary at this time but does not remember her name. The secretary was about 25 years old with light brown hair. She was pretty but not the model type. She appeared professional and was wearing a button up shirt. She seemed to know sister. The secretary showed them around the mansion and got them a drink. The secretary took pictures of them inside of his garden. The garden was on the ground level next to the house. There was a gate next to the garden to exit to the street. She took a few other pictures of and her sister, and gave her an IP0D nano. The secretary got contact information. and her sister then went shopping. flew back to Michigan. + +A few weeks later, the secretary contacted to tell her that EPSTEIN + +Investigation on 09/18/2019 ■t **Los Angelas, California, United States (In Person)** + +This document contains neither recommendations nor conclusions of the FBI. It is the moµ" ty of the FBI and is loaned to your agency; it and its contents arc nor to be distributed outside your agency. + +Comthwdion of FD-302 of (U) Interview of a 09/18/2019 .Page 2 of 4 + +had seen her photos and wanted her to meet with him and sister. gets invited to a DAVID COPPERFIELD show in Las Vegas. At this time believed EPSTEIN was giving her sister a free place to stay and he was just a kind man that was helping her out. The secretary arranged the travel. flew out of Pellston Airport. Her mother assisted the secretary in arranging the travel. This happened in January and was still 15. She knows this because in February when she returned she had turned 16 and her mother bought her a car. + +recalled arriving in Las Vegas with her sister at some point. There was a few other girls there. does not know who these girls were but they all eventually traveled to New Mexico together. She was not sure if they saw the COPPERFIELD show but remembered going back stage. They received a back stage tour which EPSTEIN was present for. There were about six people present for this tour. They only stayed in Las Vegas for the day before going back to the airport, getting on EPSTEIN's plane, and traveling to New Mexico. On the plane to New Mexico was when was really able to meet EPSTEIN. He gave her a tour of the plane, and they went into the bedroom together. EPSTEIN asked to get on the floor and feel the carpet. He told her that it was tempur-pedic carpet flooring. EPSTEIN told her that when he sleeps in the bed he likes to have women sleeping at his feet. felt insecure and not sure why he would tell her this, but doesn't ask why. Prior to getting to the ranch, EPSTEIN asked her age. told him she was 15 years old. EPSTEIN's secretary already knew her info prior to flying because gave it to her. EPSTEIN spent most of the plane ride in his room and they all drank champagne. EPSTEIN asked if her parents voted for BILL CLINTON to which she answered yes. There was a model on the plane that was on the cover of a magazine. + +When they land in New Mexico they got into a black SUV. They drove to the ranch separately from EPSTEIN. When they arrived at the ranch, stayed with her sister in a small house not connected to the main house with another girl (a photographer with red hair). Everyone ate together in a main hall. Everyone with him appeared to be his friends and not employees. It was explained to that she can do whatever she wants while on the ranch but they all have to come together for dinner. If she was needed for something someone would come and grab her. about 3-4 days. This was the last time that stayed at the ranch for was with EPSTEIN. + +Comthwdion of FD-302 of (U) Interview of a 09/18/2019 .Page 3 of 4 + +was invited to come see him again after this but she declined. + +was interested in the ATV's at the ranch. Her sister showed her the indoor pool and hot tub. They went in the hot tub in her underwear. Her sister told her that the jets are pointed so that 16 year old girls could all masturbate at the same time. While they were in the hot tub, EPSTEIN walked in. EPSTEIN told to hug him, then made fun of her underwear. + +At some point during this trip, the red headed photographer asked sexual questions. On approximately the next day, she gave a massage. During this massage, saw a video camera in the corner. It was a security type camera, "a ball type camera". did not enjoy it but did not stop her. She felt bad because she knew did not enjoy it. + +Approximately the next day, a maid type middle aged woman told that EPSTEIN wanted to see her. EPSTEIN took to his bedroom upstairs. The curtains were closed. EPSTEIN laid on his bed and asked to give him a massage. He was only in a robe. He kept opening up his robe while he was on his back and felt as though she knew what EPSTEIN wanted her to do but she did not know how to do it. He then stood up and brought her to the window and opened the curtain. He wanted her to explain her feelings. EPSTEIN told he would be there to guide her through life and her future. + +Approximately the next day, got to ride on the ATV and she crashed it. was afraid she would get in trouble but soon realized she would not get in trouble for anything she did there. felt powerless at this thought because no one was there to care about anything. + +Approximately the next day, EPSTEIN gave cash to go shopping in town. gave the cash to her sister and while in town she checked in with a family friend. + +Comimmthmormacof (U) Interview of on 09/18/2019 ins, 4 of 4 + +recalled one night while on the ranch she was made to sit at EPSTEIN's feet as he taught her breathing exercises. EPSTEIN got white lacy underwear from "Victoria's Secret" and took photos of her in them in his office (this occurred prior to the breathing incident). + +Before leaving the ranch, EPSTEIN called into his office and asked her about her future. She told him that she wanted to go to College. He wrote her a check for \$5,000 for later used that check to pay for her college. During this conversation, EPSTEIN invited to his island. + +At some point, GHISLAINE MAXWELL arrived in her helicopter with her yorkie. This was about the second day. At first, MAXWELL was very nice. During her stay there, the dog drowned in the fountain on the ranch. After this, MAXWELL became very mean. EPSTEIN told to not mind MAXWELL, and that he used to date her. All of the girls on the ranch were "so young" about "17-23 years old". One of the girls' name was . She was about 20 years old and a model in a magazine. MAXWELL was the only older, boss type woman present. MAXWELL was not around for the sexual experiences. She was just around the property. The red head said that EPSTEIN really wanted to make orgasm. did not have any conversation with MAXWELL about this incident. + +left the ranch with about \$400 cash from her shopping spree and the \$5,000 check. She may have flown home on his private jet. She had to go back to high school and her mother picked her up. At some point, either her sister or the secretary reached out to and invited her to the island. There was to be a famous photographer there. mother thought it would be a great modeling opportunity but did not want to go. never saw EPSTEIN after this. + +In November of 2014, saw EPSTEIN on TV when she was in rehab. + +would not speak with or text with the secretary. + +email address is \ No newline at end of file diff --git a/marker2/ds9/EFTA00090594/EFTA00090594.metadata.json b/marker2/ds9/EFTA00090594/EFTA00090594.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..0319d3160a17e593e819c6430abd0e102ed911ef --- /dev/null +++ b/marker2/ds9/EFTA00090594/EFTA00090594.metadata.json @@ -0,0 +1,194 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090594.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 4, + "chars": 8279, + "elapsed_seconds": 0.99, + "image_assets": [ + "_page_0_Picture_3.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "FEDERAL BUREAU OF INVESTIGATION", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 188.496, + 49.41 + ], + [ + 387.8359680175781, + 49.41 + ], + [ + 387.8359680175781, + 62.21759033203125 + ], + [ + 188.496, + 62.21759033203125 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 89 + ], + [ + "Line", + 38 + ], + [ + "Text", + 10 + ], + [ + "PageHeader", + 2 + ], + [ + "SectionHeader", + 1 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 87 + ], + [ + "Line", + 42 + ], + [ + "Text", + 5 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 72 + ], + [ + "Line", + 35 + ], + [ + "Text", + 8 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 3, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 69 + ], + [ + "Line", + 34 + ], + [ + "Text", + 9 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00090594" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00090594/_page_0_Picture_3.jpeg b/marker2/ds9/EFTA00090594/_page_0_Picture_3.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..e6afee18cd83479c0ad2e276e4b8b1343cba7f5d --- /dev/null +++ b/marker2/ds9/EFTA00090594/_page_0_Picture_3.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:b557ce5b1ffc139256df52661eca1fe324baf66b753ae59494636be8212bb879 +size 4843 diff --git a/marker2/ds9/EFTA00090598/EFTA00090598.md b/marker2/ds9/EFTA00090598/EFTA00090598.md new file mode 100644 index 0000000000000000000000000000000000000000..f0e21152fa3c440511cceb1f57b24674624f846c --- /dev/null +++ b/marker2/ds9/EFTA00090598/EFTA00090598.md @@ -0,0 +1,15 @@ +![](_page_0_Picture_3.jpeg) + +Date of entry 01/14/2020 + +Attorney BRAD EDWARDS was interviewed over the phone on 11/1/2019. EDWARDS reached out to Detective in order to relay information about this investigation that he had deemed relevant. After being advised of the identity of the interviewing Agent and the nature of the interview, EDWARDS provided the following information: + +EDWARDS advised Detective that a person that may be useful for the government to interview would be used to be a butler for Glen Dubin and Eva Anderson. EDWARDS believes that lives in New York. EDWARDS states that he deposed in the past as part of a MAXWELL lawsuit. The deposition is under seal but thinks an interview with him would be fruitful. EDWARDS also believes that would be someone useful to the government if interviewed. has a facebook page. + +attorney's information is as follows: + +New York NY + +Investigation on 11/01/2019 at Manhattan, New York, United States (Phone) + +This document contains neither recommendations nor conclusions of the FBI. 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Present for the interview was attorne , along with AUSA , AUSA Special Agent , and Detective . After being advised of the identities of the above listed individuals and the nature of the interview, -provided the following information: + +On or about September 2006, stated she was sexually trafficked. (known to law enforcement as was abused on JEFFREY EPSTEIN's island with advised that LESLEY GROFF, , and GHISLAINE MAXWELL all ruined life. + +but and her attorney were not available to meet for a full interview, is willing to sit down and meet at a future date. + +Investigation on 08/28/2019 m New York, New York, United States (In Person) + +This document contains neither recommendations nor conclusions of the FBI. 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After being advised of the identity of the interviewing Agents and the nature of the interview, TURNBALL provided the following information: + +TURNBALL started working security on Little St. James on July 31, 2019. He was hired by DAPHNE WALLACE, telephone numbe . WALLACE had gotten TURNBALL's number from someone and called him to come out and take a look at the island. TURNBALL met with ANNA RODRIGUEZ, who was the property manager, telephone number . TURNBALL was told his job entailed looking for people that were coming to the island, including paparazzi. + +TURNBALL owns MT Security. He has seven people who work under him for both Little St. James and Great St. James, both of which JEFFREY EPSTEIN owned. TURNBALL asked if they had security at the islands prior to him and they told him no. TURNBALL was paid and he in turn paid his employees. + +The only people TURNBALL has seen on the island are the staff, attorneys, maintenance, and boat captains. TURNBALL did not interact with workers. TURNBALL was not able to go into the structures on the islands; he was only allowed to patrol the beaches. He was allowed to use the staff bathroom. If people were to come onto the island, he was to approach them. + +TURNBALL was required to sign a non-disclosure agreement as part of his employment. + +Investigation on 08/12/2019 at Little St James, Virgin Islands, United States (In Person) + +This document contains neither recommendations nor conclusions of the FBI. 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JOSEPH, date of birth telephone number- \_, was interviewed on the island of Little St. James. After being advised of the identities of the interviewing Agents and the nature of the interview, JOSEPH provided the following information: + +JOSEPH was born and raised on St. Thomas. JOSEPH was hired for security for Little St. James. JOSEPH had heard of this job from a friend that worked with MICHAEL TURNBALL. JOSEPH's friend told her to call TURNBALL and see if there were any openings. JOSEPH called TURNBALL on Thursday, August 8 or Friday, August 9. August 12th was JOSEPH's first day working on Little St. James; she started at 7:00AM. Her job entailed securing the docks. + +Tourists can pass through the waters near the island and stay on the boat, but cannot come onto the island. JOSEPH had never met JEFFREY EPSTEIN nor had she seen him on St. Thomas. + +Prior to working security on Little St. James, JOSEPH worked for Port Authority and saw boats come and go from Little St. James. + +Investigation on 08/12/2019 at Little St. James, Virgin Islands, United States (In Person) + +This document contains neither recommendations nor conclusions of the FBI. 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After being advised of the identities of the interviewing Agents and the nature of the interview, SCULLY provided the following information: + +SCULLY advised that he worked for JEFFREY EPSTEIN on his private island from approximately 1999-2005 or 2006. During this time period he primarily worked as EPSTEIN's telecommunications technician and helped to install internet and phone systems on the island. During this time period SCULLY estimated that he visited/ worked on the island approximately 100 times. He described EPSTEIN as "a pretty bad guy" and "an intense man". SCULLY knew of two property managers that worked on the island named MILES ALEXANDER and CATHY ALEXANDER. EPSTEIN would not let them both leave the island at the same time. At least one of them would have to be on the island at all times. SCULLY believed they may have moved to South Africa. CATHY hated EPSTEIN. In EPSTEIN's bedroom there were many pictures of young girls and that disgusted CATHY. + +SCULLY stated EPSTEIN was always very concerned about having proper phone and internet service available at all points on his island. Money never seemed to be a concern for EPSTEIN when it came to these matters. He discussed setting up services between his island and his New York, Florida and Paris homes. + +SCULLY recalled seeing a pool guy on the island, who EPSTEIN brought from West Palm Beach. This pool guy tells SCULLY "what's with the young girls" and "I turned a blind eye". He also told SCULLY that it was worse in West Palm Beach. SCULLY ended up quitting the next day over hearing this. + +SCULLY discussed seeing a picture of topless in EPSTEIN's + +Investigation on 08/09/2019 at St Thomas, Virgin Islands, United States (In Person) + +This document contains neither recommendations nor conclusions of the FBI. It is the moµ" ty of the FBI and is loaned to your agency; it and its contents arc nor to be distributed outside your agency. + +Continuation of FD-302 of (U) Steve Scully Interview o f 08/09/2019 i ns, 2 of 3 + +office. In this picture was with two other girls, who were also topless and believed to be about 15-16 years old. This picture was taken on the island. + +SCULLY recalled seeing BOSCO, the engineer, on the island often. BOSCO tells SCULLY that is like EPSTEIN's daughter, and she does special projects for him. BOSCO told SCULLY, "If you like working here you do not ask about + +SCULLY was to never talk to the guests, and if needed, he would have to go through MILES. SCULLY never asked any of the girls their ages. + +SCULLY recalled EPSTEIN's attorneys staying at the island on one occasion. One of EPSTEIN's attorneys name was ALAN and he was a "dick". + +EPSTEIN would have a chef that traveled with him to the island to cook when he hosted "special parties". "Special Party" meant that there was going to be young teenaged girls there. + +LES WEXNER was always 11 speed dial on all of EPSTEIN's phones. + +SCULLY recalled seeing three young girls and a man in the "grotto" area of the island. These girls did not look 18 and they were all naked. + +On one occasion, SCULLY was on a boat with EPSTEIN and two young teenaged girls. SCULLY believed these girls were about 14 years old because that's how old his daughter was at the time. They seemed very comfortable with EPSTEIN and stood next to him at the wheel as he drove. SCULLY sensed something was wrong. + +SCULLY met GHISLAINE MAXWELL on the island. MAXWELL is a gutsy and manipulative woman. MAXWELL shared an office with EPSTEIN. + +At one point, EPSTEIN required all of his personal bodyguards to carry guns. Some of them would be kept on ankle holsters. This started after 2001. + +There was an area in EPSTEIN's room for his massage table to be set up. The table was portable and sometimes would be set up in the bedroom or on the deck outside. SCULLY never observed him getting massages and this was not a topic of conversation. SCULLY presumed the massages were done by the + +Continuation of FD-302 of ( U ) Steve Scully Interview o f 08/09/2019 " cc 3 of 3 + +girls on the island and he believed that the massages were sexual. Sometimes these girls would stay in his bedroom and not in guest rooms. SCULLY would observe massage oils in the bathroom. SCULLY observed a list of persons to give good massages and "extras" in EPSTEIN's office. + +Prince Andrew was observed to be there with a bodyguard. 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And we just got another set that I'll email you now. + +From: + +Sent: Thursday, April 23, 2020 14:26 + +To: + +Subject: RE: 302s (3 of 3) + +All set on these — with a few duplicates. Just a couple of names that were different that I want to point out. + +- 1. In the new 302s +- 2. In the new 302s our files) is listed as ur files) is listed a + +Everything else is all good and updated on the tracker. + +Fro + +Subject: FW: 302s (3 of 3) + +Following up on my email from a minute ago, this is email 3 of 3 + +From: + +Sent: Wednesday, April 22, 2020 21:42 + +To: + +Subject: 302s (3 of 3) + +nterview is in this batch. 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Af::er being advised of the identity of the interviewing Agent and the nature of the interview, provided the following information: + +was modeling when she met LEON BLACK in 2008. BLACK promised • drugs. BLACK manipulated and sexually abused . BLACK used a lot of threats towards ; she was scared of him. + +BLACK flew to JEFFREY EPSTEIN's home in Florida. BLACK told that if she talked to anyone he would tell her son that she was on drugs. was also at the house and wanted to have sex with EPSTEIN. It got to the point where they were yelling at , telling her that EPSTEIN had a sex addiction. told that EPSTEIN needed to have sex with multiple people and that if did not have sex with him then something terrible would happen to her and it would affect her life. did not have sex with EPSTEIN; she and BLACK left. + +BLACK ran a sex trafficking ring. constantly tried to run away. If fought BLACK, he hurt more. thought that every sexual encounter BLACK had with her was nonconsensual. BLACK told that if she stayed with him, he would let her stay in the country. BLACK told her she should not think about work. earned her bachelor's degree. + +BLACK told that he was friends with the police, EPSTEIN and HARVEY WEINSTEIN. There was a point where felt sick and felt like she had been poisoned. Around that time, BLACK forced his way into apartment and raped her. This was around 2014. was scared and left the country. While outside the United States, one of BLACK's associates contacted her. People that BLACK knew continued to approach her. + +In approximately 2015, BLACK told that he would pay people to destroy + +Investigation on 04/10/2020 m Now York, Now York, United States (Phone) + +This document contains neither recommendations nor conclusions or the FBI. It is the property of the FB1 and is loaned to your agency; it and its contents arc not to be distributed outside your agency. + +Continuation of FD-302 of (U) Interview of 04/10/2020 page 2 of 2 + +her life. BLACK told her he had worked for the FBI. In the fall of 2015, signed a non-disclosure agreement with BLACK. + +BLACK transferred ten million dollars to EPSTEIN in or around 2015. met a lot of EPSTEIN's assistants. was introduced to GHISLAINE MAXWELL and PRINCE ANDREW, among others. + +Other women that EPSTEIN. knew had been abused by BLACK were , and . 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You are all set. + +From: + +Sent: Wednesday, May 6, 2020 6:03 PM + +To: + +< + +Cc: n1 ) + +Subject: RE: NDO renewal + +Are you also the right person for pen register applications going to magistrate court? If so, we have one attached for tomorrow please — and if not, if you could please just let us know who to send to? + +thank you! + +From: + +Cc: ) I ‹ > + +Subject: RE: NDO renewal + +Got it, thanks very much - and thank yi + +From: + +Sent: Friday, April 17, 2020 12:43 + +To: + +Cc: + +Subject: RE: NDO renewal + +has been handling the NDOs, I sent it to him, it will go to Mag court with the afternoon batch today. + +The Judges are still on the same schedule 10am & 3pm. + +We have an NDO renewal we need to submit for the Epstein case, and I'm not sure what the current protocol is? I'm sorry for bothering you about it — I'm sure there's guidance in some email from the past few weeks, but I can't find anything on the current logistics. Attached is what I think we need, but I'm happy to send it to whoever is the right person (or the judge, etc.). Thank you as alwaysll \ No newline at end of file diff --git a/marker2/ds9/EFTA00090608/EFTA00090608.metadata.json b/marker2/ds9/EFTA00090608/EFTA00090608.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..ff4cbbd48aff3fa5c2754ed1551ad9132f824690 --- /dev/null +++ b/marker2/ds9/EFTA00090608/EFTA00090608.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090608.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 1173, + "elapsed_seconds": 1.71, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 67 + ], + [ + "Text", + 38 + ], + [ + "Line", + 31 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 13 + ], + [ + "Line", + 7 + ], + [ + "Text", + 4 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00090608" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00090610/EFTA00090610.md b/marker2/ds9/EFTA00090610/EFTA00090610.md new file mode 100644 index 0000000000000000000000000000000000000000..7e892f3ff9ec224c9b86e1954346c3d18937313a --- /dev/null +++ b/marker2/ds9/EFTA00090610/EFTA00090610.md @@ -0,0 +1,96 @@ +From: + +To: ' (USANYS)" + +Subject: FW: Your Curb Ride Receipt + +Date: Fri, 15 Nov 2019 23:55:02 +0000 + +Attachments: ereceipt.pdf + +Inline-Images: —WRD056.jpg; image00 1 jpg + +H + +Attached is my last receipt for my most receint trip on the Epstein case. It's the receipt for my cab from la after the trip. + +anks very much, + +From: + +Sent: Friday, November 15, 2019 6:47 PM + +To: + +Subject: Fwd: Your Curb Ride Receipt + +Begin forwarded message: + +From: Curb + +Date: November 15, 2019 at 5:26:16 AM EST + +To: + +Subject: Your Curb Ride Receipt + +Confirmation #HQLA21 + +Hey thank you for choosing Curb! + +\$73.70 + +**YOUR RIDE** + +**November 15 at 5:03 AM** + +Fare \$52.00 + +[REDACTED] \$52.00 + +Toll \$6.12 + +Service Fee \$0.00 + +Improvement Surcharge \$0.30 + +State Surcharge \$0.50 + +Congestion Surcharge \$2.50 + +Tip \$12.28 + +Subtotal \$73.70 + +Total \$73.70 + +Confirmation #HQLA21 + +*A PDF copy of your receipt is attached below.* +Questions regarding a charge? Email [support@gocurb.com](mailto:support@gocurb.com). + +Pickup [REDACTED] at 5:03 AM + +Dropoff [REDACTED], New York, NY [REDACTED] at 5:26 AM + +**SERVICED BY** + +**Curb** + +Driver: SURAJU + +Vehicle #8E22 + +Trip #6112 + +Give \$i 'Get S5 + +Share your promo code: \ + +![](_page_2_Picture_2.jpeg) + +![](_page_2_Picture_4.jpeg) + +![](_page_2_Picture_6.jpeg) + +I Lost something? 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NYM + +Serviced by + +Curb + +Driver: SURAJU Vehicle #8E22 + +Trip #6112 \ No newline at end of file diff --git a/marker2/ds9/EFTA00090613/EFTA00090613.metadata.json b/marker2/ds9/EFTA00090613/EFTA00090613.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..bbae25674acbafb4ebe2d6bd0f5c40fb09ffc084 --- /dev/null +++ b/marker2/ds9/EFTA00090613/EFTA00090613.metadata.json @@ -0,0 +1,62 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090613.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 508, + "elapsed_seconds": 0.75, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 48 + ], + [ + "Line", + 23 + ], + [ + "Text", + 11 + ], + [ + "PageHeader", + 3 + ], + [ + "Table", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00090613" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00090614/EFTA00090614.md b/marker2/ds9/EFTA00090614/EFTA00090614.md new file mode 100644 index 0000000000000000000000000000000000000000..243c86eba691d6b31e3ac02dc56fb5d084bf223d --- /dev/null +++ b/marker2/ds9/EFTA00090614/EFTA00090614.md @@ -0,0 +1,116 @@ +From + +Subject: RE: Your recently announced run for Manhattan DA District attorney + +Date: Tue, 19 Nov 2019 20:13:26 +0000 + +Inline-Images: image001.jpg + +Yeah this has my email wrong so I didn't get it originally (though I've received other communications from the same individual that we previously passed along). + +From: + +Sent: Tuesday, November 19, 2019 14:08 + +To: • (NY) (FBI) + +Subject: FW: Your recently announced run for Manhattan DA District attorney + +I think this is the email you were looking for. + +From: + +Sent: Thursday, November 14, 2019 5:52 PM + +To + +Subject: Fwd: Your recently announced run for Manhattan DA District attorney + +aIflflIERN ATI DISTRICT , ASSISTANT US ATTORNEY OFFICE + +RE: INFORMATION RE CYRUS VANCE CORRUPTION IN 2 VERY SERIOUS UNREPORTED MATTERS, ONE MATTER HAVING TO DO WITH COVERING UP A RIKERS BRIBE SCHEME PERPETRATED BY ALAN DERSHOWITZ FOR ONE OF HIS CLIENTS, GIGI JORDAN, BRIBING NORMAN SEABROOK + +( Separate Bribe than the one Seabrook was arrested for) + +MR a + +MY name is I read that yourself, and MS=and MSMI are the Assistant US attorneys assigned to Jeffrey Epstein's case, and that the case /investigation is still continuing into Epstein's accomplices. + +https://www.thedai lybeast .cotn/je ffrey-epstein-case- federa l-prosecutors-are-lini ng-up-w itnesses-agai nst-hiscronies + +I have information about corruption/coverup of crimes by Cyrus Vance (as a favor to powerful connected persons) in 2 separate criminal matters (separate from anything that has been reported recently) . The information /Evidence I have on Vance corruption started in 2013, and goes through the present. The reason the information I have has never been reported is because when I sent an email to Manhattan ADA Gordon on May 19, 2015, at 11:39 am , advising her that I plan to go to NY Post with the evidence I have on Manhattan DA corruption/coverup in the matters detailed below ...12 hrs later , NYPD shows up at my house to arrest me. And Cyrus Vance maliciously prosecuted me on that case for 2 1/2 years. The case was dismissed by Judge when I + +finally had enough , and sent the Judge evidence of the Manhattan DA corruption in that case, and Judge Dawson dismissed the case shortly thereafter. + +So as you can imagine, this has had a very chilling effect and caused fear on my willingness to come forward and suffer further arrests/retaliation by Vance's Office. + +One Matter in vvVaKAkihn tAggrAgtIrklylan to cover up a million Dollar embezzlement and child abuse by a certain nest, fr \figuth . + +The second matter/coverup by Vance involves a huge Rikers Bribe scheme perpetrated by One of Vance's high profile defendants , Gigi Jordan (the millionaires that killed her 8 yr old son), during her time at Rikers awaiting trial. + +https://www.google.corn/search? + +q=gigiijordan&rlz=1C5CHFA enUS754US754&oq=gigiijordan+&ags=chrome..69i57j69i60j35i3912j012.6016 jQp&sourceid=chrome&ie=UfF-8 + +The Rikers Bribe scheme by Gigi Jordan was from 2010-2015 , and Literally involved the entire Jail. The person on the receiving end of the Bribe was Norman Seabrook . I have evidence that Vance knew about it and covered it up as a favor to Norman Seabrook (in 2015) . Gigi Jordan's lawyer was Alan Dershowitz, and Dershowitz joined Gigi Jordan's defense team literally a few months later after the infamous " Alan Dershowitz' client Jeffrey Epstein court hearing in 2011, when our DA Cyrus Vance ordered his Sex crimes unit chief show up to court to implore the Epstein's Judge to to downgrade Epstein to Level 1 sex offender. (WOW) . + +I have a CO contact that has information/names of COs who are witnesses to Gigi Jordan's lawyers (ie Alan Dershowitz), actually being involved in the actual crime of the Rikers Bribe . + +Im just going to include a quick summary of facts and events below...I have emails and recordings with various officials in Vance's office, and I have documents spanning the last 5 years (both on the Gigi Jordan Bribe coverup, and the Cardinal Dolan coverup) . Just an example , I have incriminating emails and recordings with 4 of Vance's Burea directors, Vance's Financial Crimes unit, and recordings with State Police Investigator, who admits to me on a recorded line that Vance's office ordered him to "Not investigate and squash any investigation/arrests of Fr Miqueli for the million Dollar embezellment and child abuse... As you can imagine, I have gone to all levels of City Government , including DOI in 2015 and 2016, while still under Commissioner Mark Peters, and Mark Peters ordered investigations into all of this "squashed"... I have gazzlion emails and recordings with DOI, all the way up to Mark Peters departure in Nov 2018. + +The information below is corruption by Cyrus Vance, as pertains to Vance colluding with Ny Archdiocese to cover up and protect a certain Priest, Fr Miqueli (as a favor to Cardinal Dolan) . Fr Miqueli is a priest who embezzled a million dollars at a Roosevelt island Parish St Francis Cabrini (Vance's teritory), Vance also helped Cardinal Dolan cover up child abuse (what else is new!?) by Fr Miqueli of at least one kid , that I know of. The Coverup and protection of Fr Miqueli crimes is ordered by Cyrus Vance personally (I have evidence, in the way of emails and recording and documents) . + +Just to give you some background on who I am A few years ago , you might remember the story about a girl who exposed a Gay priest who embezzled a million dollars, and Cardinal Dolan who covered it up. It was front page worldwide news ... + +htt s://www. oo • le.corn/search? + +if you do remember the story from reading it. tni lmihuhlk thoucht t otit, cl f "there must be some much more to it" . Boy is there ever! The Priest and are being protected by Cardinal Dolan, who has had full knowledge of everything , but covered it up, "cooked the books", etc, be Fr Miqueli and have MAJOR blackmail on the NY Archdiocese and the Vatican. Below is an investigative report which will give you some idea of what the blackmail is . Vance's office knows all this and covered it up (I have timestam ed dated emails proving Vance's office has all this information) . + +http youtu. + +Also, a high ranking Archdiocese insider came forward a year and confirmed that Cardinal Dolan knew all about the Million dollar embezzlement by Fr Miqueli, and , and the child sex abuse , and why Cardinal Dolan covered it up. Below is an interview with him . + +## MANHATTAN DA / CYRUS VANCE COLLUSION WITH NY ARCHDIOCESE TO PROTECT FR MIQUELI AND [REDACTED] (AS A FAVOR TO CARDINAL DOLAN) + +As payback for me exposing all this, Cardinal Dolan has taken some preemptive steps of retaliation against me for exposing this corruption, and pulled in favors with top ranks of NYPD and Manhattan DA office to protect [REDACTED] and Miqueli, and squash any investigation/arrests into their embezzlement and other crimes, and to maliciously prosecute me (I have emails /recordings with top ranks of NYPD and IA and Manhattan DA) . The Blackstar News article below summarizes all that (there is a retaliatory false arrest by NYPD, and much much more, what's addressed in the article is just the tip of the iceberg) + + [REDACTED] +When she never heard from Gordon, on May 19, 2015, at 11:39 AM, [REDACTED] sent her e-mail messages with what she claims were past alleged crimes never investigated by the Manhattan DA's office after she'd provided evidence. +Some were allegations of corruption unconnected to [REDACTED]. One was a beating that [REDACTED] suffered at a bachelor's party that she had organized in 2012, by individuals she believes were prominent New York City officials, who were drunk and had been snorting cocaine. The incident was recorded on a surveillance camera at an event's space. Even though one arrest was made there's been no prosecution to date, [REDACTED] claimed, in the e-mail message to Gordon. "I told her in that e-mail that I plan to go to The Daily News to expose the corruption in the Manhattan DA's office." + +Link below is the actual email to ADA Gordon (Vance's office) that is referred to in the above Blackstar News article above, where I inform ADA Gordon that I plan on going to NY Post with evidence of various corruption at Manhattan DA . + +12 hrs after I sent Manhattan DA this email above, at 11:39 am 5/19/15, I am arrested at my house by the NYPD.. What that email was referring to was the huge bribe scheme going on at Rikers perpetrated by inmate Gigi Jordan (the multi millionaires that killed her son). Norman Seabrook was on the receiving end of that Bribe (different bribe than the one he got arrested for), and other corruption/coverup by Vance's office in my case, and the retaliation against me when I tried to expose it. +[ada gordon email may 19 2015 11:39 am re Manhattan..](http://www.google.com/webhp?sourceid=chrome-instant&ion=1&espv=2&ie=UTF-8#q=Gigi+Jordan) + +## GIGI JORDAN RIKERS BRIBE + + + +The bribe scheme was going on for the 5 yrs that Gigi was at Rikers prior to her being convicted /sentenced, and being sent upstate circa summer 2015. The bribe scheme was indicated to be 20k/month. How I know about this is I was at Rikers for 8 months, March 2014 to Nov 2014 . What I was doing at Rikers in the first place, and the NYPD corruption/false arrest that put me there is detailed in the media article above by Blackstar News . But in the meantime, while at Rikers, I gathered up as much info as I could. Literally, the entire jail was involved in it, one way or another (All the COs knew about it, they either knew about it, or were involved in executing the "special favors " that Gigi's 20k/month was buying.) I know for a fact both Wardens knew about it (Bailey and Clifford), but everyone was too afraid to say something bc they were following orders of Norman Seabrook. + +When I got out from Rikers, I immediately reported this to Gigi's prosecutor, **ADA Bagdanos** at Manhattan DA in Feb 2015. I was shocked when Bagdanos admitted to me (by accident, I'm very good at getting people to admit things to me) that Manhattan DA knew about it all along. I was shocked, started grilling ADA Bagdanos about why he did not make arrests, is it bc of the high ranking official on the receiving end who is being protected?....Bagdanos realized his screwup by his admission, and kicked me out of his office...I started writing emails to Mr Vance's top ranks, including Vance's Trial Bureau Chief, Armond Durasanti, and other department heads...I demanded they turn the Gigi Jordan Rikers Bribe coverup directly to Vance, (even though I knew vance already knew about it). They all continued to cover it up. On 5/19/15 I wrote an email to ADA Gordon (she was the prosecutor in against [REDACTED] (and Fr Miquelis [REDACTED]), [REDACTED], in a Domestic Violence crime [REDACTED] did against me. I was ADA Gordon's Domestic Violence Victim .. On 5/19/15, at 11:39 am, I sent her an email telling her I plan to go to Ny post with evidence of corruption at Manhattan DA office, specifically to expose that they knew about the Gigi Jordan Rikers Bribe (as per Bagdano's admission to me), and that they covered it up, and the coverup of Fr Miqueli's embezzlement and child abuse .... + +12 hrs later, NYPD come to my house to arrest me. Vance's office maliciously prosecuted me on that case for 2 1/2 years.../ finally wrote a letter to the Judge and provided evidence of the corruption in my case, and she dismissed it outright shortly thereafter. I have a TON of evidence of Vance"s Office corruption on that case. + +Below is also a Crime Watch Daily episode that they did about my story of the false arrest /malicious prosecution by Vance's Office on 5/19/15 (as a favor to Cardinal Dolan) + +## Crimewatch Daily Episode about the Collusion by Vances office and Manhattan DA to prosecute me and Protect Fr Mi ueli and (as a favor to Cardinal Dolan) + +https://vimeo.co + +## FURTHER INFORMATION RE ALAN DERSHOWITS (heading up Gigis Legal team) INVOLVED IN THE GIGI JORDAN RIKERS BRIBE /COVERUP BY VANCE'S OFFICE + +Alan Dershowitz was the Lead lawyer for Gigi Jordan (along with about 6 others). Here is a pie of Dershowitz and Ron Kuby at Gigi Jordan trial (picture is worth a thousand words!) + +I found information and spoke to a Corrections Officer (I at Norman Seabrook sentencing in Feb 2019 had information that Gigi's lawyers directly personally participated in the Rikers bribe crime in one certain aspect...They bribed the CO who is in charge of attorney visits, + +or o sneaVme lawyers in inside the Jail (where the inmates are), to have private all day visits with Gigi Jordan inside the inmate housing areas, and also the Co was bribed to allow the la ers to bring in la to s, cellphones (which are strictly prohibited inside the jail , and are contraband) . CO was Co coworker in the lawyer visiting area .. AS per Co Monclavas information, CO found out about CO "getting paid" from Gigi Jordans lawyers in exchange for giving Gigi Jordan and her lawyers certain "ille al Favors". CO was jealous, and filed a formal complaint that Gigi's lawyers were bribing CO .... Both and in addition .ICOs, kol were also the Rikers Union delegates, reporting directly to Norman Seabrook. After CO made formal complaint, it seems that Norman Seabrook "gave her whatever she wanted ", so she did not press the issue further. Whats important about all of this is that there was Documentation at Rikers from CO's about the Gigi Jordan bribe(involving her lawyers, ) . Vance office and Department of Investigation (DOI) covered it up. + +Im just giving you a quick synopsys here, obviously there is alot more to this, specifically about vance himself and the actual criminal case vs Gigi Jordan. I have everything fully documented, especially the retaliation against me by Vance's office when I tried to expose this. + +I believe that the information/evidence on Cyrus Vance/ Norman Seabrook/ALan Dershowitz that I have that I have obtained as part of my fight for Justice and exposing Vances Corruption in my personal case , as it so happens, currently complements several of the major cases on going at the US Attorneys office (Epstein, Seabrook, etc). Technically my Norman Seabrook Bribe information is separate from the Bribe Seabrook got prosecuted for by your office, but at the same time is VERY similar. More importantly, the "other Noman Seabrook Bribe" case technically still isn't over, Seabrook is appealing, plus , even worse, is freely "walking the earth", as we speak. I attended Seabrooks sentencing hearing, and Judge Heller was very clear when he allowed Seabrook to be out on bail pending appeal....That bail is contingent on "there being no other additional criminal actions outstanding by Norman Seabrook "... I believe that if the evidence of the criminal actions by Seabrook in the Gigi Jordan/Alan Dershowitz Rikers bribe, just on that alone , if presented to Judge Heller, would result in Judge Heller Revoking Seabrook's Bail, which would be HUGE win and Justice being served for the Citizens of NY. Additionally, any information/evidence that Your office obtains showing criminal activity by Alan Dershowitz in a separate (but similar) non Epstein matter, would give your office huge leverage over Dershowitz to force Dershowitz to flip on any fo Epstein's accomplices that Dershowitz has information on . + +I am including my direct cell number below. Is it possible to schedule an appointment for me to come in and give US attorney Office further information and provide whatever evidence I have , of which there is tons. + +917 891 4696 \ No newline at end of file diff --git a/marker2/ds9/EFTA00090614/EFTA00090614.metadata.json b/marker2/ds9/EFTA00090614/EFTA00090614.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..c51fb47f98e433a7d390d45b886cc07ef55d6b8c --- /dev/null +++ b/marker2/ds9/EFTA00090614/EFTA00090614.metadata.json @@ -0,0 +1,271 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090614.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 5, + "chars": 15640, + "elapsed_seconds": 18.37, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "MANHATTAN DA / CYRUS VANCE COLLUSION WITH NY ARCHDIOCESE TO PROTECT FR MIQUELI AND [REDACTED] (AS A FAVOR TO CARDINAL DOLAN)", + "heading_level": null, + "page_id": 2, + "polygon": [ + [ + 31.212, + 63.99000000000001 + ], + [ + 552.024, + 63.99000000000001 + ], + [ + 552.024, + 91.53 + ], + [ + 31.212, + 91.53 + ] + ] + }, + { + "title": "GIGI JORDAN RIKERS BRIBE", + "heading_level": null, + "page_id": 2, + "polygon": [ + [ + 31.212, + 392.04 + ], + [ + 203.796, + 392.04 + ], + [ + 203.796, + 405.81000000000006 + ], + [ + 31.212, + 405.81000000000006 + ] + ] + }, + { + "title": "Crimewatch Daily Episode about the Collusion by Vances office and Manhattan DA to \nprosecute me and Protect Fr Mi ueli and (as a favor to Cardinal Dolan)", + "heading_level": null, + "page_id": 3, + "polygon": [ + [ + 30.6, + 119.07 + ], + [ + 523.7138671875, + 119.07 + ], + [ + 523.7138671875, + 147.3170166015625 + ], + [ + 30.6, + 147.3170166015625 + ] + ] + }, + { + "title": "FURTHER INFORMATION RE ALAN DERSHOWITS (heading up Gigis Legal team) INVOLVED IN \nTHE GIGI JORDAN RIKERS BRIBE /COVERUP BY VANCE'S OFFICE", + "heading_level": null, + "page_id": 3, + "polygon": [ + [ + 30.6, + 186.3 + ], + [ + 577.116, + 186.3 + ], + [ + 577.116, + 215.103515625 + ], + [ + 30.6, + 215.103515625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 77 + ], + [ + "Line", + 36 + ], + [ + "Text", + 21 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 111 + ], + [ + "Line", + 50 + ], + [ + "Text", + 15 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 16 + ], + [ + "SectionHeader", + 4 + ], + [ + "PageHeader", + 2 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 3, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 102 + ], + [ + "Line", + 48 + ], + [ + "Text", + 9 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 4, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 3 + ], + [ + "Text", + 2 + ], + [ + "Line", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00090614" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00090619/EFTA00090619.md b/marker2/ds9/EFTA00090619/EFTA00090619.md new file mode 100644 index 0000000000000000000000000000000000000000..53dc17104f55b24f2747102f0297e2a7e73abcbe --- /dev/null +++ b/marker2/ds9/EFTA00090619/EFTA00090619.md @@ -0,0 +1,31 @@ +To + +Cc + +Subject: FW: Prince Andrew as Epstein witness? - HuffPost + +Date: Thu, 21 Nov 2019 19:51:10 +0000 + +From: Sara Boboltz + +Sent: Thursday, November 21, 2019 2:49 PM + +To: + +Subject: Prince Andrew as Epstein witness? - Huff Post + +Hello, + +Writing to ask whether Britain's Prince Andrew will submit to questioning by U.S. investigators looking into Jeffrey Epstein's potential co-conspirators. The Telegraph reported this morning that the prince is preparing to do so. + +Please let me know one way or the other if you can confirm. Thank you. + +Sara Boboltz + +Reporter; HtePost + +770 Broadway, 4th Floor + +New York, NY 10003 + +(t) sara\_bee \ No newline at end of file diff --git a/marker2/ds9/EFTA00090619/EFTA00090619.metadata.json b/marker2/ds9/EFTA00090619/EFTA00090619.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..d1483057743e98eac0f7420ef9f094b7d2f7b233 --- /dev/null +++ b/marker2/ds9/EFTA00090619/EFTA00090619.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090619.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 659, + "elapsed_seconds": 0.89, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 42 + ], + [ + "Line", + 20 + ], + [ + "Text", + 18 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00090619" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00090620/EFTA00090620.md b/marker2/ds9/EFTA00090620/EFTA00090620.md new file mode 100644 index 0000000000000000000000000000000000000000..74a1f80e987d523e03f06bc3babfdf9958c809bc --- /dev/null +++ b/marker2/ds9/EFTA00090620/EFTA00090620.md @@ -0,0 +1,138 @@ +To: ' + +Cc: "Seaman, Gillian P." + +Subject: RE: October 3, 2019 Grand Jury Subpoena to TD Bank N.A. CONFIDENTIAL TREATMENT REQUESTED + +Date: Thu, 21 Nov 2019 23:39:15 +0000 + +Perfect. + +Thanks. + +From: + +Sent: Thursday, November 21, 2019 6:38 PM + +To: Bourtin, Nicolas + +Cc: Seaman, Gillian P. + +Subject: (EXTERNAL] RE: October 3, 2019 Grand Jury Subpoena to TD Bank N.A. CONFIDENTIAL TREATMENT REQUESTED + +Can we plan for 4:30pm tomorrow? Happy to call you, just let me know the best number. + +Thanks, + +Assistant United States Attorney Southern District of New York I St. Andrew's Plaza New York, NY 10007 + +From: Bourtin, Nicolas + +Sent: Thursday, November 21, 2019 5:05 PM + +To: + +Cc: Seaman, Gillian P. • + +Subject: RE: October 3, 2019 Grand Jury Subpoena to TD Bank N.A. CONFIDENTIAL TREATMENT REQUESTED + +Thanks, Would tomorrow 9-10 am or after 4 pm work? If not, we can look for times next week. + +Nic + +From: + +Sent: Thursday, November 21, 2019 3:39 PM + +Hi Nic, + +This is to confirm that TD can close out the accounts referenced in our prior hold-open letter. We are no longer requesting that the accounts remain open. Thank you very much for your assistance. + +In connection with our ongoing investigation, we are planning to subpoena records from other TD accounts related to Epstein. Would you be available for a call to discuss in the next few days? + +Thanks, + +Assistant United States Attorney Southern District of New York I St. Andrew's Plaza New York, NY 10007 + +From: Bourtin, Nicolas Sent: Wednesday, November 20, 2019 2:06 PM To: Cc: Seaman, Gillian P. itt . + +Subject: RE: October 3, 2019 Grand Jury Subpoena to TD Bank N.A. CONFIDENTIAL TREATMENT REQUESTED + +Hi + +Following up on our call on Friday, I just wanted to check in on the government's timing. Please let us know if TD can begin to close out these accounts or if you'd like the bank to hold them open longer. + +Thanks. + +Nic + +From: + +Sent: Tuesday, October 22, 2019 4:06 PM + +To: Bourtin, Nicolas. ; Seaman, Gillian P. + +Cc: + +Subject: [EXTERNAL] RE: October 3, 2019 Grand Jury Subpoena to TD Bank N.A. CONFIDENTIAL TREATMENT REQUESTED + +As discussed, attached please find a formal letter requesting that the accounts we have previously discussed be kept open for one month from today's date. We will also send a hard copy to your office. + +Best, + +Assistant United States Attorney Southern District of New York l St. Andrew's Plaza New York. NY 10007 + +From: Bourtin, Nicolas Sent: Tuesday, October 22, 2019 1:41 PM To: Cc: >; Seaman, Gillian R + +Subject: RE: October 3, 2019 Grand Jury Subpoena to TD Bank N.A. CONFIDENTIAL TREATMENT REQUESTED + +Thanks for getting back to us on those two points. I also wanted to let you know our plan to close the other accounts. In order to accommodate the government's request, we'd propose the following process: + +- TD Bank will send the account holders a letter informing them that the Bank is closing their accounts within 14 days. The letter will inform account holders that the Bank will wire the funds to an account of their designation and will contain specific instructions on how to provide the Bank with the wire instructions. The letter will also give customers a phone number to call with any questions. +- If TD Bank doesn't hear from the customer after 5 business days from the date the letter is sent, the Bank will attempt to call the customer to request that they call the Bank about closing their account and providing wire instructions. +- If at the end of the 14 days the Bank still hasn't heard from the customer or doesn't have wire instructions, the Bank will cut a check and mail it to the customer. +- Before TD Bank sends any checks, we'll let you know which account holders we haven't heard from and for whom we don't have wire instructions. + +Let me know if you have any questions or concerns about this process. + +We'll look out for the keep open letter. + +From: Sent: Tuesday, October 22, 2019 1:08 PM To: Bourtin, Nicolas • Seaman, Gillian R Cc: Subject: [EXTERNAL] RE: October 3, 2019 Grand Jury Subpoena to TD Bank N.A. CONFIDENTIAL TREATMENT REQUESTED + +Nic, + +Thank you for your patience on this. We do not need the statement for the JSC Interiors LLC account. I expect to send you the keep-open letter you requested regarding the other accounts we've discussed later today. + +Thanks, + +Assistant United States Attorney Southern District of New York I St. Andrew's Plaza New York, NY 10007 + +From: Bourtin, Nicolas < Sent: Tuesday, October 15, 2019 5:03 PM To: Cc: >; Seaman, Gillian P. Subject: RE: October 3, 2019 Grand Jury Subpoena to TD Bank N.A. CONFIDENTIAL TREATMENT REQUESTED + +Let us know if you're unable to access the disk. In the meantime, in addition to the eight "HBRK Associates" accounts (we're sending you those statements tonight), there is another account associated with Richard Kahn. This one is in the name of "JSC Interiors LLC," and Kahn is the authorized signer. Can you let us know if you'd like us to produce the statements for that account and hold it open? + +Thanks. + +From: Sent: Tuesday, October 15, 2019 2:47 PM To: Seaman, Gillian P. Cc: Bourtin, Nicolas ]< Subject: [EXTERNAL] RE: October 3, 2019 Grand Jury Subpoena to TD Bank N.A. CONFIDENTIAL TREATMENT REQUESTED + +Thanks Gillian. I received the disc but am unable to run the software program on my computer. I'll work with our paralegal and IT to hopefully access it soon and get back to you with a timeline for our review. + +Best, + +Assistant United States Attorney Southern District of New York 1 St. Andrew's Plaza New York, NY 10007 + +From: Seaman, Gillian P. Sent: Tuesday, October 15, 2019 11:03 AM To: Cc: Bowfin, Nicolas + +Subject: October 3, 2019 Grand Jury Subpoena to TD Bank N.A. CONFIDENTIAL TREATMENT REQUESTED + +Please see attached for the letter that is being sent to you this morning via messenger. The password for the hard drive that you will receive will follow in a separate email. + +Please let us know whether you have any questions or have difficulty accessing the data. + +Regards, Gillian + +Gillian Palmer Seaman Sullivan & Cromwell LLPI I25 Broad Street New York, NY 10004-2498 + +This e-mail is sent by a law firm and contains information that may be privileged and confidential. If you are not the intended recipient, please delete the e-mail and notify us immediately. + +\*\*This is an external message from: ■■ \ No newline at end of file diff --git a/marker2/ds9/EFTA00090620/EFTA00090620.metadata.json b/marker2/ds9/EFTA00090620/EFTA00090620.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..2f73761d54511ec85eb6935cd53c25ae33ef93a5 --- /dev/null +++ b/marker2/ds9/EFTA00090620/EFTA00090620.metadata.json @@ -0,0 +1,216 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090620.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 6, + "chars": 6321, + "elapsed_seconds": 1.58, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 65 + ], + [ + "Line", + 32 + ], + [ + "Text", + 29 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 67 + ], + [ + "Line", + 33 + ], + [ + "Text", + 19 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 69 + ], + [ + "Line", + 35 + ], + [ + "Text", + 11 + ], + [ + "ListItem", + 4 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 3, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 65 + ], + [ + "Line", + 31 + ], + [ + "Text", + 9 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 4, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 67 + ], + [ + "Line", + 32 + ], + [ + "Text", + 10 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 5, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 14 + ], + [ + "Line", + 6 + ], + [ + "Text", + 2 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00090620" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00090626/EFTA00090626.md b/marker2/ds9/EFTA00090626/EFTA00090626.md new file mode 100644 index 0000000000000000000000000000000000000000..d5522d8b0d348b3447cf4bc2310ae930eaf6e792 --- /dev/null +++ b/marker2/ds9/EFTA00090626/EFTA00090626.md @@ -0,0 +1,45 @@ +From: ' + +To: ' + +Cc: rt . + +Subject: RE: Jeffrey Epstein Victim; Ms , 17 years old + +Date: Fri, 22 Nov 2019 18:37:01 +0000 + +called on our 800 line from New Mexico sex trafficking that the AG in New Mexico gave her our 800 line. she believes that her daughter is a victim of + +I don't know if this is Epstein. + +From: + +Sent: Friday, November 22, 2019 1:24 PM + +To: + +Cc: > + +Subject: RE: Jeffrey Epstein Victim; Ms 17 years old + +Will do, thank you! + +From: + +Sent: Friday, November 22, 2019 13:17 + +To: > >; > + +Subject: FW: Jeffrey Epstein Victim; Ms 17 years old + +Can you send to FBI. + +From: + +Sent: Thursday, November 21, 2019 8:12 PM + +To: + +Subject: Jeffrey Epstein Victim; Ms 17 years old + +I am a very close friend of Ms. and her guardian, Ms. of Calderitas, Mexico. Ms. was abused by Jeffrey Epstein on numerous occasions at his townhome in New York and his caribbean island home in the Virgin Islands. They both have expressed their interest in asking me to register her claim as a victim in any case involving Mr. Epstein's estate, which she believes she may have a claim. She does not have legal representation yet, but is in negotiations to retain and attorney soon. 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The benefits of consistent naming cannot be overstated, and I am pleased to be able to explain every detail of the intricacies of this crucial element of federal prosecution. In this TED Talk, I will + +Original Message + +From: + +aNIMIN>: To: + +Sent: Wednesda November 27, 2019 13:45 + +Cc: < IMIN> + +Subject: RE: 302s, photos, & Proffer notes + +Yes, I hear= is particular about this ... + +aNIMIN> From: + +Original Messa e + +alMIN> To: ; + +Sent: Wednesda , November 27, 2019 1:44 PM + +Cc: + +Subject: RE: 302s, photos, & Proffer notes + +I already put them all in the relevant folders, but would be great i f=could doublecheck me on the naming convention :) + +Original Messa e + +From: + +Sent: Wednesday, November 27 2019 1:43 PM + +To: + +Cc: + +Subject: FW: 302s, photos, & Proffer notes + +Hi MI— when you can, could you please save these in the Epstein witness folder with convention? Thanks! file naming + +Original Messa e + +From + +Sent: , 1 .46 A M + +To: ) • ; + +•c > + +Cc: DCPJ SDLCODF + +Subject: French Judicial Police + +Hello, + +I am the deputy of the Central Unit for Minors Protection in France and this unit is in charge of the french case against EPSTEIN and J-L BRUNEL. + +We are actively trying to investigate crimes commited in France or abroad by J-L BRUNEL against french or foreign victims and any implication BRUNEL had in providing women and young girls for EPSTEIN. + +We have officialy reached out to certain government officials in the US to try to coordinate our efforts but we haven't received any substantiel communication or assistance. Our request was maybe directed to the wrong people. + +We would really like to coordinate our efforts with you in this case and would like to know what your intentions are, if your have any, concerning Jean Luc BRUNEL. + +We have started to collect quite a few victim statements of rape against BRUNEL but because of the statute of limitations we can not pursue him for these rapes. For these victims, we would really like to have a strong case against him and find other victims. Any information linked to BRUNEL could help us. + +Kind re arts + +Tél 101 rue des Trois Fonlanot - 92000 NANTERRE + +![](_page_1_Picture_19.jpeg) + +![](_page_1_Picture_20.jpeg) + +CAPITAINE DE POLICE + +Direction centrale de la police judiciaire + +Office Central pour la Répression des Violences aux Personnes Adjoint du Groupe Central des Mineurs Victimes + +- Fax : + +Pour une administration exemplaire, preservons l'environnement. 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When you have a moment, could you please email us all the SARs/CTRs filed by JP Morgan for Epstein's accounts? + +Thanks, + +![](_page_0_Picture_33.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00090633/EFTA00090633.metadata.json b/marker2/ds9/EFTA00090633/EFTA00090633.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..0be0f50679e1a8a9ee5bf857cc20be021669ab56 --- /dev/null +++ b/marker2/ds9/EFTA00090633/EFTA00090633.metadata.json @@ -0,0 +1,62 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090633.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 315, + "elapsed_seconds": 1.7, + "image_assets": [ + "_page_0_Picture_27.jpeg", + "_page_0_Picture_30.jpeg", + "_page_0_Picture_33.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 13 + ], + [ + "Text", + 10 + ], + [ + "Line", + 7 + ], + [ + "Picture", + 3 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00090633" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00090633/_page_0_Picture_27.jpeg b/marker2/ds9/EFTA00090633/_page_0_Picture_27.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..f79a4da09e15ead478a964719203dccc6e0aef4d --- /dev/null +++ b/marker2/ds9/EFTA00090633/_page_0_Picture_27.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:9ec8b3cbe59cd9fffd7e4344a0f6779e75343d3d37f747c83916473e34e2f3b7 +size 9583 diff --git a/marker2/ds9/EFTA00090633/_page_0_Picture_30.jpeg b/marker2/ds9/EFTA00090633/_page_0_Picture_30.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..47d25df0aadca81d8a6dc0e562965443ba48560d --- /dev/null +++ b/marker2/ds9/EFTA00090633/_page_0_Picture_30.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:6eebca93dbc43b60d8bbbb1db9af22ad77de7426db279313e08ad19554db183c +size 1277 diff --git a/marker2/ds9/EFTA00090633/_page_0_Picture_33.jpeg b/marker2/ds9/EFTA00090633/_page_0_Picture_33.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..c4beda005f81e9e0327dd9e95fe90dc0ba3dedc2 --- /dev/null +++ b/marker2/ds9/EFTA00090633/_page_0_Picture_33.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:b461eae2e9f48691506e73620cc8af2cabd57f548a0f955ba35e3af6c9234054 +size 6039 diff --git a/marker2/ds9/EFTA00090634/EFTA00090634.md b/marker2/ds9/EFTA00090634/EFTA00090634.md new file mode 100644 index 0000000000000000000000000000000000000000..1c678d85e5cb91fc6595e2e99546e52437b6b62b --- /dev/null +++ b/marker2/ds9/EFTA00090634/EFTA00090634.md @@ -0,0 +1,37 @@ +To: "Bourtin, Nicola + +Cc: "Seaman, Gillian P." + +Subject: RE: October 3, 2019 Grand Jury Subpoena to TD Bank N.A. CONFIDENTIAL TREATMENT REQUESTED + +Date: Wed, 27 Nov 2019 16:13:29 +0000 + +Thanks very much, Nic. Happy Thanksgiving! + +Assistant United States Attorney + +Southern District of New York + +I St. Andrew's Plaza + +New York, NY 10007 + +From: Bourtin, Nicolas + +Sent: Wednesday, November 27, 2019 9:29 AM + +To: + +Cc: Seaman, Gillian P. < + +Subject: RE: October 3, 2019 Grand Jury Subpoena to TD Bank N.A. CONFIDENTIAL TREATMENT REQUESTED + +Hi Maurene — + +We wanted to get back to you to confirm that TD Bank neither has nor had any accounts in Epstein's name or for which Epstein was a signatory. Please let us know if you need anything further. + +Happy Thanksgiving. + +Nic + +This e-mail is sent by a law firm and contains information that may be privileged and confidential. If you are not the intended recipient, please delete the e-mail and notify us immediately. \ No newline at end of file diff --git a/marker2/ds9/EFTA00090634/EFTA00090634.metadata.json b/marker2/ds9/EFTA00090634/EFTA00090634.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..2a22370f5231ac643686ea3593b86d0e9b25bcdc --- /dev/null +++ b/marker2/ds9/EFTA00090634/EFTA00090634.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090634.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 957, + "elapsed_seconds": 1.03, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 53 + ], + [ + "Line", + 24 + ], + [ + "Text", + 22 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00090634" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00090635/EFTA00090635.md b/marker2/ds9/EFTA00090635/EFTA00090635.md new file mode 100644 index 0000000000000000000000000000000000000000..f349c55854f12bdd7977bf135abfa653232149d6 --- /dev/null +++ b/marker2/ds9/EFTA00090635/EFTA00090635.md @@ -0,0 +1,41 @@ +From: ' To:" Cc: r>i " + +Subject: RE: legal / coordination question + +Date: Tue, 03 Dec 2019 08:51:53 +0000 + +Glad you are reaching out. There has been quite a bit of news in the UK about FBUDOJ interest in Prince Andrew. Right now I have open afternoons today and tomorrow, but have events both nights. So if there is a time that works between 1:30 and 5 pm GMT (8:30-noon EDT), let me know. I have some time late in my day on Thursday. Friday is pretty much flat out. + +Thanks, + +US Department ofJustice Attaché + +United States Embassy + +33 Nine Elms Lane + +London SW1 17US + +Desk: + +Mobile: after hours) + +From US: + +Email: + +## SBU -LAW ENFORCEMENT + +From: + +Sent: Tuesday. December 3 2019 12:23 AM + +Cc: + +Subject: RE: legal / coordination question + +My colleagues wand I are the team of prosecutors working on the Jeffrey Epstein investigation, and we wondered if we might be able to set up a call with you for sometime this week, to ask you some logistical questions we're hoping you might either be able to answer or to point us in the right direction on. Would that be possible? If there are a few times in the coming days that you're free, we can try to figure out a slot that works for everyone. + +Thanks very much, and looking forward to being in touch. + +![](_page_1_Picture_1.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00090635/EFTA00090635.metadata.json b/marker2/ds9/EFTA00090635/EFTA00090635.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..2b35685bac413a365166853c9f227801e59d0adc --- /dev/null +++ b/marker2/ds9/EFTA00090635/EFTA00090635.metadata.json @@ -0,0 +1,118 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090635.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 1275, + "elapsed_seconds": 1.21, + "image_assets": [ + "_page_1_Picture_1.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "SBU -LAW ENFORCEMENT", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 241.12800000000001, + 502.20000000000005 + ], + [ + 370.592041015625, + 502.20000000000005 + ], + [ + 370.592041015625, + 516.8341064453125 + ], + [ + 241.12800000000001, + 516.8341064453125 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 62 + ], + [ + "Line", + 29 + ], + [ + "Text", + 25 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 7 + ], + [ + "Line", + 4 + ], + [ + "PageHeader", + 1 + ], + [ + "Picture", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00090635" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00090635/_page_1_Picture_1.jpeg b/marker2/ds9/EFTA00090635/_page_1_Picture_1.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..4866d5b512640f62ccdcb7f1b29bb06438957ea8 --- /dev/null +++ b/marker2/ds9/EFTA00090635/_page_1_Picture_1.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:716106c36ced74812c7e90acca1cdd4aff0f00731ec198346374a6eef7e6c2bb +size 1292 diff --git a/marker2/ds9/EFTA00090637/EFTA00090637.md b/marker2/ds9/EFTA00090637/EFTA00090637.md new file mode 100644 index 0000000000000000000000000000000000000000..cb29c825ac5d3a6020992ee14e993eb01f580756 --- /dev/null +++ b/marker2/ds9/EFTA00090637/EFTA00090637.md @@ -0,0 +1,29 @@ +![](_page_0_Picture_46.jpeg) + +**Subject:** RE: JP Morgan + +**Date:** Thu, 05 Dec 2019 20:33:09 +0000 + +--- + +![](_page_0_Picture_49.jpeg) + +I queried the FinCen database utilizing BSARs and CTRs filed by JP Morgan Chase which reference Epstein's SSN. The query produced 14 SARs (8 with attachments) and 89 CTRs. I have copied those files to a DVD which I will leave for Andrew to pick up. Additionally, I have included a document index in the DVD. + +If you have any questions, please contact me. + +Best + +![](_page_0_Picture_53.jpeg) + +![](_page_0_Picture_54.jpeg) + +**Subject:** JP Morgan + +Hi [REDACTED] + +Hope you had a nice Thanksgiving. When you have a moment, could you please email us all the SARs/CTRs filed by JP Morgan for Epstein's accounts? + +Thanks, + +![](_page_0_Picture_59.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00090637/EFTA00090637.metadata.json b/marker2/ds9/EFTA00090637/EFTA00090637.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..b9ce8d52a0082efbc0e51bc04aa0cdf52855b623 --- /dev/null +++ b/marker2/ds9/EFTA00090637/EFTA00090637.metadata.json @@ -0,0 +1,64 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090637.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 780, + "elapsed_seconds": 3.18, + "image_assets": [ + "_page_0_Picture_46.jpeg", + "_page_0_Picture_49.jpeg", + "_page_0_Picture_53.jpeg", + "_page_0_Picture_54.jpeg", + "_page_0_Picture_59.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 23 + ], + [ + "Text", + 19 + ], + [ + "Line", + 12 + ], + [ + "Picture", + 5 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00090637" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00090637/_page_0_Picture_46.jpeg b/marker2/ds9/EFTA00090637/_page_0_Picture_46.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..5ae83169e5796a016514fb9ef19b608ffdd296f3 --- /dev/null +++ b/marker2/ds9/EFTA00090637/_page_0_Picture_46.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:bc3a33d8d48b4c5e69be31e20c35f7a7cab1f5ed207bde8ce3efd17d0b0de1bb +size 10656 diff --git a/marker2/ds9/EFTA00090637/_page_0_Picture_49.jpeg b/marker2/ds9/EFTA00090637/_page_0_Picture_49.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..04eeb85264e46ab8e52bfcb52b6ba4d6182ba6bc --- /dev/null +++ b/marker2/ds9/EFTA00090637/_page_0_Picture_49.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:2282720024531842fb0f15e06f2b1d5a26a0933fd8ca56a072bbd5bdd98c4b71 +size 1201 diff --git a/marker2/ds9/EFTA00090637/_page_0_Picture_53.jpeg b/marker2/ds9/EFTA00090637/_page_0_Picture_53.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..bbdb6890d31bf0574e57dc19a6294d4d291e09c4 --- /dev/null +++ b/marker2/ds9/EFTA00090637/_page_0_Picture_53.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:27d7b2a3fdfb4bee2d2dadbe4851ce8f7f5eeddb5ed4d7848f8882b0866b6ed9 +size 1240 diff --git a/marker2/ds9/EFTA00090637/_page_0_Picture_54.jpeg b/marker2/ds9/EFTA00090637/_page_0_Picture_54.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..1fae631dd0a267a492852ac8498eb983f837c44f --- /dev/null +++ b/marker2/ds9/EFTA00090637/_page_0_Picture_54.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:5dfaba6c2d4c9b90acd5c98ee162dfd61914ffebedbf553327b36df5174ce953 +size 7068 diff --git a/marker2/ds9/EFTA00090637/_page_0_Picture_59.jpeg b/marker2/ds9/EFTA00090637/_page_0_Picture_59.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..a7b73aa93737ae55318b86b877896f9651a8bef7 --- /dev/null +++ b/marker2/ds9/EFTA00090637/_page_0_Picture_59.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:5221cf30e0fe4ec3cc4314031b2a78ad9633bdadd1b08032e6d3b30e8c08a44b +size 5019 diff --git a/marker2/ds9/EFTA00090638/EFTA00090638.md b/marker2/ds9/EFTA00090638/EFTA00090638.md new file mode 100644 index 0000000000000000000000000000000000000000..0b31587da242deb41722ed86a2317c4df096fe26 --- /dev/null +++ b/marker2/ds9/EFTA00090638/EFTA00090638.md @@ -0,0 +1,37 @@ +**To:** "[REDACTED]" <[REDACTED]>, [REDACTED] +[REDACTED] )" <[REDACTED]>, [REDACTED] )" + +**Cc:** "Sahni, Anjan" <[REDACTED]> + +**Subject:** JPMorgan Chase Production + +**Date:** Tue, 03 Mar 2020 23:25:23 +0000 + +**Attachments:** 2020-03-02\_SDNY\_Letter.pdf + +--- + +[REDACTED], + +Attached is a letter on behalf of our client, JPMorgan Chase, which is also being sent via FedEx. The password for the disc is: [REDACTED] + +Please let us know if you have any issues accessing the materials. + +Thank you, +Allison + +**Allison Stoddart | WilmerHale** + +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] + +**Please consider the environment before printing this email.** + +--- + +This email message and any attachments are being sent by Wilmer Cutler Pickering Hale and Dorr LLP, are confidential, and may be privileged. If you are not the intended recipient, please notify us immediately—by replying to this message or by sending an email to [REDACTED]—and destroy all copies of this message and any attachments. Thank you. + +For more information about WilmerHale, please visit us at . \ No newline at end of file diff --git a/marker2/ds9/EFTA00090638/EFTA00090638.metadata.json b/marker2/ds9/EFTA00090638/EFTA00090638.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..a3789420a1343f8791c37cb97f4085db98fda4d2 --- /dev/null +++ b/marker2/ds9/EFTA00090638/EFTA00090638.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090638.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1107, + "elapsed_seconds": 4.99, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 37 + ], + [ + "Text", + 30 + ], + [ + "Line", + 18 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00090638" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00090639/EFTA00090639.md b/marker2/ds9/EFTA00090639/EFTA00090639.md new file mode 100644 index 0000000000000000000000000000000000000000..b7dafe3423f2f1c6b4d264c8e176428914583f13 --- /dev/null +++ b/marker2/ds9/EFTA00090639/EFTA00090639.md @@ -0,0 +1,172 @@ +## FOIA CONFIDENTIAL TREATMENT REQUESTED PURSUANT TO 28 C.F.R. § 16.8 AND 5 U.S.C. § 552 + +By E-mail (Without Enclosures) And by FedEx + +Esq. Assistant United States Attorney One St. Andrew's Plaza New York, New York 10007 + +Anjan Salmi + +•1 (.0 + +Re: August 11, 2019 Grand Jury Subpoenas to JPMorgan Chase Bank. N.A., Chase Bank USA. N.A., and J.P. Morgan Securities LLC; August 16, 2019 and September 3, 2019 Grand Jury Subpoenas to JP Morgan Chase + +Dear Mr. + +In response to the above-referenced subpoenas, on behalf of our client JPMorgan Chase ("JPMorgan" or the "Finn"), we submit the enclosed encrypted disc containing documents bates labeled JPM-SDNY-00003382 through JPM-SDNY-00054724. + +Enclosed at JPM-SDNY-00003382 through JPM-SDNY-00054724 are account statements related to Jeffrey Epstein, Ghislaine Maxwell, and . For your convenience, Appendix A includes a chart identifying the account numbers, account names, and date ranges of account statements by Bates number. The chart is organized by the individual associated with each account. Consistent with our production dated September 25, 2019, accounts listed under the header "JE DM" are associated with Mr. Epstein's overall relationship with the Firm, but Mr. Epstein does not necessarily have control of or access to those accounts. Certain accounts associated with Mr. Epstein and Ms. Maxwell overlap with accounts related to "JE DM," and are identified as such. + +As discussed, we anticipate making further productions on a rolling basis. + +Pursuant to the Freedom of Information Act ("FOIA"), 5 U.S.C. § 552, 28 C.F.R. § 16.8, and any other applicable law, rule, or regulation, Wilmer Cutler Pickering Hale and Don LLP requests on behalf of JPMorgan that confidential treatment be accorded to this letter (Bates numbered JPM-SDNY-CL-005-0001 through JPM-SDNY-CL-005-0009) and the referenced materials (Bates numbered JPM-SDNY-00003382 through JPM-SDNY-00054724 on JPM- + +![]()March 3, 2020Page 2Material has been marked “Confidential Treatment Requested by JPMorgan Chase.” The Confidential Material contains confidential business information concerning JPMorgan. Furthermore, public disclosure of the Confidential Material could reasonably be expected to cause substantial competitive harm to JPMorgan. Accordingly, the Confidential Material is subject to, without limitation, Exemption 4 of the FOIA, 5 U.S.C. § 552(b)(4), and the Trade Secrets Act, 18 U.S.C. § 1905, and will continue to remain exempt from mandatory disclosure even after the conclusion of the Department of Justice’s (“Department”) consideration of this matter. + +We note further that, since the Confidential Material constitutes investigatory records obtained by the Department in connection with a potential law enforcement proceeding, such records are subject, at least at present, to the exemption from mandatory disclosure under Exemption 7(A) of the FOIA, 5 U.S.C. § 552(b)(7)(A).1 Since the documents pertain to the activities of JPMorgan, its employees, and its clients and their employees and agents, and not to the activities of any federal agency, JPMorgan also believes the documents are exempt from disclosure pursuant to Exemption 7(C) of the FOIA, 5 U.S.C. § 552(b)(7)(C).2 + +Should any third person request the opportunity to inspect or copy the Confidential Material pursuant to the FOIA or otherwise, we request on behalf of JPMorgan that the undersigned immediately be notified of such request and be furnished with a copy of all written materials pertaining to such request (including but not limited to the request and any agency determination with respect to such request). JPMorgan expects that it will be given an opportunity to object to such disclosure. And, should the Department be inclined to grant any such request, it is JPMorgan’s expectation that, pursuant to the procedures required by 28 C.F.R. § 16.8, and Exec. Order 12,600, 52 Fed. Reg. 23,781 (1987), we will be given reasonable advance notice of any such decision to enable our client to pursue any remedy that may be available to it.3 In such event, we request that you telephone the undersigned rather than rely upon the United States mail for such notice. If the Department is not satisfied that the submission is exempt from disclosure pursuant to the FOIA, we stand ready to supply further particulars. + +The requests set forth in the preceding paragraphs also apply to any memoranda, notes, recordings, or other writings of any sort whatsoever which are made by, or at the request of, any employee of the Department (or any other government agency) and which (1) incorporate, include, or relate to any of the information contained in the Confidential Material; or (2) refer to any conference, meeting, telephone conversation, or interview between (a) our client’s current or + +*Confidential Treatment Requested by JP Morgan Chase* + +--- + +1 *See, e.g., NLRB v. Robbins Tire & Rubber Co.*, 437 U.S. 214 (1978). + +2 *See Dep’t of Justice v. Reports Comm. For Freedom of Press*, 489 U.S. 749 (1989). + +3 *See, e.g., Chrysler Corp. v. Brown*, 441 U.S. 281 (1979). + +![]()March 3, 2020 + +Page 3 + +former employees, associates, representatives, agents, auditors, or counsel and (b) employees of the Department (or any other government agency). + +This letter is not intended to, and does not, waive any applicable privilege or other legal basis under which information may not be subject to production. + +\* \* \* + +If you have any questions, please do not hesitate to contact me at the above-referenced number. + +Sincerely, + +![]()Anjan Sahni + +Enclosure + +*Confidential Treatment Requested by JP Morgan Chase* + +Page 4 + +Esq. + +## APPENDIX A + +| Account Number Account Name | Date Range | | Bates Range | +|-----------------------------|---------------------|------------|----------------------| +| | 1. Epstein Accounts | | I | +| | 2/28/2013 | 12/31/2013 | JPM-SDNY-00003382 - | +| | | 3/31/2014 | JPM-SDNY-00003490 - | +| | 1/31/2003 | | JPM-SDNY-00005124 | +| | 12/1999 | 12/31/2013 | JPM-SDNY-00005125 - | +| | 10/31/2006 | 12/31/2013 | JPM-SDNY-00007691 - | +| JPMorgan Card | 12/2012 | 8/2014 | JPM-SDNY-00008692 - | +| Air Ghislaine Inc | 5/31/2007 | 1/31/2013 | JPM-SDNY-00008764 - | +| | 3/29/2013 | 12/31/2013 | JPM-SDNY-00009263 - | +| | 3/29/2013 | 12/31/2013 | JPM-SDNY-000 10200 - | +| LLC | 8/31/2013 | 3/31/2014 | JPM-SDNY-000 17330 - | +| Hyperion Air, Inc. | 3/21/2013 | 7/31/2013 | JPM-SDNY-00017410 - | +| JEEPERS, Inc. | 2/28/2013 | 11/30/2013 | JPM-SDNY-00018113 - | + +Esq. + +March 3, 2020 + +Page 5 + +| JEGE INC | 7/31/2013 | 3/31/2014 | JPM-SDNY-00018847 - | +|----------------|------------|------------|----------------------| +| JEGE LLC | 2/28/2013 | 12/31/2013 | JPM-SDNY-000 19557 - | +| Mort Inc. | 2/28/2013 | 3/31/2014 | JPM-SDNY-00019641 - | +| Neptune LLC | 9/29/2006 | 1/31/2013 | JPM-SDNY-00019781 - | +| NES, LLC | 4/30/2010 | 12/31/2013 | JPM-SDNY-00020041 - | +| Plan D Inc | 5/31/2011 | 1/31/2014 | JPM-SDNY-00022797 - | +| Plan D LLC | 4/30/2010 | 12/31/2013 | JPM-SDNY-00023152 - | +| Financial, LLC | 12/31/2001 | 1/31/2013 | JPM-SDNY-00023232 - | +| | 5/31/2007 | 1/31/2013 | JPM-SDNY-00023308 - | +| | 3/29/2013 | 12/31/2013 | JPM-SDNY-00023734 - | +| Company, Inc | 3/29/2013 | 12/31/2013 | JPM-SDNY-00023854 - | +| | 8/31/2013 | 3/31/2014 | JPM-SDNY-00024072 - | +| | 3/21/2013 | 7/31/2013 | JPM-SDNY-00024532 - | +| | 2/28/2013 | 11/30/2013 | JPM-SDNY-00024596 - | + +Page 6 + +Esq. + +| FDN INC | 7/31/2013 | 3/31/2014 | JPM-SDNY-00024752 - | +|-------------|------------|------------|---------------------| +| Checking | 2/28/2013 | 12/31/2013 | JPM-SDNY-00025414 - | +| | 2/28/2013 | 3/31/2014 | JPM-SDNY-00026190 - | +| Savings | 9/29/2006 | 1/31/2013 | JPM-SDNY-00027076 - | +| Zorro Trust | 4/30/2010 | 12/31/2013 | JPM-SDNY-00027848 | +| | 4/30/2003 | 3/31/2014 | JPM-SDNY-00028370 - | +| | 10/31/2008 | 12/31/2013 | JPM-SDNY-00028684 - | +| | 2/28/2010 | 12/31/2013 | JPM-SDNY-00029204 - | +| | 2/27/2009 | 12/31/2013 | JPM-SDNY-00029554 - | +| | 3/31/2009 | 12/31/2013 | JPM-SDNY-00029898 - | +| | 5/31/2002 | 7/31/2013 | JPM-SDNY-00036857 - | + +Page 7 + +Esq. + +| Financial Trust | | | | +|---------------------------------------------------------------|------------|-----------------------------------------|----------------------------------------| +| Company, Inc. - Morgan Guaranty Trust Company | 8/31/1999 | 7/31/2013 | JPM-SDNY-00039475 - JPM-SDNY-00039826 | +| Inc HBRK Associates | 10/31/2008 | 12/31/2013 | JPM-SDNY-00039827 - JPM-SDNY-00040048 | +| Lyn & JOJO LLC Southern Trust | 4/28/2006 | 10/31/2013 | JPM-SDNY-00040049 - JPM-SDNY-00041313 | +| Company, Inc - Derivatives Account The 2007 Jeffrey E Epstein | 7/31/2013 | 12/31/2013 | JPM-SDNY-00041314 - JPM-SDNY-00041361 | +| Insurance Trust #3 DTD 11/01/2007 The Jeffrey E | 11/28/2008 | 12/31/2013 | JPM-SDNY-00041362 - JPM-SDNY-00041639 | +| Epstein Insurance Trust #1 DTD 11/01/2007 The Jeffrey E | 11/28/2008 | 1/31/2013 | JPM-SDNY-00041640 - JPM-SDNY-00041843 | +| Epstein Insurance Trust #2 DTD 11/01/2007 | 11/28/2008 | 1/31/2013 4. "JE DM" & Maxwell Accounts | JPM-SDNY-00041844 - JPM-SDNY-0004205 1 | +| Max Foundation | 9/30/2009 | 5/30/2014 | JPM-SDNY-00042052 - JPM-SDNY-00043105 | +| ST LLC 116 EAST 65TH | 10/2006 | 4/30/2014 | JPM-SDNY-00043106 - JPM-SDNY-00044447 | +| Ellmax | 9/30/2011 | 4/30/2014 | JPM-SDNY-00044448 - JPM-SDNY-00044667 | +| Pot and Kettle | 9/30/2011 | 4/30/2014 | JPM-SDNY-00044668 - JPM-SDNY-00044879 | +| Project, Inc. Terra Mar | 4/30/2012 | 4/30/2014 | JPM-SDNY-00044880 - JPM-SDNY-00045131 | + +Page 8 + +Esq. + +| Terra Mar | | | +|--------------------------------------------------------------------------|---------------------|---------------------------------------| +| 4/30/2012 Project, Inc. - Savings Account | 4/30/2014 | JPM-SDNY-00045132 - JPM-SDNY-00045259 | +| U Ghislaine | 5. Maxwell Accounts | | +| 1/31/2013 Maxwell - OAP IHD, TAP DYS, TAP ARFI Ghislaine | 6/30/2014 | JPM-SDNY-00045260 - JPM-SDNY-00046933 | +| 2/28/2005 Maxwell - Asset Account Portfolio | 5/31/2014 | JPM-SDNY-00046934 - JPM-SDNY-00049525 | +| Maxwell - HY 10/2/2019 Ghislaine Ghislaine | 4/30/2014 | JPM-SDNY-00049526 - JPM-SDNY-00050097 | +| 7/31/2011 Maxwell - OAP FDG | 3/31/2014 | JPM-SDNY-00050098 - JPM-SDNY-00050891 | +| Maxwell IRA 5/31/2008 Ghislaine Ghislaine Maxwell | 3/31/2014 | JPM-SDNY-00050892 - JPM-SDNY-00051717 | +| 9/30/2009 JPMorgan Chase Bank, N.A. Money Mark Deposit Account Ghislaine | 4/30/2014 | JPM-SDNY-00051718 - JPM-SDNY-00051941 | +| 3/31/2003 Maxwell Premier Checking Chase Business | 4/30/2014 | JPM-SDNY-00051942 - JPM-SDNY-00052759 | +| 5/2011 Custom Checking Max Hotel Services Corp | 4/2014 | JPM-SDNY-00052760 - JPM-SDNY-00052901 | +| 6. | Accounts | | + +Esq. + +March 3, 2020 + +Page 9 + +|

    Cunningham State Department

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The only wrinkle, which unfortunately is completely beyond our control, is that there is now some talk of government international travel being prevented due to the coronavirus situation, but we'll talk to the relevant people here immediately. + +One thing that would be extremely helpful for us in the near-term, including in terms of getting approvals here — and we talked about this on the phone as well — would be to get an attorney proffer about your understanding of generally what information you expect your client will convey on the subjects we've spoken about? We completely understand that it's best to have her tell her story directly to us, but in terms of our preparation it's often very useful for both us and the witness for us to have had a conversation with counsel in the first instance. Would it be possible to set up a call to have that discussion? We could do as soon as tomorrow or Friday, or also next week. + +Thanks very much, + +From: Jill Greenfield .c: > + +Sent: Wednesday, March 04, 2020 11:46 + +To: + +Cc: Louise Scott 4 2° + +Subject: RE: Epstein investigation [FFW-DOCS.FID6003375] + +Hi + +There is the possibility of a meeting on the 19th March if you are able to come to London. Could you let me know please? + +Kind regards + +Jill + +Jill Greenfield + +Partner + +D: + +Personal Injury Team of the Year - Solicitors Journal Awards 2017 + +Sent: Tuesday, March 3, 2020 11:17 PM + +To: Jill Greenfield + +Cc: Kyle Phillips O; Louise Scott c + +Subject: RE: Epstein investigation + +te + +We wanted to quickly follow up since I think you and I last spoke a little over a week ago—understand if you are still discussing with your client, just wanted to check in, and we're happy to provide any additional information that might be useful, as always. + +thank you, + +From: Jill Greenfield + +Sent: Saturday, February 22, 2020 17:09 + +To: + +Cc: Kyle Phillips Louise Scott <= > + +> + +Subject: Re: Epstein investigation + +Thanks M. + +Understood + +I will call tomorrow + +Regards + +Jill Greenfield + +Partner + +0: M. IMM + +Personal Injury Team of the Year - Solicitors Journal Awards 2017 + +Sent from my iPhone + +On 22 Feb 2020, at 21:51, > wrote: + +Jill, + +No problem at all, we understand this takes time, and we appreciate you getting back to us, and we're very grateful that your client is open to speaking with us. + +On your questions, we are certainly fine with the first two questions / requests — we're happy to meet with you and your client in an initial conversation, during which we can do the kind of introductions and explanations we've done with you + +(and that we do with all victim witnesses we meet), including answering any questions to the best of our ability, and then to take a break and have a more substantive discussion later on. + +Regarding the friend, does that individual also represent her as counsel? We aren't normally able to include individuals in addition to the witness and counsel in an interview—what does sometimes work is for someone who is providing support (a parent, friend, etc.) to be close by for any discussions, assistance, etc. anytime that a witness wants to speak with that person, which would of course be totally fine in this instance. Or if he represents her in his capacity as an attorney then he of course could be in the interview in that role (with the only caveat that we would just want to confirm that he himself is not separately a witness of some sort in the case). We unfortunately are not able to pay for third parties (including counsel) to travel in connection with witness interviews, though — if it's preferable, we certainly could pay for your client's travel to the U.S. for the interview, including airfare and lodging, if that makes it easier for the friend to be present? And we're happy to discuss any of this further by email or phone if that's useful — I'll be at my desk for the next several hours and most of tomorrow, at or we could also set a time to chat, whatever would be helpful. + +thank you, + +IM• + +From: Jill Greenfield < + +Sent: Saturday, February 22, 2020 13:55 + +To: > + +Cc: Kyle Phillips ) 4 sca ; Louise Scott + +Subject: RE: Epstein investigation + +Hello MI + +Apologies for the slight delay. My client is willing to help but asks the following: + +- That there be a morning meeting at which introductions with a discussion as to the investigation and my clients involvement. I appreciate that you have explained this to me but I think further verbal clarification would assist. +- In the afternoon and after a break, my client would be willing to answer questions, in so far as she can. +- That a friend of hers be allowed to be present as well. However that friend is based in the US and would need to be flown over to London. He is a US lawyer. + +Perhaps you could let me know if this is possible? + +Kind regards, + +Jill + +Jill Greenfield + +Partner + +D: M: + +Personal Injury Team of the Year - Solicitors Journal Awards 2017 + +imanc001.jpod + +Cc: Kyle Phillips <[REDACTED]>; Louise Scott <[REDACTED]>; [REDACTED] +[REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> + +**Subject:** RE: Epstein investigation + +Understood – thanks very much. + +[REDACTED]. + +--- + +**From:** Jill Greenfield <[REDACTED]> + +**Sent:** Saturday, February 15, 2020 07:22 + +**To:** [REDACTED] <[REDACTED]> + +Cc: Kyle Phillips <[REDACTED]>; Louise Scott <[REDACTED]>; [REDACTED] +[REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]> + +**Subject:** Re: Epstein investigation + +Thanks [REDACTED] + +This is helpful. I've gone back to my client with this. I will be back in touch shortly. + +Regards + +Jill + +**Jill Greenfield** + +Partner + +D: [REDACTED] + +M: [REDACTED] + +[Personal Injury Team of the Year - Solicitors Journal Awards 2017](#) + +[](#) + +Sent from my iPhone + +On 14 Feb 2020, at 21:43, [REDACTED] <[REDACTED]> wrote: + +Jill, + +Following up on our phone call, thank you for talking with us again, and we wanted to get back to you regarding some of the additional follow-up questions you asked, and to describe in more detail for your client how we would expect to approach any discussion with your client if she were comfortable meeting with us. + +The absolute most important thing is that any discussion would be entirely voluntary, and by that we mean the decision to meet with us but also as to any topic or question—your client would be absolutely free to determine what topics she felt comfortable discussing. There is absolutely no pressure on victim witnesses to address anything that would make them uncomfortable at any time, and even if your client was willing to meet with us, we would tell her, as we do for any witness, that if any topic comes up that she wants to skip, or discuss with you privately, that is no problem at all. + +In fact, if you and she would prefer, we would be happy to have a meeting where we simply introduced ourselves, explained the status of our investigation, talked about how a discussion would proceed if your client ended up being comfortable with that, and answered in person any questions she. We have done that previously, where we do the + +talking rather than asking questions in an initial meeting, and that would of course be without any requirement for anything additional if she preferred not to. As I mentioned on the phone, we have consistently found that we are able to reassure individuals when we have the opportunity to meet in person so they can see directly our interest in approaching these discussions with great sensitivity and care. As I also mentioned on the phone, even if your client were willing to speak with us, there would be absolutely no need or requirement for her to talk about any assault or victimization she experienced. We wrote in our first email that we would primarily be interested in talking about topics such as the general scope of her employment, directions she received from Epstein or Maxwell, etc., and as always we would be guided by her comfort level. + +In terms of who would attend a meeting, we almost always work in pairs, so two prosecutors and two officers, and that's not to have extra people, but rather because it helps us to be as efficient as we can, and so witnesses can meet the people on the team. Our team is also majority female, and we always tell witnesses that if topics come up in a discussion that they would prefer to speak about just with women, that's fine and we can be flexible in the moment and are always guided by the comfort level of the victim. But I also want to stress that in terms of your client in particular, we don't expect to initially address issues of a very personal or sexual nature, and we certainly would tell you in advance if there came a time when we thought that might be important to address, and how we could facilitate that. Who exactly from our team would be at any meeting would depend on schedules, but we can assure you that every one of us has now spoken with dozens of victims in this case, and every one of us has extensive experience more generally working with victims and working on cases involving sex offenses. We are proud of how we have been able to work with victims in this case especially, given all of the circumstances, and we absolutely would take the same sensitive approach with your client as we have with the many other victims in this case who have spoken with us. + +Again, if it would be helpful even for us to just come to the U.K. and introduce ourselves and explain in person how our process works, and answer any questions your client has in person, we would absolutely be happy to do that with no obligation at all from her. We also could do that with the possibility that if she felt comfortable, we could just address the general subject of her employment, for example. But no obligation and no pressure. We continue to appreciate your and her willingness to even broach the possibility of a discussion, and we hope this is helpful. + +thank you very much, + +Assistant U.S. Attorney Southern District of New York + +From: + +Sent: Saturday, February 08, 2020 14:25 + +To: Jill Greenfield + +Cc: Kyle Phillips O; Louise Scott + +Subject: RE: Epstein investigation + +Jill, + +Thanks for circling back, and we'll do our best to answer these questions. In terms of who would be in the room, the most likely answer is that it would be two of the prosecutors and the two law enforcement officers on the case. The only reason I saw "most likely" rather than having a definitive answer is that when we're interviewing in a foreign country, it sometimes is the case the local law enforcement also insists on having representatives present. I don't believe that's required in the U.K., but we can check on it and give you a definitive answer in the coming days if that's useful. (Also, if she preferred to be interviewed in the U.S., we certainly could guarantee that the room would be just the case team, and we could arrange for travel and lodging for her. Let us know if that's the case, but otherwise we're of course happy to travel to her.) + +Regarding access to notes, it would principally be the investigative team—so again, the prosecutors and the FBI team working on the case. Our respective supervisors also theoretically have access to our files, but the reports are not generally widely disseminated. The basic logistics are that an agent takes notes during an interview, and then types up those notes into a formal report (called an FBI Form 302). We don't ordinarily share notes with other entities, but I can also check on that to see if I can make a more specific representation with respect to your client. + +With respect to anonymity, I confess that I'm not familiar with the distinction you're referring to. In terms of our investigation, we don't publicly disclose the names of individuals we meet with, and we don't disclose to any other witnesses, for example, the identities of victims or witnesses we are meeting with. (And our policies on that don't change even for individuals who are in the position of your client, who have been widely publicly reported to have been connected to Epstein and/or his employees or associates). But if that doesn't answer your question, we're of course happy to discuss further. Let me know if it might be useful to have a call? Or if not, also happy to address any follow-up via email. + +thanks, + +From: Jill Greenfield + +Sent: Saturday, February 08, 2020 13:17 + +To: + +Cc: Kyle Phillips ) < >; ; Louise Scott + +Subject: Re: Epstein investigation + +Hi MI + +Thanks for this. I've been asked who would be in the room and thereafter who would have access to any notes made. Would her permission be sought before disclosing to any other parties or officials? + +As you know there is a real difficulty in relation to her anonymity in the US versus the UK. Are you able to provide any comfort on this? + +Many thanks + +Jill + +Jill Greenfield + +Partner + +D: + +M: + +Personal Injury Team of the Year - Solicitors Journal Awards 2017 + +kimage001. jpgd + +Sent from my iPhone + +On 6 Feb 2020, at 21:53, ) > wrote: + +Thank you again for speaking with us earlier today regarding our interest in talking with your client in connection with our investigation into the conduct of Jeffrey Epstein. + +As requested, we wanted to briefly memorialize our current views and understandings of your client, and also to reiterate our interest in approaching any discussion with great care and sensitivity, particularly to avoid adding to her trauma or causing re-victimization. + +As we mentioned on the • hone our client + +we discussed, our knowledge of your client specifically is somewhat limited, having never spo en o er—an • therefore knowing about her only through other witnesses and records—but it certainly has been our experience that the overwhelming majority of young women and girls who were in the orbit of Jeffrey Epstein during the relevant periods were subject to his abuse. It does not surprise us, nor do we have any trouble believing, that your client was similarly a victim. I hope that is helpful in understanding the capacity in which we hope to speak with her. + +Separately, and as we also discussed, any discussion with our team would be entirely voluntary—and that extends not just to whether she would be willing to meet with us at all, but also including her ability to decline to discuss particular topics or even particular questions, and to talk with her counsel at any time, to take any breaks that would be beneficial while we're meeting, etc. + +In terms of topic areas, we would be hoping to learn about the general narrative of her interactions with Epstein and his other associates and employees, including Ghislaine Maxwell, whom we understand she may have worked directly for. That would broadly include how she came to be in contact with them, the nature and scope of her employment, any instructions she was given relating to other women or girls, and just generally her experiences and observations in interacting with them. We ordinarily would also be interested in understanding the general nature of the abuse she was subjected to, but I want to emphasize that we would not need to discuss with her the specifics if she weren't comfortable with that, and in particular we often don't even broach that subject in a first meeting. + +Please let us know if you have any additional questions, and in particular whether any other information from us would be useful, and we look forward to speaking with you again soon. + +Regards, + +Assistant U.S. Attorney Southern District of New York + +Fieldfisher, Riverbank House, 2 Swan Lane, London EC4R 3TT. + +www.fieldfisher.com + +We do not intend to change our bank details. If you receive any communication that any of our bank details have changed, telephone us and speak to your contact at our office before transferring any funds. We do not accept responsibility for monies paid into a wrong bank account in any circumstances. + +This email and any attachments are confidential and may also be privileged. If you receive this message in error, please contact the sender immediately, destroy the email and any attachments and do not use, copy, store or disclose this email and any attachments for any purpose. Fieldfisher does not accept service of documents by electronic means without express prior agreement. + +For details about what personal information we collect and why, please see our Privacy Notice on our website at www.fieldfisher.com. + +Fieldfisher is the trading name of Fieldfisher LLP. a limited liability partnership registered in England and Wales (registered number 0C31 &f72) and is authorised and regulated by the Solicitor? Regulation Authority. A list of its members and their professional qualifications is mailable at its registered office, Riverbank House. 2 Swan Lane. London EC4R 311'. 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Maxwell - [conferral re photo and other discovery deficiencies] + +Date: Mon, 24 May 2021 11:58:50 +0000 + +Inline-Images: image001.prig; image002.png + +Just as an FYI, I've looked at our files and we do not have for the files listed in the "overlay", we have no matching MD5s. The MD5s from the non-nude index are correct, but not the overlay ones. + +I'm around if anyone wants to chat. + +Special Agent FBI - New York Office Child Exploitation and Human Trafficking Task Force + +From: I c > + +Sent: Thursday, May 20, 2021 8:22 PM + +To: Nicole (NY) (FBI) < >; (USANYS) [Contractor] < II> I. (NY) (FBI) + +Cc: (USANYS) Sa; + +Subject: [EXTERNAL EMAIL] - FW: US v. Maxwell - [conferral re photo and other discovery deficiencies] + +Hi all, + +Please see below from Maxwell's attorneys regarding the images produced from the CDs seized from Epstein's residence, which was the PROD011 production from PAE. Can we please have a call to discuss? + +Thanks, + +From: Laura Menninger + +Sent: Thursday, May 20, : + +To: < >; (USANYS) + +Cc: Jeff Pagliu Bobbi Sternheim + +Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies] + +Thank you for your explanation. I also have gone back to our IT department and, unfortunately, your FBI/vendor explanation is insufficient. + +- Based on our review, which has been double-checked, there are hash values in the overlay that don't match the index and visaversa. +- The snips below show an example of an entry from the overlay file you provided (with file names and MD5 Hash) which did not join to the non-nude index. We were able to find the corresponding file in the index using the file name, which in this particular + +| ProdBegBates File Name | MD5 Hash | +|----------------------------------------------|----------------------------------| +| SDNY_GM_00503260 Jeffrey VF2.psd | DA920F87819FCC13F38E0584D8D77DFB | +| SDNY GM 00506551 LSJ librarywindow150dpi.tif | 58ACSC8E826591AEFD0604ABA2262720 | + +## From non-nude index + +| File Name | SHA-1 | MD5 | +|-------------------------------|------------------------------------------|----------------------------------| +| 1 LJJ librarywindow150dpi.tif | 043670EDF17D35EE5794EBDF094AEF63A95D4B9A | BDEB66247E99D1C9EED2BA30FB8F7D2S | + +- More importantly, if as you report you did not deduplicate the production and if the index you produced is accurate, we should be able to match files based on the combination of File Name and MD5 hash. The hash + file name combination might not be unique, but each hash+file name value in the index should have a corresponding entry in the overlay unless hash values and/or file names were modified somewhere in the process. +- As previously reported, if we require a match on the hash value and ignore file names, there are 65 production numbers that don't match the index. +- There are more entries in SDNY011 (40,567) than entries on the non-nude index (40,536). We cannot understand the discrepancy based on your explanation. + +My earlier requests - a new copy of the non-nude index with an added column to note the production number of each file and a new index for the produced files that were not included in the prior index — still stand. + +Thank you, + +Laura + +Laura A. Menninger I Partner I laddon, Morgan & Foreman, P.C. 150 . 10th Avenue - Denver. CO 80203 + +From: + +Sent: Tuesday, May 11, 2021 9.15 PM + +To: Laura Menninger (USANYS) + +Cc: Jeff Pa 'Bobbi Sternheim + +Subject: RE: US v. Maxwell - (conferral re photo and other discovery deficiencies] + +Laura, + +I have consulted with the FBI and our vendor regarding the issues you raised with the overlay. Below is what I understand from them: + +- When using the overlay, you should require only a match of the hash value. +- When our vendor uses the overlay, they do not see any production numbers that do not have a match in the index. If you are still seeing outliers, please let us know which files are not matching up with the index, and our vendor will look into what that issue could be. +- The 17 files with no hash values were either incomplete files or corrupt files when they were recovered from the CDs. We produced them to you so that you would have a copy of every file on the CDs that did not have identifiable nudity. +- Any non-unique hash values are duplicate files. There were many duplicate files on the CDs. The FBI and vendor did not deduplicate the images before producing them in an effort to ensure that you had a complete set of all files recovered from the CDs. +- There are a number of files that were recovered from the CDs but are unopenable on our end. We produced them to you so that you would have a copy of every file on the CDs that did not have identifiable nudity. If you would like to check to see if any particular files are unopenable on our end, we would be happy to check. + +Given the above, the FBI and the vendor believe the overlay previously provided should be sufficient to allow you to review the metadata in this production. + +Assistant United States Attorney Southern District of New York I St. Plaza New York, NY 10007 + +From: Laura Menninger + +Sent: Wednesday, April 28, 2021 1:18 PM + +To: < >; (USANYS) + +Cc: Jeff Pagliuca obbi Sternheim + +Subject: FW: US v. Maxwell - [conferral re photo and other discovery deficiencies] + +Thank you for sending the overlay. After review, it unfortunately does not appear sufficient to allow us to properly match the metadata to your production of native files. + +Based on your representations, the "Non-Nude index" located at Bates 467567 in Excel should match the Bates number native images produced at SDNY011. However: + +- The number of entries in the Non-Nude Index is less than the number of files produced. +- Although the overlay file has 40,567 entries (the same number of files in SDNY011), they don't match up to the Non-Nude Index. o When joining the overlay file to the index: If we require a matching value for both MD5 hash and file name, there are 24,757 entries in the overlay that do not match the index. If we require a match on the hash value and ignore file names, there are 65 production numbers that don't match the index; 17 of those don't have hash values at all. +- The overlay has many non-unique hash values, meaning we cannot rely on hash value alone. +- The Non-Nude index also has many non-unique hash values. + +I think the only feasible resolution is for you to provide a new copy of the non-nude index with an added column to note the production number of each file. We also need a new index for the produced files that were not included in the prior index. + +Let me know if you will agree to produce these two new indices. + +Thank you, + +Laura + +Laura A. Henninger I Partner + +Iladdon, Morgan & Foreman, P.C. + +CO 80203 + +From: + +Sent: Tuesday, April 27, 20219:35 PM + +To: Laura Menninge + +Cc: ; Jeff Pagliuca IIIIIIIIIIIIIIIIIII;.Bobbi Sternheird . . . - nferral re photo and other discovery deficiencies] + +Laura, + +Attached please find a metadata overlay for the production of images from the CDs recovered from Epstein's residence. This file contains the file name and the MDF Hash for each file, which corresponds with the information contained in the SDNY\_GM\_00467567 Spreadsheet. This overlay should allow your team to see which row of metadata corresponds with which Bates number in the production. + +Best, + +Assistant United States Attorney Southern District of New York I St. Plaza New York, NY 10007 + +From: Sent: Friday, April 23, 2021 1:44 PM To: Laura Menninger Cc: (USANYS) >; ) c e; I 'Bobbi Sternhei Subject: RE: US v. axwe - con errs re p o o an o erdiscovery e ciencies + +Laura, + +Our vendor has explained the issue with SDNY\_GM\_00467566. That file is a temporary file without content. The file that contains the content is SDNY\_GM\_00467567. + +Best, + +Assistant United States Attorney Southern District of New York I St. Plaza New York, NY 10007 + +From: Sent: Friday, April 23, 2021 12:13 PM To: Laura Menninge Cc: (USANYS) Jeff Pagliuca 'Bobbi Sternheim Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies] + +- I have asked our vendor to look into the issues with SDNY\_GM\_00467566. When I attempt to access that document on our Relativity database, I also receive an error message saying that the document is corrupt. I am not sure what this spreadsheet is because the only two spreadsheets that I'm aware of that correspond with the SDNY\_PROD011 contained in the November 9, 2020 production are the two other Excel spreadsheets you referenced. In any event, I am looking into the issue. +- I am similarly working with our vendor to understand how to best identify for you which Bates number corresponds with the metadata in the index contained in the Excel spreadsheets. Can you please provide me with a list of the photos that you are unable to view? Once I have that list, I will check to see whether we are able to open them on our end. +- Can you be more specific in identifying photographs that you believe should have been produced but have been omitted, please? We have endeavored with the FBI to produce copies of all non-nude photographs recovered from searches of Epstein's residence to the defense, and I am not aware of any intentional omissions. +- I am discussing with the FBI your request that we produce all Highly Confidential images to you. I will respond to that request next week. +- Once we have a firm trial date, I will let you know by what date I expect to be able to provide you with a list of the Highly Confidential photographs we may introduce at trial. +- I am working with our paralegals to assess the list of files that your client is unable to review at the MDC. As soon as we have finished looking into those issues, I will let you know. + +Best, + +From: Laura Menninge Sent: Wednesday, April 21, 2021 1A2 PM + +To: + +Cc: + +'Bobbi Sternhe Subject: US v. Maxwell - [conferral re photo and other discovery deficiencies] + +I'm writing to follow-up on our discussion last Thursday regarding the photo evidence and to address a number of other critical problems with the discovery provided to date. + +Unfortunately, both in the production to defense counsel and on the hard-drive supplied by your office to our client at MDC, there are thousands, if not hundreds of thousands, of photos that are still unreadable. We have spent countless hours, and a chunk of our client's resources, trying to rectify a number of these problems ourselves, to no avail. Our ability, and our client's ability, to review all of the discovery in this case is absolutely critical and is constitutionally guaranteed. Unless you can quickly propose a solution, we believe we need to raise this with the Court. + +- We do not have a functional copy the Excel spreadsheet located at SDNY\_GM00467566. I have confirmed that the original spreadsheet provided to us is corrupt and the vendor and -discovery provider cannot open it. +- The other two Excel spreadsheets from the production (and presumably the one we cannot open) are insufficiently detailed to tell us which photo goes with which meta-data. O The index contains multiple instances of the same "file name" with different hash values. o The index does not match any particular file with a Bates stamp. o The index does not indicate which files were withheld as "highly confidential." + +" Many of the photo files that larg provided in discovery SDNY011) do not have a discernible reader. I cannot open them. Ms. Maxwell does not have a reader on her MDC laptop that can read them. If the government is able to view them, then we should be provided the means to view them as well. " A number of photo files appear to be missing from the MDC laptop and are not highly confidential, based on my review of documents last week. Because we do not have a list of what was/was not produced, however, we cannot confirm. " As you know, the 2 x "highly confidential hard-drives" in NY did not work until Thursday once an appropriate reader was added to the laptop. I did not have enough time to view all of the files. I do not have the reader that you ultimately added to that laptop. The discs that I attempted to view in NY (from various binders) would not load on the government laptop. I was unable to match up disks with potential files on the hard-drives. Because I did not have a functioning Excel spreadsheet, I also was not able to match any highly confidential photos from the hard-drives with the associated metadata. + +I am requesting that you produce to defense counsel replicas of the two hard-drives that you made available for review last week, subject to all of the strictures of the protective order. + +I recognize that you have designated as "highly confidential" photos that you contend contain "nude, partially-nude, or otherwise sexualized images, videos, or other depictions of individuals." Among the photos on the hard-drive that I was able to view, there were a lot of "nude" and "partially-nude" photos of adults, but I did not see anything that would qualify as child pornography under the statute. Some of the photos only showed a woman's back or shoulder. If you have reason to believe that there is child pornography contained on the two hard-drives, then certainly defense counsel is not asking to possess that material; you can designate it as such and we can view it at an acceptable location as occurs in any CP case. + +Otherwise, I think the burden of reviewing adult nudity only in the government's office or courthouse imposes an extraordinary cost on our client and prevents us from analyzing the metadata, having our experts review the file structures, keeps us from preparing photos for use at trial, and generally impedes our defense. + +In a similar vein, can you let me know when you are willing to disclose any photos that you intend to introduce at trial? As to any of those, I will need sufficient information and time to analyze them for foundation and admissibility purposes with an appropriate expert. + +Finally, I am attaching an incomplete list of the documents that our client still cannot read at MDC. It is a small sample, as she has had to spend hours of her "review" time communicating to our staff which files she cannot read. Also, the manner in which the discovery was provided to her (load file format) precludes her from comparing the "image" and the "native" files (they do not, for example, have clearly labeled bates-stamps). + +I would appreciate as prompt a response as you can provide so that we can address any issues with the Court on Friday. + +Thanks, Laura + +Laura A. 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Maxwell - [conferral re photo and other discovery deficiencies] + +Date: Mon, 24 May 2021 13:34:01 +0000 + +Inline-Images: image001.prig; image002.png + +Thanks very much, . Would be great if you're able to join the 11am call. + +From: Sent: Monday, May 24, 2021 7:59 AM To: (USANYS) [Contractor] < I> Cc: (USANYS) NY) (FBI) .• (USANYS) [Contractor] < E> Cc: I 4IIIIIIIIIIIIIIk I. (NY) (FBI) < (USANYS) >; + +Subject: [EXTERNAL EMAIL] - FW: US v. Maxwell - [conferral re photo and other discovery deficiencies] + +Hi all, + +Please see below from Maxwell's attorneys regarding the images produced from the CDs seized from Epstein's residence, which was the PROD011 production from PAE. Can we please have a call to discuss? + +Thanks, + +From: Laura Menninger Sent: Thursday, May 20, To: a>: < >; ) Cc: Jeff Pagliuca (USANYS) Bobbi Sternheim + +Thank you for your explanation. I also have gone back to our IT department and, unfortunately, your FBI/vendor explanation is insufficient. + +- Based on our review, which has been double-checked, there are hash values in the overlay that don't match the index and visaversa. +- The snips below show an example of an entry from the overlay file you provided (with file names and MD5 Hash) which did not join to the non-nude index. We were able to find the corresponding file in the index using the file name, which in this particular instance was unique. As you can see, the MD5 hashes don't match. + +From the overlay file + +| ProdBegBates File Name | MD5 Hash | +|----------------------------------------------|----------------------------------| +| SDNY_GM_00503260 Jeffrey VF2.psd | 0A920F87819FCC13F38E0584080770F6 | +| SDNY_GM 00506551 LSJ librarywindow150dpi.tif | SSAC5C8E826591AEFD0604ABA226272D | + +From non-nude index + +| File Name | SHA-1 | MD5 | +|-------------------------------|------------------------------------------|----------------------------------| +| 1 LSJ librarywindow150dpi.tif | 043670EDF17D35EE5794EBDF094AEF63A95D4B9A | BDEB66247E99D1C9EED2BA30FB8F72D5 | + +- More importantly, if as you report you did not deduplicate the production and if the index you produced is accurate, we should be able to match files based on the combination of File Name and MD5 hash. The hash + file name combination might not be unique, but each hash+file name value in the index should have a corresponding entry in the overlay unless hash values and/or file names were modified somewhere in the process. +- As previously reported, if we require a match on the hash value and ignore file names, there are 65 production numbers that don't match the index. +- There are more entries in SDNY011 (40,567) than entries on the non-nude index (40,536). We cannot understand the discrepancy based on your explanation. + +My earlier requests - a new copy of the non-nude index with an added column to note the production number of each file and a new index for the produced files that were not included in the prior index — still stand. + +Thank you, + +Laura + +Laura A. Henninger I Partner + +Haddon, Morgan & Foreman, P.C. + +150 I. 10th Avenue I Denver, CO 80203 + +From: + +Sent: Tuesday, May 11, 2021 9:15 PM + +To: Laura Menninger <- (USANYS) + +< >; ) 'Bobbi Sternheim + +- con errs repoo an o er discovery deficiencies] + +Laura, + +I have consulted with the FBI and our vendor regarding the issues you raised with the overlay. Below is what I understand from them: + +- When using the overlay, you should require only a match of the hash value. +- When our vendor uses the overlay, they do not see any production numbers that do not have a match in the index. If you are still seeing outliers, please let us know which files are not matching up with the index, and our vendor will look into what that issue could be. + +- The 17 files with no hash values were either incomplete files or corrupt files when they were recovered from the CDs. We produced them to you so that you would have a copy of every file on the CDs that did not have identifiable nudity. +- Any non-unique hash values are duplicate files. There were many duplicate files on the CDs. The FBI and vendor did not deduplicate the images before producing them in an effort to ensure that you had a complete set of all files recovered from the CDs. +- There are a number of files that were recovered from the CDs but are unopenable on our end. We produced them to you so that you would have a copy of every file on the CDs that did not have identifiable nudity. If you would like to check to see if any particular files are unopenable on our end, we would be happy to check. + +Given the above, the FBI and the vendor believe the overlay previously provided should be sufficient to allow you to review the metadata in this production. + +Best, + +Assistant United States Attorney Southern District of New York I St. Plaza New York, NY 10007 + +From: Laura Menninge Sent: Wednesday, April 28, 2021 1:18 PM To: (USANYS) Cc: Jeff Pa liuca 'Bobbi Sternheim u je : : v. axwe - con errs rep o o an o her discovery deficiencies] + +Thank you for sending the overlay. After review, it unfortunately does not appear sufficient to allow us to properly match the metadata to your production of native files. + +Based on your representations, the "Non-Nude index" located at Bates 467567 in Excel should match the Bates number native images produced at SDNY011. However: + +- The number of entries in the Non-Nude Index is less than the number of files produced. +- Although the overlay file has 40,567 entries (the same number of files in SDNY011), they don't match up to the Non-Nude Index. o When joining the overlay file to the index: If we require a matching value for both MD5 hash and file name, there are 24,757 entries in the overlay that do not match the index. If we require a match on the hash value and ignore file names, there are 65 production numbers that don't match the index; 17 of those don't have hash values at all. +- The overlay has many non-unique hash values, meaning we cannot rely on hash value alone. +- The Non-Nude index also has many non-unique hash values. + +I think the only feasible resolution is for you to provide a new copy of the non-nude index with an added column to note the production number of each file. We also need a new index for the produced files that were not included in the prior index. + +Let me know if you will agree to produce these two new indices. + +From: I + +Sent: Tuesday, April 27 20219:35 PM + +To: Laura Menninger + +Cc: < =a; + +;Jeff Pagliuc + +lanlacdoiSternhei + +Subject: RE: US v. Maxwell - [conferral re photo an of erdiscovery e iciencies + +Laura, + +Attached please find a metadata overlay for the production of images from the CDs recovered from Epstein's residence. This file contains the file name and the MDF Hash for each file, which corresponds with the information contained in the SDNY\_GM\_00467567 Spreadsheet. This overlay should allow your team to see which row of metadata corresponds with which Bates number in the production. + +Best, + +Assistant United States Attorney Southern District of New York I St. Plaza New York. NY 10007 + +From: + +Sent: Friday, April 23, 2021 1:44 PM + +To: Laura Menning4 + +Cc: (USANYS) + +; Jeff Pagliu + +'Bobbi Sternhei + +Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies) + +Laura, + +Our vendor has explained the issue with SDNY\_GM\_00467566. That file is a temporary file without content. The file that contains the content is SDNY\_GM\_00467567. + +Best, + +Assistant United States Attorney Southern District of New York I St. Plaza New York, NY 10007 + +Sent: Friday, April 23, 2021 12:13 PM + +To: Laura Menninger + +Cc: (USANYS) + +< E>; Jeff Pagliuca + +'Bobbi Sternheim + +Subject: RE: US v. Maxwell - (conferral re photo and other discovery deficiencies) + +Laura, + +I am working with our team as quickly as we can to address the issues you raised in the below email. In particular: + +- I have asked our vendor to look into the issues with SDNY\_GM\_00467566. When I attempt to access that document on our Relativity database, I also receive an error message saying that the document is corrupt. I am not sure what this spreadsheet is because the only two spreadsheets that I'm aware of that correspond with the SDNY\_PROD011 contained in the November 9, 2020 production are the two other Excel spreadsheets you referenced. In any event, I am looking into the issue. I am similarly working with our vendor to understand how to best identify for you which Bates number corresponds with the metadata in the index contained in the Excel spreadsheets. +- Can you please provide me with a list of the photos that you are unable to view? Once I have that list, I will check to see whether we are able to open them on our end. +- Can you be more specific in identifying photographs that you believe should have been produced but have been omitted, please? We have endeavored with the FBI to produce copies of all non-nude photographs recovered from searches of Epstein's residence to the defense, and I am not aware of any intentional omissions. +- I am discussing with the FBI your request that we produce all Highly Confidential images to you. I will respond to that request next week. Once we have a firm trial date, I will let you know by what date I expect to be able to provide you with a list of the Highly Confidential photographs we may introduce at trial. I am working with our paralegals to assess the list of files that your client is unable to review at the MDC. As soon as we have finished looking into those issues, I will let you know. + +Best, + +From: Laura Menninge + +Sent: Wednesday, April 21, 20211:42 PM + +To: mc > Cc: (USANYS) + +• Jeff Pa liuca + +'Bobbi Sternhei + +Subject: US v. axwe - con errs re p o o an o erdiscovery e iciencies] + +I'm writing to follow-up on our discussion last Thursday regarding the photo evidence and to address a number of other critical problems with the discovery provided to date. + +Unfortunately, both in the production to defense counsel and on the hard-drive supplied by your office to our client at MDC, there are thousands, if not hundreds of thousands, of photos that are still unreadable. We have spent countless hours, and a chunk of our client's resources, trying to rectify a number of these problems ourselves, to no avail. Our ability, and our client's ability, to review all of the discovery in this case is absolutely critical and is constitutionally guaranteed. Unless you can quickly propose a solution, we believe we need to raise this with the Court. + +- We do not have a functional copy the Excel spreadsheet located at SDNY\_GM\_00467566. I have confirmed that the original spreadsheet provided to us is corrupt and the vendor and discovery provider cannot open it. The other two Excel spreadsheets from the production (and presumably the one we cannot open) are insufficiently detailed to tell us which photo goes with which meta-data. o The index contains multiple instances of the same "file name" with different hash values. o The index does not match any particular file with a Bates stamp. o The index does not indicate which files were withheld as "highly confidential." +- Many of the photo files that were provided in discovery (M., SDNY011) do not have a discernible reader. I cannot open them. Ms. Maxwell does not have a reader on her MDC laptop that can read them. If the government is able to view them, then we should be provided the means to view them as well. A number of photo files appear to be missing from the MDC laptop and are not highly confidential, based on my review of documents last week. Because we do not have a list of what was/was not produced, however, we cannot confirm. As you know, the 2 x "highly confidential hard-drives" in NY did not work until Thursday once an appropriate reader was added to the laptop. I did not have enough time to view all of the files. I do not have the reader that you ultimately added to that laptop. +- The discs that I attempted to view in NY (from various binders) would not load on the government laptop. I was unable to match up disks with potential files on the hard-drives. Because I did not have a functioning Excel spreadsheet, I also was not able to match any highly confidential photos from the hard-drives with the associated metadata. + +I am requesting that you produce to defense counsel replicas of the two hard-drives that you made available for review last week, subject to all of the strictures of the protective order. + +I recognize that you have designated as "highly confidential" photos that you contend contain "nude, partially-nude, or otherwise sexualized images, videos, or other depictions of individuals." Among the photos on the hard-drive that I was able to view, there were a lot of "nude" and "partially-nude" photos of adults, but I did not see anything that would qualify as child pornography under the statute. Some of the photos only showed a woman's back or shoulder. If you have reason to believe that there is child pornography contained on the two hard-drives, then certainly defense counsel is not asking to possess that material; you can designate it as such and we can view it at an acceptable location as occurs in any CP case. + +Otherwise, I think the burden of reviewing adult nudity only in the government's office or courthouse imposes an extraordinary cost on our client and prevents us from analyzing the metadata, having our experts review the file structures, keeps us from preparing photos for use at trial, and generally impedes our defense. + +In a similar vein, can you let me know when you are willing to disclose any photos that you intend to introduce at trial? As to any of those, I will need sufficient information and time to analyze them for foundation and admissibility purposes with an appropriate expert. + +Finally, I am attaching an incomplete list of the documents that our client still cannot read at MDC. It is a small sample, as she has had to spend hours of her "review" time communicating to our staff which files she cannot read. Also, the manner in which the discovery was provided to her (load file format) precludes her from comparing the "image" and the "native" files (they do not, for example, have clearly labeled bates-stamps). + +I would appreciate as prompt a response as you can provide so that we can address any issues with the Court on Friday. + +Thanks, Laura + +Laura A. Menninger I Partner Haddon. 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Maxwell - [conferral re photo and other discovery deficiencies) + +Date: Mon, 24 May 2021 15:35:33 +0000 + +Inline-Images: iinage001.prig; image002.png + +Laura, + +I am still working with our vendor and the FBI to address the issues you raised regarding the metadata for this production. In the meantime, I am able to explain why there are more entries in SDNY011 than on the non-nude index. The non-nude index does not include the 3 excel files or the 28 pdf files that were contained in the SDNY011 production. Those 31 files should explain the discrepancy between the number of files in SDNY011 and the number of entries in the non-nude index. + +Best, + +From: + +Sent: Thursday, May 20, 20218:22 PM + +To: 'Laura Menninger' 4 :3\*' (USANYS) ) < + +Cc: Jeff Pagliuca Bobbi Sternheim (bcsternheim@mac.com)' + +Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies] + +Laura, + +I will pass this on to the FBI and our vendor for review. Once I have consulted with them, I will revert back to you on this issue. + +Thank you, + +From: Laura Menninger + +Sent: Thursday, May 20, 2021 3:28 PM + +Cc: Jeff Pa 'Bobbi Sternheim + +Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies] + +(USANYS) + +Thank you for your explanation. I also have gone back to our IT department and, unfortunately, your FBI/vendor explanation is insufficient. + +- Based on our review, which has been double-checked, there are hash values in the overlay that don't match the index and visaversa. +- The snips below show an example of an entry from the overlay file you provided (with file names and MD5 Hash) which did not join to the non-nude index. We were able to find the corresponding file in the index using the file name, which in this particular instance was unique. As you can see, the MD5 hashes don't match. + +| ProdBegBates | File Name | MD5 Hash | | +|------------------|-----------------------------|----------------------------------|--| +| SDNY_GM_00503260 | Jeffrey VF2.psd | DA92DF87819FCC13F38E0584D8D77DFB | | +| SDNY_GM_00506551 | LSJ librarywindow150dpi.tif | 58AC5CBE826591AEFD0604ABA226272D | | + +## From non-nude index + +| File Name | SHA-1 | MD5 | +|-------------------------------|------------------------------------------|----------------------------------| +| 1 LSJ librarywindow150dpi.tif | 043670EDF17D35EE5794EBDF094AEF63A95D4B9A | BDEB66247E99D1C9EED2BA30FB8F72D5 | + +- More importantly, if as you report you did not deduplicate the production and if the index you produced is accurate, we should be able to match files based on the combination of File Name and MD5 hash. The hash + file name combination might not be unique, but each hash+file name value in the index should have a corresponding entry in the overlay unless hash values and/or file names were modified somewhere in the process. +- As previously reported, if we require a match on the hash value and ignore file names, there are 65 production numbers that don't match the index. +- There are more entries in SDNY011 (40,567) than entries on the non-nude index (40,536). We cannot understand the discrepancy based on your explanation. + +My earlier requests - a new copy of the non-nude index with an added column to note the production number of each file and a new index for the produced files that were not included in the prior index — still stand. + +Thank you, + +Laura + +Laura A. Menninger I Partner + +Haddon, Morgan & Foreman, P.C. + +150 1. 10th Avenue I Denver. CO 80203 + +From: + +Sent: Tuesday, May 1 + +To: Laura Menninger (USANYS) + +Cc: Jeff Pagliuca 'Bobbi Sternheim + +Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies] + +Laura, + +I have consulted with the FBI and our vendor regarding the issues you raised with the overlay. Below is what I understand from them: + +- When using the overlay, you should require only a match of the hash value. +- When our vendor uses the overlay, they do not see any production numbers that do not have a match in the index. If you are still seeing outliers, please let us know which files are not matching up with the index, and our vendor will look into what that issue could be. +- The 17 files with no hash values were either incomplete files or corrupt files when they were recovered from the CDs. We produced them to you so that you would have a copy of every file on the CDs that did not have identifiable nudity. +- Any non-unique hash values are duplicate files. There were many duplicate files on the CDs. The FBI and vendor did not deduplicate the images before producing them in an effort to ensure that you had a complete set of all files recovered from the CDs. +- There are a number of files that were recovered from the CDs but are unopenable on our end. We produced them to you so that you would have a copy of every file on the CDs that did not have identifiable nudity. If you would like to check to see if any particular files are unopenable on our end, we would be happy to check. + +Given the above, the FBI and the vendor believe the overlay previously provided should be sufficient to allow you to review the metadata in this production. + +From: + +Assistant United States Attorney Southern District of New York I St. Plaza New York, NY 10007 + +From: Laura Menninger Sent: Wednesday, April 28, 2021 1:18 PM To: mc ›; Cc: Jeff Pagliuca cM M (USANYS) obbi Sternheim + +Subject: FW: US v. Maxwell - [conferral re photo and other discovery deficiencies] + +Thank you for sending the overlay. After review, it unfortunately does not appear sufficient to allow us to properly match the metadata to your production of native files. + +Based on your representations, the "Non-Nude index" located at Bates 467567 in Excel should match the Bates number native images produced at SDNY011. However: + +- The number of entries in the Non-Nude Index is less than the number of files produced. +- Although the overlay file has 40,567 entries (the same number of files in SDNY011), they don't match up to the Non-Nude Index. o When joining the overlay file to the index: If we require a matching value for both MD5 hash and file name, there are 24,757 entries in the overlay that do not match the index. If we require a match on the hash value and ignore file names, there are 65 production numbers that don't match the index; 17 of those don't have hash values at all. +- The overlay has many non-unique hash values, meaning we cannot rely on hash value alone. +- The Non-Nude index also has many non-unique hash values. + +I think the only feasible resolution is for you to provide a new copy of the non-nude index with an added column to note the production number of each file. We also need a new index for the produced files that were not included in the prior index. + +Let me know if you will agree to produce these two new indices. + +Thank you, Laura + +Laura A. Henninger I Partner Haddon, Morgan & Foreman, P.C. 80203 + +Sent: Tuesday, April + +To: Laura Menninger + +Cc: (USANYS) + +Attached please find a metadata overlay for the production of images from the CDs recovered from Epstein's residence. This file contains the file name and the MDF Hash for each file, which corresponds with the information contained in the SDNY\_GM\_00467567 Spreadsheet. This overlay should allow your team to see which row of metadata corresponds with which Bates number in the production. + +Best, + +Assistant United States Attorney Southern District of New York I St. Plaza New York, NY 10007 + +From: + +Sent: Friday, April 23, 2021 1:44 PM + +To: Laura Menninge + +Cc: (USANYS) >; Jeff Pagliuca + +Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies] + +- I have asked our vendor to look into the issues with SDNY\_GM\_00467566. When I attempt to access that document on our Relativity database, I also receive an error message saying that the document is corrupt. I am not sure what this spreadsheet is because the only two spreadsheets that I'm aware of that correspond with the SONY\_PROD011 contained in the November 9, 2020 production are the two other Excel spreadsheets you referenced. In any event, I am looking into the issue. +- I am similarly working with our vendor to understand how to best identify for you which Bates number corresponds with the metadata in the index contained in the Excel spreadsheets. Can you please provide me with a list of the photos that you are unable to view? Once I have that list, I will check to see whether we are able to open them on our end. +- Can you be more specific in identifying photographs that you believe should have been produced but have been omitted, please? We have endeavored with the FBI to produce copies of all non-nude photographs recovered from searches of Epstein's residence to the defense, and I am not aware of any intentional omissions. +- I am discussing with the FBI your request that we produce all Highly Confidential images to you. I will respond to that request next week. +- Once we have a firm trial date, I will let you know by what date I expect to be able to provide you with a list of the Highly Confidential photographs we may introduce at trial. +- I am working with our paralegals to assess the list of files that your client is unable to review at the MDC. As soon as we have finished looking into those issues, I will let you know. + +Best, + +From: Laura Menninger Sent: Wednesday, April 21, 2021 1:42 PM To: ) Cc: (USANYS) < erdell@cohengresser.com 'Bobbi Sternhei + +Subject: US v. Maxwell - [conferral re photo and other discovery deficiencies] + +I'm writing to follow-up on our discussion last Thursday regarding the photo evidence and to address a number of other critical problems with the discovery provided to date. + +Unfortunately, both in the production to defense counsel and on the hard-drive supplied by your office to our client at MDC, there are thousands, if not hundreds of thousands, of photos that are still unreadable. We have spent countless hours, and a chunk of our client's resources, trying to rectify a number of these problems ourselves, to no avail. Our ability, and our client's ability, to review all of the discovery in this case is absolutely critical and is constitutionally guaranteed. Unless you can quickly propose a solution, we believe we need to raise this with the Court. + +- We do not have a functional copy the Excel spreadsheet located at SDNY\_GM00467566. I have confirmed that the original spreadsheet provided to us is corrupt and the vendor and -discovery provider cannot open it. The other two Excel spreadsheets from the production (and presumably the one we cannot open) are insufficiently detailed to tell us which photo goes with which meta-data. o The index contains multiple instances of the same "file name" with different hash values. o The index does not match any particular file with a Bates stamp. o The index does not indicate which files were withheld as "highly confidential." +- Many of the photo files that were provided in discovery (M., SDNY011) do not have a discernible reader. I cannot open them. Ms. Maxwell does not have a reader on her MDC laptop that can read them. If the government is able to view them, then we should be provided the means to view them as well. + +- • A number of photo files appear to be missing from the MDC laptop and are not highly confidential, based on my review of documents last week. Because we do not have a list of what was/was not produced, however, we cannot confirm. +- • As you know, the 2 x "highly confidential hard-drives" in NY did not work until Thursday once an appropriate reader was added to the laptop. I did not have enough time to view all of the files. I do not have the reader that you ultimately added to that laptop. +- • The discs that I attempted to view in NY (from various binders) would not load on the government laptop. I was unable to match up disks with potential files on the hard-drives. Because I did not have a functioning Excel spreadsheet, I also was not able to match any highly confidential photos from the hard-drives with the associated metadata. + +I am requesting that you produce to defense counsel replicas of the two hard-drives that you made available for review last week, subject to all of the strictures of the protective order. + +I recognize that you have designated as "highly confidential" photos that you contend contain "nude, partially-nude, or otherwise sexualized images, videos, or other depictions of individuals." Among the photos on the hard-drive that I was able to view, there were a lot of "nude" and "partially-nude" photos of adults, but I did not see anything that would qualify as child pornography under the statute. Some of the photos only showed a woman's back or shoulder. If you have reason to believe that there is child pornography contained on the two hard-drives, then certainly defense counsel is not asking to possess that material; you can designate it as such and we can view it at an acceptable location as occurs in any CP case. + +Otherwise, I think the burden of reviewing adult nudity only in the government's office or courthouse imposes an extraordinary cost on our client and prevents us from analyzing the metadata, having our experts review the file structures, keeps us from preparing photos for use at trial, and generally impedes our defense. + +In a similar vein, can you let me know when you are willing to disclose any photos that you intend to introduce at trial? As to any of those, I will need sufficient information and time to analyze them for foundation and admissibility purposes with an appropriate expert. + +Finally, I am attaching an incomplete list of the documents that our client still cannot read at MDC. It is a small sample, as she has had to spend hours of her "review" time communicating to our staff which files she cannot read. Also, the manner in which the discovery was provided to her (load file format) precludes her from comparing the "image" and the "native" files (they do not, for example, have clearly labeled bates-stamps). + +I would appreciate as prompt a response as you can provide so that we can address any issues with the Court on Friday. + +Thanks, +Laura + +**Laura A. Menninger | Partner +Haddon, Morgan & Foreman, P.C.** +150 - 100 Avenue L Denver, CO 80203 + +![](_page_5_Picture_109.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00090668/EFTA00090668.metadata.json b/marker2/ds9/EFTA00090668/EFTA00090668.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..741036825f018bcb92d7a931b82258081e3244e2 --- /dev/null +++ b/marker2/ds9/EFTA00090668/EFTA00090668.metadata.json @@ -0,0 +1,301 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090668.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 6, + "chars": 14940, + "elapsed_seconds": 12.49, + "image_assets": [ + "_page_5_Picture_109.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "From the overlay file", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 62.424, + 38.07 + ], + [ + 150.06967163085938, + 38.07 + ], + [ + 150.06967163085938, + 50.10113525390625 + ], + [ + 62.424, + 50.10113525390625 + ] + ] + }, + { + "title": "From non-nude index", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 62.424, + 107.73000000000002 + ], + [ + 153.6075439453125, + 107.73000000000002 + ], + [ + 153.6075439453125, + 119.85113525390625 + ], + [ + 62.424, + 119.85113525390625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 76 + ], + [ + "Line", + 38 + ], + [ + "Text", + 21 + ], + [ + "ListItem", + 2 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 92 + ], + [ + "Line", + 45 + ], + [ + "Text", + 17 + ], + [ + "ListItem", + 8 + ], + [ + "SectionHeader", + 2 + ], + [ + "Table", + 2 + ], + [ + "ListGroup", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 87 + ], + [ + "Line", + 42 + ], + [ + "Text", + 16 + ], + [ + "ListItem", + 4 + ], + [ + "ListGroup", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 3, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 77 + ], + [ + "Line", + 35 + ], + [ + "Text", + 28 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 4, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 87 + ], + [ + "Line", + 44 + ], + [ + "ListItem", + 8 + ], + [ + "Text", + 6 + ], + [ + "ListGroup", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 5, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 59 + ], + [ + "Line", + 30 + ], + [ + "Text", + 17 + ], + [ + "ListGroup", + 2 + ], + [ + "PageFooter", + 2 + ], + [ + "Picture", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00090668" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00090668/_page_5_Picture_109.jpeg b/marker2/ds9/EFTA00090668/_page_5_Picture_109.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..23d05cb46b337396a0775dd269695a04951aa394 --- /dev/null +++ b/marker2/ds9/EFTA00090668/_page_5_Picture_109.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:797fa8d608297c2a1459d96736f6f9c5fcdb30f0a2010009ef2a0f119eb35d5e +size 4180 diff --git a/marker2/ds9/EFTA00090674/EFTA00090674.md b/marker2/ds9/EFTA00090674/EFTA00090674.md new file mode 100644 index 0000000000000000000000000000000000000000..e509d17dff4fa16b14ffd98cff5643cd230d6eb4 --- /dev/null +++ b/marker2/ds9/EFTA00090674/EFTA00090674.md @@ -0,0 +1,13 @@ +From: IM=Mina + +To: + +Cc: + +Subject: New serials + +> Date: The, 26 Oct 2021 21:54:16 +0000 + +Attachments: (U)\_Call\_with ; (U)\_Collect\_evidence.pdf; (U)\_Interview\_o df; (U)\_Materials\_from\_Palm\_Beach\_Police\_Department.pdf; (U)\_Reimbursement\_ofexpenses\_incurred\_for trial. dl 2021.10.07+Subpoena+to+PBPD.pdf; FD-794 meal.pdf; PBPD-FProperty+Receipt+10.8.21.pdf; PBPDTrash-HFPull+100-PAR+11.6.06.pdf; Receipt\_01Jul2021\_230610.pdf; Reports+from-HFPBPD-F-+Received+10.8.21.pdf; Trash+Pull+100-PAR+(PBPD).pdf; U \_FOUO\_Accusations\_of\_Rape\_and\_human\_trafficking.pdf + +Attached are new serials and their attachments. 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Beach Police Department. These items were recovered from inside of the Town of Palm Beach's storage warehouse by Sgt Physical media found inside of these boxes were separated out (4 CD's, 1 VHS tape, 2 cassette tapes & 4 micro cassette tapes). + +Collected From: (U) Sergeant Palm Beach Police Department + +Receipt Given?: Yes + +Holding Office: NY - NEW YORK + +#### Item Type Description + +1B Digital (U) (1) Envelope containing 4 CD's Collected On: 10/08/2021 01:00 PM EDT Special Handling Codes: Breakable Seizing Individual: + +(U) (2) Bankers box containing various EPSTEIN related case materials Collected On: 10/08/2021 01:00 PM EDT Seizing Individual: Located By: + +# UNCLASSIFIED + +This document contains neither recommendations nor conclustor. of it: the moperty of the FBI and is loaned to your agency; it and its contents are not to he distributed outside your agency. + +Title: (U) Collect evidence + +Re: 50D-NY-3027571, 10/15/2021 + +Located By: + +Device Type: Compact Disc/Digital Video Disc(CDs/DVDs) + 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(U) Receipt +2. 2. 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    05-364 | DATE/TIME RECOVERED
    10/18/21 | PROPERTY NUMBER (Leave Blank) | BIN NUMBER (Leave Blank) | | | + +ADDRESS WHERE PROPERTY IMPOUNDED + +| DISCOVERED BY / D.O.B. | ADDRESS | Street | City | Zip | PHONE NUMBER | +|------------------------|---------|--------|------|-----|--------------| +| | | | | | | + +| OWNER'S NAME / D.O.B. | ADDRESS | Street | City | Zip | PHONE NUMBER | +|-----------------------|-----------------------------------|--------|------|-----|------------------| +| Palm Beach Pake Dep | 345 S. County Rd. Palm Beach 3540 | | | | 561 - 838 - 5454 | + +| SUSPECT'S NAME / D.O.B. | ADDRESS | Street | City | Zip | PHONE NUMBER | +|-------------------------|---------|--------|------|-----|--------------| +| | | | | | | + +| ADDT'NL SUSPECT / D.O.B. | ADDRESS | Street | City | Zip | PHONE NUMBER | +|--------------------------|---------|--------|------|-----|--------------| +| | | | | | | + +| SPECIAL INSTRUCTIONS | FOUND PROPERTY
    90 DAYS | CLAIM
    NOT CLAIM | +|----------------------|---------------------------|----------------------------------------------------------------------| +|----------------------|---------------------------|----------------------------------------------------------------------| + +| ITEM # | QUANTITY | VALUE | DESCRIPTION | +|--------|----------|-------|-----------------------------| +| 1 | 2 | | Knakers Box - CASE FURS | +| | | | | +| | | | | +| | | | | +| | | | | +| | | | | +| | | | | +| | | | | +| | | | | +| | | | | +| | | | | +| | | | | +| | | | | +| | | | | +| | | | | +| | | | | +| | | | | +| | | | | +| | | | TOTAL PACKAGE WEIGHT | + +I hereby acknowledge that the above list represents all property taken from me and that I have received a copy of this receipt. [REDACTED] *10/8/21* + +I hereby acknowledge that the above list represents all property impounded by me in the official performance of my duty as a police officer. [REDACTED] *756 com* + +| SIGNATURE | DATE | SIGNATURE | ID# | UNIT | +|-------------|--------|-------------|--------------------|--------------------| +| RECEIVED BY | REASON | RECEIVED BY | DATE/TIME RECEIVED | DATE/TIME RECEIVED | +| | | | | | +| | | | | | +| | | | | | +| | | | | | +| | | | | | \ No newline at end of file diff --git a/marker2/ds9/EFTA00090678/EFTA00090678.metadata.json b/marker2/ds9/EFTA00090678/EFTA00090678.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..a193a8117933865bf53d4cad969a3434f36ee024 --- /dev/null +++ b/marker2/ds9/EFTA00090678/EFTA00090678.metadata.json @@ -0,0 +1,90 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090678.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 4675, + "elapsed_seconds": 11.78, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "PALM BEACH POLICE DEPARTMENT \nPROPERTY RECEIPT", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 203.18400000000003, + 20.25 + ], + [ + 420.548095703125, + 20.25 + ], + [ + 420.548095703125, + 49.0670166015625 + ], + [ + 203.18400000000003, + 49.0670166015625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 66 + ], + [ + "Line", + 26 + ], + [ + "Form", + 7 + ], + [ + "Text", + 3 + ], + [ + "Table", + 2 + ], + [ + "SectionHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00090678" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00090679/EFTA00090679.md b/marker2/ds9/EFTA00090679/EFTA00090679.md new file mode 100644 index 0000000000000000000000000000000000000000..9d88ca405d77ba9e5435faa6706842c6031b9dee --- /dev/null +++ b/marker2/ds9/EFTA00090679/EFTA00090679.md @@ -0,0 +1,136 @@ +![](_page_0_Picture_56.jpeg) + +3826-SEL CHECK 6 +DIGIT + +FLORIDA UNIFORM TRAFFIC CITATION + +| COUNTY OF
    PALM BEACH | | (1) F.H.P. (2) P.D. (3) S.O. (4) OTHER | | | | | +|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------|------------------------------------------|----------------------------------|--------------------------| +| CITY (IF APPLICABLE)
    WEST PALM BEACH | | | | | | | +| IN THE COURT DESIGNATED BELOW THE UNDERSIGNED CERTIFIES THAT HE/SHE HAS JUST AND REASONABLE GROUNDS TO BELIEVE AND DOES BELIEVE THAT ON
    SUMMONS (DEFENDANT'S COPY) | | | | | | | +| DAY OF WEEK
    THURSDAY | MONTH
    10 | DAY
    19 | YEAR
    2006 | TIME
    06:17 | | | +| NAME (PRINT) FIRST
    ROBERT | MIDDLE
    W | LAST
    PARR | IF DEFENDANT THROUGH ONE OR DRIVER LICENSE "X" HERE | | | | +| CITY
    PALM BEACH | | STATE
    FL | ZIP CODE
    33480 | | | | +| TELEPHONE NUMBER | | DATE BIRTH
    [REDACTED] | LAST NAME
    [REDACTED] | RACE
    W | SEX
    M | HGT
    601 | +| DRIVER LICENSE NUMBER | STATE
    FL | CLASS
    E | CDL LICENSE
    N | YR LICENSE EXP.
    2007 | IF COMMERCIAL MTR. VEH. "X" HERE | | +| VR. VEHICLE
    2004 | MAKE
    LNDR | STYLE
    UT | COLOR
    BLU | IF PLACARDED HAZARDOUS MATERIAL "X" HERE | | | +| VEHICLE LICENSE NO.
    J52THE | TRACER TAG NO. | STATE
    FL | YEAR LICENSES
    2007 | IF COMPANION CITATIONED "X" HERE | | | + +USED A BULK STREET OR HOUSING OR OTHER LOCATION HEREIN +**195 SE 1 MILE SOF 45TH STREET** + +FT \_\_\_\_\_ MILES \_\_\_\_\_ N S E W OF NODE \_\_\_\_\_ + +DID UNLAWFULLY COMMIT THE FOLLOWING OFFENSE. CHECK ONLY ONE OFFENSE EACH CITATION. + + UNLAWFUL SPEED \_\_\_\_\_ MPH SPEED APPLICABLE \_\_\_\_\_ MPH + + INTERSTATE 4-LAME HWY WITH 29 FT. MEDIAN OUTSIDE BUS. OR RES. DIST. + + CARELESS DRIVING SAFETY BELT VIOLATION EXPIRED DRIVER LICENSE FOUR (4) MONTHS OR LESS + + VIOLATION OF TRAFFIC CONTROL DEVICE IMPROPER OR UNSAFE EQUIPMENT MORE THAN FOUR (4) MONTHS + + VIOLATION OF RIGHT-OF-WAY EXPIRED TAG SIX (8) MONTHS OR LESS NO VALID DRIVER LICENSE DRIVING WHILE LICENSE SUSPENDED OR REVOKED + + IMPROPER CHANGE OF LAME OR COURSE MORE THAN SIX (8) MONTHS FAILURE TO STOP AT A TRAFFIC SIGNAL + + IMPROPER PASSING NO PROOF OF INSURANCE DRIVING WHILE LICENSE SUSPENDED OR REVOKED + + CHILD RESTRAINT DRIVING UNDER THE INFLUENCE OF ALCOHOLIC BEVERAGES, CHEMICAL OR CONTROLLED SUBSTANCES, DRINKING ACTUAL PHYSICAL CONTROL WHILE IMPAIRED, OR DRIVING ACTUAL PHYSICAL CONTROL WITH UNLAWFUL BLOCKAIRING ALCOHOL LEVEL BAL. \_\_\_\_\_ % + +OTHER VIOLATIONS OR COMMENTS PERTAINING TO OFFENSE +**REAR ENDED VEHICLE TRAVELING IN SAME DIRECTION** + +FHPL-06-OFF-066887 + + AGREES THAT THE FOLLOWING ARE IN VIOLATION OF STATE STATUTE IN VIOLATION OF STATE STATUTE **316.1925.1** + +CRASH YES NO PROPERTY DAMAGE PROPERTY TO ANOTHER SERIOUS DOUBT INJURY TO ANOTHER FATAL YES NO + + CRIMINAL VIOLATION COURT APPEARANCE REQUIRED AS INDICATED BELOW + INFRACTION COURT APPEARANCE REQUIRED AS INDICATED BELOW + INFRACTION WHICH DOES NOT REQUIRE APPEARANCE IN COURT. + +COURT INFORMATION +DATE **PALM BEACH COUNTY COURT DELRAY 04** TIME **PM** +COUNT **WITHIN 30 DAYS** +LOCATION **SEE MAILER** + +ARREST DELIVERED TO \_\_\_\_\_ DATE \_\_\_\_\_ + +I APPROVE AND PROVIDE TO COMPLY AND ANSWER TO THE CHANGES AND INSTRUCTIONS SPECIFIED IN THIS DISTRICT. WILL IN AFFIDAVIT TO ACCEPT AND REFUSE THE CITATION MAY RESULT IN APPEAL I UNDERSTAND MY SIGNATURE IS NOT AN ADMISSION OF CALL OR REASON OF COURT'S IF YOU NEED REMEMBRANCE FACULTY ACCOMMODATIONS TO ORIGINATE WITH THIS CITATION, CONTACT THE CLERK OF THE COURT. + +SEE MAILER AT FOR FURTHER INFORMATION +RANK - SIGNATURE OF OFFICER \_\_\_\_\_ BADGE NO. \_\_\_\_\_ ID NO. \_\_\_\_\_ TROOP UNIT \_\_\_\_\_ + +IMPORTANT INSTRUCTIONS TO INDIVIDUAL CHARGED WITH A NON-CRIMINAL TRAFFIC INFRACTION NOT REQUIRING A COURT APPEARANCE + +You were charged with a civil infraction which requires that you comply with one of the following options with the Clerk of County Court in the county where you received this citation within thirty (30) calendar days. IF YOU FAIL TO COMPLY WITHIN THE SPECIFIED PERIOD, YOUR DRIVING PRIVILEGE WILL BE SUSPENDED UNTIL YOU COMPLY. YOU SHALL BE REQUIRED TO PAY AN ADDITIONAL CIVIL PENALTY AND A SERVICE FEE. + +OPTIONS: \*Note: Place the amount on the back of the white complaint copy also. + +1. Pay a civil penalty in the amount of **\$118.50** by mail or in person to the Clerk of Court. Payment must be received by the clerk within the period specified. POINTS WILL BE ASSESSED AS APPLICABLE. FOR DRIVER LICENSE, TAG OR REGISTRATION, OR INSURANCE INFRACTIONS, PROOF OF COMPLIANCE IN THE FORM OF A VALID DRIVER LICENSE, REGISTRATION CERTIFICATE OR PROOF OR INSURANCE, WHICHEVER IS APPLICABLE, IS REQUIRED IN ADDITION TO PAYMENT. + +NOTE: IF YOUR DRIVER LICENSE, TAG, REGISTRATION, OR INSURANCE WAS VALID AT THE TIME THE CITATION WAS ISSUED, YOU MAY PRESENT THE DRIVER LICENSE, TAG, REGISTRATION OR PROOF OF INSURANCE WITHIN THIRTY (30) CALENDAR DAYS TO CLERK OF COURT, AND THE CHARGE WILL BE DISMISSED. A FEE MAY BE ASSESSED. If you cannot provide proof of registration or insurance, you may sign a sworn statement at the Clerk's office. + +NOTE: YOU MUST ENCLOSE THIS CITATION IF YOU MAIL PAYMENT. PAYMENT SHOULD BE IN THE FORM OF MONEY ORDER OR A CASHIER'S CHECK. + PERSONAL CHECKS ARE ACCEPTED PERSONAL CHECKS ARE NOT ACCEPTED +(Make Payable to the Clerk of the County Court) + +MAIL ADDRESS FOR THE CLERK OF COURT: \_\_\_\_\_ + +2. Elect a court hearing by contacting the Clerk of Court at the address listed above or indicated on the front of your citation. If you request a hearing and the County Judge/Magistrate determines that you have committed the offense, the County Judge/Magistrate may impose a penalty not to exceed 500.00 or require completion of a Driver Improvement Course, or both. POINTS WILL BE ASSESSED AS APPLICABLE. If the County Judge/Magistrate determines that no infraction has been committed, no cost or penalties shall be imposed and any cost or penalties which have been paid shall be returned. + +3. Any person who does NOT hold a commercial driver's license can elect to attend and complete a Driver Improvement Course approved by Florida. Initiate by contacting the Clerk of Court listed above. In such case, adjudication shall be withheld and POINTS SHALL NOT BE ASSESSED provided you have not made a prior election to attend within the last 12 months preceding this election. No person may make more than five ci these elections in a lifetime (F.S. 318.14(3)). By electing this option you shall pay a penalty. Also, a court cost may be required. This option is not available for driver license, tag or registration violations. + +4. If you were charged with violation of F.S. 322.065 (driver license expired for 4 months or less), F.S. 320.07(3)(a) (lage or registration expired 6 months or less), F.S. 322.15(1) (failure to display a valid driver license), F.S. 320.0605(1) (failure to possess a valid registration) or F.S. 316.648(1) (failure to maintain proof of insurance), you may, in lieu of payment of fine or court appearance, elect to enter a plea of nolo contendere and present a valid driver license, tag or registration or proper proof of insurance to the Clerk of Court. In such case, adjudication shall be withheld by the Clerk. You must pay court costs. This option is available ONLY if you HAVE NOT made this election within the last twelve (12) months. No person may make more than three (3) elections under this provision in a lifetime F.S. 318.14(10)(8). If you fail to comply within the specified period, your driving privilege will be suspended as of the date of such failure, until compliance is met. You shall be required to pay an additional civil penalty and a service fee. + +5. If charged with F.S. 316.610, operating a motor vehicle in an unsafe condition or not properly equipped as required in F.S. 316.610, or F.S. 316.2935, non-criminal violation, you may, WITHIN THIRTY (30) DAYS from the date the citation was issued, have the defect corrected, pay a \_\_\_\_\_ fee to the local police or sheriff's office and have the CORRECTION CERTIFIED ON AN AFFIDAVIT OF COMPLIANCE BY THE POLICE OR SHERIFF'S OFFICE. YOU MUST MAIL OR PRESENT THE AFFIDAVIT + +OF COMPLIANCE, TOGETHER WITH A FEE IN THE AMOUNT OF \_\_\_\_\_ TO THE CLERK OF THE COURT WITHIN THIRTY (30) DAYS OF THE DATE THE CITATION WAS ISSUED. NO POINTS WILL BE ASSESSED. + +NOTE: This option shall not apply to violations of F.S. 316.610 by a commercial motor vehicle or transit bus owned by a government entity. +**FAULTY EQUIPMENT AFFIDAVIT OF COMPLIANCE** +(For Local Police or Sheriff's Department Use Only) + +I certify that the equipment on this vehicle described herein as indicated on the front of this citation has been corrected and upon this date complies with the requirements of the traffic laws of Florida. +DATE \_\_\_\_\_ (CHECK ONE) Local Police Sheriff +Signed \_\_\_\_\_ Name, Title, and ID# \_\_\_\_\_ + +Agency Address \_\_\_\_\_ County \_\_\_\_\_ +Accumulation of Points May Increase Your Costs of Motor Vehicle Insurance If You Were Exceeding the Speed Limit by More Than 15 MPH. This is Your Second Infraction Within the Past 18 Months, or This is Your Third or Subsequent Infraction Within the Past 36 Months ( F.S. 626.9541(1)(D)(4) ). + +## Zurich Mortgage Solutions + +Robert W. Parr, if + +Principal + +Business Cell Fax + +![](_page_1_Picture_4.jpeg) + +![](_page_1_Picture_5.jpeg) + +**NEXT** + +*Financial Associates Inc.* + +Robert W. Parr + +*Director* + +▶ Office: +Cellular: +Fax: + +![](_page_2_Picture_15.jpeg) + +▶ Email: + +[Redacted] +[www.applytoryourloannow.com](http://www.applytoryourloannow.com) + +![]()![](_page_4_Picture_0.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00090679/EFTA00090679.metadata.json b/marker2/ds9/EFTA00090679/EFTA00090679.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..f7608b623ba4e02ce2a1db1d09dc1d8c6f39784c --- /dev/null +++ b/marker2/ds9/EFTA00090679/EFTA00090679.metadata.json @@ -0,0 +1,258 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090679.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 5, + "chars": 13926, + "elapsed_seconds": 38.36, + "image_assets": [ + 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FL ilt West Palm Beach. 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County Rd. Palm Beath. FL Phone: 561438-5474 Far 561455-9653 + +| Report Number
    2002-10 | | Date Opened
    12/06/1901 | Date Closed
    / / | Review Date
    / / | Case Title
    Prostitution-Epstein | Employee
    Not on File | | +|------------------------------------|-----------------------------------|----------------------------------|----------------------------------------|--------------------------------------|-------------------------------------------|--------------------------------|--------| +| Assisting | | | Active ?
    Active | Case Disposition
    UNFOUNDED | | Source | Agency | +| Location (Arename / Case Location) | | | | | Zone | Best | Grid | +| File Number
    300-13 | Date Entered
    08/06/2004 | Entered By
    Import | Date Last Updated
    08/06/2004 | Last Updated By
    Import | | | | + +Printed By: Printed Friday. October 08. 2021 + +# Narrative/Notes + +12/07/01 + +File 100 + +Sgt. + +On 12/06/01, OCVAN received intelligence from the WPBPD concerning Maxwell. According to the report, Maxwell is hiring young women from PBAC to come toher house and answer the phone. They are paid 8200.00 per day for htis service. It is unclear what is occurring in the residence, however, contact information for PBAC students was provided. Follow-up will be initiated as soon as possible. + +10/13/03 + +Fil + +Det. + +On 12/10/01, information was passed on from Sgt. regarding Ghislaine Maxwell and Jeffrey Epstein of 358 El Brillo Way. A West Palm Beach intelligence report read as follows: "Three female college students from PBAC ( and ) were approached by an English woman who identified herself as Maxwell, on the Palm Beach Atlantic Campus. Maxwell said she needed young, beautiful unmarried women to answer phones and do office work at her home on Palm Beach. ent to the house on several occasssions and described the telephone en call in saying when they were going to drop of particular girls. All three girls said Maxwell and Epstein were secretive about what was going on at the house, and at least two of the girls complained about Epstein touching them inappropriately. They said Maxwell asked for a list of other girls who she could call to work on short notice. She said she needed a large pool of girls to call as she did not know how many she would need at any given time. The callers were receptive to the idea of forwarding numbers of undercover personnel to Maxwell. Maxwell pays S200.00 per day for answering phones (cash). said she only worked there one da , but she hd been there on at least one of er occasion. I did not speak with Their telephone number is at their dorm room on campus (roomm . Maxwell and Epstein allegedly have a private plane and frequently go to New York leaving them out of the area for extended periods of time." + +Numerous attempts were made to reach the girls at the above listed number with negative results. Finally, I contacted PBA security who stated the college was closed for the semester and would not re open until next year. + +In the beginning of January, many messages were left which met with negative results. + +A check of Jeffrey E Epstein, DOB 01/20/53, revealed an expired florida drivers license of E-123-425-53-020-0. Epstein did not return with any criminal history. An Accurint check revealed he has a florida concealed weapon permit 49012027, which expires on 03/29/05. Several ownership address were listed for Epstein including 358 El Brillo Way, Palm Beach, 457 Madision Ave, New York, NY, and numerous vehicle and watercraft ownerships. In addition, many UCC filings were recorded. Finally, associations were listed with the following companies: Ghislaine Corp (Inactive); Har Adom, Limited (CO-Active); L.A.W. Plantation Management (GA-Active); Nine East 71st street Corp. (NY-Active); RHC Licensing Corp (TX-Dead); and the other two Florida inactive corporations. + +A check of Ghislaine Noelle Maxwell, DOS S revealed a valid florida driver license \$M with no criminal history. An Accurint check on Maxwell revealed numerous vehicles, with nothing additional. + +On 1/28/02, trash pulls were initiated on this case, and conducted intermittently through 4/16/02. Numerous intelligence items were discovered within the trash, to include: individual directory listings for massages in New York, and the United Kingdom, numerous phone messages, daily calendars, list of female names titled "People that I want you to meet", listing females, ages, descriptions, and what they do (trash pull on 3/29/02), front page of bell south phone bill indicating phone account under the name of Jeffrey Epstein and account under the name of Ghislainne Maxwell, correspondence to inoicate a weapon is ept on the property, financial information, nude photographs of women and numerous references to massages through daily calendars, phone messages, etc. It should be noted a list was complied of all names associated with Epstein/Maxwell/358 El Brillo Way, and is documented in the file. + +It should be noted that all attempts to reach reporting parties have met with negative results at this time. + +On 02/8/02, an investigative subpoena was completed requesting all incoming and outgoing lines to the address 358 El Brillo Way. + +On 02/13/02, the above referenced subpoena was received from the SAO and was served on Bell South via fax. + +On 02/12/02, an inquiry into corporations on line revealed Jeffrey E. Epstein related to three Florida entities: Financial Strategy Group, Inc; Ghislaine Corp; Financial Trustees, Inc. None of the aforementioned entities are active. + +On 02/22/02, I received information from Bell South which revealed the following lines are installed at 358 El Brillo Way: + +Under name G. Maxwell Jeffrey Epstein Main house line + +![](_page_1_Picture_12.jpeg) + +I I + +All above lines are considered to be residential lines. + +On 02/27/02, an investigative subpoena was completed requesting all incoming and outgoing calls rom 1/28/02 through 2/4/02 on the following telephone numbers: ■ + +**On 02/28/02, 411 computer checks revealed the lines 832-4117 and to be listed under the name Jeffrey Epstein. On 03/1/02, the above referenced subpoena was received from the SAO and was served via fax to Bell South.** + +**On 03/5/02, a fax was received from Bell South indicating the subpoena has been received and Bell South was working on the information.** + +**On 03/11/02, documents phone records were received from Bell South and evaluated. With the exception of their being numerous phone lines at the residence, nothing unusual was detected.** + +**On 03/19/02, an investigative subpoena was completed requesting all incoming and out calls rom 1/28/02 through 2/4/02 on the following telephone numbers: ;** I. + +On 03/20/02, the above referenced subpoena was received from the SAO and was served via fax to Bell South on 03/21/02. + +On 03/26/02, drive by surveillance revealed the following vehicle tags: F58XCK; Jeffrey Epstein, F57XCK; Jeffrey Epstein, and + +On 03/29/02, additional phone records from Bell South were received and evaluated. It should be noted nothing usual was detected within these records. + +I subsequently contacted security at PBAC and advised them of the received from WPBPD. They provided the following information: are now living off campus at "Jefferson term physical address is I FL long term physical address is , FL Elm. Security stated these two girls are rooms on Apartments and their phone number is IIIIIIII5. In addition, is residing on campus at a different location than last semester. ecurity agreed to conduct an unannounced room search on McCoy, and advised will me as soon as that is complete. I advised them I will not attempt contact until the search has been done. information and + +On 04/12/02, I was contacted by PBA Security. A room search was conducted and the following report provided: "At 1420, 020411 a room search was conducted in by Sgt. Officer and the Director of Security per the request of Residenti • MI accompanied the officer's to + +McCoy was not present during the search. Six full bottles and two empty bottles of Smirnoff Ice were found in standin closet. Along with the illegal alcohol, several papers were oun y personal laptop computer that had what appeared to be porn site addresses on em. These papers were not confiscated due to there being other personal related information on them. + +with visual pornography on it. + +Another piece of paper that was seen indicated that information had been about some type of adult work that paid \$2,200.00 weekly. obtained + +Nothing else found. is handling all discipline." + +Security explained to me that will no longer be allowed to reside at the PBAC campus, however, he will contact me with whatever address she moves to. + +Later, I was contacted with the following address for FL. A cell phone number of 'c oy was provided for + +On 04/24/02, Sgt. and I interviewed and confirmed they had been approached by Maxwell and had briefly answering phones, and were paid well. Althou something "weird" about the subjects residing there, did not observe anything illegal at the time. Both subjects worked at the residence h the felt there was advised they + +On 04/25/02, Sgt. and I met with . stated that she did not recall anything illegal occurring at e, ere were nude photographs of women all over the residence. added there were women runnin around the pool area topless, and that people were always getting massages. stated that Epstein offered a massage to IIIIllat one time, (he did not phys do the massa e-a tech did it), but Epstei her take her top off for the massage. stated that made her extremely uncomfortable and she has not been back since. + +Although it appears as though usual activity is occurring at this residence, at this time, no illegal activity has been reported or detected. This information will remain as intelligence purposes only, until a crime is reported or possibly another student or young female and report to us while working at the residence. + +# Links + +| Expenses/Income | 0 | +|----------------------------|---| +| Source Payments | 0 | +| Aircraft | 0 | +| Associated Cases | 0 | +| Arrests | 0 | +| Arrest Charges | 0 | +| Arrest Warrants | 0 | +| Businesses | 0 | +| Case Logs | 0 | +| Calls | 0 | +| Confiscations and Seizures | 0 | +| Associated Employees | 0 | +| Evidence | 0 | +| Gangs and Groups | 0 | +| Locations | 0 | +| Media | 0 | +| People | 0 | +| Search Warrants | 0 | + +Vehicles Watercraft - 0 + +![](_page_5_Picture_0.jpeg) + +### Case Report + +| Report Number
    2006-07 | | Date Opened
    02/05/2005 | Date Closed
    / / | Case Title
    Sexual Battery | Employee
    Not on File | | | +|----------------------------------------------------------------------------|-----------------------------------|----------------------------------|----------------------------------------|------------------------------------------|--------------------------------|------|--------| +| Assisting | | | Active ?
    Active | Case Disposition
    CLOSED-ARREST | Source | | Agency | +| Location (Arename / Case Location)
    358 El Brillo / 358 El Brillo | | | | | Zone | Beat | Grid | +| File Number
    05-368 | Date Entered
    05/04/2006 | Entered By
    [REDACTED] | Date Last Updated
    01/07/2008 | Last Updated By
    [REDACTED] | | | | + +Paim&m0POM MMNUM USSCotrayRd. Palen Beach, Plane' Fax: + +Printed By. + +#### People + +Printed: Friday, October 08 202 + +Epstein, Jeffrey E - Unknown W/M Dob: 01/20/1953 358 El Brillo Way Palm Beach, FL 33480 + +### Narrative/Notes + +See PBP'... + +01-07-08 + +300 + +On January 3, 2008, an article in the Palm Beach Daily News revealed Epstein's plea hearing was postponed until March of 2008. Epstein, had agreed to plea in State court on the charges filed against him. Based on a agreement with Federal authorities Epstein was to plea to a 18 month imprisonment followed by house arrest. Epstein was to register as a sex offender for life. According to the article Epstein decided at the last minute not register as a sax nffenridar and wished to negotiate that option further. FBI agent Has notified of the findings. + +At•.ached is the article. + +#### Links + +| Source Payments | 0 0 | +|------------------|-----| +| Aircraft | 0 | +| Associated Cases | 0 | +| Arrests | 0 | +| Arrest Charges | 0 | +| Arrest Warrants | 0 | +| Businesses | 0 | + +# Links + +| Case Logs | - 0 | +|----------------------------|-----| +| Calls | - 0 | +| Confiscations and Seizures | - 0 | +| Associated Employees | - 0 | +| Evidence | - 0 | +| Gangs and Groups | - 0 | +| Locations | - 0 | +| Media | - 0 | +| People | - 1 | +| Search Warrants | - 0 | +| Vehicles | - 0 | +| Watercraft | - 0 | + +See PBPD 05-368 + +01-07-08 + +300 + +On January 3, 2008, an article in the Palm Beach Daily News revealed Epstein's plea hearing was postponed until March of 2008. Epstein, had agreed to plea in State court on the charges filed against him. Based on a agreement with Federal authorities Epstein was to plea to a 18 month imprisonment followed by house arrest. Epstein was to register as a sex offender for life. According to the article Epstein decided at the last minute not register as a sex offender and wished to negotiate that option further. FBI agent I was notified of the findings. + +Attached is the article. + +NOTE: AS OF 10/11/2005 ALL NEW SUPPLEMENTS FOR JEFFREY EPSTEIN SHOULD BE FILED 2600-8 + +See Drug Trak Case #2002-10 + +See associate Ghislaine Maxwell + +03-11-04 + +File # 2600 + +Det. + +On 03-05-04, Sgt. completed an intel regarding a WF ast name unknown, who was giving a message to Jeffery Epstein at 358 El Brillo. Mr stated that several times Epstien asked her to take off her top or her pants. She refused. r contacted the police department later that day and wanted to make a complaint. She also said that she would work with police. I contacted on 03- 06-04 at 11:00 p.m. and introduced myself then told her that I wouild contact her at a later date. + +On 03-11-04, I left a message for —r to call me regarding the Epstien incident. Her phone number is + +Investigation Continues + +File 2600 + +August 10, 2004 + +Det. + +On August 10, 2004 I received an intelligence report written by Off. in indicating that he had been flagged down by a taxi cab driver who had just dropped off two unknown white females, who appeared to be approximately 15 and 17 yoa, at the residence of Epstein, 358 El Brillo Way. The taxi cab drive stated that he picked the females up in West Palm Beach and while traveling to Epstein's residence he overheard the females discussing how much money they would make "dating" in Palm Beach and possible drug use. + +Off. a drove by the residence and observed two vehicles in the driveway, one registered to Epstein, a black Chevy V99YEE and a black Mercedes bearing FL U90801, which came back as no record found. + +Det. i would also complete a drive by later in the evening and observe ' enter a small red vehicle, This vehicle is registered to EM, D + +No further information regarding known criminal activity obtained; however, efforts will be made to commence trash pulls from Epstein's residence in the near future. + +Attached is the Intel report provided by Off. n. + +File 300 + +November 29, 2004 + +Det. + +On November 29, 2004 I reviewed an intelligence report completed by Officer M. regarding + +According the report, who is the property manager for 358 El Brillo Way, which is the residence of Jeffrey Epstein, responded to the Police station to report that a suspicious vehicle was parked in the driveway of the residence. + +Upon arrival, Off. • came into contact with who advised that she was there to pick up an envelope from the homeowner (Epstein). stated that Epstein did leave an envelope for and went inside to retrieve it. While waiting, received a phone call and stated, "I can't talk, I can't talk, I'm at school, I gotta go" before terminating the call. When questioned who had called El advised it was her mother. + +was advise that she works at Abercrombie and Fitch at the Wellington Green Mall and was introduced to Epstein through a friend who worked there. • told i that Epstein allows then to come over anytime and use the house and pool. + +would ask what was in the envelope that was given to and was told it was money for being a message erapist. confided, "off the record, he (Epstein) has many young girls come over for that...there's always a different young girl at the pool or inside with him when he's here." + +Detectives will attempt contact with in the near future for possible follow-up assistance. + +Nothing further at this time. + +CC: Jeffrey Epstein + +File 2600 + +January 18, 2005 + +Det. + +On or about January of 2005, I located an article on the Internet regarding Jeffrey Epstein. The article details some of the financial ventures and background regarding Epstein. According the this article, Epstein is a financial manager and only has a clientele with a net worth of 1 billion dollars. + +Attached is article for informational purposes. + +File#2600 + +Det: + +03/31/2005 + +On March 30, 2005, I was asked to begin conducting surveillance and trash pulls reference Detective investigating Epstein as a suspect involved in a sexual battery of a 14 year old female. I was advised that Epstein was possibly engaging in sexual contact with young females. + +March 30, 2005, I made contact with Town of Palm Beach Sanitation Office Supervisor, and requested trash pulls for 358EI Brillo Way to begin on March 31, 2005. + +March 31, 2005 at 9:20 a.m., I met with Town of Palm Beach sanitation employee, Jeffrey who collected seventeen white plastic trash bags from Epstein's property and turned them over to me. + +I took the trash bags to the sanitation office were I sifted through them. I collected mail correspondence from Armani Exchange addressed to a, "Jeffrey E. Epstein" notepaper with a important message notepaper addressed to J.E dated 03/29/05 at 8:15 p.m. reference Peggy Seagal, U.S Airways boarding pass copy for passenger, Montgomery County, Maryland Health Department food service la for and Ghislaine Maxwell notepaper with names and phone numbers. Photocopies of the trash collected were attached with the supplement. + +March 31, 2005, at 3:00 p.m., I set up a surveillance vehicle equipped with a video monitoring device. The surveillance vehicle was parked approximately fifty feet east of Epstein's driveway, to monitor and record all vehicle and pedestrian traffic entering and leaving Epstein's property. + +Video surveillance was conducted near Epstein's property from March 31 through April 3, 2005. + +The video surveillance tapes were regularly changed out with new tape. Six Maxell T-160 VHS tapes were reviewed for intelligence. The tapes were filed in the OCVAN office. + +End of supplement. + +File#2600 + +Det III + +04/01/2005 + +On April 01, 2005 at 9:30 a.m., while parked in the area of 358 El Brillo Way waiting to collect Epstein's Elm public works, I observed a white female, who I recognized as a from her river's license search I conducted from mail correspondence collected from the trash. I made no contact with =Ma. While parked in the area, I also observed Epstein's GMC Yukon truck leave the property as well as other vehicles arrive and park across the street from the property. The occupants of these vehicle appeared to be house workers, maintenance, and gardeners. + +At 9:38 a.m., I collected trash from sanitation employee, Jessie. I sifted through the trash and collected mail correspondence addressed to Jeffrey Epstein, automotive records and personal documents for and a as well as "Jeffrey Epstein" notepaper with girls names and times + +I also found a three inch purple finger size object which had a broken end. The object appeared to be a broke piece from a sexual toy (Cyclone Vibrator) possibly used for rectal gratification.. The object was photographed for Detective , packaged in a bio-hazard evidence bag (possible body fluids) and secured as investigative evidence. + +Copies of the trash collected were attached with the supplement. + +End of supplement. + +File#2600 + +Det: III + +04/05/2005 + +On April 05, 2005 at 9:18 a.m., I collected trash from sanitation employee, Jessie. I transported the trash bags back to the sanitation site, where I sifted through the trash bags and collected mail correspondence addressed to Jeffrey Epstein as well as notepaper (Important Message) names and telephone numbers. The following are items of paper collected from Epstein's trash. + +G. a + +blank piece of white paper (-8) + +black paper (fl + +black paper 3) + +David (-2) + +MSN Hotmail web page with email address + +The following items were documented for Detective investigation prior to disposal. + +End of supplement. + +File: 2600 + +Det: • + +04/21/2005 + +During the month of April 2005, trash pull were conducted at 358 El Brillo Way to gather further intelligence related to Detective investigation of Jeffrey Epstein possibly being sexually involved with underage girls. + +Trash from Epstein's residence was collected by Palm Beach Sanitation employee, Jessie. The trash bags from Epstein's were turned directly over to me upon Jessie driving away from the property on most days, however if I was unable to met with Jessie, he would leave the Epstein's trash bags at a designated area at the sanitation office. + +All trash collected from Epstein's which included, mail correspondences addressed to Jeffrey Epstein, and other household members, notepad papers, with names, telephone numbers, notes and a three inch purple object that appeared to be part of a sexual toy were turned over to Detective + +The six Maxell T-160 vhs video tapes collected from the surveillance remained in my custody. + +End of supplement. + +File#2600 + +Det: • + +06/14/2005 + +On June 14, 2005, Detectiv. ontacted me and advised that the airplane belonging to Jeffrey Epstein of 358 El Grillo Way was parked at Palm Beach International Airport. + +Detective requested that I begin trash pulls for the purpose of gather intelligence. + +I made contact with of Palm Beach Sanitation and requested that on June 1S, 2005, all of Epstein's trash be collected and transported to the sanitation department. + +End of supplement. + +File 100 + +September 12, 2005 + +Det. + +On or about September 11, 2005, was arrested for possession of marijuana in the north end of the island during a traffic stop by Off. M. See case number 05-1263 for further information. + +Previous intelligence indicates that may have been paid money for sexual acts from Jeffrey Epstein. would have been under the age of 18 at the time this act would have allegedly taken place. + +On September 12, 2005 I made telephone contact with at phone number stated that she was willing to speak with me about a resident on the island involved in "disgusting activity". indicated that this person was of high influence and had 6 to seven assistants working for him. • stated that she has heard he also has police officers working for him. • discussed her concerns about the marijuana arrest and stated that she is know living in outside of Jacksonville and would not be able to assist police. • indicated that she would come to the police department today; however, it was determined by Capt. that she should be more thoroughly interviewed at a later date. + +It should be noted that Epstein's name was not mentioned during the entire conversation and • was instructed not discuss this matter with anyone else. • indicated that she last spoke with Epstein through e-mail approximately 2 weeks ago. was further asked to save/document any future correspondence. + +Det. Bureau notified of information. + +Sgt. + +05-368 + +2600 + +September 21, 2005 + +On Wednesday September 21, 2005 Detective Min requested that the trash at 358 El Brillo Way be collected for evidentiary purposes. I contacted Sanitation Supervisor at ext 7041 and requested that the trash be collected while an investigator observes the collection. He then contacted who is the employee on that route and informed him to contact me prior to picking up the trash. At 9:30 a.m., I had not received a call from Mr. s so I responded to the area to wait for him to arrive. As I approached El Brillo Way, I observed driving his collection vehicle eastbound on El Brillo to South County Road. I met with Ms on South County Road and collected four bags from the back of his truck. I then responded to the Police Department and informed Detective MEI that I would search through the trash. He then met with me in the basement area and assisted in the search for items. Several items of paper with information either typed or handwritten was taken into evidence. + +Contact was made with Supervisor Higgins, to request that trash be collected again on Friday September 23, 2005. + +Investigation Continuing. + +File 2600 + +September 23, 2005 + +Det. + +On or about September 23, 2005 at approximately 0915 hours, I responded to 358 El Brillo and met with PB Sanitation worker I observed a enter the driveway of 358 El Brillo and remove several plastic bags of trash and place the contents into the back of an empty sanitation truck. + +I then followed as to a predetermined location and seized the trash from the truck. The trash was transported to the Palm Beach Police Department where I began sifting through its contents. There were a total of 4 white in color plastic bags and each contained documentation and correspondence for 358 El Brillo and Jeffrey Epstein. All documents of evidentiary value were removed and turned over to Det. a for follow-up. + +No further action taken. + +File 2600 + +September 23, 2005 + +Det. + +On or about September 26, 2005 at approximately 0900 hours, I responded to 358 El Brillo and met with PB Sanitation worker . I observed enter the driveway of 358 El Brillo, where no trash was located within the receptacles. I left the area without incident and notified Det. a to that affect. + +On or about September 27, 2005 at approximately 0915 hours, I responded to 358 El Brillo and met with PB Sanitation worker. I observed enter the driveway of 358 El Brillo and remove one plastic bag of trash and place it in the back of an empty sanitation truck. + +I then followed to a predetermined location and seized the trash from the truck. The trash was transported to the Palm Beach Police Department where I began sifting through its contents. There were a total of 1 white in color plastic bag which contained correspondence for 358 El Brillo. All documents of evidentiary value were removed and turned over to Det. for follow-up. + +No further action taken. + +On or about Monday October 3, 2005 at approximately 0915 hours, I responded to 358 El Brillo and met with PB Sanitation worker s. I observed a enter the driveway of 358 El Brillo and remove several plastic bags of trash and place the contents into the back of an empty sanitation truck. + +I then followed to a predetermined location and seized the trash from the truck. The trash was transported to the Palm Beach Police Department where I began sifting through its contents. There were a total of 7 white in color plastic bags with a red tie and 1 black in color bag which contained 2 white in color plastic bags with a red tie. Each of the bags contained documentation and correspondence for 358 El Brillo and Jeffrey Epstein. Also located was a broken piece of a hard plastic or clear acrylic stick, which was shaped with small ridges. This device is commonly used as a sexual toy which is inserted into the vagina or anus for stimulation. This item, along with all documents of evidentiary value were removed and turned over to Det. for follow-up. + +On or about Tuesday October 4, 2005 at approximately 0928 hours, I responded to 358 El Brillo and met with PB Sanitation worker MIMs. I observed Ms enter the driveway of 358 El Brillo and remove several plastic bags of trash and place the contents into the side well of the sanitation truck. This side of the truck is separate from the rear of the truck and does not come into contact with other trash. + +I then followed a to a predetermined location and seized the trash from the truck. The trash was transported to the Palm Beach Police Department where I began sifting through its contents. There were a total of 2 white in color plastic bags which were tied at the top. Each of the bags contained documentation and correspondence for 358 El Brillo and Jeffrey Epstein. All documents of evidentiary value were removed and turned over to Det. for follow-up. + +File 2600 + +October 5, 2005 + +Det. + +On or about Wednesday October 5, 2005 at approximately 0928 hours, I responded to 358 El Brillo and met with PB Sanitation worker as. I observed s enter the driveway of 358 El Brillo and remove several plastic bags of trash and place the contents into the bed of the sanitation truck. + +I then followed to a predetermined location and seized the trash from the truck. The trash was transported to the Palm Beach Police Department where I began sifting through its contents, with the assistance of Det. . There were a total of 2 bags, one of which was white in color and tied in a knot at the top, and the other was a black in color bag, which contained two white in color trash bags along with loose debris. Each of the bags contained documentation and correspondence for 358 El Brillo and Jeffrey Epstein. All documents of evidentiary value were removed and turned over to Det. for follow-up. + +File 2600 + +October 5, 2005 + +Det. + +On Friday, October 7, 2005 at approximately 0923 hours, I responded to 358 El Brillo and met with PB Sanitation worker. I observed c enter the driveway of 358 El Brillo and remove several plastic bags of trash and place the contents into the bed of an empty sanitation truck. + +I then followed s to a predetermined location and seized the trash from the truck. The trash was transported to the Palm Beach Police Department where I began sifting through its contents. There were a total of 3 bags, one of which was white in color and tied in a knot at the top, and the other two + +bags were black in color. One bag contained documentation and correspondence for Jeffrey Epstein, which was copied and given to Det. for informational purpose. It is described as a white piece of stationary with "Jeffrey E. Epstein" typed at the bottom. Handwritten on the letter was, '-Sunday 100 (1:00), Improve Saturday 1500 Bay Road Miami Flamingos Beach". Nothing of evidentiary value was located. + +File 2600 + +October 5, 2005 + +Det. + +On Monday, October 10, 2005 at approximately 0943 hours, I responded to 358 El Brillo and met with PB Sanitation worker Mas. I observed a enter the driveway of 358 El Brillo and remove a plastic bag of trash and place it into the bed of an empty sanitation truck. + +I then followed a to a predetermined location and seized the trash from the truck. The trash was transported to the Palm Beach Police Department where I began sifting through its contents. There was one white in color plastic bag which was tied in a knot at the top. The bag contained nothing of evidentiary value. + +File 2600-8 + +October 20, 2005 + +Det. + +On Tuesday, October 18, 2005 at approximately 0948 hours, I responded to 358 El Brillo and met with PB Sanitation worker -s. I observed as enter the driveway of 358 El Brillo and remove a single black in color plastic bag of trash and place the contents into the bed of the sanitation truck. + +I then followed a to a predetermined location and seized the trash from the truck. The trash was transported to the Palm Beach Police Department where I began sifting through its contents. There were a total of 2 bags inside, both white in color and tied with a knot at the top along with several loose pieces of debris. Each of the bags contained documentation and correspondence for 358 El Brillo and Jeffrey Epstein. All documents of evidentiary value were removed and turned over to Det. i for follow-up. + +On Wednesday, October 19, 2005 at approximately 0932 hours, I responded to 358 El Brillo and met with PB Sanitation worker as. I observed as enter the driveway of 358 El Brillo and verify that no trash was available for removal. Det. la was notified to that affect. + +On Thursday, October 20, 2005 at approximately 0920 hours, a search warrant was executed at the residence of Jeffrey Epstein, 358 El Brillo, Palm Beach by Det. . Further details of the items seized will be completed at a later date. Investigation continues. + +NOTE: AS OF 10/11/2005 ALL NEW SUPPLEMENTS FOR JEFFREY EPSTEIN SHOULD BE FILED # 2600-8 + +File#2600-8 + +Det: + +11/14/2005 + +On November 13, 2005 at 3:18 p.m., I received a telephone call from Detective /Ma requesting that on November 14, 2005, I begin trash pulls at Jeffrey Epstein's residence located 358 El Brillo Avenue. + +On November 14, 2005 at 8:30 a.m., I responded to 358 El Brillo. Upon my arrival, I made contact with Town of Palm Beach Public Works Supervisor, IMa. I requested that ME\* contact the employee assigned to the route of Epstein's residence and advise them to turn the trash over to me upon collecting it. + +At 10:20 a.m., I met with PB Sanitation worker Jeffery s. I observed M enter the driveway of 358 El Brillo and remove the trash and place the contents into the bed of the sanitation truck. + +I then followed to a predetermined location and seized the trash bags from the truck. I transported the trash to the Palm Beach Sanitation Department where I began sifting through its contents. There were a total of 2 bags inside, one black bag with a yellow draw string and a white in color bag with a yellow draw string. No items of evidentiary value were collected from the black bag. Inside the white bag, I found a Jeffrey E. Epstein white piece of note pad paper with a telephone number . This telephone number was held for evidentiary value, and turned over to Det. for follow-up. + +• + +A photo copy was attached with the supplement. + +End of supplement. + +File#2600-8 + +Det: • + +11/15/2005 + +On November 15, 2005 at 8:30 a.m., I responded to 358 El Brillo. While waiting for the sanitation employee, at 9:26 a.m., I observed Epstein's vehicle, a black 2004 Chevrolet Suburban leave the property with one occupant. I was unable to identify the driver of the vehicle. + +At 10:49 a.m., I met with PB Sanitation workerJeffreyy n. I observed s enter the driveway of 358 El Brillo. I observed s return to the sanitation truck without any trash bags from Epstein's property. I then followed Ms to a predetermined location, to confirm that no trash had been collected from Epsteins property. a advised me that Epstein's trash containers were empty. + +No other action was taken. + +File#2600.8 + +Det: + +11/16/2005 + +On November 16, 2005 at 8:30 a.m., I responded to 358 El Brillo. At 11:17 a.m., I met with PB Sanitation worker . I observed\_enter the driveway of 358 El Brillo. I observed return to the sanitation truck with a white trash bag from Epstein's property. I then followed =Ito a predetermined location, to seize the trash from the truck. + +I transported the trash to the Palm Beach Sanitaion Department where I began sifting through its contents. The white trash bag was tied in a knot at the top. The bag contained documentation and correspondence for and two news letter magazines containing black and white adult pornographic pictures, articles and classified sex ads. + +The magazines and correspondences addressed to were collected for Detective . Upon returning to the police department, Detective IM advised me that materials collected contained nothing of evidentiary value. + +The material was disposed of . + +No other action was taken. + +File#2600-8 + +Det: + +11/18/2005 + +On November 18, 2005, I was unable to respond to 358 El Brillo to due other job related functions. I made contact with Detective i and advised him that arraignments needed to be made to met with the sanitation employee to seize the trash. + +No other action was taken. + +File#2600.8 + +Det: + +11/21/2005 + +On November 21, 2005, at 10:40 a.m., I responded to 358 El Brillo. At 10:40 a.m., I met with PB Sanitation workers. I observed a enter the driveway of 358 El Brillo. I observed a collect the trash from Epstein's property. I then followed a to a predetermined location, to seize the trash from the truck. + +I transported the trash to the Palm Beach Sanitation Department where I began sifting through its contents. The trash bag was white in color with a knot tied at the top. The bag contained documentation and correspondence for and Palm Beach magazines address to Jeffrey Epstein. + +The trash bag contained nothing of evidentiary value. + +Upon returning to the police department, I was advised by Sgt. Dean per Sgt. a to discontinue the trash pull for 358 El. Brillo. + +No other action was taken. + +2600-8 + +07-03-08 + +On June 30, 2008, Epstein pled guilty to the charges of Solicitation of Prostitution and procurement of a minor for prostitution. He was sentenced to 18 months imprisonment and must register as a sex offender. The Palm Beach Daily news as well as other sources of media rant the story. The Daily news article read as follows: + +Palm Beach billionaire Jeffrey Epstein pleaded guilty Monday morning in Palm Beach Circuit Court to felony charges that he solicited underage girls for prostitution. + +Judge Deborah Dale Pucillo sentenced Epstein, 55, to 18 months at the Palm Beach County Jail, followed by 12 months of house arrest, during which he will be confined to his home on El Brillo Way and permitted to leave only for work or community service. + +Epstein was taken directly into custody. + +He was sentenced to 12 months in jail for solicitation of a prostitute and six months for procuring a person under age 18 for prostitution. + +That will be followed by 12 months of house arrest, during which time he will be allowed no unsupervised contact with minors and no access to pornographic materials. The State Attorney's Office would not say how many victims there were in the case, but the incidents occurred in 2004 and 2005. + +In court Monday, Epstein wore a blue blazer, tennis shoes and blue jeans and was accompanied by at least two attorneys, West Palm Beach lawyer Jack A. Goldberger and Miami attorney Guy Lewis. + +Epstein responded politely when asked by the judge if he had read and fully understood the terms of his plea agreement. + +As a condition of the agreement, Epstein will be registered as a sex offender for the rest of his life. But he will not be required to undergo treatment for his condition. His lawyer said Epstein has been seeing a psychiatrist. + +After he leaves jail, Epstein will not be required to wear an electronic monitor, but will have to keep a daily log of his activities and maintain weekly contact with a probation officer. He will be allowed to leave his home for up to a half-hour while traveling to and from work or community service. + +Goldberger would not comment on the case. But Epstein's spokesman, Howard J. Rubenstein, said in a statement that Epstein has now resolved the criminal case. + +"Mr. Epstein accepted responsibility for the charges, relating to conduct that occurred several years ago," Rubenstein said. + +A Manhattan investment banker, Epstein was scheduled to go to trial in July after being indicted in July 2006 on a felony charge of soliciting prostitution. + +The indictment followed an 11-month investigation by Palm Beach Police. Police said Epstein paid five underage girls for massages and sometimes sex at his El Brillo Way home. + +Epstein also faces five lawsuits in federal and state courts from women who claim that he sexually assaulted them when they were younger than 18. The lawsuits claim Epstein procured the underage girls, through a Palm Beach Community College student, to come to his El Brillo Way home and give him massages. + +Lewis, who is representing him in the civil cases, has said the lawsuits are without merit and that the alleged victims lied about their ages. + +Epstein was cuffed, fingerprinted and taken to jail. He will fulfill a 12-month community service requirement at his own nonprofit Florida science foundation. + +08-01-08 + +2600.8 + +On Saturday July 12, 2008, an article ran in the Sun Sentinel newspaper local section. The article stated the following: + +Two underage girls who claim to have been sexually abused by Palm Beach billionaire Jeffrey Epstein appeared in federal court Friday to argue that the government's plea agreement with the investment banker was too lenient and "they had no voice in the process." + +"These girls want justice. They want this guy in prison," said attorney Brad Edwards, who represents them in federal civil suits filed against Epstein in February. There are about five suits each asking for SS0 million pending in federal court against him. + +On June 30, according to a plea agreement struck with the government, Epstein pleaded guilty to procuring a person under 18 for prostitution and felony offer to commit prostitution. The counts stemmed from his involvement with one underage girl. + +He faced a maximum of 15 years and was given 18 months. In court Friday, Edwards told U.S. District Judge Kenneth Marra the plea agreement "was worked out behind the victims' backs." Edwards said that part of the confidential agreement was that the federal government would not prosecute Epstein for abusing more victims if he pleaded guilty to abusing one in state court. + +"The agreement was that he could plead guilty to abusing one girl in state court so that he wouldn't be prosecuted in federal court for the 100 other girls he molested," Edwards told Marra. + +The two girls, identified in court papers as and did not testify on Friday. + +Epstein's attorneys were not present at the hearing which involved federal prosecutors. Edwards invoked a federal crime victims law to raise the issue in federal court, where he wanted Marra to kill the plea agreement. Under the law, victims have a right to confer and Edwards said they were not consulted about the agreement. Assistant U.S. Attorney argued that the federal court did not have jurisdiction and Marra agreed. Epstein's attorney, Jack Goldberger, could not be reached for comment. + +Edwards said that one of his underage clients started visiting Epstein at his sprawling mansion on El Brillo Way when she was 13 to give him massages for \$200. Police reports have said that the girls would be escorted to a bedroom with a massage table and that Epstein would enter wearing only a towel and instruct the girls to remove their clothing and massage him. These sessions escalated into touching and other activities, sometimes with sex toys. Edwards said that when his client turned 14, Epstein told her that she could make \$200 for every girl she recruited for the massage sessions. She claimed she recruited 50. + +In court, Edwards told Marra: "Mr. Epstein is a billionaire who has sexually abused dozens and dozens of 13- to 17-year-old girls. And because of his deviant appetites and his vast wealth, he might just be the most dangerous sexual predator in the world." + +Based on the above article, on July 15, 2008, I contacted Atty. Brad Edwards. Atty. Edwards explained he was going to contact me reference his clients. His clients have claimed that they are victims of sexual abuse. They allege that Jeffrey Epstein had sexually abused them and approximately fifty (50) others underage girls. Edwards explained he would reach out to the clients and schedule appointments for interviews. I provided Edwards with my telephone numbers and advised to call me when he is available. I informed him I would contact to ascertain if the plea negotiations which occurred on June 30, 2008, covered only the listed victims in the State v. Jeffrey Epstein case. Edwards assured me that his clients were not previously interviewed by our agency during the previous investigation. I telephoned the State Attorney's Office and left messages for to call me. + +After leaving several messages for ASA , I made telephone contact with her on Friday, July 18, 2008. MMM was asked which victims were covered under the plea agreement. stated all the victims I had presented her originally in the probable cause affidavit were covered in the plea agreement. I received a telephone call from Atty Edwards who advised he had spoken with his clients and they are willing to meet with me at the Palm Beach Police Department. Edwards stated he would be going on his annual leave and return during Aug 4, 2008. I informed Atty Edwards I would advise him when I would meet with his clients after August 12, 2008. It should be noted the meeting did not occur due to the fact Edward's clients were already covered the on the original agreement. + +08/25/09 + +2600-8 + +On July 22, 2009, several news agencies reported the following: + +Jeffrey Epstein left the Palm Beach County jail just before dawn Wednesday after serving less than 13 months of his 18-month sentence for procuring a young girl for prostitution and soliciting prostitution. + +"Jeffrey is just happy this is over," his attorney Jack Goldberger told reporters gathered at the jail's front door -- an exit Epstein avoided, using a side door instead to leave without comment. While this closes the chapter for now on his criminal troubles, Epstein still faces many legal battles. + +A dozen lawsuits have been filed against the money manager on behalf of underage girls who claim to be his victims. "There was never any victims. There are women who have filed lawsuits against Mr. Epstein and we will challenge them," Goldberger said. + +For now, Epstein is headed to his Palm Beach home, Goldberger said. He described Epstein as feeling "relief and excitement." "He just wanted to go home and rest right now, and that's what he did," Goldberger said. The 56-year-old has 48 hours to register as a sex offender. + +He'll be on probation for the next year and will have to contact his probation officer weekly. Epstein is also required to donate a sample of his DNA for the state's database. While Epstein has been serving time since he pleaded guilty to two felony charges last June, this won't be his first time he steps out of confinement. He's been heading to work every weekday and some weekends since last October as part of a work-release program. + +According to jail records, Epstein, wearing an ankle bracelet, was free from 7 a.m. to 11 p.m. weekdays and even weekends to work at the Florida Science Foundation, a nonprofit he created before he was sentenced. + +The lawsuits filed on behalf of several alleged victims all describe the man's pursuit of erotic massages and sex from young girls similarly: A minor girl (some reported to be as young as 15) is brought to Epstein's mansion on El Brillo Way and taken to the spa room upstairs by one of his assistants. Then he'd ask the girl to give him massages and/or perform sex acts for which he would pay her. + +After Epstein's release from Palm Beach County Jail, I was informed that Epstein was to be confined to his house on El Brillo Way in Palm Beach. I confirmed with Epstein's probation officer, what he is allowed to do while out on community control for one year. stated he is to submit a schedule for any appointments he must have. This also includes any work related issues. On August 19, 2009 , while driving in the area of Hammon and the Ocean, I observed Jeffrey Epstein walking northbound along the ocean. I maintained visual contact with Epstein and was able to photograph Epstein walking with his bodyguard/trainer Igor. + +During the time from when Epstein was incarcerated, his release and recent, any media files have been placed in the OCVAN files under Jeffrey Epstein. + +10/09/2009 + +On October 9, 2009, I was notified by ASA about Jeffrey Epstein possibly violated the nonprosecution agreement. Epstein, accompanied by his body guard/trainer, a, showed up to a deposition on one of the victims. The deposition was to be held at the attorney for the victim s office. Epstein was to be phoned to participate in the deposition. Epstein walked into the lobby and stood directly in front of the victim s Epstein stared at her and whispered something to the bodyguard while smirking and pointing at the victim. The victim burst into tears and left the deposition. + +As Epstein was not allowed to any contact with the victim, ASA is seeking prosecution on Epstein for violating the no contact order. I recommended she contact the AUSA for assistance on the no contact prosecution. As the incident did not occur within the Town of Palm Beach, This is for the file only. + +10/17/2019 + +Sgt. a + +On August 10, 2019, several news outlets reported the death of Jeffrey Epstein. On July 6, 2019, Epstein was arrested on federal charges stemming from this investigation of alleged sexual abuse of underage girls. Epstein was found unresponsive in his cell at the Manhattan Correctional Center (NY,NY) and his death was being investigated as an apparent suicide. + +09/07/2020 + +Detective a - + +See below + +Original Message + +From: m> + +Sent: Monday, September 07, 2020 9:18 AM + +To: m>; Om> + +Subject: FW: Epstein's Buddy Clinton + +Lt. a & Sgt. a, + +Did either of you receive this email too? + +Regards, + +---Original Message + +From: Chris Hepburn li n> + +Sent: Sunday, September 06, 2020 5:26 AM + +To: M> + +Subject: Epstein's Buddy Clinton + +\*\*\*\*\*\*Note: This email was sent from a source external to the Town of Palm Beach. Links or attachments should not be accessed unless expected from a trusted source. Additionally, all requests for information or changes to Town records should be verified for authenticity.\*\*\*\*\*\* + +See below where I Ref Clinton the " Guest Of Honour" at times at Epstein's parties that were awash with underage girls. + +I am aware that people find integrity a tad problematic within your Parasitic Nation. + +However what I am not aware of was there a codicil to that pissant piece of paper that was penned by a bunch of semi literate colonials the US Constitution. + +Did that codicil state that crackers such as Clinton can rape women without risk of prosecution. + +Did it say crackers like Clinton can engage in sexual acts with girls in their early teens. + +Punch will be spinning in his grave at how vacuous and vile the US media has become as would Kay Graham. + +The so called Holy Grail of Journalism a Pulitizer who would want one. + +I would rather that buffoon in Albany dining out on his Daddies name would give me a " Get Out Of Jail" card in advance. + +One 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FIRST | | W | +| ROBERT | | | + +PALM BEACH + +| TELEPHONE NUMBER | DATE OF BIRTH | +|------------------|---------------| +|------------------|---------------| + +CONTROL WORK IMPAIRED, OR DRAWING FACTUAL, PHYSICAL CONTRAINT WITH OTHER VIOLATIONS OR COMMENTS PERTAINING TO OFFENSE + REAR ENDED VEHICLE TRAVELING IN SAME DIRECTION + +FHPL-06-OFF-066887 + +CRIMINAL VIOLATION COURT APPEARANCE REQUIRED AS BECAUSE THE COURT WAS NOT REQUIRING APPEARANCE IN COURT. + +![Stamped court information for Palm Beach County Court Delray 04.]()COURT INFORMATION DATE PALM BEACH COUNTY COURT DELRAY 04 + WITHIN 30 DAYS + LOCATION SEE MAILER + +ARREST DELIVERED TO \_\_\_\_\_ DATE \_\_\_\_\_ + ARREST AND PROCEED TO COMPLT AND ARREST TO THE CHARGES AND INSTRUCTIONS SPECIFIED IN THIS STATION VOL. FILE REPORT. TO ACCEPT AND SEND THE + FILES AND PROCEED TO COMPLT AND ARREST TO THE CHARGES AND INSTRUCTIONS SPECIFIED IN THIS STATION VOL. FILE REPORT. TO ACCEPT AND SEND THE + FILES AND PROCEED TO COMPLT AND ARREST TO THE CHARGES AND INSTRUCTIONS SPECIFIED IN THIS STATION VOL. FILE REPORT. TO ACCEPT AND SEND THE + FILES AND PROCEED TO COMPLT + +**NEXT** Financial Associates Inc. + +Robert W. Parr +Director + +▶ Office: [REDACTED] + Cellular: [REDACTED] + Fax: [REDACTED] + +► Email: [www.applyforyourloannow.com](mailto:www.applyforyourloannow.com) + +*The Sunshine State* — +LICENSE NUMBER + +**COPY RESTRICTIONS** + +**DECEMBER 23, 2015** + +H DATE SEX AGE RACE + +DATE SEX HGT REST ENDORSE + +REC'D EXPIRES 09-18-07 DUPLICATE 09-15-04 + +**A** second step in the process of constructing a structure is to design a structure that is completely compatible with + +ORGAN DONOR +P030406150018 +Operation of a motor vehicle constitutes consent to any subjective test required by law. + +Zurich Mortgage Solutions +Robert W. Parr, II +Principal + +Business Cell Fax **561-629-9400** \ No newline at end of file diff --git a/marker2/ds9/EFTA00090716/EFTA00090716.metadata.json b/marker2/ds9/EFTA00090716/EFTA00090716.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..a1b2f52b6bf613c500c562a4d0a9e4e2aecc32c9 --- /dev/null +++ b/marker2/ds9/EFTA00090716/EFTA00090716.metadata.json @@ -0,0 +1,50 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090716.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 2299, + "elapsed_seconds": 192.69, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Text", + 62 + ], + [ + "Form", + 2 + ], + [ + "Picture", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00090716" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00090717/EFTA00090717.md b/marker2/ds9/EFTA00090717/EFTA00090717.md new file mode 100644 index 0000000000000000000000000000000000000000..05fcd3e8bb3ee7dd74a6c4c8d5960942f8f09207 --- /dev/null +++ b/marker2/ds9/EFTA00090717/EFTA00090717.md @@ -0,0 +1,21 @@ +## FEDERAL BUREAU OF INVESTIGATION Import Form + +![](_page_0_Picture_2.jpeg) + +Form Type: .)-71A - Guardian Complaint Form Date: 13/18/2021 + +Title : 7.1! ./FCJC Accusations of Rape and hurts!: trafficking + +Approved By: + +Drafted By: + +Case ID #: 50D-NY-3027571 (U) EPSTEIN, JEFFREY; CHILD SEX TRAFFICKING + +Synopsis: U//FOUO DOCUMENT SYNOPSIS CREATED ON 10-18-2021 01:07 PM--SEE GUARDIAN 762214\_NY FOR CURRENT ASSESSMENT DATA. + +An attorney serving as outside counsel for the Attorney General of Virgin Islands in a civil matter against the Jeffrey Epstein estate contacted SSA regarding information obtained in the course of her investigation. + +Two women, one located in and one made accusations against Jes Staley, the CEO of rape. One of the women believes that she spoke accusations previously. Attorney wanted was aware of these accusations. located elsewhere, have Barclays to the FBI to be sure Bank, of violent with these that the FRI + +in addition, during the course of their investigation they have seen information showing that Epstein's attorney and accountant were aware of the activities occurring and were helping in perpetuating the crimes being committed by covering them up. \ No newline at end of file diff --git a/marker2/ds9/EFTA00090717/EFTA00090717.metadata.json b/marker2/ds9/EFTA00090717/EFTA00090717.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..ef767b88ef15bda7a9c439d114bbf53d135da1fc --- /dev/null +++ b/marker2/ds9/EFTA00090717/EFTA00090717.metadata.json @@ -0,0 +1,92 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090717.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1186, + "elapsed_seconds": 0.81, + "image_assets": [ + "_page_0_Picture_2.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "FEDERAL BUREAU OF INVESTIGATION \nImport Form", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 129.744, + 59.129999999999995 + ], + [ + 476.64617919921875, + 59.129999999999995 + ], + [ + 476.64617919921875, + 87.482421875 + ], + [ + 129.744, + 87.482421875 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 76 + ], + [ + "Line", + 35 + ], + [ + "Text", + 11 + ], + [ + "PageHeader", + 2 + ], + [ + "PageFooter", + 2 + ], + [ + "Picture", + 1 + ], + [ + "SectionHeader", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00090717" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00090717/_page_0_Picture_2.jpeg b/marker2/ds9/EFTA00090717/_page_0_Picture_2.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..920783ed11112f63797e0be90929d8fa72493ddb --- /dev/null +++ b/marker2/ds9/EFTA00090717/_page_0_Picture_2.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:727974bd74c25ca98f1dc03fc17302cec3dddbf57a282b940ed87d2f6f656dea +size 4724 diff --git a/marker2/ds9/EFTA00090718/EFTA00090718.md b/marker2/ds9/EFTA00090718/EFTA00090718.md new file mode 100644 index 0000000000000000000000000000000000000000..9661d98606bb812185b3cc1fb7fabeeb1b678744 --- /dev/null +++ b/marker2/ds9/EFTA00090718/EFTA00090718.md @@ -0,0 +1,114 @@ +Generated: 10/18/2021 1:07 PM EDT + +#### Incident Summary + +762214\_NY (U//FOUO) Accusations of Rape and human trafficking + +![](_page_0_Picture_4.jpeg) + +| James 'Jos" Edwards Staley HO-CID-108-III-21 (UHFOUO) Human Trafficking | | 762214_NY Status: Closed (on 10/18(2021) This relates to or enhances an existing Pl(FI | | +|-------------------------------------------------------------------------|------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------| +| Subject Type: | Main | | | +| Oa* Lag Checked | Database | | | +| (Male) Social Security: | (U//FOUO) James -Jet" Edwards Staley Other Information: CEO of Barclays Bank | S. | Criminal Status: Closed Information Only | +| | | Threat to Lae' | NO | +| | | Report Type: | Human Trafb:kag/ EXPIPtelian | +| | | Activity Type: | Sexual Exploitation/Muse. | +| | | | C0mmertLel sex (Clad sex tourism oversees) | +| | | Receipt /nettled. Reported By | Te | +| | | Feld Deco. | NEW YORK | +| | | ASSIV*0 SOW | NY.C20 | +| | | RW0vel(S) Report Creator Report Owner | NY .c"n Strarocers | +| Beserine Compliant O | tCV14/2021 | Baseline P Authoriced Methods UN Dale Last checked Technique 1J:had admnistrativenoce (or intormewnsi purposes Baseline Comptant | | + +(U//FOUO) An attorney serving as outside counsel for the Attorney General of Vi in Islands in a civil matter against the Jeffrey Epstein estate contacted SSA regarding information obtained in the course of her investigation. + +Two women, one located in New York City and one located elsewhere, have made accusations against Jes Staley, the CEO of Barclays Bank. of violent rape. One of the women believes that she spoke to the FBI with these accusations previously. Attorney —wanted to be sure that the FBI was aware of these accusations. + +In addition, during the course of their investigation they have seen information showing that Epstein's attorney and accountant were aware of the activities occurring and were helping in perpetuating the crimes being committed by covering them up. + +#### Subjects + +(U//FOUO) James "Jes" Edwards Staley (Male) + +Other Information: CEO of Barclays Bank + +Social Security: + +Subject Type: Main + +# Investigative Notes + +(U) Conferrals + +Authorized Administrative note for informational purposes. Method: + +Status: Completed + +History: 1O11412021 01:55:51 PM Created Note: Conferrals ( NEW YORK MY-C20) + +Description: On 8/25/2021 and 10/13/2021 Detective I= conferred with SSA regarding the inlet and its origin provided in this guardian. Detectives and agents in Now York are aware of complaints associated with the listed individuals. On 10/13/2021 Detective conferred with AUSA regarding the information provided in this guardian. + +# Referrals + +Has this matter No been referred to OGNState/ Local? + +#### Disposition + +# (U) Disposition + +Note: Investigation Type: Disposition: Associated Case Numbers: Relates to captioned case. Full This relates to or enhances an existing PI/FI 50D-NY-3027571 + +# Workflow + +08/25/2021 12:23:51 PM Created Incident + +08/25/2021 12:34:27 PM Incident submitted for opening + +09/17/2021 12:12:56 PM Incident transferred Health Care Fraud UM (HCFU) SSA ed this information while in contact with Attorney on an unrelated HCF matter. HCFU is transferring tits Incident to NYO for information and any action deemed appropriate. 09/17/2021 12:50:30 PM Incident assigned + +for action deemed appropriate + +09/21/2021 01:53:35 PM Incident reassigned + +09/21/2021 02:55:46 PM Incident assigned for pre-assessment + +I believe you already spoke to this FBI SSA about this allegation. + +10/14/2021 01:56:34 PM Incident submitted from pre-assessment + +10/18/2021 01:06:49 PM Closed as Information Only + +Assigned By: CRIMINAL INVESTIGATIVE /Ma + +Assigned To: CRIMINAL INVESTIGATIVE 7124-a + +Assigned By: CRIMINAL INVESTIGATIVE /06-HCFU ) + +Assigned To: ( CRIMINAL INVESTIGATIVE 106 HCFU Assigned By: CRIMINAL + +INVESTIGATIVE /D6-HCFU ) Assigned To: ( NEW YORK ) + +Assigned By: NEW YORK /NY-OSIS ) + +Assigned To: NEW YORK MY-C19 + +Assigned By: ( NEW YORK MY-C19) + +Assigned To: NEW YORK /NY-C20 ) + +Assigned By: ( NEW + +YORK /NY-C20) + +Assigned To: ( NEW YORK /NY-C20 + +Assigned By: ( NEW YORK + +/NY-C20) + +Assigned To: NEW 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+https://radaronline.com/exclusives/2015/01/jeffrey-epstein-sex-scandal-victim-hollywood-actress/ \ No newline at end of file diff --git a/marker2/ds9/EFTA00090720/EFTA00090720.metadata.json b/marker2/ds9/EFTA00090720/EFTA00090720.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..de0915ab659074cd97f761e2a72945f6b63affba --- /dev/null +++ b/marker2/ds9/EFTA00090720/EFTA00090720.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090720.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 192, + "elapsed_seconds": 0.3, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + 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Pagliuca Laura A. Menninger HADDON MORGAN & FOREMAN P.C. + +Denver Phone: + +Christian R. Everdell COHEN & GRESSER LLP + +New York NY Phone: + +Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim + +Attorneys for Chislaine Maxwell + +#### TABLE OF CONTENTS + +- I. +- A. +- B. +- C. +- D. THIS COURT SHOULD PRECLUDE INTRODUCTION OF ALLEGED CO-CONSPIRATOR STATEMENTS AS A SANCTION FOR GOVERNMENTS FAILURE TO COMPLY WITH THIS COURT'S SEPTEMBER 3, 2021 ORDER 1 The Court's Order was Neither Ambiguous Nor Misread by the Defense 1 The Court Has the Authority to Require Disclosure 2 There Should Be a Sanction 4 There are Substantial Issues with the Government's Anticipated Position 5 +- II. GOVERNMENT CONCEDEDLY FAILED TO GIVE NOTICE OF THE BASIS OR REASONING TO ADMIT ANY 404(B) EVIDENCE 6 + - A. The Emails Bear No Relationship to the Charged Conspiracy, Reflect Pure Propensity Evidence, and Otherwise are Unduly Prejudicial to Uninvolved Third-Party Adults .7 + - B. 11 + - 1. 12 + - 2. The government has apparently abandoned efforts to introduce her testimony as Rule 404(b) evidence 13 + - 3. constitutes an impermissible constructive amendment and variance to the Indictment. 13 + - C. briefing and ruling on the admissibility for two weeks. 15 Ms. Maxwell reiterates her re. uest to defer +- III. THIS COURT SHOULD EXCLUDE i TESTIMONY UNDER FEDERAL RULE OF EVIDENCE 702 AND DAUBERT V. MERRELL DOW PHARMACEUTICALS, INC., 509 U.S. 579 (1993) AND GRANT A DAUBERT HEARING 15 + - A. This Court should reject the government's arguments to the extent that they are based on newly disclosed material, which this Court ordered the government to produce six months ago 15 + - B. proposed testimony is inadmissible 17 + - C. At a minimum, this Court should hold a Daubers hearing. 23 +- IV. THE COURT SHOULD EXCLUDE EVIDENCE RELATEDMI 24 +- V. THE GOVERNMENT CONCEDES THAT IT WILL NOT OFFER EVIDENCE OF MS. MAXWELL'S ALLEGED "FLIGHT" 32 + +- VI. THE GOVERNMENT CONCEDES THAT IT WILL NOT OFFER EVIDENCE OF MS. MAXWELL'S ALLEGED FALSE STATEMENTS AND AGREES TO MS. MAXWELL'S PROPOSED REDACTIONS32 +- VII. THE COURT SHOULD HOLD A PRE-TRIAL EVIDENTIARY HEARING ON MS. MAXWELL'S MOTION TO SUPPRESS IDENTIFICATION. 32 +- VIII. GOVERNMENT AGREES NOT TO ELICIT LAW ENFORCEMENT OPINION TESTIMONY 35 +- IX. THE COURT SHOULD PRECLUDE TESTIMONY ABOUT ANY ALLEGED "RAPE" BY JEFFREY EPSTEIN 36 +- XII. REFERENCE TO ACCUSERS AS "VICTIMS" IS IMPROPER VOUCHING 38 +- XIII. THE COURT SHOULD PRECLUDE INTRODUCTION OF GOVERNMENT EXHIBITS 52, 251, 288, 294, 313, 606 AND THE SEARCH OF EL BRILLO WAY 41 + - A. The Court Should Exclude the Challenged Government Exhibits 41 + - B. Government Exhibit 52 42 + - C. The Palm Beach Search of El Brillo Way 42 + - D. 43 + - E. The Twin Torpedoes 43 + - F. Government Exhibit 313 44 + - G. Government Exhibit 606 44 + +### TABLE OF AUTHORITIES + +#### Cases + +| Cf. State v. Wigg, 889 A.2d 233 (Vt. 2005) | 40 | +|---------------------------------------------------------------------------------------|--------| +| Daubert v. Merrell Dow Phanns., Inc., 509 U.S. 579 (1993) | passim | +| 2018) | 41 | +| Esquivel-Quintana v. Sessions, 137 S. Ct. 1562 (2017) | 30 | +| Highland Capital Mgmt., L.P. v. Schneider, 379 F. Supp. 2d 461 (S.D.N.Y. 2005) | 41 | +| Lou v. United States, 218 F.2d 675 (5th Cir. 1955) | 5 | +| Old Chief v. United States, 519 U.S. 172 (1997) | 38 | +| People v. Davis, 423 N.Y.S.2d 229 (N.Y. App. Div. 1979) | 39 | +| Raheem v. Kelly, 257 F.3d 122 (2d Cir. 2001) | 34 | +| Ricketts v. City of Hartford, 74 F.3d 1397 (2d Cir.1996) | 41 | +| Solomon v. Smith, 645 F.2d 1179 (2d Cir. 1981) | 34 | +| State v. Cortes, 851 A.2d 1230 (Conn. App. Ct. 2004) | 39 | +| State v. Sperou, 365 Or. 121, 131, 442 P.3d 581 (2019) | 40 | +| Talkington v. State, 682 S.W.2d 674 (Tex. App. 1984) | 39 | +| United States v. Angelilli, 660 F.2d 23 (2d Cir. 1981) | 8 | +| United States v. Arroyo, 600 F. App'x 11 (2d Cir. 2015) | 7 | +| United States v. Bagaric, 706 F.2d 42 (2d Cir. 1983) | 26 | +| United States v. Bocio, 103 F. Supp. 2d 531 (N.D.N.Y. 2000) | 2 | +| United States v. Bozeman, No. 3:11-CR-129, 2012 WL 1071207 (E.D. Tenn. Mar. 29, 2012) | 3 | +| 2018) | 3 | +| United States v. Bums, No. 07 CR 556, 2009 WL 3617448 (N.D. III. Oct. 27, 2009) | 20, 21 | +| United States v. Cummings, 60 F. Supp. 3d 434 (S.D.N.Y. 2014) | 26 | +| United States v. Curley, 639 F.3d 50 (2d Cir. 2011) | 26 | +| United States v. D 'Amelio, 683 F.3d 412 (2d Cir. 2012) | 14 | +| United States v. Dupre, 462 F.3d 131 (2d Cir. 2006) | 14 | +| United States v. Ehrens, No. CR-15-200-C, 2015 WL 7758544 (W.D. Okla. Dec. 1, 2015) | 39 | + +| United States v. English, No. 18 Cr. 492 (PGG) (S.D.N.Y. 2020) | 37 | +|--------------------------------------------------------------------|------------| +| United States v. Golyansky, 291 F.3d 1245 (10th Cir. 2002) | 4 | +| Gross, 15-cr-769 (MN), 2017 WL 4685111 (S.D.N.Y. Oct. 18, 2017) | 14 | +| Jacobs, 650 F. Supp. 2d 160 (D. Conn. 2009) | 2 | +| LaFlan:, 369 F.3d 153 (2d Cir. 2004) | 7 | +| Lee, 834 F.3d 145 (2d Cir. 2016) | 4 | +| Lewis, 818 F. App'x 74 (2d Cir. 2020) | 15 | +| Moccia, 681 F.2d 61 (1st Cir. 1982) | 38 | +| Mollica, 849 F.2d 723 (2d Cir. 1988) | 14 | +| Nektalov, 325 F. Supp. 2d 367 (S.D.N.Y. 2004) | 29, 37 | +| Pineros, 532 F.2d 868 (2d Cir. 1976) | 4 | +| Raymond, 700 F. Supp. 2d 142 (D. Me. 2010) | 20, 21, 22 | +| Rigas, 490 F.3d 208 (2d. Cir. 2007) | 14 | +| Salmonese, 352 F.3d 608 (2d Cir. 2003) | 14 | +| Sena, No. 19-CR-01432, 2021 WL 4129247 (D.N.M. Sept. 9, 2021) | 39, 40 | +| Sliker, 751 F.2d 477 (2d Cir.1984) | 41 | +| Smalls, No. CR 06-2403 RB, 2008 WL 11361098 (D.N.M. Jan. 24, 2008) | 3 | +| Stein, 521 F. Supp. 2d 266 (S.D.N.Y. 2007) | 38 | +| Tracy, 12 F.3d 1186 (2d Cir.1993) | 5 | +| Velez, No. 3:10CR147 JBA, 2010 WL 4929266 (D. Conn. Nov. 30, 2010) | 3 | +| Vickers, 708 F. App'x 732 (2d Cir. 2017) | 28, 31 | +| Von Foelkel, 136 F.3d 339 (2d Cir. 1998) | 26 | +| Williams, 506 F.3d 151 (2d Cir. 2007) | 22 | + +### Statutes + +| 18 U.S.C. § 1591 | 37 | +|-------------------------|----| +| 18 U.S.C. § 2422 | 28 | +| 18 U.S.C. § 2423(a) | 28 | +| N.Y. Penal Law § 130.55 | 28 | + +### Other Authorities + +## Rules + +| Fed. R. Crim. 16 | 17 | +|----------------------|----------------| +| Fed. R. Evid. 104 | 41 | +| Fed. R. Evid. 401 | 22, 43 | +| Fed. R. Evid. 402 | 10, 16, 43, 44 | +| Fed. R. Evid. 403 | passim | +| Fed. R. Evid. 404(b) | passim | +| Fed. R. Evid. 412 | 14, 18, 22 | +| Fed. R. Evid. 702 | 17, 21, 22 | +| Fed. R. Evid. 801 | 2, 3, 5 | + +Ghislaine Maxwell hereby submits her Reply In Support of Her Motions in Limine. + +#### I. THIS COURT SHOULD PRECLUDE INTRODUCTION OF ALLEGED CO-CONSPIRATOR STATEMENTS AS A SANCTION FOR GOVERNMENT'S FAILURE TO COMPLY WITH THIS COURT'S SEPTEMBER 3, 2021 ORDER + +The government offers several excuses for its failure to comply with this Court's September 3, 2021 Order. These excuses are insufficient and should be rejected. + +# A. The Court's Order was Neither Ambiguous Nor Misread by the Defense + +First, the government suggests that Ms. Maxwell has misread the Order. We disagree. The Court unambiguously rejected the government's position and ruled that the government's expressed concern about disclosure "does not outweigh the risk of surprise to the Defendant in this case or the need for the parties to litigate co-conspirator issues in advance of trial to ensure the absence of delay." Dkt. 335 at 3. To both "avoid the risk of surprise" and "litigate coconspirator issues in advance of trial to ensure the absence of delay, " the Court identified two things that were necessary from the government: First, no later than October 11, 2021, the government was required to "disclose to the defense the identities of any unnamed coconspirators who allegedly participated in the conspiracies charged in the S2 indictment to whom the government will refer at trial." Id. Second, the Court, unambiguously and emphatically, directed: "The Government is FURTHER ORDERED to disclose all co-conspirator hearsay statements it intends to offer at trial no later than October 11, as consistent with this Court's scheduling order. Dkt. No. 297 at 1." (emphasis in original.) + +The Court used the word "disclose" both as to the identity of the co-conspirators "to whom the government will refer to at trial" and "all co-conspirator hearsay statements it intends to offer at trial...." The government, in an attempt to blunt the Order, decided to interpret the same word, "disclose" in materially distinct fashions. As to the identity of the co-conspirators, the government disclosed (Le., identified) three names. When it was parsing the second part of + +the Order, however, the government defined the word "disclose" differently. Disclose, as to the actual statements, according to the government, means "produced" at some time in the past or to be produced in the future, perhaps as an oral statement during trial. + +Of course, the Court will tell the parties whether it meant two completely different things when it used the same word, as argued by the government, or whether it intended for the government to disclose the statements it intends to offer as co-conspirator statements. To avoid delay over this issue during trial, Ms. Maxwell suggests that she cannot litigate this issue in advance of trial without knowing what statements are being offered under Federal Rule of Evidence 801(d)(2)(e). + +What is clear from the government's response is not that it misunderstood the Order, but rather, it continues to disagree with the Order. + +# B. The Court Has the Authority to Require Disclosure + +Second, doubling down on its disagreement with the Court, the government claims "it is aware of no such case" in which a court ordered the identification of anticipated co-conspirator statements prior to trial. While the government may not be "aware" of such cases, they certainly, and abundantly, exist. + +In United States v. Bocio, 103 F. Supp. 2d 531, 534 (N.D.N.Y. 2000), the court ordered pretrial disclosure of statements of co-conspirators (Government "must disclose to the defendant and make available for inspection, copying, or photographing: any relevant written or recorded statements ..., or copies thereof, within the possession, custody, or control of the government."). + +In United States v. Jacobs, 650 F. Supp. 2d 160, 171 (D. Conn. 2009), the court ordered co-conspirator statements be produced in advance of trial ("In the case of a co-conspirator who the government plans to call as a witness at trial, that time is now, and the government is directed to produce any relevant statement to defense counsel forthwith.") + +In United States v. Velez, No. 3: 10CRI47 JBA, 2010 WL 4929266, at \*7 (D. Conn. Nov. 30, 2010), the defendant moved for disclosure of any co-conspirator statements in advance of trial. In response, the government agreed to disclose "well in advance of trial, exactly which of the intercepted telephone calls will be offered as full exhibits at trial and transcripts of those calls will be provided in advance of trial." Based on that representation the court denied the motion to produce as moot, "without prejudice to renew if the Government fails to comply with its ongoing disclosure obligations." Id. + +In United States v. Smalls, No. CR 06-2403 RB, 2008 WL 11361098, at \*8-9 (D.N.M. Jan. 24, 2008), the court's order was very detailed: + +The United States is hereby instructed to: + +file a supplemental brief identifying the summary witness; specifically identifying each and every coconspirator statement it intends to offer at trial as evidence against Defendants pursuant to Fed. R. Evid. 801(d)(2)(E); and stating how each proffered statement satisfies the requirements of Rule 801(d)(2)(E). Specifically, with respect to each alleged coconspirator statement, the United States must indicate: a) the identity of the coconspirator who made the alleged statement; b) the identity of the person or persons to whom the coconspirator statement was made; c) the identity of the witness who will testify at trial about the coconspirator statement; d) the content of the coconspirator statement; e) when the statement was made; 0 how the statement is in the course of the alleged conspiracy; and g) how the statement is in furtherance of the alleged conspiracy. Additionally, the United States must identify the independent evidence it intends to offer in support of admission of the alleged coconspirator statements. + +See also United States v. Brewington, No. 15-CR-00073-PAB, 2018 WL 1411274, at \*3 (D. Cob. Mar. 21, 2018) (court required the government to identify and produce all its purported 801(d)(2)(e) statements, in the hundreds; held an evidentiary pre-trial hearing about the admissibility of those statements; and made detailed, statement by statement rulings about admissibility, excluding some and conditionally admitting others); United States v. Bozeman, No. 3: II-CR-129, 2012 WL 1071207, at \*14 (E.D. Tenn. Mar. 29, 2012), affd, No. 3:11-CR- + +129-1, 2012 WL 1565099 (E.D. Tenn. May I, 2012) (government must disclose any statements of co-conspirators that it intends to use at trial three weeks prior to the trial). + +There is ample legal authority for the Court to enter the Order to avoid delays and arguments during trial about what statements are or are not within the 10-year conspiracy alleged here and to prevent surprise and prejudice to the Defendant. + +# C. There Should Be a Sanction + +Hedging its bets, the government acknowledges that it "may have misread the court's order" but offers no solution other than the defense is "free to litigate the admissibility of any such statement during trial." This was the government's losing argument before the Order. + +District courts have broad discretion to sanction a party who violates discovery orders. United States v. Golyansky, 291 F.3d 1245, 1249 (10th Cir. 2002). In considering a particular remedy for a violation, the factors considered are "the reasons why disclosure was not made, the extent of the prejudice, if any, to the opposing party, the feasibility of rectifying that prejudice by a continuance, and any other relevant circumstances." United States v. Lee, 834 F.3d 145, 159 (2d Cir. 2016) (quoting United States v. Pineros, 532 F.2d 868, 871 (2d Cir. 1976)). The appropriate remedy is exclusion. Ms. Maxwell has been in jail for approximately 18 months. She is trying not to request a continuance of the trial and her lawyers are making every effort to review massive amounts of discovery, interview potential witness, prepare for trial, and juggle a myriad of other responsibilities. The government offers no legitimate excuse for noncompliance. It clearly knows what statements it will try to introduce, it just does not want to tell anyone to avoid challenges to the statements. This is willful, not negligent or inadvertent conduct which should not be sanctioned by the Court. + +**D. There are Substantial Issues with the Government’s Anticipated Position** + +For a statement to fall within the definition of Fed. R. Evid. 801(d)(2)(E), “a court must find (1) that there was a conspiracy, (2) that its members included the declarant and the party against whom the statement is offered, and (3) that the statement was made both (a) during the course of and (b) in furtherance of the conspiracy.” *United States v. Tracy*, 12 F.3d 1186, 1196 (2d Cir. 1993). A cursory review of the discovery produced related to one purported co-conspirator demonstrates the folly of proceeding as the government persists. + +The government failed to follow the Court’s Order and fails to explain why it did not disclose the statements as ordered. Accordingly, the Court should prohibit introduction of any alleged co-conspirator statements at trial. + +### II. GOVERNMENT CONCEDEDLY FAILED TO GIVE NOTICE OF THE BASIS OR REASONING TO ADMIT ANY 404(B) EVIDENCE + +The government concedes that (i) it was aware of the December 2020 Amendments to Rule 404(b) (Resp. at 34), (ii) those Amendments required it to give notice of the "permitted purpose for which the prosecutor intends to offer the [404(b)] evidence and the reasoning that supports the purpose" (id.) ("Notice"), and (iii) the October 11'h "Maxwell Rule 404 Letter" ("Letter") did not identify the "permitted purpose" under Rule 404(b) for which the government seeks (alternative) admission of the two categories of evidence, nor the "reasoning that supports that evidence."' The government wholly fails to explain why it could not comply with these "relatively modest" new Notice requirements on the timeline ordered by this Court. Nowhere in response does the government seek leave for an extension to provide the appropriate Notice out of time nor justify its "good cause" for failure to timely comply with both the Court's Order and the Rule. Instead, they assert that "any alleged gap in the Government's notice is remediated by this brief." Resp. at 39-40. To quote the government's response to Ms. Maxwell's motion in limine,"to the extent the [government] takes issue with the rule" requiring specific pre-trial Notice under Rule 404(b), "that complaint is properly directed to the drafters of the Federal Rules of Evidence." Resp. at 61 n.15. + +Having failed to comply with the Notice requirements of the Rule by the (extended) Court ordered deadline of October 11, the government belatedly argues that the tendered evidence is either direct evidence or admissible under Rule 404(6). They are wrong on both fronts. + +I Under the misleading and disingenuous sub-heading (2) ("The Government has Met and Exceeded its Notice Obligations"), the government points only to its (i) October 11 disclosure of certain of the evidence (which gives neither a a proper "purpose" or "reasoning"), and (ii) its Response (the required "notice is remediated by this brief'). + +"In assessing whether a district court properly admitted other act evidence, we consider whether (1) it was offered for a proper purpose; (2) it was relevant to a material issue in dispute; (3) its probative value is substantially outweighed by its prejudicial effect; and (4) the trial court gave an appropriate limiting instruction to the jury if so requested by the defendant." *United States v. Arroyo*, 600 F. App'x 11, 13 (2d Cir. 2015) (summary order) (quoting *United States v. LaFlam*, 369 F.3d 153, 156 (2d Cir. 2004)). [REDACTED] are offered for improper purposes, i.e., propensity, are not relevant to any material issue in dispute and their probative value is substantially outweighed by their prejudicial effect. + +**A. [REDACTED] Bear No Relationship to the Charged Conspiracy, Reflect Pure Propensity Evidence, and Otherwise are Unduly Prejudicial [REDACTED]** + +The government's argument for admissibility of [REDACTED] is breathtaking in its claims and unsupported by admissible evidence. Without expert testimony or even bothering to interview [REDACTED] the government contends [REDACTED] represent "direct evidence" of a conspiracy (to recruit, groom, and sexually abuse *minor females* or to entice, transport or traffic them for Jeffrey Epstein's sexual pleasure) that [REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] Resp. at 36. + +[REDACTED] + +[REDACTED] + +--- + +2 The proffered evidence is found at GX 401-404, 409-410 and 413 [REDACTED]. + +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] + +The government contends that [REDACTED] reveal "defendant's intent and motive," but their argument is defies logic. [REDACTED] + +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] + +[REDACTED] This is exactly the type of evidence forbidden by Rule 404(b). *See United States v. Angelilli*, 660 F.2d 23, 40–41 (2d Cir. 1981) ("While we conclude that the custom and practice evidence was admissible for the purposes we have discussed, we agree with the defendants that Rule 404(b) barred its use to prove that the individual defendants acted in conformity with the custom and practice. ..."). + +Even if the Court overlooks the government's failure to provide notice, [REDACTED] absence of relevance to the charged conspiracy, and the government's failure to set forth a non-propensity ground for admissibility, [REDACTED] should also be excluded under Rules 401 and 403, as they do not tend to make any fact of consequence more or less probable, and their probative value is substantially outweighed by the danger of unfair prejudice and confusing the issues. [REDACTED] + +[Redacted] + +[Redacted] + +[Redacted] + +[Redacted] + +[Redacted] + +[Redacted] + +[Redacted] + +[Redacted] + +[Redacted] + +[Redacted] + +[Redacted] + +[Redacted] + +[Redacted] + +[Redacted] + +[Redacted] + +[Redacted] + +[Redacted] + +[Redacted] + +--- + +[Redacted] + +[Redacted] + +[Redacted] + +[Redacted] + +[Redacted] + +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] + +Ms. + +Maxwell strongly disputes that suggestion. Notably, as the Court can tell, the government did not offer any evidence (or any offer of proof in their Response) that this document *was* in fact + +--- + +drafted by Ms. Maxwell. *Compare* GX 417-B, 418-B, 420-B, 420-B (all purporting to represent metadata of other emails with the author identified). [REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] Such arguments are based on outdated stereotypes and reveal a reliance on character evidence that the Rules of Evidence specifically disallow. + +This Court should reject the belated, insufficient, improper argument that [REDACTED] are direct evidence of the charged conspiracy, should find they are propensity evidence barred by Rule 404(b) and should also exclude them under Rule 403 as more prejudicial than probative. + +**B.** [REDACTED] + +[REDACTED] + +[REDACTED] + +1. [REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] Mot. at 7. Defense counsel had insufficient time to + +review, investigate or rebut the admissibility of the materials as direct evidence less than one week later on October 18th. For that reason, the Motion did not move to exclude the evidence as direct evidence but rather sought additional time in which to do so. Given the drafting of hundreds of pages of pleadings in the last week, counsel is still unprepared to make the required showing on the direct evidence point and seeks additional time in which to do so. [REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] + +--- + +5 Bear in mind that the government also moved to *exclude* evidence that these same "abused" individuals reported to the police that they had no interactions or dealings with Ms. Maxwell. Gov't Motion in Limine at 42 ("The defendant is not charged with committing crimes against [the] victims [who reported that they had no interactions or dealings with Ms. Maxwell].") The fact that the government clearly intends to rely on how open the alleged abuse was, the relevance of evidence that even the people who claim they were abused by Epstein during the same time frame but without any knowledge or participation by Ms. Maxwell becomes highly relevant to rebut such testimony. + +#### 2. The government has apparently abandoned efforts to introduce her testimony as Rule 404(b) evidence. + +In their response, the government still fails to comply with the new Rule 404(b) notice requirements. First, they do not actually identify the evidence with any specificity, especially with respect to the "exhibits" that they hope to introduce through her. Second, while they use the words "plan and preparation" or "knowledge," they fail to explain how those uses of the testimony are independent of the character / propensity inference banned by Rule 404(b). How are the process and frequency of massages or the sexual nature of massages after the period of the conspiracy proof of a plan or preparation, apart from the propensity inference? A plan or preparation usually comes before an event. Planning or preparing for something after it has occurred can only be based on an assumption that because you are the kind of person who solicits underage massages later, you must have been the kind of person to do so earlier. Similarly, knowledge after the end of the conspiracy is not the same as knowledge at the time of or before the purported charged acts occurred, except by way of propensity. Finally, unspecified exhibits, many of which appear to have been written after the conspiracy (e.g., GX 505 — dated Feb. 14, 2005) cannot likewise be proof of the charged crimes which were allegedly completed before showed up. + +uses of Because the government makes no effort to argue the non-propensity purpose for these via Rule 404(b), and failed to give notice of the purposes or reason in advance in any event, this Court should exclude the evidence on this ground. + +#### 3. constitutes an impermissible constructive amendment and variance to the Indictment. + +Finally, what is clear from the government's proffer in their Response, the anticipated testimony o will serve as an improper constructive + +amendment to, and an impermissible variance of, the Indictment. As this Court previously has ruled: + +"To prevail on a constructive amendment claim, a defendant must demonstrate that 'the terms of [an] indictment are in effect altered by the presentation of evidence and jury instructions which so modify essential elements of the offense charged that there is a substantial likelihood that the defendant may have been convicted of an offense other than that charged in the indictment." United States v. D'Amelio. 683 F.3d 412. 416 (2d Cir. 2012) (quoting United States v. Mollica. 849 F.2d 723. 729 (2d Cir. 19881). Because the doctrine of constructive amendment protects a defendant's Grand Jury Clause rights, a constructive amendment constitutes a "per se violation" of the defendant's constitutional rights—i.e. there is no requirement that a defendant make a specific showing of prejudice. Id. at 417. In contrast to a constructive amendment, "[a] variance occurs when the charging terms of the indictment are left unaltered, but the evidence at trial proves facts materially different from those alleged in the indictment." Id. (quoting United States v. Salmonese, 352 F.3d 608. 621 (2d Cir. 2003)). + +United States v. Gross, 15-cr-769 (MN), 2017 WL 4685111, at \*20 (S.D.N.Y. Oct. 18, 2017). + +As this Court then recognized, the Second Circuit has consistently relied on the same start and end dates of a conspiracy to find that differing trial proof did not affect a constructive amendment or variance. See id. ("The indictment and the evidence at trial contained the same starting and ending dates of the conspiracy...") (quoting United States v. Rigas, 490 F.3d 208, 229 (2d. Cir. 2007)); see also United States v. Dupre, 462 F.3d 131, 141 (2d Cir. 2006) ("The starting and ending dates of the conspiracy noted in the indictment correspond to the conspiracy proven at trial..."). Conversely, the substantial quantity of testimony — for the post-conspiracy time period of , who never met any of the four accusers as far as can be gleaned, and the documents she intends to authenticate, run a substantial risk that the government's proof at trial will not be the same core evidence charged in the Indictment because it will be based on evidence that postdates the events charged in the Indictment. + +### C. Ms. Maxwell reiterates her re uest to defer briefin and rulin on the admissibility for two weeks. + +For the reasons already detailed, the complexity of the issues and the fact that ■ **recently disclosed testimony appears to be of utmost centrality to the government's case, Ms. Maxwell repeats and reiterates her request that she be afforded additional time to submit a comprehensive motion in limine concerning the introduction of this testimony and exhibits as supposed direct evidence of the charged conspiracy. In that there remains a full month before opening statements, Ms. Maxwell's fundamental rights to present a defense, to have the effective assistance of counsel, and to a right to confront witnesses and subpoena witnesses to testify in her defense all will be preserved by a small delay on this issue.** + +#### **III. THIS COURT SHOULD EXCLUDE TESTIMONY UNDER FEDERAL RULE OF EVIDENCE 702 AND DAUBERT V. MERRELL DOW PHARMACEUTICALS, INC., 509 U.S. 579 (1993) AND GRANT A DAUBERT HEARING** + +#### A. This Court should reject the government's arguments to the extent that they are based on newly disclosed material, which this Court ordered the government to produce six months ago. + +Recognizing that proposed testimony is on shaky ground (to say the least), the government belatedly tries to shore up its case and hoist up its expert witness. Two days ago, and six months after the court-imposed deadline for expert disclosures, the government first disclosed to defense counsel about 300 pages of material on which apparently relied in reaching her conclusions. This Court should reject the government's untimely effort to save testimony from exclusion. See United States v. Lewis, 818 F. App'x 74, 79 (2d Cir. 2020) (unpublished) (affirming exclusion of defendant's proffered expert evidence "that did not adhere to the discovery schedule"). + +In any case, the newly discovered material doesn't help the government's cause. Exhibit A (literally) to the government's response is a journal article describing "grooming" as a "construct." Resp, Ex. A, Natalie Bennett & William O'Donohue, The Construct of Grooming in Child Sexual Abuse, 23 J. Child Sexual Abuse 957, 974 (2014). (In fact, Ms. Maxwell cited this article in her motion.) Far from supporting conclusions, the article proves their unreliability: + +There have been claims that some child molesters engage in a "seduction stage" prior to committing abuse. These behaviors, commonly known as "grooming," are understood as methods child molesters use to gain access to and prepare future victims to be compliant with abuse. However, there is a lack of consensus regarding exactly what this process entails and how it is clearly distinguished from normal adult-child interactions. . . . Furthermore, there are no methods of known psychometrics to validly assess grooming. + +Gov't Resp., Ex. A, p 2 (emphasis added). The article concludes: + +Currently there is no consensus regarding how to define grooming. In addition, there is no valid method to assess whether grooming has occurred or is occurring. The field possesses an insufficient amount of knowledge about key issues such as the interrater reliability of these judgments or the error rates of these judgments including the frequency of false negatives or false positives. Thus currently it appears that grooming is not a construct that ought to be used in forensic settings as it does not meet some of the criteria in the Daubert standard. . . . Right now it does not appear to be the case that there are "reliable principles and methods" to define and detect grooming. + +Id. at 19 (emphasis added). + +Because the government cannot justify admission of testimony based on its prejudicially late disclosures, and because those disclosures don't support views, and underscore that "grooming" is not a scientific principle based on psychometric testing, this Court should preclude from testifying. And as explained below, the government's other defenses of fall far short of what is required by Rules 401, 402, 403, 404, 702, and 704. + +### B. proposed testimony is inadmissible. + +According to the government, Ms. Maxwell "does not contest that Dr. is a qualified expert." Resp. at 9. To the degree that Dr. has the credentials of a potential expert, the government is right. + +But saying that is a "qualified expert" is not enough. The government must identify what is an expert in. Fed. R. Evid. 702; Fed. R. Crim. 16. As Ms. Maxwell pointed out in her motion, the government hasn't done that. Mot. at 2. + +What's more, even if is a "qualified expert" in something, she is not a "qualified expert" in everything. (For example, the government agrees that she is not an expert in the human brain or memory generally. Resp. at 30 n.7.) And as even the government admits, has no experience or expertise in diagnosing, evaluating, or treating alleged perpetrators of sexual abuse. Resp. at 19, 23, 26. She cannot therefore speak to the psychology of alleged perpetrators and their so-called "grooming techniques." + +The government attempts a two-step to get around this problem. "By virtue of experience treating victims," says the government, "Dr. is necessarily informed about perpetrators' actions." Resp. at 19. + +But how does know her patients were victims of sexual abuse? Because her patients told her so, and assumes they are telling the truth. Again, opinions are based on her treatment of a self-selected, unrepresentative group of individuals she assumes are telling the truth and are therapeutic consumers in a financial relationship with her. + +The government has no response to this, other than to say that and other "[c]linical psychologists are not so credulous." Resp. at 16. If this were right, though, one would expect the government to explain how clinical psychologists ensure their patients are telling the truth — in other words, how clinical psychologists like test and verify their opinions. + +But that's not what the government does. Instead, right after claiming that "[c]linical psychologists are not so credulous," the government essentially says to Ms. Maxwell, "How dare you?" In the government's words, "The Court should reject the defendant's speculative claim that Dr. has been misled by hundreds of patients who sought professional treatment for traumatic events that did not occur." Resp. at 16. + +In this way, and in one breath, the government attests that is "not so credulous." But in the next breath, the government asks this Court to assume that "has [not] been misled by hundreds of patients who sought professional treatment for traumatic events that did not occur." In other words, the government asks this Court to assume patients are telling the truth, just as does. Apparently is "so credulous." But there is no reason this Court should be. + +The government next notes that the term "grooming-by-proxy" "appears nowhere in the Government's expert notice." Resp. at 26. That's hardly surprising, though, because there is no reliable way to assess or analyze if one individual "grooming" a minor to facilitate abuse by someone else, even though that is exactly what the government says Ms. Maxwell did. + +As detailed today is Ms. Maxwell's Rule 412 motion, the Indictment alleges "grooming" or "normalization" of sexual behavior by Ms. Maxwell over a dozen times. The government does not, however, contend that Ms. Maxwell "groomed" anyone for her own benefit; instead, the government contends that she "groomed" them for Epstein's benefit. But as the government does not dispute, there is nothing—not a journal article, and not a study, nothing—to validate opinions on grooming-by-proxy (even if she doesn't use that phrase).6 + +6 The articles and cases the government cites involve alleged grooming behavior by the preparator of the abuse, not alleged grooming behavior by a third patty. + +Recognizing that opinions are thus unreliable, the government says: "If the victim experienced attachment and grooming, it makes no analytical difference whether the perpetrator intends to engage in sexual contact with the victim or, instead, is preparing the victim for abuse by a third party." Resp. at 26. + +Hardly. It makes all the difference in the world because Ms. Maxwell is on trial, not Mr. Epstein. The logic (such as it is) of grooming evidence is that the perpetrator normalizes sexual behavior to facilitate his later abuse of the victim. But because Ms. Maxwell did not abuse anyone, there is no basis to conclude that anything she did was "grooming." The government thus intends to have characterize innocent conduct by Ms. Maxwell as something more nefarious, thereby further blurring the line that experts are already unable to draw reliably. Resp. Ex. A, p 2 ("There is a lack of consensus regarding exactly what [the grooming] process entails and how it is clearly distinguished from normal adult—child interactions."). + +The government's additional arguments fail. + +- A psychologist who treats alleged victims of abuse but does not treat alleged perpetrators is nothing like a urologist who treats urology patients. Resp. at 11 (citing Bosco v. United States, No. 14 CIV. 3525 (JFK), 2016 WL 5376205 (S.D.N.Y. Sept. 26, 2016)). assumes her patients are telling the truth, and she never hears or credits the other side of the story. The urologist, by contrast, has scientific means to verify what her patients tell her, and there isn't another person whose side of the story she needs to hear. +- The government repeatedly says that "courts have frequently admitted testimony about the psychological relationship between victims of sexual abuse and their perpetrators." Resp. at 13. See also id. at 7-8. But those cases do not address the + +situation here, in which the alleged "groomer" was not the person who perpetrated the alleged abuse. + +- Even where the "groomer" and "perpetrator" are the same person, courts have recognized the unreliability of grooming testimony. United States v. Gonyer, No. 1:12-CR-00021-JAW, 2012 WL 3043020, at \*2-3 (D. Me. July 24, 2012); United States v. Raymond, 700 F. Supp. 2d 142, 146-47 (D. Me. 2010); United States v. Schneider, No. CRIM.A. 10-29, 2010 WL 3734055, at \*4 (E.D. Pa. Sept. 22, 2010); see also United States v. Raniere, No. 18-CR-2041-NGG-VMS, 2019 WL 2212639, at \*7 (E.D.N.Y. May 22, 2019); United States v. Burns, No. 07 CR 556, 2009 WL 3617448, at \*5 (N.D. Ill. Oct. 27, 2009) (criticizing the "grooming theory" in the context of a sentencing guidelines calculation). +- The government tries to distinguish United States v. Raymond by saying that the expert's own book in that case "disavow[ed] [its] reliability . . . for legal use." Resp. at 14. But that is exactly the situation here, because the primary article on which the government relies—Exhibit A to its response-flatly says "that grooming is not a construct that ought to be used in forensic settings as it does not meet some of the criteria in the Daubert standard." Resp., Ex. A, p 19. +- The government says opinions are not "anecdotal." But that's not right either, as her endorsement makes clear: opinions are based "on her education and training on psychological trauma, traumatic stress, interpersonal violence, and sexual abuse (and her] extensive clinical experience treating individuals who suffered sexual abuse and trauma in childhood and adolescence, + +as well as (herJ experience conducting forensic psychological evaluations of people who have experienced sexual abuse and trauma." Mot. Ex. 1, p 2. + +- The government tries to disclaim the importance of error rates. Resp. at 15-17. But it's not just that cannot identify an error rate, it's that her implicit conclusion is that she doesn't have an error rate. That is, all her patients are telling the truth when they say they were groomed, so any evidence that matches what her patients have told her is therefore evidence of grooming. +- But even if the error-rate discussion were misplaced, that doesn't mean opinions are reliable. As a "qualitative" matter, and as the government's own Exhibit A concedes, there are no "'reliable principles and methods' to define and detect grooming." Govt. Resp., Ex. A, p 19 (quoting Fed. R. Evid. 702). +- The government apparently expects that, "somehow, a lay jury without guidance [will] apply I I analyses reliably to the facts of a case in determining guilt." See Raymond, 700 F. Supp. 2d at 150 (rejecting argument that a jury could do just that). This Court should not, as the government request, simply punt the matter to the jury. Resp. at 17-18. The Court is the gatekeeper. It must ensure the evidence is reliable and relevant. If it's not both, it has no place in a criminal jury trial, because it will "radically simplify" an otherwise complex case, BEMIS. 2009 WL 3617448, at \*5, and it will, as the United States Supreme Court has cautioned, prejudicially mislead the jury, Daubert v. Merrell Dow Phanns., Inc., 509 U.S. 579, 595 (1993) ("Expert evidence can be both powerful and quite misleading because of the difficulty in evaluating it."). + +- The government denies Ms. Maxwell's argument that "a lay jury will be unable to apply Dr. analyses to the facts of this case" because "[t]hat is not how Rule 702 works." Resp. at 20. Responds the government: "That is precisely how Rule 702 works in cases where experts testify about general principles, which the Rule contemplates." Id. at 21. Surely that is not right when, as here, the "general principles" are unreliable. Fed. R. Evid. 702, Advisory Committee Note (if expert testifies to general principles but not apply them, "the testimony [must] be reliable"). See also Mot. at 10; Raymond, 700 F. Supp. 2d at 150 n.12 (expert testimony about general principles is helpful only when it "describe[es] widely recognized and highly predictable and verifiable phenomena"). +- The government attempts to fault Ms. Maxwell for making "no argument that the minor victims in this case are distinctive in some way such that general principles of psychology may diverge as to them." Resp. at 18. This argument flips the proper analysis on its head. It's the government's burden to prove reliability. E.g., United States v. Williams, 506 F.3d 151, 160 (2d Cir. 2007). It's not Ms. Maxwell's burden to prove unreliability (though if it were her burden, she would have met it). +- The government says that "the causal connection between ... psychological problems and child sexual abuse is outside the experience of the average juror" and is relevant to the alleged victims' credibility. Resp. at 24. It's not, and any minor probative value the evidence has is substantially outweighed by the danger of unfair prejudice. Fed. R. Evid. 401, 403. And as explained in the Rule 412 motion today, if offers testimony and the government presents argument + +along these lines, that will open the door to other sexual behavior evidence. That door can remain at least partially closed if is not permitted to offer her irrelevant and unfairly prejudicial testimony. + +- The government still hasn't explained how it helps the jury to be told that a victim of sexual abuse might make an immediate disclosure, or she might make an incremental disclosure, or she might make a delayed disclosure. Resp. at 27-30. And when the government says, "[s]exual abuse also impacts the way memory is encoded," that opinion is far outside expertise because the parties agree that she is not an expert in "the human brain or memory generally." Resp. at 30 n.7. + +# C. At a minimum, this Court should hold a Daubert hearing. + +There is ample reason for this Court to exclude testimony outright. At the very least, Ms. Maxwell is entitled to a Daubert hearing. The government implicitly concedes as much. In a footnote, the government acknowledges the decision in United States v. Raniere, in which Judge Garaufis ordered a Daubert hearing on the government's proposed expert testimony on grooming. 2019 WL 2212639, at \*7-8. In that case, however, the government withdrew its endorsement rather than submit to an Daubert hearing. Resp. at 19 n.3. + +Judge Garaufis reasoned that even if other courts in other cases had admitted testimony about grooming, "that [did] not make Dr. Hughes's opinion about grooming techniques reliable under the Daubert standard," if only because "her extensive academic and clinical experience appears focused on victims of sexual abuse, not perpetrators." See id. at \*7. The same is true here, particularly because has no experience in, and there is no authority supporting her opinions on, grooming-by-proxy. Quite the contrary. The government's late-breaking disclosure states: + +Thus currently it appears that grooming is not a construct that ought to be used in forensic settings as it does not meet some of the criteria in the Daubert standard. . . . Right now it does not appear to be the case that there are "reliable principles and methods" to define and detect grooming. + +Id. at 19 (emphasis added). + +At a minimum, therefore, this Court should hold a Daubert hearing. + +### IV. THE RT SHOULD EXCLUDE EVIDENCE RELATED + +The government's arguments in favor of admitting evidence related as direct evidence of the charged conspiracies all but concede that the evidence is more appropriately considered under Rule 404(b). In an effort to bolster their position, the government makes the sweeping assertion that as long as was under the age of 18, her evidence is admissible as direct evidence of the conspiracy. That is a fundamentally incorrect statement of the law and should be rejected. The government's arguments for admitting evidence under Rule 404(b) and for denying the defense's requested limiting instruction are similarly baseless. The Court should therefore exclude evidence related to or, if it is admitted, give the jury the requested limiting instruction.' + +The government advances four principal arguments for why evidence related to should be admitted as direct evidence of the charged conspiracies: (1) her testimony allegedly shows a "pattern" of how Epstein and Ms. Maxwell sexually abused young women and establishes Ms. Maxwell's "intent" to participate in the charged conspiracies (Resp. at 45-46), (2) her allegations are included in the S2 Indictment and are therefore not covered by Rule + +As it pertains to and the other accusers, the defense will be submitting proposed jury instructions and special verdict findings. + +4O4(b) (id. at 46-47), (3) her evidence is "intrinsic" proof of the charged conspiracies and necessary to "complete the story" of the charged offenses (id. at 47-49), and (4) + +was under the age of 18, the age of consent under federal law, when the alleged sexual abuse took place, and that is "all that is required for evidence relating to the defendant's exploitation of Minor Victim-3 to be direct evidence of the charged offenses" (id. at 50). The first is an argument for admission of this evidence under Rule 404(b), not as direct evidence of the conspiracy. The second simply begs the question and assumes that the government can circumvent Rule 404(b) by alleging "other act" evidence in the indictment. The third overlooks the numerous precedents in this Circuit finding that evidence of criminal offenses that are separate and distinct from the charged offenses are not admissible as direct evidence of a conspiracy. And the fourth completely misstates the law. These arguments should be rejected. + +First, the government argues that evidence is admissible as direct evidence of the charged conspiracies because it is relevant to show the "pattern" of abuse including "grooming" the accusers, encouraging them to give massages to Epstein, and asking them to recruit others—and her "intent" to participate in the charged conspiracies. (Id. at 45-46). But "pattern" is just another word for "modus operandi," which along with "intent" are bases for admission under Rule 404(b), not as direct evidence of the conspiracies. See Fed. R. Evid. 404(b) ("other act" evidence may be admissible to prove "motive, opportunity, intent, preparation, plan, knowledge, identity, absence of mistake, or lack of accident) (emphasis added); United States v. Walia, No. 14—CR-213 (MKS), 2014 WL 3734522, at \*13 (S.D.N.Y. Jul. 25, 2014) (Rule 404(6) permits "other act" evidence to be admitted to prove "modus operandi"). + +The very case the government cites in support of their position, United States v. Curley, 639 F.3d 50 (2d Cir. 2011), affirmed the district court's decision to admit "other act" evidence of prior spousal abuse to prove "intent" and "pattern" under Rule 404(b) "with an appropriate instruction on this evidence's limited purpose," not as direct evidence of the conspiracy. See Curley, 639 F.3d at 59 (citing United States v. Von Foelkel, 136 F.3d 339, 340-41 (2d Cir. 1998) (per curiam) (affirming district court's decision to admit evidence of prior domestic violence to prove defendant's intent under Rule 404(b)). Indeed, the evidence could not have been admitted as direct evidence of a conspiracy because Curley was not charged with a conspiracy. See United States v. Curley, No. SI 08 Cr. 404 (SCR), 2009 WL 10688209, at \*1 (S.D.N.Y. Jul. 15, 2009) (defendant was convicted of two counts of stalking and one count of interstate violation of a protection order). Curley therefore supports the defense's position that the admissibility of. evidence must be evaluated under Rule 404(6). + +Second, the government does not confront the defense's point that simply including "other act" evidence in the indictment does not necessarily mean it is direct evidence of the conspiracy. See Mot. at 9-10. Instead, the government engages in circular reasoning by effectively arguing that (i) allegations in an indictment are not 404(6) evidence, (ii) allegations are in the indictment, (iii) therefore they are not 404(b) evidence. See Resp. at 46-47. But as the defense pointed out in its Motion, "other acts" are only admissible as evidence of a conspiracy "as long as they are within the scope of the conspiracy. " United States v. Cummings, 60 F. Supp. 3d 434, 437 (S.D.N.Y. 2014), vacated on other grounds 858 F.3d 763 (2d Cir. 2017) (quoting United States v. Bagaric, 706 F.2d 42, 64 (2d Cir. 1983)). The government has not explained why evidence provides any proof that Ms. Maxwell "furthered" an alleged conspiracy to cause minors (she did not) to travel (she did not) + +for the purpose of engaging in unlawful sexual activity (it was not). Moreover, allowing the government to circumvent Rule 404(b) by charging "other act" evidence in the Indictment would swallow the rule and allow the jury to broadly consider evidence that should only be considered for a limited purpose and with an appropriate limiting instruction regarding propensity. The Court should not allow this. + +Third the government claims that evidence can be admitted as intrinsic proof of the charged conspiracies to show Ms. Maxwell's (1) "relationship with Epstein, including her willingness to procure teenagers to give Epstein massages," (2) "knowledge of both the sexual nature of those massages and the need to procure additional victims," and (3) "willingness to transport minors to further their abuse." Resp. at 47. The government further argues that evidence is necessary to "complete the story" of the charged offenses. Id. at 48-49. In its Motion, the defense cited numerous cases in this Circuit holding that evidence of other conduct involving alleged co-conspirators—even conduct that was similar to the charged offenses—was not admissible as intrinsic proof of the conspiracies if the other conduct was separate and distinct from the charged offenses. See Mot. at 9 (citing cases). The government concedes that these cases so hold and points out that these cases admitted some of the proffered evidence under Rule 404(b). Resp. at 48 n.11. This just proves the point; the admissibility of evidence should be evaluated under Rule 404(b). + +Fourth, the government asserts that the defense "misunderstands" the law and that the government simply needs to prove that Ms. Maxwell "took steps to provide Jeffrey Epstein with access to girls under the age of 18, knowing that Epstein intended to have sexual contact with those girls." Id. at 50 (emphasis added). In the government's view, it is totally irrelevant that + +See id. at 49-50. According to the government, "all that is required" for evidence to be admissible as direct evidence of the charged conspiracies is that she was under the age of 18, the age of consent under U.S. federal law, and that Ms. Maxwell knew that Epstein intended to engage in sexual contact with her. See id. + +It is the government. not the defense, that apparently does not understand the law. The Mann Act conspiracies charged in the S2 Indictment each require proof that Ms. Maxwell acted with the intent that the alleged victim would "engage in sexual activity for which a person can be charged with a criminal offense." S2 Ind. ¶¶ 12 (citing 18 U.S.C. § 2422), 18 (citing 18 U.S.C. § 2423(a)). That element incorporates offenses under state law. See United States v. Lincoln, No. 19-CR-6047 (CJS), 2019 WL 719822, at \*4 (W.D.N.Y. Dec. 23, 2019) (collecting § 2422 cases); United States v. Vickers, 708 F. App'x 732, 735 (2d Cir. 2017) (summary order) (criminal sexual activity under § 2423 includes crimes "under federal, state, or foreign law"). Indeed, the Mann Act conspiracies in the S2 Indictment charge a violation of a New York State misdemeanor as the "sexual activity for which a person can be charged with a criminal offense." S2 Ind. ¶¶ 13b, 1913 (citing N.Y. Penal Law § 130.55). Section 130.55 prohibits "subject[ing] another person to sexual contact without the latter's consent." N.Y. Penal Law § 130.55. To be guilty of Section 130.55 based on the victim's incapacity to consent due to age, the victim must be under the age of 17. Id. § 130.05(3)(a). The government itself acknowledged this in its draft proposed jury instructions, as well as the fact that Ms. Maxwell cannot be convicted of the Mann Act conspiracies unless she knew that the alleged victim was under 17. See Gov't Proposed Jury Instructions ("[I]n order to find that the intended acts were nonconsensual solely because of the + +victim's age, you must find that the defendant knew that the victim was less than seventeen years old.") (emphasis added). + +It is unclear whether the government is now claiming that to admit evidence as proof of the Mann Act conspiracies, it only needs to prove that was under the age of 18 at the time of the alleged abuse and that Ms. Maxwell did not need to know anything about age, or that Ms. Maxwell only needed to know that ■ **was under the age of 18. Either one is a misstatement of the law. For "sexual activity" to be "criminal," it must be illegal under the laws of the jurisdiction where the sex acts allegedly took place. If those crimes are based on lack of consent due to age, it is only illegal if the alleged victim is under the age of consent in that jurisdiction. And according to the government's own proposed jury instructions, Ms. Maxwell can only be found guilty of the Mann Act conspiracies if she knew (and the other alleged victims) were under the age of consent in the particular jurisdictions where the sex acts allegedly took place. Because was, at all times, over the age of consent in the relevant jurisdictions, her evidence is not within the scope of the charged conspiracies and is therefore not admissible as direct evidence. At the very least, because it is not "manifestly clear" that evidence is proof of the charged conspiracies, "the proper course is to proceed under Rule 4O4(b)." United States v. Townsend, No. SI 06 CR. 34 (JFK), 2007 WL 1288597, at \*1 (S.D.N.Y. May 1, 2007) (citing United States v. Nektalov, 325 F. Supp. 2d 367, 372 (S.D.N.Y. 2004)).** + +**evidence should also be excluded under Rule 404(b) and Rule 403. As argued in our initial Motion, evidence that Ms. Maxwell allegedly encouraged an adult to engage in legal sexual activity is not, in any way, evidence of her intent to facilitate Epstein's** + +alleged scheme to cause minors to travel to engage in illegal sex acts, or her knowledge of the same. See Mot. at 11. Nor is the evidence of alleged "grooming" sufficiently unique to qualify as proof of "modus operandi." See id. at 12. Furthermore, there is a strong likelihood that the jury will assume that Epstein's alleged sex acts with were illegal and will misapply that evidence in evaluating Ms. Maxwell's guilt or innocence to the charged Mann Act conspiracies. Her evidence should therefore be excluded under Rule 403. See id. at 12-13. + +If the Court decides to admit evidence, it should preclude the government and from referring to her as a "minor" or asserting that she was a "minor" at the time of the alleged sex acts, (2) preclude the government and from representing that she was "sexually abused" by Jeffrey Epstein, and (3) give the jury the appropriate limiting instruction the defense has requested. See Mot. at 14-15. + +The government argues that the term "minor" is appropriate because was, for a brief time, below the age of 18, which is the age of consent under federal law. Resp. at 52-53. Although the government would like to believe that U.S. federal law is the only law that matters, even as to acts that allegedly took place in a foreign country, that is not the case. The Court should not permit to be referred to as a "minor" because she was not a "minor" under the laws of the relevant jurisdiction when any of the alleged sex acts took place. It would not only be inaccurate to call her a "minor," but it would also mislead the jury to believe that the acts that allegedly took place in the U.K. were "criminal sexual activity" when they were not. The same is true for the phrase "sexual abuse," which connotes criminal activity. See Mot. at 14-15 (citing Esquivel-Quintana v. Sessions, 137 S. Ct. 1562, 1569 (2017)). + +Finally, the government opposes the defense's requested jury instruction regarding the age of consent under U.K. law on the grounds that it is "irrelevant" and would "confuse the + +jury." Resp. at 53-54. Apparently, the government believes the jury would be "confused" if the Court told the jurors what the law actually is so that they do not improperly assume that testimony is being offered as proof of "criminal sexual activity" and apply it incorrectly to convict Ms. Maxwell of the Mann Act conspiracies. The jurors would not be "confused"; they would be educated on how to properly evaluate evidence. The government's objection is non-sensical. But not as non-sensical as the government's final proclamation: + +The sexual activity involving Minor Victim-3 can be considered criminal for purposes of the crimes charged in the Indictment, because it is probative proof of the defendant's guilt of those crimes. The instruction the defense proposes, in contrast, creates serious risk that the jury will think the Court is telling them that the conduct is lawful and therefore irrelevant to the case. + +Id. at 54. A better example of circular reasoning you could not find — sex acts with Epstein are "criminal" because they are "proof of the defendant's guilt of those crimes"? No. And the "risk that the jury will think that ... the conduct is lawful? It was lawful. Whatever misgivings may now have about those alleged sex acts, and whether she now views those incidents as "sexual abuse," there was nothing illegal about them. + +And that is precisely the point. If she is permitted, will testify about feeling sexually abused by Epstein and the jury will assume that the sex acts were illegal. Unless the Court instructs the jury that the sex acts were not illegal under U.K. law, and they cannot be considered as "criminal sexual conduct" in evaluating the elements of the Mann Act conspiracies, there is a substantial risk that the jury will misapply her evidence and improperly convict Ms. Maxwell of those counts. The government has agreed to do this in similar cases and it is appropriate to do so here. See Vickers, 708 F. App'x at 735-36 (government sought and received jury instructions explaining the applicable criminal laws of the relevant jurisdictions and jury returned a special verdict form finding "that the defendant intended to engage in sexual + +activity for which the defendant could be charged with specific New Jersey, Pennsylvania, New York, and Canadian criminal offenses” (emphasis added)). Accordingly, the Court should give the jury the defense’s requested limiting instruction.8 + +**V. THE GOVERNMENT CONCEDES THAT IT WILL NOT OFFER EVIDENCE OF MS. MAXWELL’S ALLEGED “FLIGHT”** + +The government has conceded that it will not elicit any evidence or argue to the jury that Ms. Maxwell “was hiding from, evading, or fleeing from law enforcement between Epstein’s arrest and her own.” Resp. at 81-82. + +**VI. THE GOVERNMENT CONCEDES THAT IT WILL NOT OFFER EVIDENCE OF MS. MAXWELL’S ALLEGED FALSE STATEMENTS AND AGREES TO MS. MAXWELL’S PROPOSED REDACTIONS** + +The government has also conceded that it will not elicit any evidence concerning Ms. Maxwell’s alleged false statements in her 2016 depositions and agrees to the defense’s request to redact the perjury counts and related allegations from the S2 Indictment. Resp. at 82. + +**VII. THE COURT SHOULD HOLD A PRE-TRIAL EVIDENTIARY HEARING ON MS. MAXWELL’S MOTION TO SUPPRESS IDENTIFICATION.** + +From approximately [REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] + +--- + +8 The defense also agrees with the government that the Court should instruct the jury that it cannot convict Ms. Maxwell of the charged conspiracies based solely on [REDACTED] evidence. See Resp. at 50 n.12. + +[REDACTED] +[REDACTED] +[REDACTED] +[REDACTED] + +It was not until 2020, after making a multi-million dollar claim to the Epstein Victim Compensation fund, that the SDNY interviewed [REDACTED] and then in 2021 showed her photos -- the majority of which were men or women much younger than Ms. Maxwell. Only two of the photos look anything like Ms. Maxwell and [REDACTED] thought one was Ms. Maxwell and the other might be Ms. Maxwell. Of course, no one thought to ask [REDACTED] if her lawyers had shown her photos of Ms. Maxwell as part of her multi-million-dollar request or if she had seen any of the many photographs displayed on the internet of Ms. Maxwell, including those published in relation to the first indictment by Acting U.S. Attorney Strauss’s Rule 23.1-violative press conference, or any of the millions of photographs published in the wake of the Indictment. The photo array process was not recorded, and we do not know why certain photos in the array were selected or by whom. No one documented how long the photo array was viewed or any other relevant indicia of reliability. + +The claim that the show-up was merely a “confirmatory identification” of someone that [REDACTED] had “known and identified by name over the years” is completely unsupported by the evidence. Tellingly, the government appends no supporting exhibit or declaration in support of this conclusory statement because it cannot. The truth of the matter is that [REDACTED] had never identified Ms. Maxwell as someone who abused her and never claimed to have seen Ms. Maxwell prior to 2020 when it became economically prudent for her to do so. + +The facts about interaction with Ms. Maxwell are hotly disputed. Ms. Maxwell rejects the government's unsupported conclusory statements about when and if she interacted with Ms. Maxwell and her ability to do so absent suggestion. + +When the prosecution offers testimony from an eyewitness to identify the defendant as a perpetrator of the offense, fundamental fairness requires that that identification testimony be reliable. Raheem v. Kelly, 257 F.3d 122, 133 (2d Cir. 2001). The court must first determine whether the pretrial identification procedures unduly and unnecessarily suggested that the defendant was the perpetrator. If the court finds, however, that the procedures were suggestive, it must then determine whether the identification was nonetheless independently reliable. Id. + +The critical question here, ignored by the government, is not whether knew that she was accusing Ms. Maxwell in 2020 (she undoubtably was) but whether she could identify Ms. Maxwell as the person she was now claiming abused her. Of the pictures selected here, had a high probability of picking Ms. Maxwell -- even then, she was tentative about one person who was not Ms. Maxwell. The show up was neither confirmatory nor fair. + +The protection against unduly suggestive procedures encompass not only the right to avoid improper police methods that suggest the initial identification, but as well the right to avoid having suggestive methods transform a selection that was only tentative into one that is positively certain. Solomon v. Smith, 645 F.2d 1179, 1185 (2d Cir. 1981). + +Ms. Maxwell has met her burden of demonstrating the show up was unduly suggestive. Under these circumstances the Court should next consider the well know "five factors": (1) the witness's opportunity to observe the criminal at the time of the crime, (2) the degree of the witness's attention at that time, (3) the accuracy of the witness's initial description of the + +criminal, (4) the certainty with which the witness first identified the suspect, and (5) the time lapse between the crime and the identification. Id. at 1186. Each of these factors weighs heavily in Ms. Maxwell's favor: as to 1-3, until 2020, had never claimed Ms. Maxwell participated in any abuse and never identified Ms. Maxwell -- indeed, she had never before been asked to identify Ms. Maxwell. Concerning number 4, was less than certain, as demonstrated by her selection of someone else who may have been "Ms. Maxwell." Factor 5 also weighs in Ms. Maxwell's favor, as the delay was 17 years. + +Accordingly, Ms. Maxwell requests that the Court hold an evidentiary hearing on this motion and find that the show up was unduly suggestive and suppress any identification of Ms. Maxwell, before or during trial. + +## VIII. GOVERNMENT AGREES NOT TO ELICIT LAW ENFORCEMENT OPINION TESTIMONY + +The government agrees that it has not noticed any law enforcement officers as experts and, as to their fact police officers, "will not elicit expert testimony from them." Resp. at 82-83. Overlooking the long list of potential law enforcement opinion testimony that has been disallowed by Courts in the past (see Mot. at 2-5), the government then goes on to make the confusing claim that the defense should have to "provide expert" testimony from the government's own case agents if it wants to call them as witnesses. Resp. at 83 n.24. + +The defense has no intention of eliciting opinion testimony from the agents when they testify. As the motion makes clear, the defense fully understands the contours of lay versus opinion testimony from law enforcement officers. The case agents are first hand percipient witnesses to a number of facts in the investigation and prosecution of this case, including as the impeachment witness for the many changed stories of the accusers. + +As evidenced by their recently disclosed interviews, the government lawyers, despite its protests about the defense's ability to call percipient fact witnesses, have been preparing the case agents for months to testify in the defense's case. The risk highlighted by the defense it its footnote is that, even though they are not asked a question that calls for opinion testimony, the agents are likely to try to offer their opinions either during the defense's questioning or when the government attempts to rehabilitate them. Because neither side has noticed any opinion testimony from the case agents, they should be prohibited from offering any, especially because it will be non-responsive to any questions that should be asked of them. + +### IX. THE COURT SHOULD PRECLUDE TESTIMONY ABOUT ANY ALLEGED "RAPE" BY JEFFREY EPSTEIN + +The government argues that the expected testimony of that she was raped by Jeffrey Epstein is admissible to show the "ongoing relationships between the defendant, Epstein, and the victims" and is necessary "to complete the story of the crime on trial." Resp. at 79-80. The government offers no explanation, however, for why testimony of an alleged rape would prove the relationship "between the defendant, Epstein, and the victims" when has never claimed in her prior statements to the FBI or anywhere else that Ms. Maxwell knew of, facilitated, or participated in the alleged rape in any way. Nor does the government explain %shy this testimony is somehow necessary "to complete the story of the crime on trial" when the rape allegation is an outlier and does not fit the "story" of alleged sexual abuse that the government has described in the S2 Indictment—namely, "grooming" the alleged victims to gradually break down their inhibitions so that forcible rape is not required to engage in sexual activity with them. Because the rape allegation is the only one of its kind and has no connection to the other incidents of alleged sexual abuse, it should not be admitted as intrinsic proof of the charged crimes. See United States v. Townsend, No. SI 06 CR. 34 (JFK), 2007 WL 1288597, at \*2 + +(S.D.N.Y. May 1, 2007) (defendant's prior narcotics and firearm transactions with the same confidential informant not "inextricably intertwined" with the charged narcotics conspiracy, even though the conduct was "generally similar to the conduct underlying the offenses charged in the indictment"); United States v. Nektalov, 325 F. Supp. 2d 367, 369-70 (S.D.N.Y. 2004) (prior similar money laundering transactions between defendant and cooperating witness not "inextricably intertwined" with the charged money laundering offense or "necessary to complete the story" of the charged conspiracy (emphasis in original)). + +Testimony concerning the alleged rape should also be excluded because the S2 Indictment contains no allegations of rape and such testimony is therefore irrelevant to the charged crimes. The government dismisses this point arguing that indictments do not need to include all of the government's evidence, and the terms "sexual activity" and "commercial sex act" are broad enough to cover rape. See Resp. at 80. But this misses the point. The rape allegations are irrelevant to the charges because the charges are based on sexual activity that was illegal because the alleged victims were under the age of consent. The indictment does not charge any crimes that are premised on sex acts that involve the use of force, like rape. For example, Counts Five and Six charge sex trafficking offenses. See S2 Ind. II 22-27. But they do not charge the section of the statute that criminalizes sex trafficking that "was effected by means of force, threats of force, fraud, or coercion." 18 U.S.C. § 1591(b)(1). The government is therefore off base when its states that "evidence of rape, where it occurs ... is the core conduct in the case." Resp. at 81. It is only the "core conduct" of the case when the indictment alleges forcible sex acts. Indeed, the cases cited by the government prove this point. See Ex. E, Indictment, United States v. English, No. 18 Cr. 492 (PGG) (S.D.N.Y. 2020) (defendant charged with sex trafficking conspiracy "effected by means of force" under 18 U.S.C. § 1591(b)(1)); + +United States v. Graham, No. 14 Cr. 500 (NSR), 2015 WL 6161292, at \*1 (S.D.N.Y. Oct. 20, 2015) (same). + +Finally, whatever minimal probative value the rape allegation might have would be substantially outweighed by the danger of unfair prejudice, confusing the issues, and misleading the jury. Fed. R. Evid. 403. As we previously argued in our initial Motion, rape is highly emotional and inflammatory, much more so than the "sexualized massages" alleged in the S2 Indictment. See Mot. at 2-3. Admitting testimony of an alleged rape would pose a serious risk that the "jury will convict for crimes other than those charged—or that, uncertain of guilt, it will convict anyway because a bad person deserves punishment." Old Chief v. United States, 519 U.S. 172, 181 (1997) (quoting United States v. Moccia, 681 F.2d 61, 63 (1st Cir. 1982) (Breyer, J.)) (discussing propensity evidence). Such evidence would also confuse the issues at trial and mislead the jury. It will cause the jurors to focus on conduct that is not relevant to the charged offense and suggests that they convict Ms. Maxwell on an improper and highly emotional basis. See United States v. Stein, 521 F. Supp. 2d 266, 273 (S.D.N.Y. 2007) (excluding other-act evidence in a conspiracy case under Rule 403 because of the "risk that this evidence would confuse the issues, cause undue delay, and be used for an improper purpose"). The Court should therefore preclude any testimony or evidence about an alleged rape. + +# XII. REFERENCE TO ACCUSERS AS "VICTIMS" IS IMPROPER VOUCHING + +Without explaining its logic, and by way of cases concerning jury instructions, the government disagrees that use of the term "victim" by witnesses and the prosecution during trial amounts to improper vouching. Yet, the government offers that the only times it expects the word will be used at trial are (a) by the prosecutors during their jury addresses, and (b) in Dr. testimony concerning her patients. Resp. at 77. The government's legal analysis and + +argument are flawed, and the Court should enter the order proposed by Ms. Maxwell that all parties, witnesses, and the Court should refer to the individuals by their proper names. + +First, overlooking the frequency with which state courts must grapple with fair trials inherent in sex crimes, the government complains that the defendant cited no federal authority for the proposition that the Court, witnesses, and parties should use the individuals' names rather than the word "victim." To remedy that perceived problem, counsel refers the Court to United States v. Sena, No. 19-CR-01432, 2021 WL 4129247, at \*1-2 (D.N.M. Sept. 9, 2021), and the other cases cited therein: + +"(Defendant] is correct that the term (victim] is prejudicial when the core issue at trial is whether a crime has been committed—and, therefore, whether there is a victim. See State v. Cones, 851 A.2d 1230, 1239-40 (Conn. App. Ct. 2004), aff'd, 885 A.2d 153 (Conn. 2005) (holding that jury charges using the term "victim" instead of "alleged victim" violated a defendant's due process right to a fair trial); Talkington v. State, 682 S.W.2d 674, 674 (Tex. App. 1984) (use of the term "victim" in court's rape charge was reversible error when the issue at trial was whether complainant consented to sexual intercourse); People v. Davis, 423 N.Y.S.2d 229, 230 (N.Y. App. Div. 1979) ("By referring in its charge to the complainant as the `victim' and to the defendant as the 'perpetrator', the court impermissibly insinuated to the jury that the complainant was the victim of injuries resulting from acts committed by the defendant."). + +At [the] upcoming trial, the jury has the responsibility of deciding whether a crime occurred and whether that crime resulted in harm to [the accuser]. Thus, to label [the accuser] as a victim at the outset of trial carries the risk of improperly influencing the jury's decision. Moreover, there is virtually no probative value in allowing the government to use the term "victim" to describe [the accuser]. See United States v. Ehrens, No. CR-15-200-C, 2015 WL 7758544, at \*2 (W.D. Okla. Dec. 1, 2015) (considering a similar motion and finding that there was "no need by any party to refer to [the alleged victim] by any particular descriptor other than her name"). Restricting the use of the term "victim" does not prevent the government from describing (the accuser's] injuries, or from presenting any of its other evidence. The government and its witnesses remain free to refer to (the accuser] by name or by other descriptive terms (e.g., "the mail carrier"). + +Id. (emphasis added). + +As argued in the motion, when the government, the Court, or another witness uses the term "victim" at the outset of the trial, it risks the jury pre-judging the merits, improperly + +speculating that the accusers have already been found credible by someone, or that their decision is a foregone conclusion. On the other side of the probative-prejudicial scale, the government simultaneously fails to articulate any probative value in use of the term "victim," either in its jury address or otherwise. Cf. State v. Wigg, 889 A.2d 233, 236 (Vt. 2005) ("the use of the term 'victim' had no inherent probative value"). + +Second, the government improperly suggests in response that the stricture on vouching should not apply to the witnesses themselves. Resp. at 79. As explained by numerous cases, having any witness refer to themselves or another witness as a "victim" is the very height of improper vouching. Sena, supra; State v. Sperou, 365 Or. 121, 131, 442 P.3d 581, 590 (2019) ("another witness's description of the complaining witness as a 'victim' conveys an opinion that the complaining witness is telling the truth. That is what the vouching rule is intended to prevent."); Wigg, supra. + +Finally, the government contends that Dr. can use the word "victim" in reference to "victims of sexual abuse generally," but her use of the term is even more problematic. For the reasons articulated in our Daubert motion and reply, Dr. bases her expertise on her therapeutic number of individuals who have self-identified as sexual abuse victims, without any research or investigation as to whether the individuals' self-reports are true. She then intends to draw from her anecdotal and experiential treatment to generalize about all "victims" without their ever having been a finding that any of the persons she has provided treatment to were, in fact, "victims." If she is permitted to testify, there is no reason for her to vouch for the credibility of her patients, unless she clarifies each time that she is taking the individual at their word that they were in fact a victim. The danger of confusion to a jury is that anyone treated by Dr. must have been a victim. As the Wigg court recognized, there will be a "danger of unfair + +prejudice because the [witness's] choice of language implied that he and the prosecution believed the complainant's testimony." Id. + +For these and the previously stated reasons, Ms. Maxwell asks the Court to order that the parties, the witnesses, and the Court use individuals' names in the presence of the jury. + +#### XIII. THE COURT SHOULD PRECLUDE INTRODUCTION OF GOVERNMENT EXHIBITS 52, 251, 288, 294, 313, 606 AND THE SEARCH OF EL BRILL() WAY + +### A. The Court Should Exclude the Challenged Government Exhibits + +Rule 901(a) of the Federal Rules of Evidence provides that "[t]he requirement of authentication or identification as a condition precedent to admissibility is satisfied by evidence sufficient to support a finding that the matter in question is what its proponent claims." See also Ricketts v. City of Hanford, 74 F.3d 1397, 1409 (2d Cir.1996); United States v. Sliker, 751 F.2d 477, 496-500 (2d Cir.1984) (discussing the interaction between Fed.R.Evid. 104 and 901). "In order for a piece of evidence to be of probative value, there must be proof that it is what its proponent says it is. The requirement of authentication is thus a condition precedent to admitting evidence." United States v. Sliker, 751 F.2d 477, 497 (2d Cir. 1984). A motion in limine to preclude evidence calls on the "[C]ourt to make a preliminary determination on the admissibility of evidence under Rule 104 of the Federal Rules of Evidence." Highland Capital Mgmt., L.P. v. Schneider, 379 F. Supp. 2d 461 (S.D.N.Y. 2005) (internal quotation marks omitted). "The purpose of a motion in limine is to allow the trial court to rule in advance of trial on the admissibility and relevance of certain forecasted evidence." Dougherty v. County of Suffolk, No. CV 13-6493 (AKT), 2018 WL 1902336, at \*1 (E.D.N.Y. Apr. 20, 2018) (internal quotation marks omitted). + +Ms. Maxwell has filed in limine motions challenging the admissibility of discrete items of evidence that the government intends to offer at trial. As discussed below, the Court should hold + +a pre-trial hearing at which the government must demonstrate that the proposed evidence is both authentic, admissible, relevant and not unduly prejudicial. + +### B. Government Exhibit 52 + +Government Exhibit (GX) 52 was acquired by the government as part of a sting operation from worked for Jeffrey Epstein for approximately six months, from late 2004 to early 2005. In 2009, he was deposed and then ultimately arrested in an undercover sting operation in which the government claims exhibit 52 was seized from ■ **apparently on or about November 3, 2009, by one who is not listed as a testifying witness. No one knows where or when the exhibit was acquired by** ■ what he did with it for as long as he had it, who may have created the exhibit, and where it came from. In its Response, the government does not identify what it claims this exhibit to be, who might authenticate the exhibit, only that a "witness with personal knowledge of the physical book is expected to testify to its authenticity." Resp. at 73. Given that is dead, and be. is not a witness, we are left to wonder who this foundational witness may + +The government further claims that even if the exhibit is hearsay, it is admissible, not for the truth of the matter asserted, but to show "the defendant kept contact information for relevant individuals at trial, including victims." Id. These are bold, unexplained claims that Ms. Maxwell disputes. The proffers here are inadequate to meet any burden of admissibility. The government should not be allowed to refer to the exhibit prior to the establishment of an adequate foundation; and Ms. Maxwell requests a pretrial evidentiary hearing on this issue. + +### C. The Palm Beach Search of El Brillo Way + +Again, the government claims that it will have live witnesses "to establish the authenticity of the evidence at trial." It does not identify the witness or the basis of that person's + +knowledge. The government does not provide any clues about who may have touched the evidence after it was seized in October 2005, ten months after the end of the conspiracy alleged and it does not address how these items seized are relevant to acts allegedly seized 10 years after the start of the alleged conspiracy or even 10 months after it ended. + +GX 295 is not a “past recollection recorded” by some other witness. It is a testimonial hearsay statement by a dead witness and admission of any part of GX 295 would violate Ms. Maxwell’s rights to confront the declarant and the rules of evidence. The government offers no explanation about how the affidavit of [REDACTED] could possibly be the recorded recollection of someone else; and a pretrial evidentiary hearing is warranted. + +**D.** [REDACTED] + +The supposed relevance for [REDACTED], again seized almost one year after the alleged conspiracy ended, is that they “help to establish that *it was apparent* from [REDACTED] + +[REDACTED] *Id.* at 74-75. [REDACTED] + +[REDACTED] + +[REDACTED] + +[REDACTED] The [REDACTED] then, establish no material fact in this case and their admission should be prohibited under Federal Rules of Evidence 401, 402, 403, and 404(b). + +### **E. The Twin Torpedoes** + +Seized in 2005, and still in the box, unopened, no witness will testify that Ms. Maxwell used these devices. The items were not and could not have been used in connection with any alleged act in this case, assuming a foundation can be established. Accordingly, the exhibit, whether it be the photograph or the actual boxed items, should not be admitted under FRE 401, 402, 403, and 404(b). + +### F. Government Exhibit 313 + +GX 313 was seized in 2019. It was not seized from Ms. Maxwell. No one will testify about where it was taken, who took it, or where it was kept. Because the government cannot establish the location of the photograph, it is not corroborative, as the government claims, of "topless swimming" at the Palm Beach pool, which is also not relevant to the allegations here. Ms. Maxwell has not challenged other photographs showing a close relationship between Ms. Marcell and Epstein, and we expect there to be evidence of their relationship at trial. Accordingly, any probative value of the evidence is substantially outweighed by the prejudicial impact of the picture. Again, this exhibit should be excluded under FRE 401, 402, 403, and 404(b). + +### G. Government Exhibit 606 + +GX 606 comes from an unknown author, created at an unknown time, and for an unknown purpose. The government's proffer is speculative and does not supply any evidentiary foundation, authenticity, or relevance. The exhibit should be excluded under FRE 901, 802, 401, 402, 403, and 404(b). As with the other exhibits discussed herein, Ms. Maxwell requests a pretrial evidentiary hearing. + +Dated: October 27, 2021 + +Respectfully submitted, + +s/ Jeffrey S. Pagliuca + +Jeffrey S. Pagliuca + +Laura A. Menninger + +HADDON MORGAN & FOREMAN P.C. + +Denver + +Phone: + +Christian R. Everdell + +COHEN & GRESSER LLP + +New York NY + +Phone: + +Bobbi C. Stemheim + +Law Offices of Bobbi C. Sternheim + +Attorneys for Ghislaine Maxwell + +**Certificate of Service** + +I hereby certify that on October 27, 2021, I electronically filed the foregoing *Ghislaine Maxwell's Reply In Support of Her Motions In Limine* with the Clerk of Court using the CM/ECF system which will send notification of such filing to the following: + +![](_page_51_Picture_39.jpeg) + +U.S. Attorney's Office, SDNY +One Saint Andrew's Plaza +New York, NY 10007 + +![](_page_51_Picture_41.jpeg) + +*s/ Nicole Simmons* + +--- \ No newline at end of file diff --git a/marker2/ds9/EFTA00090721/EFTA00090721.metadata.json b/marker2/ds9/EFTA00090721/EFTA00090721.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..c768b6d69f8c8c15181fcee13b783f27f3ce2ca6 --- /dev/null +++ b/marker2/ds9/EFTA00090721/EFTA00090721.metadata.json @@ -0,0 +1,2603 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090721.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 52, + "chars": 87218, + "elapsed_seconds": 143.69, + "image_assets": [ + "_page_51_Picture_39.jpeg", + "_page_51_Picture_41.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 71.28 + ], + [ + 299.3348083496094, + 71.28 + ], + [ + 299.3348083496094, + 101.9830322265625 + ], + [ + 68.544, + 101.9830322265625 + ] + ] + }, + { + "title": "GHISLAINE MAXWELL'S REPLY IN SUPPORT OF \nHER MOTIONS IN LIMINE", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 148.10399999999998, + 302.94 + ], + [ + 464.3270263671875, + 302.94 + ], + [ + 464.3270263671875, + 333.7330322265625 + ], + [ + 148.10399999999998, + 333.7330322265625 + ] + ] + }, + { + "title": "TABLE OF CONTENTS", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 250.92000000000002, + 72.08999999999999 + ], + [ + 398.1162109375, + 72.08999999999999 + ], + [ + 398.1162109375, + 86.853515625 + ], + [ + 250.92000000000002, + 86.853515625 + ] + ] + }, + { + "title": "TABLE OF AUTHORITIES", + "heading_level": null, + "page_id": 3, + "polygon": [ + [ + 241.12800000000001, + 71.28 + ], + [ + 407.91925048828125, + 71.28 + ], + [ + 407.91925048828125, + 86.9830322265625 + ], + [ + 241.12800000000001, + 86.9830322265625 + ] + ] + }, + { + "title": "Cases", + "heading_level": null, + "page_id": 3, + "polygon": [ + [ + 68.544, + 107.73000000000002 + ], + [ + 105.0146484375, + 107.73000000000002 + ], + [ + 105.0146484375, + 122.60302734375 + ], + [ + 68.544, + 122.60302734375 + ] + ] + }, + { + "title": "Statutes", + "heading_level": null, + "page_id": 5, + "polygon": [ + [ + 67.932, + 70.47 + ], + [ + 117.18220520019531, + 70.47 + ], + [ + 117.18220520019531, + 86.2330322265625 + ], + [ + 67.932, + 86.2330322265625 + ] + ] + }, + { + "title": "Other Authorities", + "heading_level": null, + "page_id": 5, + "polygon": [ + [ + 67.932, + 169.29 + ], + [ + 167.29054260253906, + 169.29 + ], + [ + 167.29054260253906, + 185.2330322265625 + ], + [ + 67.932, + 185.2330322265625 + ] + ] + }, + { + "title": "Rules", + "heading_level": null, + "page_id": 5, + "polygon": [ + [ + 67.932, + 208.98 + ], + [ + 104.23119354248047, + 208.98 + ], + [ + 104.23119354248047, + 224.9830322265625 + ], + [ + 67.932, + 224.9830322265625 + ] + ] + }, + { + "title": "I. THIS COURT SHOULD PRECLUDE INTRODUCTION OF ALLEGED CO-\nCONSPIRATOR STATEMENTS AS A SANCTION FOR GOVERNMENT'S \nFAILURE TO COMPLY WITH THIS COURT'S SEPTEMBER 3, 2021 ORDER", + "heading_level": null, + "page_id": 6, + "polygon": [ + [ + 86.904, + 98.82 + ], + [ + 529.899169921875, + 98.82 + ], + [ + 529.899169921875, + 141.603515625 + ], + [ + 86.904, + 141.603515625 + ] + ] + }, + { + "title": "A. The Court's Order was Neither Ambiguous Nor Misread by the Defense", + "heading_level": null, + "page_id": 6, + "polygon": [ + [ + 105.26399999999998, + 207.36 + ], + [ + 533.1207885742188, + 207.36 + ], + [ + 533.1207885742188, + 223.7335205078125 + ], + [ + 105.26399999999998, + 223.7335205078125 + ] + ] + }, + { + "title": "B. The Court Has the Authority to Require Disclosure", + "heading_level": null, + "page_id": 7, + "polygon": [ + [ + 105.26399999999998, + 374.22 + ], + [ + 418.4632873535156, + 374.22 + ], + [ + 418.4632873535156, + 390.80352783203125 + ], + [ + 105.26399999999998, + 390.80352783203125 + ] + ] + }, + { + "title": "C. There Should Be a Sanction", + "heading_level": null, + "page_id": 9, + "polygon": [ + [ + 105.26399999999998, + 208.98 + ], + [ + 287.5003356933594, + 208.98 + ], + [ + 287.5003356933594, + 225.2335205078125 + ], + [ + 105.26399999999998, + 225.2335205078125 + ] + ] + }, + { + "title": "D. There are Substantial Issues with the Government\u2019s Anticipated Position", + "heading_level": null, + "page_id": 10, + "polygon": [ + [ + 105.26399999999998, + 72.08999999999999 + ], + [ + 537.948, + 72.08999999999999 + ], + [ + 537.948, + 87.48 + ], + [ + 105.26399999999998, + 87.48 + ] + ] + }, + { + "title": "II. GOVERNMENT CONCEDEDLY FAILED TO GIVE NOTICE OF THE \nBASIS OR REASONING TO ADMIT ANY 404(B) EVIDENCE", + "heading_level": null, + "page_id": 11, + "polygon": [ + [ + 80.784, + 71.28 + ], + [ + 520.9564208984375, + 71.28 + ], + [ + 520.9564208984375, + 101.853515625 + ], + [ + 80.784, + 101.853515625 + ] + ] + }, + { + "title": "A. [REDACTED] Bear No Relationship to the Charged Conspiracy, Reflect Pure Propensity Evidence, and Otherwise are Unduly Prejudicial [REDACTED]", + "heading_level": null, + "page_id": 12, + "polygon": [ + [ + 105.26399999999998, + 290.78999999999996 + ], + [ + 514.0799999999999, + 290.78999999999996 + ], + [ + 514.0799999999999, + 319.95000000000005 + ], + [ + 105.26399999999998, + 319.95000000000005 + ] + ] + }, + { + "title": "2. The government has apparently abandoned efforts to introduce her \ntestimony as Rule 404(b) evidence.", + "heading_level": null, + "page_id": 18, + "polygon": [ + [ + 126.68399999999998, + 71.28 + ], + [ + 499.9435729980469, + 71.28 + ], + [ + 499.9435729980469, + 99.603515625 + ], + [ + 126.68399999999998, + 99.603515625 + ] + ] + }, + { + "title": "3. constitutes an impermissible \nconstructive amendment and variance to the Indictment.", + "heading_level": null, + "page_id": 18, + "polygon": [ + [ + 126.68399999999998, + 606.6899999999999 + ], + [ + 484.6098327636719, + 606.6899999999999 + ], + [ + 484.6098327636719, + 636.6035461425781 + ], + [ + 126.68399999999998, + 636.6035461425781 + ] + ] + }, + { + "title": "C. Ms. Maxwell reiterates her re uest to defer briefin and rulin on the \nadmissibility for two \nweeks.", + "heading_level": null, + "page_id": 20, + "polygon": [ + [ + 105.26399999999998, + 71.28 + ], + [ + 532.6436157226562, + 71.28 + ], + [ + 532.6436157226562, + 116.9830322265625 + ], + [ + 105.26399999999998, + 116.9830322265625 + ] + ] + }, + { + "title": "III. THIS COURT SHOULD EXCLUDE TESTIMONY UNDER \nFEDERAL RULE OF EVIDENCE 702 AND DAUBERT V. MERRELL DOW \nPHARMACEUTICALS, INC., 509 U.S. 579 (1993) AND GRANT A DAUBERT \nHEARING", + "heading_level": null, + "page_id": 20, + "polygon": [ + [ + 77.112, + 347.49 + ], + [ + 526.3199999999999, + 347.49 + ], + [ + 526.3199999999999, + 404.9830322265625 + ], + [ + 77.112, + 404.9830322265625 + ] + ] + }, + { + "title": "A. This Court should reject the government's arguments to the extent that they are \nbased on newly disclosed material, which this Court ordered the government to \nproduce six months ago.", + "heading_level": null, + "page_id": 20, + "polygon": [ + [ + 105.26399999999998, + 415.53 + ], + [ + 543.456, + 415.53 + ], + [ + 543.456, + 458.68353271484375 + ], + [ + 105.26399999999998, + 458.68353271484375 + ] + ] + }, + { + "title": "B. proposed testimony is inadmissible.", + "heading_level": null, + "page_id": 22, + "polygon": [ + [ + 104.652, + 70.47 + ], + [ + 367.4147644042969, + 70.47 + ], + [ + 367.4147644042969, + 86.103515625 + ], + [ + 104.652, + 86.103515625 + ] + ] + }, + { + "title": "C. At a minimum, this Court should hold a Daubert hearing.", + "heading_level": null, + "page_id": 28, + "polygon": [ + [ + 105.26399999999998, + 346.68 + ], + [ + 427.1644592285156, + 346.68 + ], + [ + 427.1644592285156, + 362.9830627441406 + ], + [ + 105.26399999999998, + 362.9830627441406 + ] + ] + }, + { + "title": "IV. THE RT SHOULD EXCLUDE EVIDENCE RELATED", + "heading_level": null, + "page_id": 29, + "polygon": [ + [ + 78.33600000000001, + 194.39999999999998 + ], + [ + 425.4834899902344, + 194.39999999999998 + ], + [ + 425.4834899902344, + 209.853515625 + ], + [ + 78.33600000000001, + 209.853515625 + ] + ] + }, + { + "title": "V. THE GOVERNMENT CONCEDES THAT IT WILL NOT OFFER EVIDENCE OF MS. MAXWELL\u2019S ALLEGED \u201cFLIGHT\u201d", + "heading_level": null, + "page_id": 37, + "polygon": [ + [ + 82.62, + 153.89999999999998 + ], + [ + 525.708, + 153.89999999999998 + ], + [ + 525.708, + 183.06 + ], + [ + 82.62, + 183.06 + ] + ] + }, + { + "title": "VI. THE GOVERNMENT CONCEDES THAT IT WILL NOT OFFER EVIDENCE OF MS. MAXWELL\u2019S ALLEGED FALSE STATEMENTS AND AGREES TO MS. MAXWELL\u2019S PROPOSED REDACTIONS", + "heading_level": null, + "page_id": 37, + "polygon": [ + [ + 76.5, + 277.02 + ], + [ + 515.9159999999999, + 277.02 + ], + [ + 515.9159999999999, + 321.57000000000005 + ], + [ + 76.5, + 321.57000000000005 + ] + ] + }, + { + "title": "VII. THE COURT SHOULD HOLD A PRE-TRIAL EVIDENTIARY HEARING ON MS. MAXWELL\u2019S MOTION TO SUPPRESS IDENTIFICATION.", + "heading_level": null, + "page_id": 37, + "polygon": [ + [ + 70.992, + 416.34000000000003 + ], + [ + 537.948, + 416.34000000000003 + ], + [ + 537.948, + 445.5 + ], + [ + 70.992, + 445.5 + ] + ] + }, + { + "title": "VIII. GOVERNMENT AGREES NOT TO ELICIT LAW ENFORCEMENT \nOPINION TESTIMONY", + "heading_level": null, + "page_id": 40, + "polygon": [ + [ + 66.096, + 345.87 + ], + [ + 506.5983581542969, + 345.87 + ], + [ + 506.5983581542969, + 377.8535461425781 + ], + [ + 66.096, + 377.8535461425781 + ] + ] + }, + { + "title": "IX. THE COURT SHOULD PRECLUDE TESTIMONY ABOUT ANY ALLEGED \n\"RAPE\" BY JEFFREY EPSTEIN", + "heading_level": null, + "page_id": 41, + "polygon": [ + [ + 78.33600000000001, + 289.98 + ], + [ + 518.5399780273438, + 289.98 + ], + [ + 518.5399780273438, + 320.8535461425781 + ], + [ + 78.33600000000001, + 320.8535461425781 + ] + ] + }, + { + "title": "XII. REFERENCE TO ACCUSERS AS \"VICTIMS\" IS IMPROPER VOUCHING", + "heading_level": null, + "page_id": 43, + "polygon": [ + [ + 73.44, + 539.46 + ], + [ + 513.4024658203125, + 539.46 + ], + [ + 513.4024658203125, + 555.6035614013672 + ], + [ + 73.44, + 555.6035614013672 + ] + ] + }, + { + "title": "XIII. THE COURT SHOULD PRECLUDE INTRODUCTION OF GOVERNMENT \nEXHIBITS 52, 251, 288, 294, 313, 606 AND THE SEARCH OF EL BRILL() WAY", + "heading_level": null, + "page_id": 46, + "polygon": [ + [ + 68.544, + 180.63 + ], + [ + 535.0867309570312, + 180.63 + ], + [ + 535.0867309570312, + 210.7330322265625 + ], + [ + 68.544, + 210.7330322265625 + ] + ] + }, + { + "title": "A. The Court Should Exclude the Challenged Government Exhibits", + "heading_level": null, + "page_id": 46, + "polygon": [ + [ + 105.26399999999998, + 220.32000000000005 + ], + [ + 463.5096435546875, + 220.32000000000005 + ], + [ + 463.5096435546875, + 236.2330322265625 + ], + [ + 105.26399999999998, + 236.2330322265625 + ] + ] + }, + { + "title": "B. 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her residence. terbeing advised o teientity of the interviewing Agent, Task Force officer and the nature of the interview, provided the + +following information: + +When questioned why she thought AGENTS from the Federal Bureau of Investigation (FBI) were at her residence, she responded "JEFFREY EPSTEIN". immediately advised that she had counsel and she wanted to speak with her counsel before any questioning. was served the Grand Jury Subpoena. provided her attorney name, JOSEPH E NASCIMENTO, of Ross Amsel, Raben + +and Nascimento Law Firm, telephone number + +AGENTS immediately terminated the interview served with a Federal Grand Jury Subpoena. date of birth was present and witnessed the service of the Federal Grand Jury Su poena. provided the AGENTS with a Florida Driver's License as form of + +identification. + +',nation 01/06/2019 si + +Mks 31E-NY-3027571 + +Miami, Florida, United States (In Person) + +rimednflect 07/16/2019 + +by + +This dcoumetu contains neither fOCOMIlbtOdJbeti nor conclusions of the Fill It is the geopeny oldie FIJI and is loaned to your army; a and its contents are not + +to be dins shined outside yotu agency + +31E-NY-3027571 + +(U) Proffer of + +Condweren ofFM302 Interview 41 07/12/2019 .pew 2 of 11 + +trip to Paris in approximately early 2006 was her last assignment. + +Put in contact with an agent named PAOLO ZEMPOLI who worked + +with "ID Models". It was organized for to go to New York to model. While in New York, lived in a model's apartment because she did not have the funds to pay for her own apartment. The apartment accommodated ten people and was on the same street as the model agency on Varick Street. + +had an affair with the agent. ZEMPOLI was trying to buy Elite Models + +with EPSTEIN. EPSTEIN introduced MELANIA TRUMP to DONALD TRUMP. + +EPSTEIN was visiting ZEMPOLI at the agency when there were casting auditions for models. EPSTEIN was looking through portfolios and saw + +11111111s photograph of her wearing only swim bottoms. + +and ZEMPOLI were at a night club with EPSTEIN, who was there with + +a woman who believed was + +phone number. + +Someone called, either a girl or EPSTEIN, and invited to dinner. went to EPSTEIN's residence on 71st Street in Manhattan. This was + +the first one on one interaction had with EPSTEIN. EPSTEIN made her wait; she heard him playing the piano. did not recall if she went upstairs. and EPSTEIN had dinner in the dining room. This room was straight ahead when you walked into his home. EPSTEIN asked what she liked to do. told EPSTEIN that she liked studying and that she was a good student. They talked about travels and having a model contract in Japan and South Korea. mentioned that she thought there was a lot + +of Russian prostitution. EPSTEIN told her, "That's what I like best." + +recalled EPSTEIN saying something that made her uncomfortable. EPSTEIN gave a tour of the house, took her to the massage room and + +had her lay down, took a "vibrating thing" and rubbed it on her. + +told him to stop. tescribed the massage room as a small, very dark room on the same floor as the master bedroom. A driver took home and + +she remembered being tearful in the car. + +The next morning or a day later, recalled that EPSTEIN called her. 111111/ was unsure how everything pr ressed from there. EPSTEIN may have offered her an English class, which attended. EPSTEIN offered + +31E—NY-302757l + +lul Proffer of + +(.,Alimmionorm.m2,4 Interview II 11. 07/12/2019 .pvc 3 of 11 + +her a job approximately at the end of 2004. EPSTEIN offered an apartment in New York on 66th Street in Manhattan. EPSTEIN offered job with Victoria's Secret, which was a photo shoot. EPSTEIN told + +that she needed to work out to be a model and told her to go to a specific + +gym. + +had traveled to Florida with EPSTEIN on h s plane. did + +not have a driver's license. + +went with + +organized by EPSTEIN. + +to the floor of Wall Street on a trip + +met GHISLAINE MAXWELL at her house around the end of 2004. + +MAXWELL told to purchase items like toiletries prior to getting offered the job. The job responsibilities included running errands, and helping , who was EPSTEIN's personal assistant. was 's immediate supervisor. MAXWELL gave direction. + +had intimate relations with EPSTEIN, but did not have + +intercourse. EPSTEIN had multiple sexual encounters with + +felt this was personal. + +described as having big brown eyes and chin length blonde + +hair. helped with errands, traveled with them, called pilots, and purchased things for EPSTEIN's plane. In Palm Beach, answered + +calls and confirmed massage appointments. was given this + +responsibility shortly after beginning to work for EPSTEIN. mainly stayed in Palm Beach, while 's home was in Miami. Wfien stayed + +in Palm Beach, she slept in EPSTEIN's house in one of the bedrooms. + +a + +Typically, had to travel with EPSTEIN. When they traveled to EPSTEIN's island, stayed with him on the island. They traveled a lot to Boston, specifically visiting Harvard. They met with MARTIN NOVACK and ALAN DERSHOWITZ. traveled to New Mexico and Paris with EPSTEIN. + +spent the most time in the Virgin Islands with EPSTEIN so EPSTEIN + +could count his time in the island to establish for tax residency. + +Other people that traveled regularly with EPSTEIN besides MAXWELL, + +31E—WT-3027571 + +(U) Proffer of + +conin,,,gionorFnana Interview 41 + +, and were BRUNEL, IGOR, and a chef. + +a casual relationship with EPSTEIN. + +IGOR was + +.0, 07/12/2019 .pne 4 of 11 + +JEAN LUC + +was EPSTEIN's girlfriend. had was introduced by imp + +EPSTEIN's personal trainer. + +In New York, ran errands, bought things, went to EPSTEIN's house + +and sat in on meetings. worked in MAXWELL'S house on the ground floor in New York. was given an apartment in the same building as MAXWELL.nent most of her time in New York at MAXWELL'S home. did not recall if she had made phone calls from New York. + +LESLIE GROFF was EPSTEIN's assistant in EPSTEIN's Madison Avenue office who scheduled his appointments for people coming to his house, including massage appointments. GROFF made those phone calls to schedule appointments. + +Fairly early on after working for EPSTEIN, began helping schedule + +massage appointments. In reference to knowing what occurred during the massages, stated, "It happened to me in the Virgin Islands, so I assumed that was happening to everyone else during their massages." + +saw women in his New York house that she understood were there to + +give massages. was at his New York residence a lot and would bring other girls. Another girl named would also bring other girls. IIIMI brought two girls who were dancers/ballerinas, who stated that they were 16 years old. and may have been there. EPSTEIN told them that + +he would buy them dancing shoes. + +At the time, was not sure if the girls who massaged EPSTEIN were underage but it seemed consensual and knew it was a sexual massage. + +had + +in New York. + +research girls on Twitter. One girl named was 17 + +was approximately 21 years old. EPSTEIN's massages were approximately twice a day everyday in New York and Palm Beach. In New York, + +EPSTEIN also had a lot of meetings. + +met in approximately 2004. + +roommate who may have assisted. + +MIMEO was 's + +31E-NY-302/571 + +(U) Proffer of + +Cowinurion ofThan lncerview 41 07/12/2019 " we 5 of 11 + +In Palm Beach, IIIIIII was responsible for answering phones and + +confirming massage appointments if wasn't around. EPSTEIN, as well as Mille would ask to do this. showed girls to the massage room and set up the table for them. IIIIIII also bought tickets for comedy clubs for EPSTEIN. was also responsible for researching things for + +EPSTEIN and running errands. + +When traveling from New York to Palm Beach, set up the schedule for massages or gave a list of people to call for appointments. IIIIIII may have called from New York to make appointments for Palm Beach, + +but mostly made those calls. + +Part of the regular routine for was to check in with EPSTEIN in + +the morning. EPSTEIN would be in his office, gym, or by the pool. would see who EPSTEIN wanted her to call; EPSTEIN gave her a list. + +was someone EPSTEIN commented on. EPSTEIN commented on + +S's SAT score. massaged EPSTEIN and hung out at the Palm Beach house, then went to New York. EPSTEIN helped get an internship. + +was told how to make calls and told what to say. When called to confirm appointments she said, "This is IIIIIII calling on behalf of Jeffrey Epstein...calling to confirm the massage appointment." EPSTEIN was upset when she used his name when confirming massage appointments. EPSTEIN told her to never use his name when calling people. On the calls, + +discussed what time they would come. EPSTEIN pushed her to call and + +confirm appointments. had to call multiple times to confirm + +appointments. did not remember ever calling men to confirm massage + +appointments. + +EPSTEIN wanted to put eye cream on him. EPSTEIN became upset with + +her if she missed a day. If missed a phone call for a massage appointment, EPSTEIN became very upset and left her a nasty voincemail. + +EPSTEIN raised his voice to + +thought that EPSTEIN was originally going to teach her about + +finance. EPSTEIN sent her to one to two business meetings but then was different after she started working for him. EPSTEIN became stressed with her, asking her, "Do you want to work?" when referring to her calling girls. + +31E-NY-302/571 + +(U) Proffer of + +Cedwwgionorman Of Interview II 07/12/2019 J. , 6 of 11 + +often called and asked the girls about another girl. asked + +her to do this. recalled calling and asked her to bring another girl. called and asked her to bring another girl. + +was upset with because called s home where her + +parents lived. Girls had mentioned to that they could not come + +because they had school. + +The girls would come in from the rear of the house, near the kitchen. + +offered them water. told them to go upstairs. The massage room was attached to his master bathroom with sauna, steam room, and closet, with the massage table inside the closet. may have put a towel on + +the table. EPSTEIN told to give the girls a hair band. + +was present one time when a girl massaged EPSTEIN. massaged EPSTEIN in Palm Beach. eft during most massages, going about her tasks around the house. e massages took approximately an hour. Sometimes EPSTEIN called downstairs and sometimes during the massage he would call other people. knew the massage was done when the girl would come downstairs. EPSTEIN paid the girls; he always had a huge amount + +of money in his bag. He paid the girls approximately \$200. + +and typically stayed a bit\_ longer after the massage. + +If a girl brought another girl, one would go upstairs while the one who brought the girl hung out downstairs. brought girls. EPSTEIN may have asked to pay the girls for him. 'I'll.. was instructed to bring girls from Miami to Palm Beach; these girls were associated with Ideal Models. talked about a time where one girl was sitting on the couch visibly upset and EPSTEIN had a friend who was a doctor there who told them that the girl did not feel well. EPSTEIN had a car service take the girl + +home. + +Palm Beach massages happened twice a day everyday. typed up a list of girls to call in Palm Beach and printed a few copies. threw + +these away. This list was specific to massages. + +recalled one girl calling and talking about college. The girls + +were young women. did not know their exact age. Thinking back on it, felt that she should have had the impression that they were + +31E—NY-302/571 + +(U) Proffer of + +Coetieurion °imam a Interview 41 .0, 07/12/2019 ,eigt 7 of 11 + +underage. She was used to young women being around older men in the modeling + +industry. + +MINIM recalled Min me, and traveling on EPSTEIN's plane from New York to Palm Beach. recalled other girls names that were at EPSTEIN's house, including II and 11111. There were more girls but could not recall all of their names. The girls were students, not models. Some may have been in a horse + +back riding club. The girls asked for assistance to go to college. + +Imp may have had a personal relationship in the past with EPSTEIN but had not heard anything. assumed because EPSTEIN was always + +with a girl. + +took a lot of photographs. took photographs of in + +the Virgin Islands. EPSTEIN had told that it was Ok to undress. There were a lot of nude photographs in EPSTEIN's home. There were also nude + +photographs in the gym in the New York house. + +In Palm Beach, was in the living room and started stripping when + +started taking photographs. kept the photographs in binders in + +MANNELL's house. + +felt that took advantage of her because she had do + +"nasty tasks" and had her constantly running. felt that i made her do the heavy lifting. and iiiiiii were friendly with each other + +but did not like ha treated her. + +When called to confirm appointments, she sometimes left a + +voicemail with her cell number for a call back. + +could not remember if she and talked about what happened + +with the massages or if made comments about the girls. + +In the Virgin Islands, they would travel to the island by boat. + +had to give EPSTEIN massages. A girl named would come to the island to give EPSTEIN massages. In the morning, would go to his office. There were different beach huts on the island. EPSTEIN would take a golf cart around the island. EPSTEIN worked out a lot on the island. When they + +3:E-NY-3027571 + +(0) Proffer c + +CommlumimeaFM302 of Interview ;I sek, 07/12/20:9 ,h0: 8 of 11 + +were on the island, it was more leisure time. There was a room by the kitchen where they all watched TV. Some of 's tasks included researching things online and making online purchases. There was a house manager who would ask people about allergies and they would have to fill out + +a card. + +Other tasks was responsible for were buying furniture. + +was also instructed to buy sex toys from a sex shop in New York, but could not recall who had told her to buy them. thought the sex toys she had to buy were vibrators. recalled having to go to some building + +with an upstairs. + +In Palm Beach, 'rdered books for a girl. The books were not sent in time and EPSTEIN was upset with thought the books may have been for IIII stayed more in the house. DAVID COPPERFIELD was at the house one time and may have met him. was one of the girls who + +came for massages. + +to give more. IIII may have brought a picture of her artwork. + +told to get a tutor. EPSTEIN wanted + +and\_brought girls. purchased a lot of gifts for s baby. thought was older but was unsure how old + +was. + +When traveled with EPSTEIN to New Mexico, it was a long drive to the house. It was a big house with a guest house. felt that she was likely doing the to do list from New York. had to give EPSTEIN + +facials. There was horse back riding with disclaimers. recalled that + +they barely traveled to New Mexico; they were maybe there twice. + +Somtimes there was a chiropractor who came after the massages and girls + +would get adjustments. + +was paid every two weeks. Her starting salary was \$36,000 and + +eventually was paid approximately \$40,000 - \$41,000. + +The individuals who traveled with EPSTEIN, including and + +were given massages. ALAN DERSHOWITZ received a massage from - she + +had a tattoo. and gave massages. + +understood these massages to be more professional massages. T ese massages + +31E —NY —3027571 + +(U) Proffer of + +( caut ion ormay2,,,, Interview 11 Oa 07/12/2019 .fts,, 9 of 11 + +were different than the massages the girls gave. did not think the + +girls were professional masseuses. + +was EPSTEIN's girlfriend. heard them exchange "I love + +you". was a model. was associated with and/or was under the impression that EPSTEIN was a co-owner. traveled with EPSTEIN and did not model. slept. in the bedroom with EPSTE:N. went back to modeling when she needed to renew her visa. + +and had an intimate relationship. talked about a + +time where LARRY SUMMERS.was sitting in the waiting room and having a + +lengthy meeting with EPSTEIN. + +from an event, and told her that she had been looking for girls. + +described and EPSTEIN's relationship as a strong love relationship. + +saw who looked like she came + +stated there was no alcohol around unless a guest wanted it. + +resigned from working for EPSTEIN. did not want to be + +around EPSTEIN anymore. felt that there was something weird going on with the complete situation. It took a while to make the decision to + +quit. + +stated they used a citrix based system. LESLIE GROFF put messages + +in the system. These were messages that were on the computer in New York. They eventually stopped using this system. There were small directory books. + +Phone books were outdated. There were print outs of messages. + +In approximately October 2005, s, and EPSTEIN flew to Miami. along with her dog she traveled with, went to 's house. EPSTEIN went with and later met up with them at Soho House in Miami Beach. dropped off and was told to go to Palm Beach to meet with someone. EPSTEIN told that something was stolen and had to travel to give computers to oe examined. The + +person met was alone. This happened the day before + +birthday. EPSTEIN and told to take the books, which were personal contact phonebooks - the black ones were MAXWELL's and the colorful ones were EPSTEIN's. could not remember if she took both. There were a lot of books by each phone. These were copy pads that people would put messages on and tear out to give to EPSTEIN. There were also white pads with + +31E-NY-3027571 + +(U) ',roster o + +comma.", a pean of Interview 11 Au, 07/12/2019 ,Ni, 13 of 11 + +EPSTEIN and MAXWELL'S names throughout the houses. JANUSZ BANASIAK helped + +gather the items together. There was a computer that and + +used, EPSTEIN's computer, and potentially MAXWELL'S computer that they collected. a turned these items over to a person that seemed tc be a law enforcement type person. She took an inventory of things that she gave + +to this individual, who she believed to be DETEC:IVE BLACK. + +There was a specific computer chat and used in Palm Beach. + +recalled a girl saying something about social profiles. + +also asked to bring books from the Virgin Islands and meet + +her in MAXWELL'S office. old o shred an updated list of names of girls. IIIIII had a notebook wit tie investigative agency sticker + +on it. + +EPSTEIN told that there was an investigation and that It had something to do with visas. EPSTEIN told that they were asking about her parents. EPSTEIN had surprised with a visit from her parents. + +knew that EPSTEIN was lying about how her parents got their visas. + +recalled a time where she was on the island and EPSTEIN told her, + +"Do you see the camera? They're watching me". + +did not recall how she had learned about the actual reason for + +the initial investigation. EPSTEIN's counsel DARREN INDYKE called her into + +his office and told her not to talk to law enforcement. + +In approximately October 2005,IIIIIIIIIkesigned to took it as a joke. had called her about an issue with MAXWELL; cried and told that she did not want to be there. gave notice, but + +still worked for EPSTEIN until early 2006. + +EPSTEIN promised a car. IIIIIII told him to cancel giving her the car. EPSTEIN gave a car, which she kept and it stayed in her name. + +felt that she had to stay in contact with EPSTEIN because the car + +was in his name and was under his insurance. In Early 2006, + +contacted either GROFF or someone else and asked to return the car. + +and her husband drove Co Palm Beach to return the car. + +3IE-NY-302/571 + +(U) Proffer of + +(antiunion amm o( Interview 11 O7/12/2O19 ,per 11 of 1: + +After left, approached her at Club Monaco and asked her if + +she wanted to come to the Virgin Islands to work. told her no. + +Attorneys reached out to + +New York named + +attorney was BRYCE LYONS. + +speak to LYONS. 'I'll.. thought FBI agents may want to talk with her. + +spoke with an FBI agent and she told the agent to call her attorney. + +1111111 later hired her own attorney. + +asking questions. There was a woman in + +reached out, and told her that her called the office asking if she could + +saw EPSTEIN looking at pornography on the computer that she and used. EPSTEIN said that porn websites have the best poses for models. + +EPSTEIN said that he did not have an email address but he did. Email + +addresses that EPSTEIN used were jepstein@yahoo.com and jeepstein@yahoo.com. + +an email of pictures of girls that EPSTEIN said were ugly. + +told to send photographs of girls to JEAN LUC BRUNEL for + +the purposes of casting/scouting for his agency. + +EPSTEIN did not carry a cell phone. EPSTEIN would take one of their cell + +phones and dial who he wanted. + +has received random calls and texts from New York numbers. When + +she left EPSTEIN's employment, she felt fearful that someone was following + +her. + +Not all details were covered during this interview. agreed to + +meet again at another date. + +FO.102 (It" S-2.(0) -1 cf 12- + +FEDERAL BUREAU OF INVESTIGATION + +wakftwom, + +Dsofmnry 03/31/2020 + +date of birth (DOB) was interviewed + +pursuant to a proffer agreement at West Palm Beach, Florida. Present for the interview was attorney Joseph Nesnimenlo, along with AUSA , AUSA , and Special Agent + +After being advised of the identities of the above listed + +individuals and the nature of the interview, provided the following + +information: + +spoke about two messages she recalled writing down. One cf which + +had identifier SA03008 on the message pad dated 4/1/05. This message was from JEAN LUC BRUNEL and read, "He has a teacher for you to teach you how to speak Russian. She is 2x6 years old not blonde. Lessons ere free end you can have 1st today if you call.' knew this to mean it referenced a teenage girl. wrote this message. GH:SLAINE MAXWELL was in the house and stated, "Oh, this is a funny message". Either MAXWELL made + +rewrite it or MAXWELL rewrote it herself. The message meant that + +there was a potential teenage girl for EPSTEIN to meet. + +The other message had identifier SA01446 on the message pad dated 2/28/05. This message referenced school. remembered taking this call. did not know the name, but knew the call was in reference to + +scheduling a massage. + +would have used the initial "II" when initialing her name back + +then. + +saw on Twitter that ALAN DERSHOWITZ stated that he was with his + +wife and kids when he was at EPSTETN's hone. mat :MR5901411'2 and he was alone in the house with no wife and no kids when he received a massage. + +was shown a series of copies of messages and asked about her + +recollection of each, all of which are attached in a 1A. + +',magma= 09/10/2019 reef SOD-NY-3027571 + +Koct ',atm warn, riorlda, united stares (In vorAnn) + +Daiednbal 10/03/2019 + +by + +Tbs. daces! cabin nada recaandaticac ear combo:at of the FBI its. tbe preperly ottbe FBI ad st loaned to yam 3gencya ma] ix c 9 of I2 + +liked to play mind games. On the island, was sick with a fever, when EPSTEIN came in the room and said, "Wake up lazy fuck". On one of 's days off, EPSTEIN left her a message and he was very upset. EPSTEIN made her sit on the floor and do a pedicure. EPSTEIN obsessed about putting on his eye cream; if she missed a day he would get upset. There was a time on the island where EPSTEIN said that despite the guy being married, he was gay. EPSTEIN said this gentleman needed to spend more time + +with and . This man's wife was DIANE VON PURSTENBERG. + +EPSTEIN called a Polish Nazi. + +On the island and in New Mexico, along with one time in Palm Beach, + +would have to give a massage and it would lead to sexual contact + +with EPSTEIN. Another girl, also gave massages. + +recalled a time whereI'll\* the house manager, asked her to come + +downstairs. EPSTEIN asked room topless. touched to run him a bath, was in the + +There was a time where was asked to travel to Boston. EPSTEIN often went to HARVARD. thought the trip there was a short flight on + +his Gulfstream. The bed was made. When there was nudity and a sexual encounter, EPSTEIN wanted to have sex and if said no, he stopped. + +Other times, was involved in the sexual encounters and + +initiated them. The sexual encounters were predominantly associated with massages. In 's mind she did not want to do it but went along with it. There was a very strange situation that happened on the plane when + +EPSTEIN grabbed by the neck and shook her hard. remember EPSTEIN being forceful with the sexual encounters. + +20/21 years old and stated that it was consensual. EPSTEIN sometimes told + +that she had massaging duty. was confused that this was + +part of her role. did not see give massages. + +did not was + +EPSTEIN flew s parents in as a surprise. was not happy with this because he had access to her parents. At a prior time, EPSTEIN and talked about her Polish background and EPSTEIN had said the last name of her grandmother. knew at this point he had done research on + +her family and background. + +A Department of State Agent BEN WOLF flew on EPSTE:N's plane and asked + +SOD-NY-3023571 + +commit:won orso-mo (U) Prof far o Ai D9/10/2019 - per,. ID or 12 + +who all of the girls were. EPSTEIN told that she should ask WOLF about her immigration status. EPSTEIN also told her to talk to INDYKE, but + +?NOYES' could not help. + +EPSTEIN first told that she had massage duty when they were on his island together. could not recall how it progressed to sexual contact. felt the sexual encounter with was planned. + +initiated the contact with EPSTEIN and had approximately five encounters with the two of them together. EPSTEIN joked that was his gay girlfriend. There was one time where EPSTEIN was + +not present and initiated sexual contact. + +gave a massage. also gave a massage to a girl who + +flew into the island. did not know this girl's name. met this girl at St. Darts, where this girl was a saves associate. This girl + +did not look underage to flew this girl in. + +talked about a conversation with EPSTEIN in which he talked with + +her about keeping men happy. took this as flirting or giving sexual + +favors. did not respond. + +EPSTEIN introduced the to EPSTEIN introduced his cousin to them and to other people. When looked up the word "cousin" in slang, it meant prostitute. was upset by this. She + +felt that EPSTEIN was propositioning her. + +There was a time where they flew into Aspen and LES WEXNER and other girls went shopping. They gestured to 'nd she thought they were + +talking about her. + +as + +ANDREW FARKAS introduced a Sultan from Dubai to EPSTEIN. was + +there on the phone with and EPSTEIN telling her what to say. + +lived in New York. EPSTEIN was telling her not to think about it t . . They were going to the hotel to meet up. This was in New York. They were + +all in the ear with JOJO driving. thought that she had met and saw her in New York. described as Middle Eastern. + +talked about a time when EPSTEIN, , and with her dog, + +flew into Miami. wet them at a meeting point and was asked to + +entertain II'S while EPSTEIN and went somewhere else. They were all + +SOD- NY- 302'757i + +Conlinuai,n offp.ma Prof for of 09/10/20IS pwc 11 of 12 + +standing in front of a building. EPSTEIN had helped with her Soho house in Miami Beach. EPSTEIN LOUa that she could be a real estate agent. EPSTEIN had meet up with a developer/architect. told + +that she had to drive to meet someone in Palm Beach. EPSTEIN told that something would happen with her visa, but did not remember everything about this. thought something had happened to EPSTEIN's detriment. gave the number of the person she was supposed to meet. was rushing there. JANUSZ MANASIAK and another gentleman, PAUL, were there. They were grabbing computers and notebooks. + +'as to follow up with the gentleman on when to get the items back. + +They were to be given to someone named DETECTIVE BLACK and to be returned + +when he was done with them. PAUL. BANASIAK found more books. + +and she gave them to him. because she gave traveled on to the island. + +After this, + +gave the computers and notebooks to + +called PAUL or he was still there + +thought that the instruction came from the phone number. thought they then + +asked to gather books on the island and to + +bring them back from the island. + +locations and huts. brought these items back from the island and to New York and gave them to . Sometimes when traveled to the island she went with EPSTEIN and other times she flew from Miami Lo Puerto Rico to the Virgin Islands. There was a °river that took her from the + +marina by boat. gave the books to in MAXWELL's house. There was a printout of a more recent copy. had told to shred it in MAXWELL's house. recalled having a feeling that it was all + +strange. + +reminded to go in all the + +recalled in EPSTEIN's duffel bag he kept a tape recorder. + +saw it on and turned it off. In the beginning of 2006, EPSTEIN reach for the tape recorder and slip it into his bathrobe. saw + +The initial promise EPSTEIN made Lo was for her Lo work for him, :earn things like stocks and the business world. Working for EPSTEIN was stressful for ; the verbal assaults grew and she never felt good working for him. told that she was resigning. did not Lake her seriously. Al the Lime, EPSTEIN'S accountant resigned, and she told EPSTEIN that she had resigned too. did not think EPSTEIN took + +her seriously either. received c, from them in 2006. + +SOD—NY-3O2/571 + +rumeleaueurfaxed (U) Proffer o .0. 09/10/2019 12 of 12 + +traveled to Paris with them, where met with a former boyfriend. + +then traveled to Poland. EPSTEIN asked her to go to Dubai but she + +did not go. EPSTEIN told her they did not need passports, which + +thought was strange. + +recalled a Cuba trip where kissed FIDEL CASTRO's cheek. + +was called in by INDYKE, who told her that if she ever needed + +help to contact him and never talk to the police. recalled feeling + +that something was off. + +EPSTEIN had a tape recorder and recalled him asking if she ever + +beat someone up. EPSTEIN also said to her, "Oh you don't enjoy fooling + +around with and me". + +recalled when EPSTEIN initiated the sexual encounters, telling + +her that this is what her job was all along. felt that once EPSTEIN flipped, she knew that she could not scream or say no. knew that EPSTEIN had a gun by the bed. recalled feeling that she had no where to go because she was on the island. knew EPSTEIN had guns. EPSTEIN gave a gun once for safety purposes. remembered the + +time where the gun was taken. + +FD-N2(Rn• 5-8-101 + +- I of S-FEDERALKUREAUMEINVESTIGM1ON + +lasteotonoy O9/17/2O21 + +, date of birth + +(DOB)-, + +was interviewed pursuant + +to a proffer agreement via video conference. Present for the interview was s attorney Joseph Nascimento, along with Assistant United States + +Attorneys , Special Agent + +, and Detective After being advised of the identity of the + +above listed individuals and the nature of the interview, provided + +the following information: + +was managed by was 's assistant. + +was a "runner" who ran errands. , andworked out of GHTSLATNE MAXWELL's home. When was first hired by JEFFREY EPSTEIN, she was given more informal tasks while she was modeling. One of her first tasks was to go to MAXWELL's house, where MAXWELL gave her a list of items, like toiletries to pick up for the 3O1 66" Street address. + +IMO= was F.PSFEIN's assistant. saw working with MAXWELL + +as well. Some relationships were more formal and "office like", but + +and MAXWELL's relationship was more friendly. + +Tasks that MAXWELL gave to were errands like buying shampoo and shirts for her and wanting to clean the office. In New York, the office inside MAXWELL's house was small with three desks. shared a + +desk with MAXWELL. MAXWELL spent time at EPSTEIN's other residents. + +recalled the strange message she received from JEAN LUC BRUNEL. 's English was not great at the time. MAXWELL thought the message + +was funny. MAXWELL either assisted or directed in how to write the + +message. + +had always felt a bit intimidated by MAXWELL. MAXWELL's attitude + +cane across that she was better than everyone else. was uncomfortable around MAXWELL and limited her time around her. + +Im.migalionvil O5/14/2O21 w New York, New York, United States (, Other (Vioec)) + +Hen 50C-NY-3027571 Daiedrafted Ob/14/2C21 + +b + +document contains neither retonemendaims nor conclusions °film FBI It is the property of me FBI and is 'mined to your agency: et and its contents are not + +to be dirtibisted outside pm agency + +50D-NY-3021S/1 + +contifiumwmorrn.302"r in I Proffer of On 05/14/2021 . hr 2 of 9 + +MAXWELL overlooked everything with EPSTEIN. MAXWELL and EPSTEIN seemed + +to have a family like relationship. was aware that MAXWELL and EPSTEIN used to date. was also aware that the house MAXWELL lived in in New York used to belong to EPSTEIN. In EPSTEIN's houses, MAXWELL had a bedroom and an office. In. Palm Beach, MAXWELL's office was a small room above the kitchen. In EPSTEIN's master bedroom, he had two bathrooms where the one to the left was where the massages took place, and the other room + +had a large closet where saw MAXWELL'S clothes hanging. + +recalled chat in New Mexico MAXWELL had a bedroom. thought it may have been who mentioned MAXWELL'S bedroom because she was assigning bedrooms. recalled had stayed in MAXWELL's bedroom in New Mexico. At every one of EPSTEIN's properties, MAXWELL acted almost like an + +owner; people treated her like an owner. + +spent approximately l5-20W of the time around MAXWELL. While in + +Palm Beach, s home was in proximity so she would get time off; she would not always be around EPSTEIN's house. was mostly there at the Palm Beach residence. recalled traveling with MAXWELL approximately 15-20i of the time. recalled traveling to New Mexico with MAXWELL twice. recalled traveling to Aspen with EPSTEIN and MAXWELL. + +and EPSTEIN went to see LES WEXNER. recalled MAXWELL being + +there with a group of women and chewing them out. + +recalled when a new house manager, JANUSZ BANASIAK, started in + +Palm Beach and brought in fresh flowers, MAXWELL was impressed. + +remembered a time where MAXWELL questioned her on the ice in the water she + +was taking to EPSTEIN, asking if the ice was made from Evian. + +While in Palm Beach, EPSTEIN received two massages a day. If + +traveled with EPSTEIN, sometimes would call from New York to set up the massages. s ob was to reconfirm with them. would sometimes send the initial schedule and would call. EPSTEIN then wanted to confirm and reconfirm with them; she would have to call in + +the evening and then the next morning. + +did not recall MAXWELL confirming massages. ALFREDO R0DRIGUEZ + +may eve confirmed massages. + +When was asked if she was aware of MAXWELL's knowledge of EPSTEIN + +SOD-NY-30275/1 + +Comuu.tiono(M):m≥of **(u)** Proffer of 0, 05/14/2021 per 3 of 8 + +getting massages, she replied yes. In general, it was common knowledge EPSTEIN had two massages a day. talked about a time in New Mexico where EPSTEIN treated them to an outside location spa facility. MAXWELL told they needed to find a pretty masseuse for EPSTEIN. EPSTEIN sent MAXWELL, S and possibly to a spa facility where each of them were to be treated to a massage. MAXWELL said the masseuse for EPSTEIN must be pretty and must be good at massage. MAXWELL said this to the group. + +The phone books were contact address books. The pastel colored books were EPSTEIN's books while the black small books were MAXWELL's books. + +There was a section for massage contacts in them. + +EPSTEIN noted once that when he and MAXWELL dated that MAXWELL would bring more girls for threesomes, saying they were sexual relationships. + +> did not recall when or where EPSTEIN said this to her. EPSTEIN told that MAXWELL brought him girls. As of the date of this interview, s impression was that this was for sexual activities. It surprised that MAXWELL would bring other girls in for sex. When EPSTEIN told this she did not think that was something MAXWELL would do. MIMS + +recalled MAXWELL dating other men. described MAXWELL as "high end and sophisticated" and did not think "those types" of people would do that. + +EPSTEIN's expectations were when he had girlfriends they would have to bring other girls in. When dated EPSTEIN they brought + +in for sex and she told that she had to find + +other girls for EPSTEIN. + +When was asked about what she said in a prior interview about MAXWELL participating in threesomes, replied that she was talking about what she just referenced in regards to EPSTEIN telling that + +MAXWELL participated in threesomes. + +At the time worked for EPSTEIN from 2004-2006 she did not get a + +sense that he and MAXWELL were still in a romantic relationship. + +thought they were in a relationship years prior to working for + +them. + +took a lot of photographs, some of them of + +described them as "model type" photographs possibly for Victoria's Secret. WAS in jeans and a tank top on the island along the beach. + +50D-NY-30215/1 + +Contalunkmofni4elor (01 Proffer of .o 05/14/2021 .fts, 4 of 8 + +asked her to take off her top and bra, telling that EPSTEIN said it was ok. These types of photographs of other girls were on display all over EPSTEIN's houses. These photographs were kept in large binders at MAXWELL's + +house. They were in thumbnail form with Compact Disk's (CD) attached. There was a large commercial printer at MAXWELL's New York house where the thumbnails were printed; thought this was possibly why the binders were kept there. described the binders as large with packets and the photographs were burned onto CDs. There were contact sheets with + +thumbnails, so they knew which photographs were on which CD. These binders were stored in a large cabinet located past the three desks in MAXWELL'S office in her New York home. and worked there. There were approximately 8-10 binders of photographs. There were other photographs as well. described a time in Palm Beach where she was on the couch with and stripped, took off her top, and danced. EPSTEIN nudged to get the camera to take photographs. Either or put together the binders. Everything was at the request of EPSTEIN. enjoyed taking photographs; she had a nice camera. MAXWELL asked them to clean the office once. felt MAXWELL must have observed the printer and binders were there. They were intimate photographs so they would not have been printed commercially. The intimate photographs were of different women in binders that were mainly topless with modal like poses. Some photographs were in EPSTEIN's gym along the whole wall - they were all topless photographs. described the photographs as young women with an unknown age range. When asked if the age range was 18-20 years old, replied that the women were maybe younger but it was hard to tell because of make-up and the model style photographs. + +did not recall if MAXWELL Look nude photographs. was not + +sure if anyone other than took photographs. At the time had + +stopped working for them, the binders were still at MAXWELL'S house. MAXWELL sold the New York house at one point and thought the real + +estate agent had possibly taken photographs of MAXWELL's office. + +In regards to the storage of contact information, would get the phone numbers for made her own contact list that she typed up. printed a few copies and put them in a desk. When came + +back to New York, these were sometimes missing. + +The notebooks had massage sections, but never called from there. + +500-NY-30275/1 + +continumion of FD.302 or MI Proffer of 05/14/2021 par 5 of 8 + +only called people from the contact information given to her by + +and the contact list gave + +got + +then typed up in a word document in Palm Beach. printed a few and stored them in a drawer. + +missing one time or had thrown it out because it was crumpled in the trash can. nes at. a computer in Palm Beach at a desk near the living room that she and used for work. created a digital copy for herself. was not sure if anyone else had a digital contact list for massages. thought the contact books for massages seemed + +outdated. + +had made from contacts given to her by + +phone numbers. + +the information from. 's contact + +was not sure where list was created by hand typed up and recalled the list was + +[Agent note: was shown a document titled "Masseusses". This document is attached in a 1A.] did not recognize this document. did not format her document how this one was formatted; underlined the names. thought there were approximately 10 names on the document she created but thought there may have been more than one + +person on each line like having referrals listed. + +page Some described there being message books around the house that had a + +that copied itself, notepads, and contact numbers and information. of these were kept in the pantry behind the kitchen. There were white notepads throughout EPSTEIN's home that. had "Jeffrey Epstein" and "Ghislaine + +Maxwell" written on them. Messages were kept on these notepads. + +Phone numbers were kept in a system they used called Citrix. People's + +numbers were also kept in books. MAXWELL had books with a black cover throughout the house and EPSTEIN had books with a colorful cover throughout the house. There were multiple copies of the books throughout the house. believed that both sets of books had contact information for massages. The contact information for massages was organized by location. + +remembered skimming through the books and seeing this. MAXWELL's + +black books were very simple as they were just black and while with simple font. believed EPSTEIN's colorful books were black and white inside and simple as well, but the font was slightly larger. advised she may be able to recognize the books if she saw them; she has a photographic memory. [Agent note: At this point in the interview, was shown a document.] ecalled this document to be one of MAXWELL's contact + +SOD-NY-30275/1 + +Continuation 0(11).30? or 1Ul Proffer o 00 05/14/2021 .per 6 of 8 + +books. also recalled that the font for EPSTEIN would have been larger. The contact books were printed and not updated. nes given a project to update EPSTEIN's books; she used the Citrix system to gather the numbers from in order to update the books. did not recall being + +asked to update MAXWELL's contact books. During the time that IIIIIII worked for EPSTEIN she did not recall anyone switching the books out. + +When was asked if she recalled someone asking her to gather items from [he Palm Beach house, she stated yes. a and EPSTEIN told her to + +go to Palm Beach to meet someone to hand over the contact books and computers. EPSTEIN, , flew into + +Miami. + +and + +was told to stay with IIIII while EPSTEIN and had a + +meeting. SOHO HOUSE + +thought the meeting was held at what is now called + +HOTEL. thought EPSTEIN was involved in the + +of the hotel. recallellIIIIII telling her to meet a + +may have called before she met him. recalled + +conversation she had with EPSTEIN was where he told her that + +happened to his detriment and she needed to + +house. + +investigator. + +to the island. When arrived at the Palm Beach house, JANUSZ was there and he helped her gather items. gathered the contact books. recalled definitely gathering EPSTEIN's books, but she + +recall if she grabbed all of MAXWELL's books. thought sets to the gentleman. When the gentleman left, JANUSZ called + +he found a book, so called the gentleman back to hand it over. + +recalled the gentleman to be Detective Black. thought this + +was around October 6, because it was the day before her birthday. + +also recalled stopping at a gas station and found a record of the stop on her bank statement. had anxiety and stress while working for + +EPSTEIN. + +the construction gentleman and + +the + +something + +gather the stuff from the + +thought she was meeting with a police officer or + +-drove to Palm Beach, while and EPSTEIN flew on + +could not she gave both and said that + +recalled telling her to do the same thing on the island. + +told to remove the contact books from the island and take + +them to New York. thought she may have asked where all the books were stored because there were so many buildings. This was possibly a couple weeks after had already removed the books and computers from + +Palm Beach. + +50D -NY -3027S/1 + +colos so norm.302or 10) Proffer cf .0, 05/14/2021 my 7 of 8 + +In Palm Beach, each desk had a computer. removed the computer from EPSTEIN's office (the cabana by the pool), along with the computer that she and used and the computer from MAXWELL'S office. There was a stationary computer that security used that did not remove from the + +house. + +removed the books from the island and took them to New York. + +When returned to New York, she gave the books to + +thought left the office with the books. This was around the time + +that S had been given the assignment to update the books. + +asked MEMMEN what to do with the printouts of the contact numbers. OMEN., told S to shred it. did rot recall why told her to shred it. just recalled EPSTEIN mentioning that something was stolen or compromised. remembered EPSTEIN referring to visas and immigration. did not remember if she discussed this with anyone + +afterwards. + +recalled an individual named MARK who was the IT person they + +would call if they had computer issues. did not know if MARK worked for WEXNER. thought MARK may have knowledge about the database they + +used. + +recalled MAXWELL being somewhat intimately involved in EPSTEIN's + +life. MAXWELL was "very much present". MAXWELL had two assistants and she was "sort of like a boss". MAXWELL was one of EPSTEIN's friends and exgirlfriends. EPSTEIN kept certain people around his life, including MAXWELL and EVA DUBIN, who was an ex-girlfriend. 111111 was also very close to EPSTEIN. houghtlIIIIIII and MAXWELL were close as MAXWELL took + +to some events. recalled that EPSTEIN bought a nice + +fur for Christmas and it was to be kept at MAXWELL's home. MAXWELL was in every detail. MAXWELL questioned the staff in New York. When MAXWELL visited EPSTEIN's different homes, she seemed more like an owner. EPSTEIN and MAXWELL were close. recalled EPSTEIN telling her that he + +delivered the news of MAXWELL'S father's death to her. MAXWELL had drivers and staff who thought she was not nice. recalled a couple that worked for EPSTEIN and saw the woman crying when she came in because MAXWELL said something mean to her. MAXWELL seemed like F.PSTELN's person. + +recalled that there was a couch on display at a store and the store + +did not want to sell it. EPSTEIN said to have MAXWELL deal with it. + +SOD—NY-30275/1 + +continuation orpo.302 or MI Proffer of 0, 05/14/2021 per 8 of 8 + +There was a masseuse in Palm Beach, , who stayed at the New York + +apartment. EPSTEIN helped get an internship with a teenage + +magazine. MAXWELL was in charge of managing the apartment. + +recalled that when left the apartment, there was something missing + +from the apartment and MAXWELL said that must have took it. + +[Agent note: At this point in the interview was shown a document. This document is attached in a 1A.] recognized the document as being a printed copy from the Citrix database. was not sure which of the books this would have come from. This would have been managed by + +believed MAXWELL would have had knowledge of the massages. MAXWELL managed EPSTEIN's houses and was very much present. Any person that was in the houses would have knowledge of EPSTEIN's schedule and massages. + +People spoke freely; someone may have said that EPSTEIN was getting a massage. People walked through the kitchen and sometimes there was a girl with another girl there. One girl went upstairs while another stayed in the kitchen. recalled there was a chiropractor at the house and gave an + +appointment to a girl that was there. + +did not know what MAXWELL got out of staying with EPSTEIN. To it seemed that EPSTEIN and MAXWELL shared assets. recalled + +a time where EPSTEIN bought a new helicopter and became upset because it was shaking. He blamed it on MAXWELL. MAXWELL seemed like family to EPSTEIN. + +III was also like family and EPSTEIN was fond of her daughter MAXWELL and EPSTEIN seemed to have a family like relationship. + +FD-302(Ree 5-8-101 + +501)-NY-3027571 Serial 640 - I of 6- FEDERAL BUREAU OF INVESTIGATION + +Dmcormegy 09/17/7071 + +, date of birth (DOB)-, was interviewed + +pursuant to + +Present for the interview was s attorney Joseph Nascimento, along with AUSA AUSA and Detective After being advised of the identity of the interviewing Agents and the nature of + +the interview, provided the following information: + +\* + +a proffer agreement at SDNY 1 Saint An rews Plaza New York NY. + +is shown the "black book" (72-mm-113327-1A9)\*\*\* + +states that she recognizes this. She previously described this as + +MAXWELL's contact book. recognizes the color and the size and the format. The other contact books were bigger and a pastel color. All of MAXWELL's books were smaller. recognizes the black color and the + +smaller font. EPSTEIN's font was bigger. + +has seen this book previously. This is one of MAXWELL's books, + +there were a few of them. The smaller font is familiar. it before but may not have used the numbers out of it. + +been told by someone that this is MAXWELL's book but not sure. was tasked with updating EPSTEIN's book which was bigger. may have told about EPSTEIN's book. is not sure if she has ever seen. + +MAXWELL with this book or if she just talked about it. + +has opened + +may have + +There was a confidentiality notice with EPTEIN's book because of the names in them. a does not recall using this book to call and make massage appointments. The specific contacts in the book don't stand out. This book was seen in the small office behind the kitchen referred to as MAXWELL's + +office. This is where recalls seeing it. + +Names that stand out in this book are CAROLE RADZIWILL and JEAN LUC BRUNEL. + +She recalls that RADZIWILL came to MAXWELL's home in New York and she + +borWptimcm 08/20/2021 a New York, New York, United Stares (In Person) + +Mk\* 50D-NY-3027571 Dawdm&M 09/16/2021 + +The 60CUMM costa= matter recomnsendsbcas nor conclustom of the FBI II ss the propetty or the FBI and is 'muted to your agency: a and Its COMMIS are not + +to be distnbated outside your agency + +SOD-NY-30275n + +coasnatiofierw.302 or 18) Interview of 0,, 08/20/202: par 2 of 6 + +published a book. Her and EPSTEIN discussed the book. does not + +recall seeing her with ESTEIN. + +Both MAXWELL and EPSTEIN knew BRUNEL. He is very close to EPSTEIN and he + +had an apartment in EPSTEIN's New York apartment building. + +recalls seeing this book in other houses, perhaps in the New Mexico + +ouse. IIIIIII recalls gathering EPSTEIN's books from the Virgin Island but + +does not recall gatherrg MAXW771's. + +is shown the message pads with sticky note book #4 (31E-mm- + +108062 1B2-36)\*\*\* + +states the sticky note on page 5 could be her handwriting but not + +sure. Upon further inspection states, she does not think these + +notes are hers. + +recognizes these books and the carbon copies and the messages. would leave messages for EPSTEIN in the pantry in the kitchen. recalls seeing more than one of these pads. Some were kept in a + +drawer. + +EPSTEIN went by "JE" on the pads and the staff would refer to him in the book as "Mr Epstein". Some of the staff taking messages was IIIIIII, + +and the house manager ALFREDO RODRIGUEZ. sees a lot of "AR" in Lhe + +book. RODRIGUEZ was later fired. + +IIIIII would not recognize other staff members hand writing but she + +understands how they would sign ("Mr Epstein"). + +recognizes the name 1IIIII" • came for massages and brought + +other girls for massage. She was pregnant at one point when she came over. + +recognizes JEAN LUC BRUNEL. + +recognizes MOSCOV1TZ to be EPSTEIN's doctor in Palm Beach. + +recognizes DARREN to be EPSTEIN's lawyer. + +would still have an obligation to schedule massages even when she wasn't at the house. refers to the 2nd to last page where there is a + +message left for + +500-NY-30275/1 + +Cpounpatjan pf W.302 pr 1W Interview of 06/20/2021 p 3 of 6 + +\*ik is shown the message pads with sticky note book #1 (31E-mm- + +108062 1181-2AC)\*\*\* + +recognizes that the book is in November and states that EPSTEIN + +would have been there around that time. + +recognizes HARVEY WEINSTEIN's name in the book and slates it triggered her cries). EPSTEIN encouraged a victim of WEINSTEIN's to talk to an attorney but it turned out that the attorney was an attorney for WEINSTEIN. EPSTEIN would bring these pretty model girls around these + +business men to further his business. + +states that some of the handwriting in this book looks like hers but + +she is not sure. + +states that the last page looks like her handwriting, all of the notes on this page. She recognizes the way she writes her "P", "N" and "7". + +\* \* \* is shown the message pads with sticky note book #3 (31E-mm- + +108062 181-2AC)\*\*\* + +cognizes + +office. + +and states he worked in EPSTEIN's New York + +recognizes and states he is the husband of + +(the former girlfriend of EPSTEIN). + +recognizes DR HENRY GERETCKI. states he owns an island in + +the British Virgin Islands and visited this island with EPSTEIN and + +JEAN LUC BRUNEL. + +recognizes her handwriting on a message on 1/7/05. She recognizes + +the number "7" and that its singed by "Mir stating "that's me". + +recognizes the message on 1/8/05 signed "ms" stating "that's me...this + +entire page is from me" down to 1/9/05. + +recognizes the next page to be her handwriting starting with the + +message on 1/9/05 from states the rest of the notes after are also her handwriting. states had a sister. + +the next page to be her handwriting starting with the message on + +SOD-NY-3027571 Continuation of F1).302 or 10) Interview of + +> 1/9/05 from handwriting. + +0,, 08/20/202: ,past 4 of 6 + +states all notes on this page are her + +states all of the messages on the next page are her handwriting + +starting at 1/10/05 from JEAN LUC BRUNEL. + +IIIIIII states all of the message on the next page starting at 1/10/05 from + +JEAN LUC BRUNEL are her handwriting. + +states the next page the second message on 1/11/05 from MAXWELL that took that messages. states the next 2 messages on that page + +are from her as well. + +states the first 2 messages on the next page were taken by her + +starting at 1/20/05 from MAXWELL. + +states the next page starting at 1/24/05 the top 2 messages were + +taken by her. + +states the next page all of the messages were taken by her. The + +date on the second message is 1/24/05. + +states on the next page that\_ messages 1,2 and 4 are her handwriting. She states message #3 is likely her handwriting as well. + +states the next page starting at 1/26/05 that all of these messages + +were taken by her. + +states the next and last page of this book are all messages taken by + +her. This page starts at 1/26/05. + +\*\*\* shown the black binder + +18191\*\*\* + +marked "Book 10" (50D-NY-3027571- + +is shown the black binder marked "Book 10" and asked Co just look at + +the outside of it. states that this is one of the binders that was at MAXWELL's house with different pictures inside of them. The photos are + +of travel with EPSTEIN or photos of naked girls or women or in their underwear. They were categorized. These books were made at 's request thinks. does not recall the color or the stickers + +on the outside but she remembers the plastic sleeves with CD's and + +IIIIIII■ **not surel.** + +**50D-NV-30275/1** + +**comi.unimoimp.m or (U) Interview 0** .0,, 08/20/2021 par 5 of 6 + +thumbnails of the pictures. She does not recall how the outside was labeled with stickers or not. On the spine of the binder she recognizes stickers + +marked ZORO (EPSTEIN's ranch, could be photos from his trip), + +and + +\* \* \* is shown two black binders marked "Book 11" 6 "Book 18" (50D- + +NY-3027571-1819)\*\*\* + +is shown the black binders marked "Book 11" d. "Book 18" and asked to + +just look at the outside of them. states these are large office binders with plastic sleeves. On the spine of the binder she recognizes stickers marked IIIIII PB GIRLS (Palm Beach), 727 (one of his planes), + +LSJ and BOOBS (could be but she is + +recognizes that these binders could have been kept in MAXWELL's house where she worked. They should have been inside of her office inside of the house. The office had two rooms in it. The first room had about 3 desks for either and MAXWELL. The second room was smaller and had a large printer/copier inside of it. It was a professional photo printer. There were also cabinets inside of this room. These binders would have been store in one of these cabinets. There were multiple shelves + +containing binders. + +MAXWELL would come into the office and sit at her desk. MAXWELL would print sometimes to put these photos in EPSTEIN's homes and to document EPSTEIN's + +life. request. + +thought maybe it + +would did was + +photograph the women in nude poses it to . EPSTEIN said it + +for Victoria's Secret. + +at EPSTEIN's + +was ok and + +is asked the difference between the professional masseuses and the + +not professional masseuses coming to the houses. + +states the professional ones carried themselves different and gave + +massages to and others in the house. + +The not professional masseuses appeared to be young. Tn the moment + +didn't think of age. Sitting here today + +underage because of their style of dressing (jeans and t-shirt), they were casual, their immature behavior, not professional manor, their physical + +thinks they appeared to be + +50D-NY-3027571 + +CematationefFU402or (0) Interview of jx, 08/20/202: ,Past 6 of 6 + +appearance was that of a teenager. would have to escort them + +upstairs. •s visual observations and feeling that someone is younger than her. On one occasion asked for a tutor for for her SAT's. told a story once of her speeding and her parents having to come pick her up and she couldn't drive anymore after that. saw lots of girls face to face. thinks they were 16-18, 19 and 20. + +can now analyze that they were underage. + +about 21-22 years old and they felt younger than her. Over time + +IIIIIIIIIdiscussad a conversation with EPSTEIN the first time that she met him at his house for dinner. EPSTEIN asks how old she is and if she is 18 and he probed it further that she was over 18. was surprised + +because she was married. + +EPSTEIN presented himself to everyone like he wouldn't cross the line. + +had the impression that EPSTEIN didn't want anyone under 18 but he + +didn't say that. said once that if someone lied to him about their + +age it wouldn't matter because he would still be in trouble. \ No newline at end of file diff --git a/marker2/ds9/EFTA00090773/EFTA00090773.metadata.json b/marker2/ds9/EFTA00090773/EFTA00090773.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..e3ff5700842612478cc2b70573b8f0af3d74f915 --- /dev/null +++ b/marker2/ds9/EFTA00090773/EFTA00090773.metadata.json @@ -0,0 +1,1025 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090773.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, 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Contact number | Vaid | [Redacted] | 0017 | | | +|-------------------------------------------|-----------------------------------------------------------------|----------------------------------------------|-------------------------------------------|---------------------|-------------------| +| b. Employer identification number (EIN) | | 1 Wages, tips, other compensation
    7890.65 | 2 Federal Income tax withheld
    714.35 | | | +| c. Employer's name, address, and ZIP code | JEFFREY E. EPSTEIN
    358 EL BRILLO WAY
    PALM BEACH, FL 33480 | 3 Social security wages
    7890.65 | 4 Social security tax withheld
    439.22 | | | +| | | 5 Medicare wages and tips
    7890.65 | 6 Medicare tax withheld
    114.41 | | | +| | | 7 Social security tips | 8 Allocated tips | | | +| d. Employee's social security number | [Redacted] | 9 Advance EIC payment | 10 Dependent care benefits | | | +| e. Employee's first name and initial | Last name | Suff. | 11 Nonqualified plans | | | +| [Redacted] | | | 12a See instructions for box 12
    C 6.00 | | | +| | | 13 Benefit indicated | 12b | | | +| | | | | | | +| | | 14 Other | 12c | | | +| | | | 12d | | | +| f. Employee's address and ZIP code | | | | | | +| 18 state | Employer's state ID number | 19 State wages, tips, etc. | 20 Local wages, tips, etc. | 19 Local income tax | 20 Locality state | +| WL | | | | | | + +**W-2 Wage and Tax Statement** + For Employer. + +2006 + +Department of the Treasury-Internal Revenue Service + For Privacy Act and Paperwork Reduction + Act Notice, see back of Copy D. + +| a. Control number | | Void | 0017 | | | | +|-----------------------------------------------------------------|----------------------------|----------------------------------------------------------------------------------|---------------------|----------------------------|---------------------|------------------| +| b. Employee identification number (EIN) | | 1 Wages, tips, other compensation 38536.47 2 Federal income tax withheld 3463.23 | | | | | +| c. Employee's name, address, and ZIP code | | 3 Social security wages 38536.47 4 Social security tax withheld 2389.26 | | | | | +| JEFFREY E. EPSTEIN
    358 EL BRILLO WAY
    PALM BEACH, FL 33480 | | 5 Medicare wages and tips 38536.47 6 Medicare tax withheld 558.78 | | | | | +| | | 7 Social security tips 8 Allocated tips | | | | | +| d. Employee's social security number | | 9 Advance EIC payment 10 Dependent care benefits | | | | | +| e. Employee's first name and nitial Last name | | 11 Nonqualified plans 12a See instructions for box 12
    c C 28.62 | | | | | +| | | 13 Savings employee Remitters (see box 12b)
    14 Other 12c
    12d
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    c C 28.62 | | | | | +| | | 13 Savings employee Remitters (see box 12b)
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    12d
    12e
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" alMIE>, (USANYS)" + +Subject: Stips + +Date: Thu, 28 Oct 2021 21:42:07 +0000 + +Attachments: GX\_1008\_-\_GM\_depo\_(2021.10.28\_version).docx; GX\_1008\_- GM de (2021. 0.28\_version).pdf; GX\_1005\_- 2021.10.28\_version).docx; GX\_1005\_ depo\_M.10.28\_version).docx; GX\_10061ilidepo\_(2021.10.28\_version).pdf; 2021.10.28\_version).pdf; GX\_1 GX I 007\_-Wpo\_(2021.10.28\_version).docx; GX\_1007\_- Midepoi2021.10.28\_version).pdf + +Hey, + +Attached are stips for the various transcripts. When you have a minute, would you mind taking a look to see if you're good with them? We're hoping to get them to the defense tomorrow. + +the concluding paragraph (based on a go-by) does the authenticity issue a bit differently from the other stips. Would you confirm you're ok with this, or let me know if you'd rather I change to conform with the others? + +Thanks, + +Assistant United States Attorney + +Southern District of New York + +New York, New York 10007 \ No newline at end of file diff --git a/marker2/ds9/EFTA00090924/EFTA00090924.metadata.json b/marker2/ds9/EFTA00090924/EFTA00090924.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..ad6375cd331259eb6a506ab3be5ea9f8b4148267 --- /dev/null +++ b/marker2/ds9/EFTA00090924/EFTA00090924.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090924.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 980, + "elapsed_seconds": 0.75, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 49 + ], + [ + "Line", + 23 + ], + [ + "Text", + 15 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00090924" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00090925/EFTA00090925.md b/marker2/ds9/EFTA00090925/EFTA00090925.md new file mode 100644 index 0000000000000000000000000000000000000000..e847e799e6225e5dea391961592e14ea80d69265 --- /dev/null +++ b/marker2/ds9/EFTA00090925/EFTA00090925.md @@ -0,0 +1,37 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +x + +UNITED STATES OF AMERICA + +STIPULATION + +GHISLAINE MAXWELL, + +Defendant. + +x + +S2 20 CR 330 (AJN) + +IT IS HEREBY STIPULATED AND AGREED by and among the United States of America, by Damian Williams, United States Attorney for the Southern District of New York, and Assistant United States Attorneys, of counsel, and defendant Ghislaine Maxwell, by and with the consent of her attorneys, Christopher Everdell, Esq., Laura Menninger, Esq., Jeffrey Pagliuca, Esq., and Bobbi Sternheim, Esq., that: + +I. The document marked SDNY GM 000143740 through + +SDNY\_ GM\_ 00144203 is a true and accurate copy of a transcript of the deposition of Ghislaine Maxwell, the defendant, taken on April 22, 2016, in New York, New York. + +2. The document marked SDNY GM 00144204 through + +SDNY\_ GM \_00144423 is a true and accurate copy of a transcript of the deposition of Ghislaine Maxwell, the defendant, taken on July 22, 2016, in New York, New York. + +3. IT IS FURTHER STIPULATED AND AGREED THAT this stipulation, marked as Government Exhibit 1008, and the documents marked SDNY\_GM\_000 143740 through SDNY\_GM\_00144203, and SDNY\_GM\_00 144204 through SDNY\_GM\_00144423, may be received in evidence as Government exhibits at trial subject to objections by the defense based on relevance, hearsay, or under Rule 403. + +Dated: November 2021 New York, New York + +> DAMIAN WILLIAMS United States Attorney for the Southern District of New York + +By: + +Assistant United States Attorneys Southern District of New York + +Christopher Everdell, Esq. / Laura Menninger, Esq. Jeffrey Pagliuca, Esq. / Bobbi Sternheim, Esq. 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The document marked SDNY\_GM\_000143740 through + +SDNY\_ GM\_ 00144203 is a true and accurate copy of a transcript of the deposition of Ghislaine Maxwell, the defendant, taken on April 22, 2016, in New York, New York. + +2. The document marked SDNY\_GM\_00144204 through + +SDNY\_ GM \_00144423 is a true and accurate copy of a transcript of the deposition of Ghislaine Maxwell, the defendant, taken on July 22, 2016, in New York, New York. + +3. IT IS FURTHER STIPULATED AND AGREED THAT this stipulation, marked as Government Exhibit 1008, and the documents marked SDNY\_GM\_000143740 through SDNY\_GM\_00144203, and SDNY\_GM\_00 144204 through SDNY\_GM\_00144423, may be received in evidence as Government exhibits at trial subject to objections by the defense based on relevance, hearsay, or under Rule 403. + +Dated: November 2021 New York, New York + +> DAMIAN WILLIAMS United States Attorney for the Southern District of New York + +By: + +Assistant United States Attorneys Southern District of New York + +Christopher Everdell, Esq. / Laura Menninger, Esq. Jeffrey Pagliuca, Esq. / Bobbi Sternheim, Esq. 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The document marked 3504-009 is a true and accurate copy of the transcript of a sworn statement taken on November 21, 2005 in West Palm Beach, Florida. + +2. IT IS FURTHER STIPULATED AND AGREED THAT this stipulation, marked as Government Exhibit 1005, and the document marked 3504-009, may be received in evidence as Government exhibits at trial subject to objections by the defense based on relevance, hearsay, or under Rule 403. + +Dated: November 2021 New York, New York + +> DAMIAN WILLIAMS United States Attorney for the Southern District of New York + +By: + +Assistant United States Attorneys Southern District of New York + +Christopher Everdell, Esq. / Laura Menninger, Esq. Jeffrey Pagliuca, Esq. / Bobbi Sternheim, Esq. 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United States Attorney for the Southern District of New York, + +and Assistant United + +States Attorneys, of counsel, and defendant Ghislaine Maxwell, by and with the consent of her + +attorneys, Christopher Everdell, Esq., Laura Menninger, Esq., Jeffrey Pagliuca, Esq., and Bobbi + +Sternheim, Esq., that: + +1. The document marked 3504-009 is a true and accurate copy of the + +transcript of a sworn statement taken on November 21, 2005 in West Palm Beach, Florida. + +2. IT IS FURTHER STIPULATED AND AGREED THAT this stipulation, marked as Government Exhibit 1005, and the document marked 3504-009, may be received in evidence as Government exhibits at trial subject to objections by the defense based on relevance, hearsay, or under Rule 403. + +Dated: November 2021 New York, New York + +> DAMIAN WILLIAMS United States Attorney for the Southern District of New York + +By: + +Assistant United States Attorneys Southern District of New York + +Christopher Everdell, Esq. / Laura Menninger, Esq. Jeffrey Pagliuca, Esq. / Bobbi Sternheim, Esq. 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The document marked 3506-001 is a true and accurate copy of a transcript of the deposition taken on November 6, 2009 in West Palm Beach, Florida. + +2. IT IS FURTHER STIPULATED AND AGREED THAT this stipulation, marked as Government Exhibit 1006, and the document marked 3506-001, may be received in evidence as Government exhibits at trial subject to objections by the defense based on relevance, hearsay, or under Rule 403. + +Dated: November 2021 New York, New York + +> DAMIAN WILLIAMS United States Attorney for the Southern District of New York + +By: + +Assistant United States Attorneys Southern District of New York + +Christopher Everdell, Esq. / Laura Menninger, Esq. Jeffrey Pagliuca, Esq. / Bobbi Sternheim, Esq. 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United States Attorney for the Southern District of New York, and Assistant United States Attorneys, of counsel, and defendant Ghislaine Maxwell, by and with the consent of her attorneys, Christopher Everdell, Esq., Laura Menninger, Esq., Jeffrey Pagliuca, Esq., and Bobbi Sternheim, Esq., that: + +1. The document marked 3506-001 is a true and accurate copy of a transcript of the deposition taken on November 6, 2009 in West Palm Beach, Florida. + +2. IT IS FURTHER STIPULATED AND AGREED THAT this stipulation, marked as Government Exhibit 1006, and the document marked 3506-001, may be received in evidence as Government exhibits at trial subject to objections by the defense based on relevance, hearsay, or under Rule 403. + +Dated: November 2021 New York, New York + +> DAMIAN WILLIAMS United States Attorney for the Southern District of New York + +By: + +Assistant United States Attorneys Southern District of New York + +Christopher Everdell, Esq. / Laura Menninger, Esq. 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United States Attorney for the Southern District of New York, and Assistant United States Attorneys, of counsel, and defendant Ghislaine Maxwell, by and with the consent of her attorneys, Christopher Everdell, Esq., Laura Menninger, Esq., Jeffrey Pagliuca, Esq., and Bobbi Sternheim, Esq., that: + +1. The documents marked 3505-043 and 3505-044 are a true and accurate copy of the transcript of the deposition taken on December 4, 2009 in West Palm Beach, Florida. + +2. 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Excerpt# | SDNY GM 00165655 | 2021.10.11 | +| GX-2.O | Message Pad Excerpt# | SDNY_GM_00165658 | 2021.10.11 | +| GX-2-P | Message Pad Excerpt# | SDNY_GM_00165659 | 2021.10.11 | +| GX-2-Q | Message Pad Excerpt# | SDNY GM 00165660 | 2021.10.11 | +| GX-2-R | Message Pad Excerpt# | SDNY _ GM _ 00165663 | 2021.10.11 | +| GX-2-S | Message Pad Excerpt# | SDNY GM _ 00165669 | 2021.10.11 | +| GX-2-T | Message Pad Excerpt# | SDNY GM 00165670 | 2021.10.11 | +| GX-2-U | Message Pad Excerpt# | SDNY_ GM_ 00165674 | 2021.10.11 | +| GX-2-V | Message Pad Excerpt# | SDNY_GM_00165677 | 2021.10.11 | +| GX-2-W | Message Pad Excerpt# | SDNY GM 00165682 | 2021.10.11 | +| GX-3 | Physical Message Pad# | | 2021.10.11 | +| GX-3-A | Message Pad Cover# | SDNY_GM_00165684 | 2021.10.11 | +| GX-3-B | Message Pad Excerpt# | SDNY GM 00165688 | 2021.10.11 | + +| GX-3-C | Message Pad Excerpt# | SDNY GM 00165689 | 2021.10.11 | +|---------|-----------------------|----------------------|------------| +| GX-3-D | Message Pad Excerpt# | SDNY GM 00165690 | 2021.10.11 | +| GX-3-E | Message Pad Excerpt# | SDNY_GM 00165692 | 2021.10.11 | +| GX-3-F | Message Pad Excerpt# | SDNY GM 00165694 | 2021.10.11 | +| GX-3-G | Message Pad Excerpt# | SDNY GM 00165699 | 2021.10.11 | +| GX-3-H | Message Pad Excerpt# | SDNY_GM_00165700 | 2021.10.11 | +| GX-3-I | Message Pad Excerpt# | SDNY GM 00165701 | 2021.10.11 | +| GX-3-J | Message Pad Excerpt# | SDNY GM 00165703 | 2021.10.11 | +| GX-3-K | Message Pad Excerpt# | SDNY_GM_00165704 | 2021.10.11 | +| GX-3-L | Message Pad Excerpt# | SDNY_GM_00165706 | 2021.10.11 | +| GX-3-M | Message Pad Excerpt# | SDNY GM 00165709 | 2021.10.11 | +| GX-3-N | Message Pad Excerpt# | SDNY _ GM _ 00165710 | 2021.10.11 | +| GX-3-O | Message Pad Excerpt# | SDNY_GM_00165711 | 2021.10.11 | +| GX-3-P | Message Pad Excerpt# | SDNY GM 00165714 | 2021.10.11 | +| GX-3-Q | Message Pad Excerpt# | SDNY GM 00165719 | 2021.10.11 | +| GX-3-R | Message Pad Excerpt# | SDNY_GM_00165729 | 2021.10.11 | +| GX-3-S | Message Pad Excerpt# | SDNY GM 00165742 | 2021.10.11 | +| GX-3-T | Message Pad Excerpt# | SDNY GM 00165743 | 2021.10.11 | +| GX-3-U | Message Pad Excerpt# | SDNY_GM_00165744 | 2021.10.11 | +| GX-3-V | Message Pad Excerpt# | SDNY GM 00165745 | 2021.10.11 | +| GX-3-W | Message Pad Excerpt# | SDNY GM 00165747 | 2021.10.11 | +| GX-3-X | Message Pad Excerpt# | SDNY_GM_00165731 | 2021.10.11 | +| GX-3-Y | Message Pad Excerpt# | SDNY GM 00165736 | 2021.10.11 | +| GX-3-Z | Message Pad Excerpt# | SDNY GM 00165737 | 2021.10.11 | +| GX-3-AA | Message Pad Excerpt# | SDNY_GM_00165738 | 2021.10.11 | +| GX-3-BB | Message Pad Excerpt# | SDNY GM 00165739 | 2021.10.11 | +| GX-3-CC | Message Pad Excerpt# | SDNY GM 00165740 | 2021.10.11 | +| GX-3-DD | Message Pad Excerpt# | SDNY_GM 00165741 | 2021.10.11 | +| GX-3-EE | Message Pad Excerpt# | SDNY GM 00165742 | 2021.10.11 | +| GX-3-FF | Message Pad Excerpt# | SDNY GM 00165743 | 2021.10.11 | +| GX-3-GG | Message Pad Excerpt# | SDNY_GM_00165744 | 2021.10.11 | +| GX-3-HH | Message Pad Excerpt# | SDNY GM 00165745 | 2021.10.11 | +| GX-3-II | Message Pad Excerpt# | SDNY GM 00165747 | 2021.10.11 | +| GX-3-JJ | Message Pad Excerpt# | SDNY_GM_00165749 | 2021.10.11 | +| GX-3-KK | Message Pad Excerpt# | SDNY_GM_00165750 | 2021.10.11 | +| GX-4 | Physical Message Pad# | | 2021.10.11 | +| GX-4-A | Message Pad Cover# | SDNY_GM_00 165751 | 2021.10.11 | +| GX-4-B | Message Pad Excerpt# | SDNY_GM_00165752 | 2021.10.11 | +| GX-4-C | Message Pad Excerpt# | SDNY GM 00165754 | 2021.10.11 | +| GX-4-D | Message Pad Excerpt# | SDNY_GM_00165759 | 2021.10.11 | +| GX-4-E | Message Pad Excerpt# | SDNY GM00165761 | 2021.10.11 | +| GX-4-F | Message Pad Excerpt# | SDNY GM 00165776 | 2021.10.11 | +| GX-4-G | Message Pad Excerpt# | SDNY_GM_00 165790 | 2021.10.11 | +| GX-4-H | Message Pad Excerpt# | SDNY_GM_00165798 | 2021.10.11 | +| GX-4-I | Message Pad Excerpt# | SDNY GM 00165811 | 2021.10.11 | +| GX-4-J | Message Pad Excerpt# | SDNY GM 00165815 | 2021.10.11 | +| GX-4-K | Message Pad Excerpt# | SDNY GM 00165817 | 2021.10.11 | + +| | | 10 Series Birth Certificates | | +|-------|------------------------------------------------|-------------------------------------------|---------------------| +| GX | Description | Bates Number/Identifier | Produced to Defense | +| GX-11 | Certified Birth Certificate of Minor Victim-4# | SDNY GM 02765030 | 2021.10.11 | +| GX-I2 | Certified Birth Certificate of Minor Victim-1# | SDNY_GM_02760681 | 2021.10.11 | +| GX-13 | Certified Birth Certificate of Minor Victim-2# | SDNY GM 02753693 | 2021.10.11 | +| GX-14 | Certified Birth Certificate of Minor Victim-5# | SDNY GM 02765767 | 2021.10.28 | +| GX-I5 | Certified Birth Certificate of Minor Victim-6# | SDNY _ GM _ 02760679-SDNY _ GM _ 02760680 | 2021.10.11 | +| GX-I6 | Certified Birth Certificate of Minor Victim-3# | SDNY GM 02766968 | 2021.10.28 | + +| | | 50 Series Other Physical Exhibits | | +|---------|---------------------------------------------------|-----------------------------------|---------------------| +| aC | Description | Bates Number/Identifier | Produced to Defense | +| GX-51 | Florida Massage Table | | 2021.10.11 | +| GX-51-A | Photograph of Underside of Florida Massage Table | SDNY GM 02763005 | 2021.10.11 | +| GX-51-B | Photograph of Sticker on Florida Massage Table | SDNY GM 02763006 | 2021.10.11 | +| GX-51-C | Photograph of Sticker on Florida Massage Table | SDNY_GM_02763007 | 2021.10.11 | +| GX-52 | Black Contact Book | | 2021.10.11 | +| GX-52-A | Scanned Page from Black Contact Book?, | SDNY GM 02763008-SDNY GM 02763008 | 2021.10.11 | +| GX-52-B | Scanned Page from Black Contact Book | SDNY_GM_02763009-SDNY_GM_02763009 | 2021.10.11 | +| GX-52-C | Scanned Page from Black Contact Book | SDNY GM 02763010-SDNY GM 02763010 | 2021.10.11 | +| GX-52-D | Scanned Page from Black Contact Book | SDNY GM 02763011-SDNY GM 02763011 | 2021.10.11 | +| GX-52-E | Scanned Page from Black Contact Book | SDNY_GM 02763013-SDNY_GM_02763014 | 2021.10.11 | +| GX-52-F | Scanned Page from Black Contact Booldt | SDNY GM 02763015-SDNY GM 02763015 | 2021.10.11 | +| GX-52-G | Scanned Page from Black Contact Booldt | SDNY GM 02763016-SDNY GM 02763016 | 2021.10.11 | +| GX-52-H | Scanned Page from Black Contact Book | SDNY_GM 02765768 | 2021.10.11 | +| GX-53 | Box of five costumes | | 2021.10.11 | +| GX-54 | Hard Drive NYC024350 | | 2021.10.11 | +| GX-55 | Hard Drive NYC024349 | | 2021.10.11 | +| GX-56 | Hard Drive NYC024383 | | 2021.10.11 | +| GX-57 | New York Massage Table | | 2021.10.11 | +| GX-57-A | Photograph of Underside of New York Massage Table | SDNY_GM_027630I9-SDNY GM 02763019 | 2021.10.11 | +| GX-57-B | Photograph of Sticker on New York Massage Table | SDNY_GM_02763018-SDNY_GM_02763018 | 2021.10.11 | +| GX-58 | Pair of Boots | | 2021.10.11 | + +| | | 100 Series Photographs of People | | +|--------|-------------------------------------------------|----------------------------------|---------------------| +| GX | Description | Bates Number/Identifier | Produced to Defense | +| GX-101 | Photograph of Minor Victim-2# | SDNY_ GM_ 00166005 | 2021.10.11 | +| GX-102 | Photograph of Minor Victim-2# | SDNYGM 02750527 | 2021.10.11 | +| GX-103 | Photograph of Minor Victim-2# | SDNY GM 02760624 | 2021.10.11 | +| GX-104 | Photograph of Minor Victim-4# | SDNY_GM_02753398 | 2021.10.11 | +| GX-105 | Photograph of Females, Including Minor Victim-0 | SDNY_GM_02753398 | 2021.10.11 | +| GX-106 | Photograph of Minor Victim-1# | SDNY GM 00165992 | 2021.10.11 | + +" " , an 3 + +| GX-107 | Photograph of Minor Victim-1# | SDNY GM 00165995 | 2021.10.11 | +|--------|---------------------------------|---------------------------|------------| +| GX-108 | Photograph of Minor Victim-1# | SDNY GM 00165999 | 2021.10.11 | +| GX-109 | Photogra h of Minor Victim-3# | SDNY GM 00166002 | 2021.10.11 | +| GX-110 | Photograph of | SDNY GM 02753621 | 2021.10.11 | +| GX-111 | Photograph of Ghislaine Maxwell | SDNY GM 02753632 | 2021.10.11 | +| GX-112 | Photograph of Jeffery Epstein | SDNY GM 02753623 | 2021.10.11 | +| GX-113 | Photograph of Minor Victim-5# | Made Available for Review | 2021.10.11 | +| GX-114 | Photograph of Minor Victim-5# | SDNY GM 02753629 | 2021.10.11 | + +# 200 Series Photographs and Videos from PIIPD Search + += + +| GX | Description | Bates Number/Identifier | Produced to Defense | +|--------|-----------------------------------------------------------------------|-------------------------|---------------------| +| GX-201 | Photograph of Exterior at 358 El Brillo Way | SDNY GM_00174459 | 202 I I 0 I I | +| GX-202 | Photograph of Exterior at 358 El Brillo Way | SDNY GM 00174460 | 2021.10.11 | +| GX-203 | Photograph of Exterior at 358 El Brillo Way | SDNY GM 00174461 | 2021.10.11 | +| GX-204 | Photograph of Exterior at 358 El Brillo Way | SDNY GM 00174470 | 2021.10.11 | +| GX-205 | Photograph of Exterior at 358 El Brillo Way | SDNY GM 00174471 | 2021.10.11 | +| GX-206 | Photograph of Exterior at 358 El Brillo Way | SDNY GM 00174472 | 2021.10.11 | +| GX-207 | Photograph of Exterior at 358 El Brillo Way | SDNY GM 00174473 | 2021.10.11 | +| GX-208 | Photograph of Exterior at 358 El Brillo Way | SDNY _ GM _ 00174381 | 2021.10.11 | +| GX-209 | Photograph of Exterior at 358 El Brillo Way | SDNY GM 00174474 | 2021.10.11 | +| GX-210 | Photograph of Exterior at 358 El Brillo Way | SDNY GM 00174476 | 2021.10.11 | +| GX-211 | Photograph of Exterior at 358 El Brillo Way | SDNY _ GM _ 00174477 | 2021.10.11 | +| GX-212 | Photograph of Exterior at 358 El Brillo Way | SDNY GM 00174478 | 2021.10.11 | +| GX-213 | Photograph of Exterior at 358 El Brillo Way | SDNY GM 00174479 | 2021.10.11 | +| GX-214 | Photograph of Exterior at 358 El Brillo Way | SDNY_GM_00174480 | 2021.10.11 | +| GX-215 | Photograph of Exterior at 358 El Brillo Way | SDNY GM 00174481 | 2021.10.11 | +| GX-216 | Photograph of Exterior at 358 El Brillo Way | SDNY GM 00174482 | 2021.10.11 | +| GX-217 | Photograph of Exterior at 358 El Brillo Way | SDNY_GM 00174483 | 2021.10.11 | +| GX-218 | Photograph of Exterior at 358 El Brillo Way | SDNY GM 00174484 | 2021.10.11 | +| GX-219 | Photograph of Exterior at 358 El Brillo Way | SDNY GM 00174490 | 2021.10.11 | +| GX-220 | Photograph of Exterior at 358 El Brillo Way | SDNY GM 00174491 | 2021.10.11 | +| GX-221 | Photograph of Exterior at 358 El Brillo Way | SDNY_GM_00174492 | 2021.10.11 | +| GX-222 | Photograph of Exterior at 358 El Brillo Way | SDNY GM 00174493 | 2021.10.11 | +| GX-223 | Photograph of First Floor Office & Living Room at 358 El Brillo Way'' | SDNY GM 00174366 | 2021.10.11 | +| GX-224 | Photograph of First Floor Office & Living Room at 358 El Brillo Way'' | SDNY_GM_00 174367 | 2021.10.11 | +| GX-225 | Photograph of First Floor Office & Living Room at 358 El Brillo Way' | SDNY GM 00174368 | 2021.10.11 | +| GX-226 | Photograph of First Floor Office & Living Room at 358 El Brillo Way | SDNY GM 00174518 | 2021.10.11 | +| GX-227 | Photograph of First Floor Office & Living Room at 358 El Brillo Way | SDNY _ GM _ 00174521 | 2021.10.11 | +| GX-228 | Photograph of First Floor Office & Living Room at 358 El Brillo Way | SDNY GM 00174524 | 2021.10.11 | +| GX-229 | Photograph of First Floor Office & Living Room at 358 El Brillo Way | SDNY GM 00174525 | 2021.10.11 | +| GX-230 | Photograph of First Floor Office & Living Room at 358 El Brillo Way | SDNY _ GM _ 00174526 | 2021.10.11 | +| GX-231 | Photograph of First Floor Office & Living Room at 358 El Brillo Way | SDNY GM 00174527 | 2021.10.11 | +| GX-232 | Photograph of First Floor Office & Living Room at 358 El Brillo Way | SDNY GM 00174528 | 2021.10.11 | +| GX-233 | Photograph of First Floor Office & Living Room at 358 El Brillo Way | SDNY _ GM _ 00174530 | 2021.10.11 | +| GX-234 | Photograph of First Floor Office & Living Room at 358 El Brillo Way | SDNY _ GM _ 00174532 | 2021.10.11 | + +| GX-235 | Photograph of First Floor Office & Living Room at 358 El Brillo Way | SDNY GM 00174533 | 2021.10.11 | +|--------|----------------------------------------------------------------------|---------------------|------------| +| GX-236 | Photograph of First Floor Office & Living Room at 358 El Brillo Way | SDNY GM 00174535 | 2021.10.11 | +| GX-237 | Photograph of First Floor Office & Living Room at 358 El Brillo Way | SDNY GM 00174536 | 2021.10.11 | +| GX-238 | Photograph of First Floor Office & Living Room at 358 El Brillo Way | SDNY GM 00174545 | 2021.10.11 | +| GX-239 | Photograph of First Floor Office & Living Room at 358 El Brillo Way | SDNY GM 00174687 | 2021.10.11 | +| GX-240 | Photograph of First Floor Office & Living Room at 358 El Brillo Way | SDNY GM_00174688 | 2021.10.11 | +| GX-241 | Photograph of First Floor Office & Living Room at 358 El Brillo Way | SDNY GM 00174698 | 2021.10.11 | +| GX-242 | Photograph of First Floor Office & Living Room at 358 El Brillo Way' | SDNY GM 00174442 | 2021.10.11 | +| GX-243 | Photograph of First Floor Office & Living Room at 358 El Brillo Way' | SDNY_GM_00174444 | 2021.10.11 | +| GX-244 | Photograph of First Floor Office & Living Room at 358 El Brillo Way' | SDNY_GM_00174445 | 2021.10.11 | +| GX-245 | Photograph of First Floor Office & Living Room at 358 El Brillo Wayi | SDNY GM 00174699 | 2021.10.11 | +| GX-246 | Photograph of First Floor Office & Living Room at 358 El Brillo Way | SDNY GM 00174446 | 2021.10.11 | +| GX-247 | Photograph of First Floor Office & Living Room at 358 El Brillo Way' | SDNY_ GM_ 00174447 | 2021.10.11 | +| GX-248 | Photograph of First Floor Office & Living Room at 358 El Brillo Way | SDNY GM 00174700 | 2021.10.11 | +| GX-249 | Photograph of First Floor Office & Living Room at 358 El Brillo Way | SDNY GM 00174704 | 2021.10.11 | +| GX-250 | Photograph of First Floor Office & Living Room at 358 El Brillo Way | SDNY_ GM_ 00174448 | 2021.10.11 | +| GX-251 | Photograph of First Floor Office & Living Room at 358 El Brillo War | SDNY GM 00174449 | 2021.10.11 | +| GX-252 | Photograph of First Floor Office & Living Room at 358 El Brillo Way | SDNY GM 00174450 | 2021.10.11 | +| GX-253 | Photograph of First Floor Office & Living Room at 358 El Brillo Way' | SDNY_GM_00174451 | 2021.10.11 | +| GX-254 | Photograph of First Floor Office & Living Room at 358 El Brillo Way' | SDNY GM 00174452 | 2021.10.11 | +| GX-255 | Photograph of First Floor Office & Living Room at 358 El Brillo Way | SDNY GM 00174707 | 2021.10.11 | +| GX-256 | Photograph of First Floor Office & Living Room at 358 El Brillo Way | SDNY_GM_00 174726 | 2021.10.11 | +| GX-257 | Photograph of First Floor Office & Living Room at 358 El Brillo Way | SDNY GM 00174727 | 2021.10.11 | +| GX-258 | Photograph of First Floor Office & Living Room at 358 El Brillo Way' | SDNY GM 00174369 | 2021.10.11 | +| GX-260 | Photograph of First Floor Office & Living Room at 358 El Brillo Way | SDNY_GM_00 174425 | 2021.10.11 | +| GX-261 | Photograph of First Floor Office & Living Room at 358 El Brillo Way | SDNY GM 00174426 | 2021.10.11 | +| GX-262 | Photograph of First Floor Office & Living Room at 358 El Brillo Way | SDNY GM 00174427 | 2021.10.11 | +| GX-263 | Photograph of First Floor Office & Living Room at 358 El Brillo Way | SDNY_GM_00 174428 | 2021.10.11 | +| GX-264 | Photograph of Kitchen at 358 El Brillo Way | SDNY GM 00174504 | 2021.10.11 | +| GX-265 | Photograph of Kitchen at 358 El Brillo Way | SDNY GM 00174505 | 2021.10.11 | +| GX-266 | Photograph of Kitchen at 358 El Brillo Way | SDNY_GM_00174506 | 2021.10.11 | +| GX-267 | Photograph of Kitchen at 358 El Brillo Way | SDNY GM 00174685 | 2021.10.11 | +| GX-268 | Photograph of Kitchen at 358 El Brillo Way | SDNY GM 00174686 | 2021.10.11 | +| GX-269 | Photograph of Master Bedroom at 358 El Brillo Way | SDNY GM 00174594 | 2021.10.11 | +| GX-270 | Photograph of Master Bedroom at 358 El Brillo Way | SDNY_GM_00174432 | 2021.10.11 | +| GX-271 | Photograph of Master Bedroom at 358 El Brillo Way | SDNY GM 00174596 | 2021.10.11 | +| GX-272 | Photograph of Master Bedroom at 358 El Brillo Way | SDNY GM 00174599 | 2021.10.11 | +| GX-273 | Photograph of Master Bedroom at 358 El Brillo Way | SDNY_GM_00174600 | 2021.10.11 | +| GX-276 | Photograph of Master Bedroom at 358 El Brillo Way' | SDNY GM 00174601 | 2021.10.11 | +| GX-277 | Photograph of Master Bedroom at 358 El Brillo Way | SDNY GM _ 00174602 | 2021.10.11 | +| GX-278 | Photograph of Master Bedroom at 358 El Brillo Way' | SDNY_ GM _ 00174603 | 2021.10.11 | +| GX-279 | Photograph of Master Bedroom at 358 El Brillo Way | SDNY GM 00174604 | 2021.10.11 | +| GX-280 | Photograph of Master Bedroom at 358 El Brillo Way | SDNY GM 00174605 | 2021.10.11 | +| GX-281 | Photograph of Master Bedroom at 358 El Brillo Way | SDNY_ GM_ 00174433 | 2021.10.11 | +| GX-282 | Photograph of Master Bedroom at 358 El Brillo Way | SDNY GM 00174434 | 2021.10.11 | +| GX-283 | Photograph of Master Bedroom at 358 El Brillo Way | SDNY_GM_00174435 | 2021.10.11 | +| GX-284 | Photograph of Master Bedroom at 358 El Brillo Way | SDNY GM 00174436 | 2021.10.11 | + +| GX-285 | Photograph of Master Bedroom at 358 El Brillo Way* | SDNY GM 00174440 | 2021.10.11 | +|--------|----------------------------------------------------|---------------------------|------------| +| GX-286 | Photograph of Master Bedroom at 358 El Brillo Way | SDNY GM 00174453 | 2021.10.11 | +| GX-287 | Photograph of Master Bedroom at 358 El Brillo Way | SDNY GM 00174454 | 2021.10.11 | +| GX-288 | Photograph of Master Bedroom at 358 El Brillo Way. | SDNY GM 00174456 | 2021.10.11 | +| GX-289 | Photograph of Second Floor at 358 El Brillo Way | SDNY GM 00174557 | 2021.10.11 | +| GX-290 | Photograph of Second Floor at 358 El Brillo Way | SDNY GM_00 174558 | 2021.10.11 | +| GX-291 | Photograph of Second Floor at 358 El Brillo Way | SDNY GM 00174559 | 2021.10.11 | +| GX-292 | Photograph of Second Floor at 358 El Brillo Way | SDNY GM 00174560 | 2021.10.11 | +| GX-293 | Photograph of Second Floor at 358 El Brillo Way | SDNY_GM_00 174563 | 2021.10.11 | +| GX-294 | Photograph of Second Floor at 358 El Brillo Way | SDNY_GM_00174419 | 2021.10.11 | +| GX-295 | Property Receipts | SDNY GM 02753638-02753643 | 2021.10.11 | +| GX-296 | Video of Walkthrough at 358 El Brillo Way* | SDNY GM 00332873 | 2021.10.11 | + +### 300 Series ES[ Photographs + +m + +| X | Descri tion | Bates Number/Identifier | Produced to Defense | +|--------|------------------------------------------------------|---------------------------|---------------------| +| GX-301 | Photograph of Jet | SDNY_GM_02753644-2753692 | 2021.10.11 | +| GX-302 | Photograph of Jet | SDNY GM 02753644-2753692 | 2021.10.11 | +| GX-303 | Photograph of Jet Interior | SDNY GM 02753644-2753692 | 2021.10.11 | +| GX-304 | Photograph of Ghislaine Maxwell and Jeffrey Epstein | SDNY_GM_02753644-2753692 | 2021.10.11 | +| GX-305 | Photograph of Ghislaine Maxwell | SDNY GM 02753644-2753692 | 2021.10.11 | +| GX-306 | Photograph of Ghislaine Maxwell | SDNY GM 02753644-2753692 | 2021.10.11 | +| GX-307 | Photograph of Ghislaine Maxwell and Jeffrey Epstein | SDNY_GM_02753644-2753692 | 2021.10.11 | +| GX-308 | Photograph of Island | SDNY GM 02753644-2753692 | 2021.10.11 | +| GX-309 | Photogra . h of Minor Victim-3•# | Made Available for Review | 2021.10.11 | +| GX-310 | Photograph of Jeffrey Epstein and | SDNY_GM_02753644-2753692 | 2021.10.11 | +| GX-311 | Photograph of Plane (N404CE) | SDNY GM 02753644-2753692 | 2021.10.11 | +| GX-312 | Photograph of Plane (N908JE) | SDNY GM 02753644-2753692 | 2021.10.11 | +| GX-3B | Photograph of Ghislaine Maxwell and Jeffrey Epstein* | Made Available for Review | 2021.10.11 | +| GX-314 | Photograph of Ghislaine Maxwell and Jeffrey Epstein | SDNY GM 02753644-2753692 | 2021.10.11 | +| GX-315 | Photo h of Jeffre E stein and Plane | SDNY GM 02753644-2753692 | 2021.10.11 | +| GX-316 | Photograph of Ghislaine Maxwell, , and | SDNY GM 02753644-2753692 | 2021.10.11 | +| GX-317 | Photograph of Ghislaine Maxwell and Jeffrey Epstein | SDNY_GM_02753644-2753692 | 2021.10.11 | +| GX-318 | Photograph of Ghislaine Maxwell and Jeffrey Epstein | SDNY GM 02753644-2753692 | 2021.10.11 | +| GX-319 | Photograph of Ghislaine Maxwell and Jeffrey Epstein | SDNY GM 02753644-2753692 | 2021.10.11 | +| GX-320 | Photograph of Ghislaine Maxwell and Jeffrey Epstein | SDNY_GM_02753644-2753692 | 2021.10.11 | +| GX-321 | Photograph of Ghislaine Maxwell and Jeffrey Epstein | SDNY GM 02753644-2753692 | 2021.10.11 | +| GX-322 | Photograph of Ghislaine Maxwell and Jeffrey Epstein | SDNY GM 02753644-2753692 | 2021.10.11 | +| GX-323 | Photograph of Ranch | SDNY_GM_02753644-2753692 | 2021.10.11 | +| GX-324 | Photograph of Ghislaine Maxwell and Jeffrey Epstein | SDNY GM 02753644-2753692 | 2021.10.11 | +| GX-325 | Photograph of Ghislaine Maxwell and Jeffrey Epstein | SDNY GM 02753644-2753692 | 2021.10.11 | +| GX-326 | Photograph of Island | SDNY_GM_02753644-2753692 | 2021.10.11 | +| GX-327 | Photograph of | SDNY GM 02753644-2753692 | 2021.10.11 | +| GX-328 | Photograph of Zorro Ranch Entrywa | SDNY_GM_02753644-2753692 | 2021.10.11 | +| GX-329 | Photograph of Jeffrey Epstein and | SDNY_GM_02753644-2753692 | 2021.10.11 | +| GX-330 | Photograph of | SDNY GM 02753644-2753692 | 2021.10.11 | + +| GX-331 | Photograph of Ghislaine Maxwell, , and | SDNY GM 02753644-2753692 | 2021.10.11 | +|--------|-----------------------------------------------------|------------------------------|------------| +| GX-332 | Photograph of Minor Victim-5•# | Made Available for Review | 2021.10.11 | +| GX-333 | Photograph of Ghislaine Maxwell and Jeffrey Epstein | SDNY_GM_02753644-2753692 | 2021.10.11 | +| GX-334 | Photograph of Ghislaine Maxwell and | SDNY GM 02753644-2753692 | 2021.10.11 | +| GX-335 | Photograph of Ghislaine Maxwell and | SDNY GM 02753644-2753692 | 2021.10.11 | +| GX-336 | Photograph of Planes | SDNY_GM_02753644-2753692 | 2021.10.11 | +| GX-337 | Photograph of Ghislaine Maxwell on Plane | SDNY GM 02753644-2753692 | 2021.10.11 | +| GX-338 | Photograph of Ghislaine Maxwell | SDNY GM 02753644-2753692 | 2021.10.11 | +| GX-339 | Photograph of Ghislaine Maxwell | SDNY_GM_02753644-2753692 | 2021.10.11 | +| GX-340 | Photograph of Ghislaine Maxwell | SDNY_GM_02753644-2753692 | 2021.10.11 | +| GX-341 | Photograph of Ghislaine Maxwell and Jeffrey Epstein | SDNY GM 02753644-2753692 | 2021.10.11 | +| GX-342 | Photograph of Ghislaine Maxwell and Jeffrey Epstein | SDNY GM 02753644-2753692 | 2021.10.11 | +| GX-343 | Photograph of Ghislaine Maxwell and Jeffrey Epstein | SDNY_GM_02753644-2753692 | 2021.10.11 | +| GX-344 | Photograph of Helicopter | SDNY GM 02753644-2753692 | 2021.10.11 | +| GX-345 | Photograph of Helicopter | SDNY GM 02753644-2753692 | 2021.10.11 | +| GX-346 | Photograph of Island | SDNY _ GM _ 02753644-2753692 | 2021.10.11 | +| GX-347 | Photograph of Ghislaine Maxwell and Jeffrey Epstein | SDNY GM 02753644-2753692 | 2021.10.11 | +| GX-348 | Photograph of Ghislaine Maxwell and Jeffrey Epstein | SDNY GM 02753644-2753692 | 2021.10.11 | + +### 400 Series ESI from Relativit' I + +| GX | Description | Bates Number/Identifier | Produced to Defense | +|----------|----------------------------------------------------------------------------|------------------------------------|---------------------| +| GX-401 | Email | SDNY GM 02736489-SDNY GM 02736489 | 2021.10.11 | +| GX-402 | Email Chain | SDNY GM 02736488-SDNY_GM 02736488 | 2021.10.11 | +| GX-403 | Email Chain | SDNY_GM_02736597-SDNY GNI 02736598 | 2021.10.11 | +| GX-404 | Email Chain | SDNY GM 02736491-SDNY GM 02736491 | 2021.10.11 | +| GX-405 | NYCO24349 System Information | SDNY GM 02762473 | 2021.10.11 | +| GX-406 | Email Chain between Jeffrey Epstein and Minor Victim-3# | SDNY_GM_00631742-SDNY_GM_0063I 742 | 2021.10.11 | +| GX-407 | Email Chain between Jeffrey Epstein and Ghislaine Maxwell | SDNY GM 00623470-SDNY GM 00623470 | 2021.10.11 | +| GX-408 | Email from Ghislaine Maxwell to Jeffrey tein | SDNY GM 00579091-SDNY GM 00579091 | 2021.10.11 | +| GX-409 | Email | | 2021.10.11 | +| GX-410 | Email | SDNY GM 02736735-SDNY GM 02736735 | 2021.10.11 | +| GX-412 | Email Chain | SDNY GM 02741883-SDNY GM 02741884 | 2021.10.11 | +| GX-413 | Email | SDNY GM 02741405-SDNY GM 02741405 | 2021.10.11 | +| GX-415 | Email Chain | SDNY GM 02741441-SDNY GM 02741442 | 2021.10.11 | +| GX-416 | List of Women | SDNY GM 02736115-SDNY GM 02736115 | 2021.10.11 | +| GX-416-B | List of Women - Metadata | | 2021.10.28 | +| GX-417 | List and Contact Info of Masseuses# | SDNY GM 02735985-SDNY GM 02735991 | 2021.10.11 | +| GX-417-B | List and Contact Info of Masseuses - Metadata | | 2021.10.11 | +| GX-418 | List and Contact Info of Palm Beach House Workers & Maintenance | SDNY GM 02736160-SDNY GM 02736166 | 2021.10.11 | +| GX-418-B | List and Contact Info of Palm Beach House Workers & Maintenance - Metadata | | 2021.10.11 | +| GX-419 | NYCO24350 System Information | SDNY GM 02762473 | 2021.10.11 | +| GX-420 | List of PB New Shampoo and Massage Products | SDNY GM 027362 I2-SDNY GM 02736212 | 2021.10.11 | +| GX-420-B | List of PB New Shampoo and Massage Products - Metadata | | 2021.10.11 | +| GX-421 | Massage Therapist Help Wanted Ad | SDNY_GM_02736260-SDNY_GM_02736260 | 2021.10.11 | +| GX-421-B | Massage Therapist Help Wanted Ad - Metadata | | 2021.10.11 | + +| GX-422 | Ghislaine Maxwell and Jeffr E. stein Relationshi. Essa | SDNY GM 02736272-SDNY GM 02736272 | 2021.10.11 | +|----------|--------------------------------------------------------------------|-----------------------------------|------------| +| GX-422-B | Ghislaine Maxwell and Jeffre E. stein Relationshi. Essa - Metadata | | 2021.10.11 | +| GX-423 | Jeffrey Epstein Amazon Order Confirmation | SDNY GM 00567862 | 2021.10.11 | + +#### 500 Series + +# Financial Exhibits + +| GX | Description | Bates Number/Identifier | Produced to Defense | +|--------|-----------------------------------------------------|-----------------------------------|---------------------| +| GX-501 | June 2007 JPMC Statement for Air Ghislaine | SDNY GM 00277986-SDNY GM 00277989 | 2021.10.11 | +| GX-502 | June 2007 JPMC Statement for Ghislaine Maxwell | SONY GM 00321356-SDNY GM 00321363 | 2021.10.11 | +| GX-503 | J.P. Morgan Entity Account Application | SDNY_GM_00271135-SDNY_GM_00271137 | 2021.10.11 | +| GX-504 | September 2002 JPMC Account Activity | SDNY GM 00274703-SDNY GM 002747I1 | 2021.10.11 | +| GX-505 | JPMC October 194)9 Asset Account Portfolio Records | SDNY GM 00306061-SDNY GM 00306067 | 2021.10.11 | +| GX-506 | Air Ghislaine Account Documents | SDNY GM 00271605-SDNY GM00271610 | 2021.10.11 | +| GX-507 | Ghislaine Maxwell J.P. Morgan Account and Signature | SDNY GM 00068254 | 2021.10.11 | + +#### 550 Series + +# Phone Records + +| GX | Description | Bates Number/Identifier | Produced to Defense | +|--------|--------------------------------------------------------------|-----------------------------------|---------------------| +| GX-551 | May 2004 AT&T Wireless Monthly Statement for Jeffrey Epstein | SDNY_GM_00365036-SDNY_GM_00365049 | 2021.10.11 | + +#### 600 Series + +# Miscellaneous Documents + +| GX | Description | Bates Numberidentitier | Produced to Defense | +|--------|-------------------------------|---------------------------------------|---------------------| +| GX-601 | Journal Front Cover | SONY t i SI 00165987 | 2021.10.11 | +| GX-602 | Journal Entry | SDNY GNI 00165986 | 2021.10.11 | +| GX-603 | January 7, 1996 Journal Entry | SDNY GM 00165984 | 2021.10.11 | +| GX-604 | Janua 25, 1996 Journal Ent | SDNY GM 00165982 | 2021.10.11 | +| GX-605 | Journal Back Cover | SDNY GM 00165988 | 2021.10.11 | +| GX-606 | Household Manual | SDNY GM 00516864-SDNY GM 00516922 | 2021.10.11 | +| GX-607 | Work Hours Document | SDNY_GM_005 15785 - SDNY_GM_005 15787 | 2021.10.11 | + +# 660 Series + +# Flight Records + +| CX | Description | Bates Number/Identifier | Produced to Defense | +|--------|-------------------------------------------------------|-----------------------------------|---------------------| +| GX-661 | Logbook from Janu 23,2006 to September 19, 201313 | SDNY GM 00005650-SDNY GM 00005676 | 2021.10.11 | +| GX-662 | Flight Logbook from April 25 1991 to January 19,20061 | SDNY GM 00005532-SDNY GM 00005649 | 2021.10.11 | + +# 700 Series + +# Photographs of Places + +| GX | Description | Bates Number/Identifier | Produced to Defense | +|----|-------------|-------------------------|---------------------| +| | | | | + +| GX-701 | Ghislaine Maxwell New York Townhouse | SDNY GM 02760645 | 2021.10.11 | +|--------|--------------------------------------|------------------|------------| +| GX-702 | Ghislaine Maxwell London Townhouse | SDNY GM 02762477 | 2021.10.11 | +| GX-703 | Little Saint James | SDNY GM 02760646 | 2021.10.11 | +| GX-704 | Jeffrey Epstein New York Townhouse | SDNY GM 02760647 | 2021.10.11 | +| GX-705 | Paris Apartment Building | SDNY GM 02760648 | 2021.10.11 | +| GX-706 | New Mexico Ranch | SDNY GM 02760649 | 2021.10.11 | + +# 720 Series + +# Maps + +| GX | Description | Bates Number/Identifier | Produced to Defense | +|--------|-------------------|-------------------------|---------------------| +| GX-721 | Map of Palm Beach | SDNY_GM_02762484 | 2021.10.11 | +| GX-722 | Map of Palm Beach | SDNY GM 02762485 | 2021.10.11 | + +### 740 Series + +# Interlochen Records + +| GX | Description | Bates Number/Identifier | Produced to Defense | +|--------|--------------------------|-----------------------------------|---------------------| +| GX-741 | Donor Records | | | +| | | SDNY GM 00005018 | 2021.10. I 1 | +| GX-742 | Interlochen Application# | SDNY GM 02753443-SDNY GM 02753444 | 2021.10.11 | +| | | SDNY GM 02753480-SDNY- | GM02753481 | +| GX-744 | Student Roster# | SDNY_GM_00005077-SDNY_GM 00005103 | 2021.10.11 | + +# 760 Series + +# Professional Children's School Records + +| GX | Description | Bates Number/Identifier | Produced to Defense | +|-----------|------------------------------------------------------------|-----------------------------------|----------------------------| +| GX-761 | Professional Children's School Records for Minor Victim-1# | SDNY_GM_00005511-SDNY_GM_00005514 | 2021.10.11 | + +| | A | 780 Series Palm Beach County School District Records | | +|--------|-------------------------------------------------|------------------------------------------------------|---------------------| +| GX | Description | Bates Number/Identifier | Produced to Defense | +| GX-781 | Minor Victim-5 Enrollment Records for 1989-2002 | SDNY GM 02753596 | 2021.10.11 | +| GX-782 | Minor Victim-5 Enrollment Records for 2001-2002 | SDNY_GM_02753597-SDNY_GM 02753598 | 2021.10.11 | +| GX-783 | Minor Victim-5 Registration Records | SDNY GM 02753608-SDNY GM 02753610 | 2021.10.11 | + +### 800 Series + +# FedEx Records + +| GX | Description | Bates Number/Identifier | Produced to Defense | +|--------|----------------------------|-----------------------------------|---------------------| +| GX-801 | December 16, 2002 Invoice# | SDNY GM 00525676-SDNY GM 00525690 | 2021.10.11 | +| GX-802 | December 23, 2002 Invoice# | SDNY_GM_00525700-SDNY_GM_00525720 | 2021.10.11 | +| GX-803 | October 14, 2002 Invoice# | SDNY GM 00431553-SDNY GM 00431561 | 2021.10.11 | + +| GX | Description | Bates Number/Identifier | Produced to Defense | +|--------|-------------------------------------------------------------------|-----------------------------|---------------------| +| GX-821 | Human Resources Correspondence Regarding Minor Victim-5's Records | SDNY GM 00120681 | 2021.10.11 | +| GX-822 | Mar-A-Lago Termination List | SDNY 00120686-SDNY 00120702 | 2021.10.11 | + +#### 900 Series + +### New York Search Photos + +| GX | Description | Bates Number/Identifier | Produced to Defense | +|--------|------------------------------------------------|-------------------------|---------------------| +| GX-901 | Photograph of Stairwell and Nude Portrait* | SDNY GM 00166249 | 2021.10.11 | +| GX-902 | Photograph of Hallway and Nude Portrait* | SDNY_GM_00166251 | 2021.10.11 | +| GX-903 | Photograph of Massage Room* | SDNY GM 00166252 | 2021.10.11 | +| GX-904 | Photograph of Massage Room* | SDNY _ GM _ 00166253 | 2021.10.11 | +| GX-905 | Photograph of Bathroom* | SDNY _ GM 00166258 | 2021.10.11 | +| GX-906 | Photograph of Massage Table* | SDNY GM 00166260 | 2021.10.11 | +| GX-907 | Photograph of Nude Portrait* | SDNY_ _GM_ _00166265 | 2021.10.11 | +| GX-908 | Photograph of Stairwell and Nude Portrait | SDNY_ GM _ 00166273 | 2021.10.11 | +| GX-909 | Photograph of Townhouse Exterior | SDNY GM 00166275 | 2021.10.11 | +| GX-910 | Photograph of Interior and Stairwell | SDNY GM 00166327 | 2021.10.11 | +| GX-911 | Photograph of Interior | SDNY_ GM _ 00166328 | 2021.10.11 | +| GX-912 | Photograph of Interior | SDNY GM 00166386 | 2021.10.11 | +| GX-913 | Photograph of Interior | SDNY GM 00166417 | 2021.10.11 | +| GX-914 | Photograph of Black Binders in Closet | SDNY_ GM_ 00166594 | 2021.10.11 | +| GX-915 | Photograph of Stairwell | SDNY GM 00166719 | 2021.10.11 | +| GX-916 | Photograph of Desk | SDNY GM 00166731 | 2021.10.11 | +| GX-917 | Photograph of Massage Table | SDNY_ GM_ 00166746 | 2021.10.11 | +| GX-918 | Photograph of Vanity Drawers | SDNY GM 00166761 | 2021.10.11 | +| GX-919 | Photograph of Costumes | SDNY GM 00166767 | 2021.10.11 | +| GX-920 | Photograph of Costumes | SDNY_GM_00166768 | 2021.10.11 | +| GX-921 | Photograph of Desk | SDNY GM 00166771 | 2021.10.11 | +| GX-922 | Photograph of Interior | SDNY GM 00167663 | 2021.10.11 | +| GX-923 | Photograph of Female Portrait | SDNY GM 00166776 | 2021.10.11 | +| GX-924 | Photograph of Nude Sculpture | SDNY GM 00166778 | 2021.10.11 | +| GX-925 | Photograph of Black Binders in Closet | SDNY GM 00166779 | 2021.10.11 | +| GX-926 | Photograph of Drawer Contents | SDNY GM 00166782 | 2021.10.11 | +| GX-927 | Photograph of Nude Sculpture | SDNY_GM_00 166784 | 2021.10.11 | +| GX-928 | Photograph of Interior | SDNY GM 00166907 | 2021.10.11 | +| GX-929 | Photograph of Interior | SDNY GM 00167081 | 2021.10.11 | +| GX-930 | Photograph of Nude Portrait in Bathroom* | SDNY_ GM_ 00167094 | 2021.10.11 | +| GX-931 | Photograph of Nude Portrait in Bathroom* | SDNY GM 00167095 | 2021.10.11 | +| GX-932 | Photograph of Townhouse Exterior | SDNY GM 00167102 | 2021.10.11 | +| GX-933 | Photograph of Interior | SDNY_GM_00167111 | 2021.10.11 | +| GX-934 | Photograph of Interior | SDNY GM 00167211 | 2021.10.11 | +| GX-935 | Photograph of Bookshelves and Cabinet Contents | SDNY GM 00167251 | 2021.10.11 | \ No newline at 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Maxwell S2 20 Cr 330 (AJN) + +Date: Fri, 29 Oct 2021 22:19:41 +0000 + +Attachments: 20cr330 Order 10.29.21.pdf + +The Court just issued the attached order, ordering us to respond by Tuesday, November 12, at 12 pm. + +Thanks, + +From: + +Sent: Friday, October 29, 2021 6:09 PM + +To: + +Cc: + +Subject: FW: (EXTERNAL] US v. Maxwell 52 20 Cr 330 (AJN) + +Please see the attached letter, which was filed this evening. Are you available for a call on Monday? We anticipate that this issue will be addressed at our final pretrial conference at 11 a.m. on Monday. + +Thanks, + +From: BOBBI C STERNHEIM + +Sent: Friday, October 29, 20 15:57 PM + +To: + +Cc: Christian Everdell < •; Laura Menninger < >; Jeff Pagliuca + +Subject: [EXTERNAL] US v. Maxwell 52 20 Cr 330 (AJN) + +Courtesy copy of today's ECF filing. + +Please note my new office address and preferred email address: + +BOBBI C. STERNHEIM, ESQ. + +Law Offices of Bobbi C. Sternheim + +225 Broadway, Suite 715 + +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. \ No newline at end of file diff --git a/marker2/ds9/EFTA00090951/EFTA00090951.metadata.json b/marker2/ds9/EFTA00090951/EFTA00090951.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..70cd47ba8db3594d2a6d47b5b1789b8df370992e --- /dev/null +++ b/marker2/ds9/EFTA00090951/EFTA00090951.metadata.json @@ -0,0 +1,84 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090951.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 1367, + "elapsed_seconds": 1.33, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 55 + ], + [ + "Text", + 30 + ], + [ + "Line", + 28 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 17 + ], + [ + "Line", + 9 + ], + [ + "Text", + 6 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00090951" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00090953/EFTA00090953.md b/marker2/ds9/EFTA00090953/EFTA00090953.md new file mode 100644 index 0000000000000000000000000000000000000000..061d809948fb742926abe9d716ab8742b61033aa --- /dev/null +++ b/marker2/ds9/EFTA00090953/EFTA00090953.md @@ -0,0 +1,30 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +United States of America, + +—v— + +Ghislaine Maxwell, + +Defendant. + +| USDC SDNY | +|-----------------------------| +| DOCUMENT | +| ELECTRONICALLY FILED | +| DOC #: | +| DATE FILED: 10/29/21 | + +20-CR-330 (MN) + +ORDER + +ALISON J. NATHAN, District Judge: + +The Court is in receipt of Defendant's letter regarding delivery of Defendant's legal mail at MDC. Dkt. No. 381. The Government is hereby ORDERED to respond by Tuesday, November 2, 2021 at 12:00 p.m. + +SO ORDERED. + +Dated: October 29, 2021 New York, New York AL + +ALISON J. NATHAN United States District Judge \ No newline at end of file diff --git a/marker2/ds9/EFTA00090953/EFTA00090953.metadata.json b/marker2/ds9/EFTA00090953/EFTA00090953.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..6570bd1470453b0afc23ac4bee044868f047c09a --- /dev/null +++ b/marker2/ds9/EFTA00090953/EFTA00090953.metadata.json @@ -0,0 +1,90 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090953.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 684, + "elapsed_seconds": 1.05, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 71.28 + ], + [ + 281.019775390625, + 71.28 + ], + [ + 281.019775390625, + 99.603515625 + ], + [ + 68.544, + 99.603515625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 50 + ], + [ + "Line", + 25 + ], + [ + "Text", + 11 + ], + [ + "PageFooter", + 2 + ], + [ + "SectionHeader", + 1 + ], + [ + "Form", + 1 + ], + [ + "Caption", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00090953" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00090954/EFTA00090954.md b/marker2/ds9/EFTA00090954/EFTA00090954.md new file mode 100644 index 0000000000000000000000000000000000000000..59f80dd49a1e3f7bf8349bb093ba2097abc2a4fd --- /dev/null +++ b/marker2/ds9/EFTA00090954/EFTA00090954.md @@ -0,0 +1,11 @@ +To: " " , ' (USANYS)" )" , . , + +Subject: + +Date: Wed, 21 Apr 2021 18:23:24 +0000 + +Team, + +is available for a follow-up interview by video on the following dates: May 3, 4 (before 2pm), 5, 6, 12, 13 or 14. Please let me know what works for everyone. + +Thanks, \ No newline at end of file diff --git a/marker2/ds9/EFTA00090954/EFTA00090954.metadata.json b/marker2/ds9/EFTA00090954/EFTA00090954.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..f80cd9e8b5a66af0fc246ec93f3afee72f047d50 --- /dev/null +++ b/marker2/ds9/EFTA00090954/EFTA00090954.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090954.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 255, + "elapsed_seconds": 0.49, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 21 + ], + [ + "Line", + 11 + ], + [ + "Text", + 8 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00090954" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00090955/EFTA00090955.md b/marker2/ds9/EFTA00090955/EFTA00090955.md new file mode 100644 index 0000000000000000000000000000000000000000..cae19adbc6a0b6b52fa9b6add52aeee0d8f41c23 --- /dev/null +++ b/marker2/ds9/EFTA00090955/EFTA00090955.md @@ -0,0 +1,15 @@ +To: "CEverdell®CohenGresser.com" , Jeff Pagliuca , Laura Menninger , "meohen@cohengressercom" , bc\_stemheimlaw.com , ' (USANYS)" + +Subject: Order in 20-cr-330, United States v. Maxwell + +Date: Wed, 21 Apr 2021 23:51:54 +0000 + +Attachments: 20cr330\_Order 4.21.21.pdf + +Counsel, + +Please find attached an order signed by Judge Nathan, which will be entered into the public docket in the morning. + +Respectfully, + +The Chambers of the Hon. Alison J. Nathan \ No newline at end of file diff --git a/marker2/ds9/EFTA00090955/EFTA00090955.metadata.json b/marker2/ds9/EFTA00090955/EFTA00090955.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..c6cf87498f65560a79e77789588784106b1ea95d --- /dev/null +++ b/marker2/ds9/EFTA00090955/EFTA00090955.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090955.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 562, + "elapsed_seconds": 0.49, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 29 + ], + [ + "Line", + 15 + ], + [ + "Text", + 9 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00090955" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00090956/EFTA00090956.md b/marker2/ds9/EFTA00090956/EFTA00090956.md new file mode 100644 index 0000000000000000000000000000000000000000..b94caae546ccd948f5e878dea666d66a8181b6ee --- /dev/null +++ b/marker2/ds9/EFTA00090956/EFTA00090956.md @@ -0,0 +1,17 @@ +From: " " ‹ > + +To: " \Y) (FBI)" aa, + +Cc: SANYS " + +Subject: conference + +Date: Fri, 23 Apr 2021 14:20:10 +0000 + +Attachments: 2021.04.19\_Scheduling\_Orderpdf + +and , + +I'm attaching the order with the dial-in information for today's conference, in case you want to listen in. Hope the trip is going well. + +Assistant United States Attorney Southern District of New York One Saint Andrew's Plaza New York, NY 10007 \ No newline at end of file diff --git a/marker2/ds9/EFTA00090956/EFTA00090956.metadata.json b/marker2/ds9/EFTA00090956/EFTA00090956.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..6a3b348f065bad83ada0fb7fc325a3cb93132e47 --- /dev/null +++ b/marker2/ds9/EFTA00090956/EFTA00090956.metadata.json @@ -0,0 +1,54 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090956.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 408, + "elapsed_seconds": 0.53, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 32 + ], + [ + "Line", + 14 + ], + [ + "Text", + 10 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00090956" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00090957/EFTA00090957.md b/marker2/ds9/EFTA00090957/EFTA00090957.md new file mode 100644 index 0000000000000000000000000000000000000000..b382830b5d5c20f73eafb84904c601367e573366 --- /dev/null +++ b/marker2/ds9/EFTA00090957/EFTA00090957.md @@ -0,0 +1,48 @@ +## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK + +United States of America, + +—v— + +Ghislaine Maxwell, + +Defendant. + +| USDC SDNY | | +|----------------------|---------| +| DOCUMENT | | +| ELECTRONICALLY FILED | | +| DOC #: | | +| DATE FILED: | 4/19/21 | + +20-CR-330 (MN) + +ORDER + +ALISON J. NATHAN, District Judge: + +An arraignment on the S2 Superseding Indictment is scheduled to take place on April 23, 2021 at 2:30 p.m. The proceeding will take place in Courtroom 24B of the Daniel Patrick Moynihan Courthouse, 500 Pearl Street, New York, NY. + +Given significant public interest, a video feed of the proceeding will be available for viewing in the Jury Assembly Room and Courtroom 9C at the Daniel Patrick Moynihan Courthouse. The use of any electronic devices during the proceeding in either the Courtroom or the overflow rooms is strictly prohibited. + +Due to social distancing requirements, seating will be limited to approximately 100 members of the public. If capacity is reached, no additional persons will be admitted. Per the S.D.N.Y. COVID-19 Courthouse Entry Program, anyone who appears at any S.D.N.Y. courthouse must complete a questionnaire on the date of the proceeding prior to arriving at the courthouse. All visitors must also have their temperature taken when they arrive at the courthouse. Please see the attached instructions. Completing the questionnaire ahead of time will save time and effort upon entry. + +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 either (i) a properly fitted disposable mask under a cloth mask, with the outer edges of the inner mask pushed against the face, or (ii) a properly fitted FDA-authorized N95 or KN95 mask. 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, see https://www.nysd.uscourts.gov/covid-19-coronavirus. + +In order to ensure additional public access, the Court will also open a public teleconference line so that members of the public may listen to the audio of the proceeding. Members of the public may call into the public teleconference line by dialing 844-291-6362 and entering access code 2921822. This phone line can accommodate approximately 4,000 callers on a first come, first serve basis. Any photographing, recording, or rebroadcasting of federal court proceedings is prohibited by law. Violation of these prohibitions may result in fines or sanctions, including being held in contempt of court, removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. + +Pursuant to 18 U.S.C. § 3771(c)(1), the Government must "make their best efforts to see that crime victims are notified of, and accorded, the rights" provided to them in that section. This includes "[t]he right to reasonable, accurate, and timely notice of any public court proceeding ... involving the crime or of any release . . . of the accused." Id. § 3771(a)(2). So that appropriate logistical arrangements can be made, the Government shall inform the Court's Chambers by email by April 21, 2021 whether any alleged victims wish to attend the proceeding and whether they will attend in person or by phone. The Court will ensure access. + +In addition, defense counsel shall inform the Court's Chambers by email by April 21, 2021, whether any of the Defendant's family members wish to attend the proceeding and whether they will attend in person or by phone. The Court will ensure access. + +SO ORDERED. + +Dated: April 19, 2021 +New York, New York + +![]() + +--- + +ALISON J. NATHAN +United States District Judge \ No newline at end of file diff --git a/marker2/ds9/EFTA00090957/EFTA00090957.metadata.json b/marker2/ds9/EFTA00090957/EFTA00090957.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..f6f633e92243f52c9bdcda62615bcce5757c1c77 --- /dev/null +++ b/marker2/ds9/EFTA00090957/EFTA00090957.metadata.json @@ -0,0 +1,162 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090957.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 3, + "chars": 3903, + "elapsed_seconds": 3.02, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 68.544, + 72.08999999999999 + ], + [ + 281.4012451171875, + 72.08999999999999 + ], + [ + 281.4012451171875, + 98.82415771484375 + ], + [ + 68.544, + 98.82415771484375 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 66 + ], + [ + "Line", + 32 + ], + [ + "Text", + 11 + ], + [ + "PageHeader", + 1 + ], + [ + "SectionHeader", + 1 + ], + [ + "Form", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 49 + ], + [ + "Line", + 23 + ], + [ + "Text", + 3 + ], + [ + "PageHeader", + 1 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 2, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 19 + ], + [ + "Line", + 10 + ], + [ + "Text", + 8 + ], + [ + "PageHeader", + 2 + ], + [ + "Caption", + 2 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00090957" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00090960/EFTA00090960.md b/marker2/ds9/EFTA00090960/EFTA00090960.md new file mode 100644 index 0000000000000000000000000000000000000000..6844f723c3626a36f5f57f1d5a6343bbbed91a5b --- /dev/null +++ b/marker2/ds9/EFTA00090960/EFTA00090960.md @@ -0,0 +1,33 @@ +![](_page_0_Picture_64.jpeg) + +**To:** + +![](_page_0_Picture_66.jpeg) + +**Subject:** FW: Exhibit L + +**Date:** Fri, 23 Apr 2021 14:43:00 +0000 + +**Attachments:** x1x\_236\_US\_on\_Exhibit\_L\_in\_Maxwell.pdf + +--- + +I know you guys are super busy, so just ignore me if you don't have time to answer. Ben Weiser is confused as to which document this actually refers to, he notes that Judge Nathan previously referred to what we call "Reply Brief 3" as document "Reply Brief 6," in an earlier footnote. If you're able to clarify, thanks... + +--- + +**From:** Ben Weiser [REDACTED] + +**Sent:** Friday, April 23, 2021 10:32 AM + +**To:** [REDACTED] + +**Subject:** Exhibit L + +-- + +Benjamin Weiser + +Reporter, The New York Times + +![](_page_0_Picture_78.jpeg) \ No newline at end of file diff --git a/marker2/ds9/EFTA00090960/EFTA00090960.metadata.json b/marker2/ds9/EFTA00090960/EFTA00090960.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..f4a8dee4dde0a2c2d6e04db41a8cbee6b3a44a4b --- /dev/null +++ b/marker2/ds9/EFTA00090960/EFTA00090960.metadata.json @@ -0,0 +1,62 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090960.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 736, + "elapsed_seconds": 3.41, + "image_assets": [ + "_page_0_Picture_64.jpeg", + "_page_0_Picture_66.jpeg", + "_page_0_Picture_78.jpeg" + ], + "marker_metadata": { + "table_of_contents": [], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 33 + ], + [ + "Text", + 27 + ], + [ + "Line", + 15 + ], + [ + "Picture", + 3 + ], + [ + "PageFooter", + 2 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00090960" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00090960/_page_0_Picture_64.jpeg b/marker2/ds9/EFTA00090960/_page_0_Picture_64.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..3981ca7300980254c420b1a4be2c8c3d93408b18 --- /dev/null +++ b/marker2/ds9/EFTA00090960/_page_0_Picture_64.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:96a57b5a4c4cd800316a353b01886790b2e575ad7d6a94f6713e927117afae26 +size 6406 diff --git a/marker2/ds9/EFTA00090960/_page_0_Picture_66.jpeg b/marker2/ds9/EFTA00090960/_page_0_Picture_66.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..6932cf6d51fb69f357aaf733c2f3045f8c79b7ed --- /dev/null +++ b/marker2/ds9/EFTA00090960/_page_0_Picture_66.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:9486bb8a8d9878933b9df1288d13842ee9b06f5252cf38b189e67c7abab0827c +size 8205 diff --git a/marker2/ds9/EFTA00090960/_page_0_Picture_78.jpeg b/marker2/ds9/EFTA00090960/_page_0_Picture_78.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..a12329c3e4adfc7d63d6beca69fd280c98a7a2ba --- /dev/null +++ b/marker2/ds9/EFTA00090960/_page_0_Picture_78.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:91d839fae366447090947b7669670b83dc707139740a4eee0f3bc584077d3685 +size 2723 diff --git a/marker2/ds9/EFTA00090961/EFTA00090961.md b/marker2/ds9/EFTA00090961/EFTA00090961.md new file mode 100644 index 0000000000000000000000000000000000000000..46b428421bd2a5510e4c2906a8002634ce1b313f --- /dev/null +++ b/marker2/ds9/EFTA00090961/EFTA00090961.md @@ -0,0 +1,39 @@ +![](_page_0_Picture_112.jpeg) + +*United States Attorney +Southern District of New York* + +*The Silvio J. Mollo Building +One Saint Andrew's Plaza +New York, New York 10007* + +April 22, 2021 + +**BY ECF** + +The Honorable Alison J. Nathan +United States District Court +Southern District of New York +United States Courthouse +40 Foley Square +New York, New York 10007 + +**Re: *United States v. Ghislaine Maxwell*, 20 Cr. 330 (AJN)** + +Dear Judge Nathan: + +The Government respectfully submits this letter in response to the Court's April 22, 2021 Order (Dkt. 232) regarding whether the parties seek redactions to Exhibit L of Reply Brief 3. The Government does not seek redactions to Exhibit L and accordingly does not object to the public filing of Exhibit L. The Government has conferred with defense counsel. Defense counsel has indicated that it has no objection to the public filing of Exhibit L and, accordingly, will file Exhibit L on the public docket. + +Respectfully submitted, + +AUDREY STRAUSS +United States Attorney + +By: s/ + +![](_page_0_Picture_125.jpeg) + +Assistant United States Attorneys +Southern District of New York + +Cc: All Counsel of Record (By ECF) \ No newline at end of file diff --git a/marker2/ds9/EFTA00090961/EFTA00090961.metadata.json b/marker2/ds9/EFTA00090961/EFTA00090961.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..dc0fe58da3969c93b67f31f2b7ebd157ec953d90 --- /dev/null +++ b/marker2/ds9/EFTA00090961/EFTA00090961.metadata.json @@ -0,0 +1,124 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090961.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 1, + "chars": 1165, + "elapsed_seconds": 4.91, + "image_assets": [ + "_page_0_Picture_112.jpeg", + "_page_0_Picture_125.jpeg" + ], + "marker_metadata": { + "table_of_contents": [ + { + "title": "U.S. Department of Justice", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 318.24, + 25.92 + ], + [ + 462.06000000000006, + 25.92 + ], + [ + 462.06000000000006, + 40.5 + ], + [ + 318.24, + 40.5 + ] + ] + }, + { + "title": "BY ECF", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 67.932, + 155.52 + ], + [ + 116.892, + 155.52 + ], + [ + 116.892, + 169.29 + ], + [ + 67.932, + 169.29 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "surya", + "block_counts": [ + [ + "Span", + 62 + ], + [ + "Line", + 31 + ], + [ + "Text", + 24 + ], + [ + "SectionHeader", + 4 + ], + [ + "Picture", + 3 + ], + [ + "PageHeader", + 2 + ], + [ + "PageFooter", + 2 + ], + [ + "Caption", + 1 + ], + [ + "PictureGroup", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00090961" + } +} \ No newline at end of file diff --git a/marker2/ds9/EFTA00090961/_page_0_Picture_112.jpeg b/marker2/ds9/EFTA00090961/_page_0_Picture_112.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..a3f6f2a44f24616da53ec4c90dff6eeb0ef9a220 --- /dev/null +++ b/marker2/ds9/EFTA00090961/_page_0_Picture_112.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:21d396c1efb9b7d1a0def8977f2c5c547f272cf3b44ccadcb9cb483f076bcc4a +size 3611 diff --git a/marker2/ds9/EFTA00090961/_page_0_Picture_125.jpeg b/marker2/ds9/EFTA00090961/_page_0_Picture_125.jpeg new file mode 100644 index 0000000000000000000000000000000000000000..7328a6ceb2f0c71aeebc71577bed9dfe86358114 --- /dev/null +++ b/marker2/ds9/EFTA00090961/_page_0_Picture_125.jpeg @@ -0,0 +1,3 @@ +version https://git-lfs.github.com/spec/v1 +oid sha256:1ec4148f47910c8371dbb29db86cd0e51abb6b70263984cc5a58b1288a741df4 +size 2409 diff --git a/marker2/ds9/EFTA00090962/EFTA00090962.md b/marker2/ds9/EFTA00090962/EFTA00090962.md new file mode 100644 index 0000000000000000000000000000000000000000..3096452db5898daa0f60758cdf94962d83ba63bf --- /dev/null +++ b/marker2/ds9/EFTA00090962/EFTA00090962.md @@ -0,0 +1,63 @@ +To: "CourtMail@nysd.uscourts.gov" + +Bcc: " )" < + +Subject: Activity in Case 1:20-cr-00330-AJN USA v. Maxwell Order + +Date: Tue, 27 Apr 2021 15:15:56 +0000 + +This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT RESPOND to this e-mail because the mail box is unattended. + +\*\*\*NOTE TO PUBLIC ACCESS USERS\*\*\* There is no charge for viewing opinions. + +U.S. District Court + +Southern District of New York + +# Notice of Electronic Filing + +The following transaction was entered on 4/27/2021 at 11:15 AM EDT and filed on 4/26/2021 + +Case Name: USA v. Maxwell + +Case Number: I :20-er-00330-AJN + +Filer: + +Document Number:250 + +## Docket Text: + +ORDER as to Ghislaine Maxwell. The Court is in receipt of the parties' proposed schedules for pretrial disclosures and pretrial motions practice. Dkt. Nos. 229, 230. Having considered the parties respective positions, the Court hereby sets the schedule below, which it deems reasonable and fair: the Court hereby sets the following schedule: Government expert witness disclosure are due April 23, 2021 (agreement of the parties); Supplemental Pretrial Motions that pertain only to the new charges raised in the S2 indictment (agreement of the parties): Defense supplemental motions are due May 7, 2021; Governments response is due May 21, 2021; Defense replies are due May 28, 2021; Disclosure of the alleged victims referenced in the S2 Indictment: May 17, 2021 (agreement of the parties); The Court will address a process and schedule for the parties' proposals regarding a jury questionnaire by separate order. Finally, the parties are ORDERED to meet and confer on the Government's proposal that the Defendant submit witness statements pursuant to Federal Rule of Criminal Procedure 26.2 at least four weeks in advance of trial. The parties are further ORDERED to submit a joint letter laying out their respective positions and proposals within one week of this Order (Defense supplemental Motions due by 5/7/2021., Defense Replies due by 5/28/2021., Government's Responses due by 5/21/2021). (Signed by Judge Alison J. Nathan on 4/26/21)0w) + +1:20-cr-00330-AJN-1 Notice has been electronically mailed to: + +David Boies, II + +Jeffrey S. Pagliuca + +Mark Stewart Cohen + +Sigrid S. McCawley , achristie@bsfllp.com, + +Lara Elizabeth - USANYS.ECF@USDOJ.GOV CaseView.ECF@usdoj.gov, + +CaseView.ECF®usdoj.gov, USANYS.ECF@USDOJ.GOV + +CaseView.ECF@usdoj.gov, USANYS.ECF@USDOJ.GOV + +CaseView.ECF®usdoj.gov, USANYS.ECF@USDOJ.GOV + +caseview.ecf@usdoj.gov, usanys.ecf®usdoj.gov + +#### 1:20-cr-00330-AJN-1 Notice has been delivered by other means to: + +The following document(s) are associated with this transaction: + +## Document description:Main Document + +### Original filenamem/a + +#### Electronic document Stamp: + +[STAMP dcecfStamp\_11: 1008691343 [Date=4/27/2021] [FileNumber=25793145- 0] [1dedebe716994411b10512b236c3ae3a6ec4fefc82fefacd6a7e7738726a052437 bdt8d7aef8ad07b2d7108af1892ef52203bc4bb3d7732907c404efdeac7fbl]] \ No newline at end of file diff --git a/marker2/ds9/EFTA00090962/EFTA00090962.metadata.json b/marker2/ds9/EFTA00090962/EFTA00090962.metadata.json new file mode 100644 index 0000000000000000000000000000000000000000..7293919dd51e9ae2830890f0e88a61a9742defb0 --- /dev/null +++ b/marker2/ds9/EFTA00090962/EFTA00090962.metadata.json @@ -0,0 +1,231 @@ +{ + "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00090962.pdf", + "engine": { + "marker_major": "2", + "marker_version": "2.0.0", + "mode": "balanced", + "use_llm": false, + "force_ocr": false, + "disable_ocr": false, + "output_format": "markdown", + "preserve_source": false + }, + "fingerprint": "d889ea60d5548ac4", + "pages": 2, + "chars": 2990, + "elapsed_seconds": 1.38, + "image_assets": [], + "marker_metadata": { + "table_of_contents": [ + { + "title": "Notice of Electronic Filing", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 254.34 + ], + [ + 185.44595336914062, + 254.34 + ], + [ + 185.44595336914062, + 270.43353271484375 + ], + [ + 30.6, + 270.43353271484375 + ] + ] + }, + { + "title": "Docket Text:", + "heading_level": null, + "page_id": 0, + "polygon": [ + [ + 30.6, + 369.36 + ], + [ + 101.648193359375, + 369.36 + ], + [ + 101.648193359375, + 384.7330322265625 + ], + [ + 30.6, + 384.7330322265625 + ] + ] + }, + { + "title": "1:20-cr-00330-AJN-1 Notice has been delivered by other means to:", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 31.212, + 310.23 + ], + [ + 376.53790283203125, + 310.23 + ], + [ + 376.53790283203125, + 324.7330627441406 + ], + [ + 31.212, + 324.7330627441406 + ] + ] + }, + { + "title": "Document description:Main Document", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 31.212, + 360.45000000000005 + ], + [ + 231.73399353027344, + 360.45000000000005 + ], + [ + 231.73399353027344, + 375.7330322265625 + ], + [ + 31.212, + 375.7330322265625 + ] + ] + }, + { + "title": "Original filenamem/a", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 31.212, + 374.22 + ], + [ + 145.65615844726562, + 374.22 + ], + [ + 145.65615844726562, + 389.2330322265625 + ], + [ + 31.212, + 389.2330322265625 + ] + ] + }, + { + "title": "Electronic document Stamp:", + "heading_level": null, + "page_id": 1, + "polygon": [ + [ + 31.212, + 387.98999999999995 + ], + [ + 183.70465087890625, + 387.98999999999995 + ], + [ + 183.70465087890625, + 402.7330322265625 + ], + [ + 31.212, + 402.7330322265625 + ] + ] + } + ], + "page_stats": [ + { + "page_id": 0, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 77 + ], + [ + "Line", + 39 + ], + [ + "Text", + 20 + ], + [ + "SectionHeader", + 2 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + }, + { + "page_id": 1, + "text_extraction_method": "pdftext", + "block_counts": [ + [ + "Span", + 41 + ], + [ + "Line", + 21 + ], + [ + "Text", + 10 + ], + [ + "SectionHeader", + 4 + ], + [ + "PageFooter", + 1 + ] + ], + "block_metadata": { + "llm_request_count": 0, + "llm_error_count": 0, + "llm_tokens_used": 0, + "previous_text": "", + "previous_type": "", + "previous_order": 0 + } + } + ], + "debug_data_path": "debug_data/EFTA00090962" + } +} \ No newline at end of file